PUBLIC HEALTH ASSESSMENT
SUNFLOWER ARMY AMMUNITION PLANT
DESOTO, JOHNSON COUNTY, KANSAS
APPENDIX A: ATSDR SITE SUMMARY AND ATSDR HEALTH CONSULTATION
SITE SUMMARY
Sunflower Army Ammunition Plant
DeSoto, Kansas
December 1995
Prepared by:
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Federal Facilities Assessment Branch
INTRODUCTION
ATSDR staff conducted an initial site visit at Sunflower Army Ammunition Plant (SAAP) in DeSoto, Kansas from September 11-13, 1995. The purpose of the trip was to obtain information necessary to determine if immediate ATSDR public health actions are appropriate for the site, and to prioritize the site for a public health assessment. We toured the site and met with SAAP personnel, on-site contractors with Alliant Techsystems, and representatives from the U.S. Environmental Protection Agency and the Kansas Department of Health and Environment. We identified the following questions, which will be addressed in the public health assessment process.
BACKGROUND
SAAP is a Government-owned, contractor-operated installation operated by Hercules, Inc. Operations at SAAP began in 1942. The majority of the installation has been in standby, inactive status since 1971.
The primary mission of the installation was to manufacture smokeless powder and propellants. Other operations included manufacture and regeneration of nitric and sulfuric acid, and munitions testing. The majority of the site's infrastructure is still in place.
SAAP covers 9,065 acres and is located in a sparsely-populated rural area near the small town of DeSoto. Most of the land use surrounding the site is agricultural.
The site is on a broad ridge between Captain Creek on the west and Kill Creek on the east, both of which are perennial streams.
Possible sources of contamination at SAAP include production line areas, magazine storage areas, and approximately 70 solid waste management units (SWMUs).
Past sampling events, including the 1988 remedial investigation, have indicated the presence of hazardous substances at the site, primarily inorganic compounds, explosives and nitrate compounds. Contaminants have been detected in on-site soil and sediment and in groundwater under the site. Five surface impoundment SWMUs (settling/blender ponds) were the sources selected for EPA's Hazard Ranking Score evaluation.
ISSUES OF ATSDR CONCERN
Nitroguanidine in Cattle
Much of the site property is leased to area farmers for grazing cattle or producing hay. A citizen of a community approximately 30 miles from the site is concerned that cattle are ingesting nitroguanidine and other chemicals and that people are being exposed through the foodchain by eating that beef.
On the site tour, we learned that cattle are only kept on the site for about 120 days before being sent elsewhere. We further noted that cattle are fenced off from areas where the highest concentrations of nitroguanidine and other chemical contaminants are likely to be found.
No tissue sampling of cattle from the site has been done. We acquired a study of tissue sampling in deer that lived on a site similar to SAAP. We will use that study and other relevant data to help determine whether or not there may be a public health risk from eating beef from cattle that grazed at SAAP. We will make a determination of what public health actions are necessary, if any, following a review of those documents. That review should be completed in early 1996.
Groundwater
We learned from discussions with a geologist with the Kansas Department of Health and Environment (KDHE) and Alliant Techsystems staff that groundwater under the site does not appear to flow off site. Instead, groundwater comes to the surface at various points on site and also empties into Kill Creek on SAAP's eastern border and Captain Creek on the western border.
Groundwater under the site is not used for domestic purposes. No groundwater sampling has been done beyond SAAP's boundaries, and there are no good records of the number of private wells in the area. We will review sampling data for both on-site groundwater and surface water from the creeks into which groundwater flows to determine whether contaminants are present at levels that could potentially affect off-site potable water sources. That evaluation is scheduled for fiscal year 1996.
Kill Creek and Captain Creek
KDHE has issued fishing advisories for many Kansas water bodies due to pesticide runoff from farmlands. Kill Creek and Captain Creek are reportedly included in those advisories; we will verify this with KDHE.
Fishing reportedly does occur in the creeks. However, from observations on the site tour, it does not appear that subsistence fishing would be possible for either creek because the creeks are not big enough to support large numbers of edible-sized fish. There are not many houses adjacent to the creeks, so it is unlikely that many children, if any, play or swim in the creeks. We will review both surface water and sediment data from the creeks to determine whether contaminants are present at levels of potential public health concern. That work will be done in fiscal year 1996.
Northeast Landfill Area
An old landfill on the northeast corner of the site is located on a 300-acre parcel of land that is proposed to be transferred to Johnson County for use as a recreational area. We will review environmental sampling data for that area to determine if any contaminant levels are of potential public health concern.
OTHER ATSDR ISSUES
Based on available data, we have determined that the following issues do not currently pose a public health concern. We will, therefore, not evaluate them further unless future information indicates that we should.
Air Releases
All burning at SAAP is carried out according to strict safety protocols, and only on days when wind does not carry a substantial amount of smoke off site. The area around the site is very sparsely populated, and no houses are near the burn areas. There is, therefore, very little chance that human exposures to airborne contaminants from SAAP have occurred or will occur at levels of health concern.
On-Site Soil and Sediment
SAAP is securely fenced and has very good security, so that trespassing is not likely. Areas with the most soil and sediment contamination are fenced. Human exposures to contaminated soil and sediment are, therefore, not likely.
Physical Hazards
Since site security is good, it is unlikely that anyone other than site personnel would be in the area of any physical hazards. We assume that site personnel have been trained in and follow proper safety protocols when they are near any hazards.
COMMUNITY HEALTH CONCERNS
Besides the concern of one area resident about nitroguanidine in cattle, we have identified no specific environmental or public health concerns related to SAAP. Some general concerns about the possible presence of harmful chemicals on the site and the efficiency of site cleanup efforts were expressed in some interviews conducted for the Community Relations Plan; those concerns should be addressed in our future documents.
We will make additional citizen contact to learn of any new health concerns throughout the public health assessment process. Any concerns that people have should be directed to:
Program Evaluation, Records, and Information Services Branch
(Sunflower Army Ammunition Plant)
ATSDR, Division of Health Assessment and Consultation
1600 Clifton Road NE, MS E-56
Atlanta, GA 30333
or contact Jerome Joyce, ATSDR Regional Representative, Region VII, Kansas City, Kansas, at (913) 551-7828.
Initial Site Visit Information
Service: U.S. Army
Size: 9,065 acres
Installation Status: Standby
Installation Mission: Manufacturing of propellants
ATSDR Actions:
Initial Site Visit: September 11-13, 1995
ATSDR Site Ranking: E
Persons Met With
Thomas Stutz, Commander's Representative
Ralph Burns, Environmental Office
James Turrentine, Chemical Engineer
Joe Betteken, Alliant Techsystems
Tim Davis, Alliant Techsystems
Charles Jarrett, Alliant Techsystems
Bob Anderson, Alliant Techsystems
Kathleen Buchi, USACHPPM
Steve Wharton, US EPA
Randy Carlson, KDHE
NOTE OF EXPLANATION OF THE ATSDR SITE RANKING
ATSDR health assessors conduct site visits at all hazardous waste sites that are proposed or listed on the Environmental Protection Agency's National Priorities List (NPL), including Department of Defense facilities such as SAAP. During the site visits, the health assessors collect available information to be included in the public health assessment (PHA). The information that is collected documents the nature and extent of contamination, identifies site-related health issues of concern to the community, and provides insight into the health status of the community.
Because current resources at ATSDR are inadequate to write PHAs for all of the Federal facilities listed on the NPL, ATSDR has developed an interim site ranking scheme (see the Federal Register, 57 FR 37382, August 18, 1992) as a planning tool to identify facilities that pose the greatest public health hazard. That action ensures that ATSDR's resources can be directed to the most critical sites first.
Using the interim Site Ranking Scheme, ATSDR assigns points for contaminated media, populations within one mile of the site, possible human exposures, and community health concerns. The points are totaled to give sites a single numerical score from 0 to 140 points. The 140-point scale is divided into five Site Ranking Categories based on their numerical ranges: Category A - 140-80; Category B - 79-55; Category C - 54-35; Category D - 34-20; and Category E - 19-0. The higher the score the greater the relative hazard, and therefore the higher priority in the PHA process.
HEALTH CONSULTATION
SUNFLOWER ARMY AMMUNITION PLANT
DESOTO, KANSAS
February 27, 1996
U.S. Department of Health and Human Services
Public Health Service
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Atlanta, Georgia
TABLE OF CONTENTS
STATEMENT OF ISSUES AND SUMMARY
CONCLUSIONS AND RECOMMENDATIONS
STATEMENT OF ISSUES AND SUMMARY
This health consultation addresses a community concern that beef, from cattle grazed on Sunflower Army Ammunition Plant (SFAAP), could be contaminated with harmful levels of nitroguanidine (NQ) or other chemicals associated with past production activities at this facility. After inspecting site conditions at the SFAAP, considering currently available information about the nature and extent of environmental contamination on the installation, and reviewing pertinent scientific literature, we conclude that uptake of nitroguanidine by beef cattle is unlikely. However, it is not known if other chemicals may be present in grazing areas that could contaminate beef. We concur with the Army's proposed plan to sample soil, vegetation, and surface water in graze lands. If chemicals that are known to bioaccumulate in animals are detected in grazing areas, sampling of cattle may be needed. Details supporting our conclusions are presented here.
During our initial site scoping visit to the SFAAP in September 1995, we toured the installation and observed cattle grazing areas. Cattle, weighing on average about 500 pounds, graze on SFAAP for approximately 3 months. During that time they gain between 200-300 pounds. The cattle are then moved to finish pastures or feedlots where they remain until they weigh between 1,100-1,200 pounds. Once the cattle reach this optimum weight, they are sold to processing plants.
Much of the plant property is leased for agriculture, and cattle do graze in some areas where nitroguanidine-containing wastewater was used to irrigate pastures over a two-year period, from the fall of 1986 through the fall of 1988. A study was done to evaluate the land treatment system at SFAAP and to determine the effect of the existing system on the soil and groundwater. The process wastewater contained detectable quantities of the explosive NQ, guanidine nitrate (GN is an intermediate material in the NQ production process), nitrate-nitrogen, sulfates, and low levels of cadmium, chromium and lead. However, soil samples, from irrigated areas that received the highest cumulative wastewater loading, contained no accumulation of wastewater constituents except for nitrogen and salinity levels. The levels of nitrogen and salinity detected in these soil samples would have no effect on cattle that graze in the area. Grasses, which utilize the nitrogen from the wastewater, grow more lush. When these grasses decay, the nitrogen is returned to the soil. Possible effects of increased salinity are plant toxicity and decrease soil permeability. The concentrations of metals detected in soils were comparable to background surface soils Nitroguanidine and guanidine nitrate levels in surface soils were also very low (below 2 parts per million).
Most contamination on SFAAP is associated with areas designated as Solid Waste Management Units (SWMUs). Some of the SWMUs are within grazing areas, but fences keep cattle from entering these contaminated parcels. Although the dewatered blender ponds (SWMU 13) are not fenced, steep banks and cattle guards at the entrance make it unlikely that cattle would stray into this area from adjacent grazing land. Moreover, chemical concentrations in background soils are consistent with levels detected in soils and sludge samples from SWMU 13.
Available information does not suggest that grazing areas on SFAAP would contain significant levels of chemical contamination. There may be some runoff from SWMUs that could transport contaminants into adjacent grazing land. The Army is planning additional sampling this year to address the concern about grazing areas. They propose sampling of soil and vegetation in the northeast, central and west grazing areas to determine what type of contaminants, if any, are present. The vegetation sampling will provide information about potential uptake of contaminants in plants. Analysis will include explosives, metals, polyaromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs) and pesticides. Dioxin will also be analyzed in samples from the west grazing area, which is near the burning grounds where dioxin was previously detected. And finally, surface water and sediment samples will be collected where cattle have access to ponds and streams. If chemicals known to concentrate in tissue are present at concentrations exceeding background levels, sampling of beef cattle may be needed.
Concerns about the safety of consuming meat, primarily from game harvested from contaminated areas on ammunition plants in the U.S., have prompted a number of biota investigations. We review the findings of several of these studies and also provide information concerning the potential for nitroguanidine uptake in tissue.
Biota Studies:
Explosives
Biota studies at ammunition plants in the U.S. indicate little or no uptake of explosives in animal tissues. Deer were the target species sampled in all of these studies. These studies evaluated HMX, RDX, dinitrotoluene (DNT), trinitrotoluene (TNT) and its metabolites (1,3-dinitrobenzene, 1,3,5-trinitrobenzene, 2-A-4,6- dinitrotoluene, and 4-A-2,6-dinitrotoluene). The explosives levels in deer meat were at or below the analytical detections limits, and do not pose a health threat to people who consume the meat. Although no cattle studies were done, we expect explosives levels in beef would be comparable to those found in venison since both cattle and deer are ruminants.
At Badger Army Ammunition Plant (BAAP) in Baraboo, Wisconsin, deer tissues (liver, muscle and heart) were analyzed for dinitrotoluene (DNT). None of the tissues from the 12 deer taken from BAAP contained 2,4-DNT or 2,6-DNT at or above the 0.1 part per million (ppm) detection limit.
Liver and muscle from deer, quail and rabbit harvested from the Alabama Army Ammunition Plant were analyzed for TNT and 9 metabolites. None of these tissues contained explosives levels above the detection limit of 0.2 ppm.
Deer studies at Joliet Army Ammunition Plant (JAAP), Illinois, address concerns about environmental contamination in the explosive manufacturing area and the load, assemble and pack (LAP) area. No bioaccumulation of explosives were detected in venison, liver and kidneys from deer harvested from JAAP.
Muscle and liver from deer harvested from the Aberdeen Proving Ground and background sites in Maryland contained no detectable levels of explosives. The analysis included 2,4,6-TNT and its metabolites (1,3-DNB, 1,3,5-TNB, 2-A-4,6-DNT, and 4-A-2,6-DNT), RDX, HMX, 2,4-DNT, and 2,6-DNT.
None of the ammunition plant studies have included analysis for nitroguanidine (NQ) in animal tissue. However, because NQ-containing wastewater was land applied at SFAAP, a laboratory study was done to assess effects on local vegetation. There was some evidence that NQ, at least in soybeans, is absorbed by roots and translocated to the leaves, where it induces chlorosis (growth inhibition and leaf damage) and is metabolized. In the same study it was unclear if there was uptake of NQ in grasses (tall fescue and smooth bromegrass) because little or no effects were seen in these plants.
Laboratory studies on the effects of nitroguanidine on animals has also been investigated. Animal experiments indicate that NQ is unlikely to accumulate in tissue because the chemical is not extensively metabolized. [ pV-2] Experiments in rats given nitroguanidine orally, demonstrated that virtually 100% of the unmetabolized chemical is excreted in the urine within 48 hours. The NQ was initially concentrated in the gastrointestinal tract, then distributed in the blood to the major organs. However, within 48 hours after dosing, less than 0.02% of the administered dose remained in any major organ. [ pV-2] These findings suggest that even if NQ is detected in soils and/or vegetation in grazing areas on SFAAP, it appears improbable that tissue accumulation in beef would occur. Because the unmetabolized compound is quickly eliminated in urine, deposition of NQ in meat is not expected, particularly since the cattle are slaughtered months after they grazed on SFAAP.
No studies of health effects of nitroguanidine in humans have been reported in the literature. [pVII-1,] No chronic toxicity or carcinogenicity studies are available for NQ, therefore it is classified in Group D; Not classified as to human carcinogenicity. [ pXI-1]
Other Chemicals
Some biota studies also evaluated uptake of organochlorine pesticides (DDT, DDD, DDE), polychlorinated biphenyls (PCBs) and metals because these chemicals can be stored in tissues. At Joliet Army Ammunition Plant, Aberdeen Proving Ground (APG), and respective off-post background locations for both sites, no uptake of PCBs or organochlorine pesticides occurred in deer tissues. Arsenic was detected in venison, and in deer liver from APG, in deer harvested from both on-post and off-post locations. However, none of the arsenic levels pose a health threat to people who consume the meat. In a deer study conducted in New Jersey, cadmium levels in livers from older deer prompted the issuance of a health advisory. Based on these studies, it appears that metals can accumulate in deer tissues; however the levels may or may not pose a health threat.
CONCLUSIONS AND RECOMMENDATIONS
If further clarification is needed or if additional information becomes available for review, please do not hesitate to contact this office at 404-639-6070.
Lorna L. Bozeman, M.S.
| CREG: | Cancer Risk Evaluation Guide, a highly conservative value that would be expected to cause no more than one excess cancer in a million persons exposed over time. |
| DWEL: | Drinking Water Equivalency Level, a lifetime exposure level at which adverse, noncarcinogenic health effects would not be expected to occur. |
| EMEG: | Environmental Media Evaluation Guide, a media-specific comparison value that is used to select contaminants of concern. Levels below the EMEG are not expected to cause adverse noncarcinogenic health effects. |
| LTHA: | Lifetime Health Advisory is the concentration of a chemical in drinking water that is not expected to cause any adverse noncarcinogenic health effects for a lifetime of exposure. |
| MCL: | Maximum Contaminant Level, the enforceable drinking water regulation that is protective of public health over a lifetime at an exposure rate of 2 liters of water per day. |
| RBC: | Risk-based Concentration, a contaminant concentration that is not expected to cause adverse health effects over long-term exposure. |
| RMEG: | Reference Dose Media Evaluation Guide, a lifetime exposure level at which adverse, noncarcinogenic health effects would not be expected to occur. |
| SMCL: | Secondary Maximum Contaminant Level, a non-enforceable guideline that regulates contaminants that may cause cosmetic or aesthetic effects in drinking water. |
| SSL: | Soil Screening Level, an estimate of a contaminant concentration that would not be expected to cause noncancerous health effects over a specified duration of exposure or to cause less than one excess cancer in a million (10-6) persons exposed over a 70-year life span. |
APPENDIX C: ATSDR GLOSSARY OF ENVIRONMENTAL HEALTH TERMS
ATSDR defines an exposure pathway as having 5 parts:
When all 5 parts of an exposure pathway are present, it is called a Completed Exposure Pathway. Each of these 5 terms is defined in this Glossary.
- breathing (also called inhalation),
- eating or drinking (also called ingestion), and
- or getting something on the skin (also called dermal contact).
APPENDIX D: SAFE DRINKING WATER ACT FACTSHEET AND DRINKING WATER TREATMENT FACTSHEET
Click here to view Appendix D Part 1 in PDF format (PDF, 229KB)
Click here to view Appendix D Part 2 in PDF format (PDF, 501KB)
APPENDIX E: KWWI'S NPDES PERMIT
Click here to view Appendix E in PDF format (PDF, 259KB)
APPENDIX F: RESPONSES TO PUBLIC COMMENTS
The Agency for Toxic Substances and Disease Registry (ATSDR) received the following comments during the public comment period (September 19 to November 26, 2001) for the Sunflower Army Ammunition Plant (SFAAP) Public Health Assessment (PHA) (September 2001). For comments that questioned the validity of statements made in the PHA, ATSDR verified or corrected the statements. The list of comments does not include editorial comments, such as word spelling or sentence syntax.
Response: Thank you for the information. ATSDR downloaded the data and incorporated it into the PHA (please see the exposure from eating fish from Kill Creek or Captain Creek section).
Response: Thank you for the information. Reference to the proposed sale of SFAAP to Oz Entertainment has been changed in the PHA.
Response: ATSDR was created in 1980 to protect the public from hazardous wastes and environmental releases. This mission excludes consideration of workers exposed to chemicals used in the normal course of their employment. Instead, the health of workers is protected under the Occupational Safety and Health Act, which Congress passed in 1970. This act requires that employers provide "employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees" (section 5(a)(1)). To enforce the new legislation, the act created three government entities dedicated to protecting workers: Occupational Safety and Health Administration (OSHA), National Institute of Occupational Safety and Health (NIOSH), and the Occupational Safety and Health Review Commission (OSHRC). OSHA sets and enforces standards and regulations to prevent injury or harm to workers at their job. This includes setting standards for exposures to chemicals and regulations for providing workers with the proper equipment to protect themselves, such as respirators. OSHA regulations must be followed or the employer can be assessed fines. NIOSH gathers and analyzes information about injuries and illnesses in the workplace and recommends standards to OSHA. OSHRC is the entity that settles disputes arising from enforcement of OSHA regulations. As required, the Army and contractors at SFAAP follow OSHA standards and guidelines to protect their worker population.
Response: ATSDR has updated this community concern to include a discussion specific for dioxin exposure from consuming beef from cattle grazed at SFAAP. Dioxins were one of several families of chemicals evaluated during the grazing study by the Department of Defense (Burns & McDonnell 2002). 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 levels that would produce adverse health effects in people consuming beef from cattle grazed at SFAAP.
Response: Whenever safe to do so, lead and/or asbestos were removed by conventional methods from the buildings prior to ignition. These methods insure that any remaining lead and asbestos-containing materials are minimal in volume (KU 2001). In addition, control systems (e.g., strict meteorological conditions, water curtains, fire retardant, and close monitoring by personnel) were used to limit deposition of lead- and asbestos-containing materials to the site. The Department of the Army (Army) and the U.S. Army Industrial Operations Command, the authorities for the removal response actions, could best answer questions regarding the use of robotic techniques at SFAAP.
Response: If the results from the test burns had shown that asbestos and/or lead were at concentrations of concern downwind from the site, further sampling would have been conducted during future open burns (CHPPM 1997). However, because asbestos was never detected and lead was not detected at levels of concern at the fenceline, the U.S. Environmental Protection Agency (EPA) and the Kansas Department of Health and Environment (KDHE) were in agreement with the Army that further sampling was not warranted. The buildings that were chosen for the test burns represented worst-case scenarios for lead and asbestos contamination. In addition, most of the buildings were of similar design, structure, and build (personal communication with SpecPro representative, 2/8/02). Therefore, while there was no formal quality assurance program, the sampling that was conducted at the three test burns was determined to adequately represent the conditions of future open burnings.
There were incidences where debris from the open burnings 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 these instances SFAAP and Alliant Techsystems met with KDHE to discuss the issue of potential lead and asbestos 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].
Response: While the effectiveness of fire containment devices to contain ash and debris has not been documented specifically for SFAAP, the methods employed by SFAAP (e.g., strict meteorological conditions, water curtains, fire retardant) are commonly used, recommended practices for containing airborne particles. Several regulators (EPA and KDHE) and experts in the fields of atmospheric science and meteorology developed these methods to be effective in minimizing impacts to the neighboring community. These experts determined that (1) burning under strict meteorological conditions favors deposition of material on SFAAP property and disperses the smoke plume quickly, (2) the use of water curtains limit material suspension and localize material deposition by decreasing the plume's buoyancy and by removing suspended particles from the plume, and (3) fire retardants promote a high temperature burn that incinerates many of the suspended particles (KU 2001; personal communications with KDHE representative and a Certified Consulting Meteorologist, 2/14/02).
Response: In August 2001, KDHE responded to residents' concerns that lead and asbestos have been deposited on their properties during open burnings at SFAAP by proposing to conduct an initial biased sampling of debris, visible waste, and other areas in yards nearest to or directly adjacent to SFAAP. They projected that the sampling area will be expanded to encompass additional impacted areas if the initial sampling indicates a potential impact to residential yards (KDHE 2001d). However, the residents declined to have their soil sampled (personal communication with KDHE representative, 12/01).
Response: If soil samples are obtained by KDHE (mentioned above), then ATSDR can evaluate the levels of asbestos and lead (if any) that are present in soil of their yards for their potential to adversely affect public health.
Response: The U.S. Army Center for Health Promotion and Preventative Medicine (CHPPM) helped to develop the sampling strategy and participated in the ambient air sampling efforts at SFAAP. In addition, EPA and KDHE provided review and oversight. The aerial sampling events followed procedures established by the American National Standards, Specifications, and Guidelines for Quality System for Environmental Data Collection and Environmental Technology Programs. The project was managed by two registered Environmental Professional Engineers, with a combined experience of over 65 years, who developed the model that established criteria for wind speed, wind direction, and air stability to prevent asbestos-containing material from leaving the boundaries of the plant during a building burn. Quality assurance and quality control (QA/QC) was overseen by a certified physical engineer who for seven years was Director of Monitoring Systems/Quality Assurance at EPA Headquarters (EnviroVisions 1997).
Response: ATSDR evaluated the currently available air sampling data and determined that enough information existed to conclude that when proper burning procedures are followed, the people who live around SFAAP (including sensitive persons) are not being exposed to harmful levels of airborne asbestos or lead generated during the open burning. Please see the discussion on the Air Pathway for more details.
One of the purposes of the public health assessment process is to identify future actions to prevent adverse human health effects resulting from exposure to hazardous substances in the environment. However, the available information does not indicate that the open burnings are causing exposures that could result in adverse health effects among the community. Without documentation of the existence of an exposed population, the design of an epidemiological study is not appropriate.
Response: ATSDR drew its conclusions based on the currently available data, our best professional judgement, and a conservative evaluation process. ATSDR determiend that adequate information was available to support the conclusions. If additional data become available that could suggest potential exposure, then if requested, ATSDR can evaluate this new information.
