ORRHES Meeting Minutes
March 22, 2005
Table of Contents
- Call to Order/ Opening Remarks
- Introduction of Subcommittee Members
- Announcements, Agenda Review, and Correspondence
- Approval of September 14, 2004, ORRHES Meeting Minutes
- Status of Action items
- Status of the Draft TSCA Incinerator PHA
- Discussion of the November 30, 2004, Executive Session
- Agency Reorganization
- Status of Public Health Assessments
- Presentations/Discussion: TSCA Incinerator PHA - Public Comment Release
- Presentation/Discussion: New ATSDR Web Site for the ORRHES
- Presentation/Discussion: DHAC Proposed Plan for Collecting Information About the ORR Community
- Presentation/Discussion: Community Health Education
- Work Group Reports
- Presentation/Discussion: Y-12 Uranium PHA Video
- Discussion of Next Meeting
- Action Items From Today's Meeting
- Additional Items
- Meeting Adjourned
The Oak Ridge Reservation Health Effects Subcommittee (ORRHES) convened on March 22, 2005, in the Alpine Room at Oak Ridge Mall at 333 East Main Street, Oak Ridge, Tennessee. Chairperson Kowetha Davidson called the meeting to order at 12:15 p.m.
Kowetha Davidson asked all attendees to introduce themselves. The attendees present during the meeting were:
Kowetha Davidson, ORRHES Chair
Marilyn Horton, Designated Federal Official (DFO) for ORRHES
Tony Malinauskas, ORRHES member
David Johnson, ORRHES member
Susan Kaplan, ORRHES member
Jeff Hill, ORRHES member
Bob Craig, ORRHES member
James Lewis, ORRHES member
Pete Malmquist, ORRHES member
Herman Cember, ORRHES member
Charles Washington, ORRHES member
Karen Galloway, ORRHES member
George Gartseff, ORRHES member
Peggy Adkins, ORRHES member
Barbara Sonnenburg, ORRHES member
Don Box, ORRHES member
Lynn Roberson, public member
Luther Gibson, public member
Jon Richards, U.S. Environmental Protection Agency (U.S. EPA) Region IV liaison
Chudi Nwangwa, Tennessee Department of Environment and Conservation (TDEC) liaison
Brenda Vowell, Tennessee Department of Health (TDOH) liaison
Tim Joseph, U.S. Department of Energy (DOE)
Bill Cibulas, ATSDR
Jack Hanley, ATSDR
Bill Taylor, ATSDR
Janna Telfer, ATSDR
Susan Robinson, ATSDR
Trent LeCoultre, ATSDR
Sandy Isaacs, ATSDR
Burt Cooper, ATSDR
Bob Safay, ATSDR
Amy Adkins, TA Consulting, Inc.
Ellen Rogers, The Oak Ridger
John Wilhelmi, ERG
Liz Bertelsen, ERG
AnnouncementsKowetha Davidson announced that Bill Cibulas and Jack Hanley were named as the ATSDR co-project managers. Dr. Davidson asked if Dr. Cibulas and Mr. Hanley could sit at the front of the room. Following no objections, Dr. Cibulas and Mr. Hanley moved to sit next to the Chair.
Agenda ReviewKowetha Davidson reviewed highlights of the agenda for the meeting.
- Status of Action Items.
- Status of Public Health Assessments (PHAs).
- Presentation/Discussion: the Toxic Substances Control Act (TSCA) Incinerator PHA Public Comment Release.
- Presentation/Discussion: Launch of ATSDR's New Web Site for Activities Related to the Oak Ridge Reservation (ORR).
- Presentation/Discussion: the Division of Health Assessment and Consultation (DHAC) Proposed Plan for Collecting Information About the ORR Community.
- Presentation/Discussion: Community/Physician Health Education.
- Work Group Reports.
- View ATSDR Video on the Y-12 Uranium PHA.
CorrespondenceKowetha Davidson said that there had been two letters drafted since the last ORRHES meeting on September 14, 2004. One was a letter from ATSDR to Barbara Sonnenburg in response to a question she posed during the executive session on November 30, 2004. ORRHES members were provided with a copy of the letter during today's meeting. In addition, ORRHES members should have received a letter explaining that Bill Cibulas and Jack Hanley were named as co-project managers for ATSDR activities in Oak Ridge.
Bob Craig made the motion to approve the September 14, 2004, ORRHES meeting minutes. David Johnson seconded the motion. The minutes were unanimously approved.
Marilyn Horton directed the group's attention to the handout containing the ORRHES ATSDR recommendations and action items. She noted that there were no regular action items from the September 14, 2004, ORRHES meeting. However, she stated that the long-awaited Public Health Assessment Guidance Manual (PHAGM) was now available on CD, and had been provided to all of the subcommittee members today. Ms. Horton mentioned that people could also request a hard copy version of the PHAGM and Bill Taylor had some hard copies in the ATSDR Oak Ridge Field Office. James Lewis requested the manual in a hard copy version.
Marilyn Horton explained that all ORRHES members should have received both a hard copy and CD version of the Draft TSCA Incinerator PHA Public Comment Version. She said that this was sent out to members 2 weeks in advance of today's meeting. She noted that the public comment period began today (March 22) and would run through May 6, 2005. She added that subcommittee members had been provided with a copy of a newspaper article printed in The Oak Ridger on March 18, 2005, entitled "Health Assessment of TSCA Incinerator Releasing on Tuesday."
James Lewis asked if there would be any segment of the agenda to discuss the executive session held with Barry Lawson on November 30, 2004. He wondered if they would deal with these aspects or if the topics were "considered a dead issue." He believed that some "outstanding" issues remained and wondered how and if they would be addressed.
Marilyn Horton replied that the executive session would not be part of today's agenda. Ms. Horton explained that she had sent out Barry Lawson's summary report of the session. On multiple occasions, she had asked the ORRHES members to provide any questions that ATSDR could directly respond to regarding the session. However, Ms. Horton received no questions. She noted that Bill Cibulas, in a letter to Kowetha Davidson, responded to the issues brought up during the session. She said that one issue from the meeting regarded replacing Jerry Pereira as the project manager, and as a result, Bill Cibulas named himself and Jack Hanley as the co-project managers. In addition, Ms. Horton stated that the two-thirds majority vote was addressed in the letter and "ATSDR was committed to looking at all recommendations ORRHES makes."
James Lewis said that the interaction between ORRHES and ATSDR was not addressed nor discussed. He was not saying he necessarily wanted this handled during today's meeting, but he wanted it to be dealt with at sometime. Marilyn Horton suggested that Mr. Lewis bring this issue up during new business. Mr. Lewis would think about doing so, but wanted it noted that this issue was not addressed.
Bill Cibulas appreciated James Lewis's comments on the executive session. Dr. Cibulas said that there were some positive outcomes from the session (e.g., working out issues related to the PHAs), but believed that no one's expectations were completely met. He noted that a strong message was heard that there needed to be follow up on community concerns, and he had the sense from some of the ORRHES members that ATSDR was not doing this. Since this session, Dr. Cibulas said that ATSDR staff has had numerous conversations on how to ensure that the agency hears from the community. In addition, he explained that ATSDR is working to fill in the gaps from the needs assessment (described in detail during the meeting). He looked forward to obtaining the list of any additional issues requiring follow up and stated that ATSDR would try to address further issues that are identified.
Bill Cibulas sent the group greetings from Henry Falk and Tom Sinks. He explained that many changes have taken place at ATSDR and the Centers for Disease Control and Prevention (CDC) since the last ORRHES meeting. He noted that Dr. Falk was now the Director of the Coordinating Center for Environmental Health and Injury Prevention as part of the restructuring and reorganization within CDC. He added that the National Center for Environmental Health (NCEH)/ATSDR was now one of the CDC's centers that reports to the Coordinating Center. Also, Dr. Sinks has been asked to serve as the Acting Director of NCEH/ATSDR for a 120-day-period, and Dr. Cibulas noted that Dr. Sinks is "very engaged in activities at the ORR" and is looking forward to a meeting update.
Bill Cibulas referred the group to an overhead (attendees received as a handout) that detailed all of the upcoming PHAs and the estimated data validation draft (DVD) release dates for each PHA. Dr. Cibulas noted that he has tried to share his "strong commitment" in making sure that the work at Oak Ridge remains one of the highest priorities at ATSDR. He explained that there are eight remaining PHAs and one summary document that will be prepared at the end. He pointed out that ATSDR had an "ambitious schedule," and still remained on target for six of the eight PHAs. ATSDR did not, however, meet the schedule for polychlorinated biphenyls (PCBs) and mercury (both estimated to have DVDs released in February 2005). Dr. Cibulas next presented a more detailed slide of the status of the ORR PHAs (attendees received as a handout). Dr. Cibulas felt that PCBs and mercury were the more interesting PHAs because exposure investigations in the 1990s showed that there have been some exposures to PCBs and mercury via fish and possibly other exposure pathways.
Bill Cibulas noted that Jo Freedman, a senior toxicologist at ATSDR who had been preparing the PCBs PHA, retired from the agency with little notice. As a result, Jack Hanley has assumed the responsibility of finishing the PCBs PHA. Dr. Cibulas explained that they are learning more about subtle health effects associated with low-level exposure and about background levels of PCBs. He noted that Dr. Friedman's information is currently under review to ensure that it correlates with the most recent knowledge of PCBs. Mr. Hanley was working with Ken Orloff, also an ATSDR toxicologist, to ensure that the information contained in the PHA was up-to-date with the existing science. Dr. Cibulas said that a DVD of this PHA was scheduled for release in April 2005. He assured the group that this PHA was a priority.
Bill Cibulas explained that Bill Taylor, also a senior toxicologist within ATSDR, was the lead author on the Mercury PHA. He noted that Dr. Taylor was still receiving new data and was continuing his review of TDOH's Oak Ridge Dose Reconstruction. Dr. Cibulas believed that a DVD release of this PHA would most likely occur in May or June 2005. He added that this PHA remains a high priority for both Dr. Taylor and the agency.
Bill Cibulas asked the ORRHES members to work with ATSDR to ensure that these PHAs are the best possible documents. He noted that the Exposure Evaluation Work Group (EEWG) and the ORRHES will have a significant amount of material to review over the next year. He added that the off-site groundwater PHA was shared with the EEWG the previous evening and the TSCA Incinerator PHA &150; Public Comment Release was disseminated to the public today. He stated that the group had his and Jack Hanley's commitment to keep these documents on schedule and to work with ORRHES to the fullest extent possible.
Bob Craig asked if the Iodine 131 PHA had been released. Jack Hanley replied that this PHA was already out for DVD (when it is circulated through the designated agencies), and the document was currently undergoing internal review. Mr. Hanley said that they could move forward and present this PHA to the EEWG following this internal review.
Bob Craig asked why the White Oak Creek (WOC) PHA was back as a DVD. Jack Hanley explained that last year the EPA's Office of Radiation and Indoor Air (ORIA) had wanted to become involved, and therefore the document was sent back through data validation to give ORIA an opportunity to review the document. Mr. Hanley noted that some changes and edits have been made, and said that this should be the next PHA released for public comment.
James Lewis believed that the new process of reviewing the PHAs could have impacted the opportunity for some people to review the document at various stages. He said that certain noted scientists and others needed time to review these documents if ATSDR wanted community input. He wanted to see a time table before the document was released and circulated. Mr. Lewis was surprised that the TSCA PHA was available. He thought that copies of certain information had to be available earlier so people had ample time to review materials.
Bill Cibulas responded to James Lewis. Dr. Cibulas explained that the schedule was recently revised regarding when ORRHES can review the PHAs, which is now during the public comment period. He said that PHAs normally have a public comment period between 30 and 90 days, but it generally spans 45 days. If ATSDR had advance knowledge that there was a large interest in a PHA or that a topic was controversial, Dr. Cibulas said that ATSDR could increase the initial public comment period. He encouraged ORRHES to work with ATSDR on particular PHAs and to notify the agency if more time is needed. Dr. Cibulas added that if a good rationale existed for extending a public comment period, then the agency could certainly consider extending the period. Mr. Lewis appreciated Dr. Cibulas's comments because some of the PHAs deal with issues that are of greater interest. He did not believe that these PHAs were shared openly enough with the public (e.g., iodine).
Bill Cibulas was unsure why some people might not have known that the TSCA Incinerator PHA was being released today for public comment. Marilyn Horton explained that the PHA was sent 2 weeks ago to ORRHES members and that they needed to let her know if the document was not received. James Lewis apologized because he was referring more to products that are presented at the work group meetings. He thought that these materials (e.g., summary documents) needed to be provided to work group members with more advanced notice to allow people ample time to review them.
Because the DVD was still internal, Charles Washington wanted another column added for when the document was sent out to the public. Bill Cibulas confirmed that Mr. Washington wanted the schedule on the first slide expanded to incorporate more of the schedule from the second slide.
Tony Malinauskas asked if the TSCA Incinerator PHA had been submitted to EPA for its review. Bill Cibulas said that EPA reviewed the document during the data validation phase. Dr. Cibulas noted that any comments received from EPA Region IV, EPA ORIA, TDEC, and TDOH would have been received during this period. Dr. Malinauskas asked if these comments had been addressed. Dr. Cibulas said that the agencies' comments are all addressed before the document is released for public comment.
Jeff Hill requested that the schedule table include the final summary PHA.
Kowetha Davidson introduced John Wilhelmi, the presenter for this discussion. She said that Mr. Wilhelmi is a chemical engineer who specializes in evaluating air quality impacts from industrial emission sources. His professional career began as an air modeling specialist for a private consulting firm. For the last 10 years, he has continued this work as an environmental scientist at ERG. Dr. Davidson noted that Mr. Wilhelmi is a chemical engineer for ERGhe is not an employee of ATSDR. She added that Mr. Wilhelmi has also presented at some of the work group meetings.
John Wilhelmi presented the information on the TSCA Incinerator PHA through a PowerPoint presentation. Meeting attendees were provided with copies of these slides.
The outline for John Wilhelmi's presentation included:
- Objectives of the PHA
- Approach and background information
- A scientific analysis of the air exposure pathway
- Fate and transport
- Ambient air monitoring
- How community concerns are addressed
- Recommendations made to ensure that the incinerator continues to operate safely
According to John Wilhelmi, there were three objectives of the PHA:
- To evaluate the public health implications of off-site exposure to contamination released by the TSCA Incinerator (1991 to present; the time frame in which the incinerator has operated)
- To respond to specific community concerns
- To make recommendations to ensure that the incinerator continues to operate safely
John Wilhelmi stated that the main conclusion of the PHA is that the TSCA Incinerator does not pose a public health hazard.
John Wilhelmi explained the approach that was taken to prepare the PHA. This included:
- Identifying community concerns
- Conducting a site visit
- Obtaining and interpreting site records
- Considering relevant publications and guidance
- ATSDR: Public Health Reviews of Hazardous Waste Thermal Treatment Technologies: A Guidance Manual for Public Health Assessors
- EPA: Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities (draft)
- National Research Council (NRC): Waste Incineration and Public Health
John Wilhelmi read the following quote from ATSDR (2000), "Thermal treatment technologies [including incinerators] are inherently neither safe nor unsafe; whether they are safe depends on how they are designed and operated." Mr. Wilhelmi described this as the "guiding principle in developing the PHA" because he had to evaluate the data and available information in order to determine whether the incinerator was designed and operated safely.
John Wilhelmi presented a map to show the location of the incinerator and surrounding areas. He noted that the incinerator is located in the northeast corner of the East Tennessee Technology Park (ETTP), formerly known as K-25. He said that the nearest residents live about 1.5 miles due north of the incinerator, on the opposite side of Black Oak Ridge. There are also residents living southwest and northeast of the incinerator, but these areas are more than 2 miles from the incinerator.
John Wilhelmi presented a figure to show the design of the TSCA Incinerator. First, he explained the process for organic wastes, which are either fed into the incinerator as liquids or solids. They are almost completely destroyed either in the rotary kiln (primary combustion chamber) or in the afterburner (secondary combustion chamber). At the end of the combustion process, Mr. Wilhelmi said that the organic wastes are virtually gone, and the off-gases are cleaned by air pollution controls prior to being vented through the stack to the atmosphere.
Herman Cember asked what the organics were converted to when burned. John Wilhelmi said that at this point, mostly relatively benign molecules remain (e.g., carbon dioxide and water) and by-products of combustion. Mr. Wilhelmi stated that the environmental regulations require that 99.99% of organic wastes be destroyed or removed, and 99.9999% of PCBs be removed or destroyed. He demonstrated this through a visual aide that had characteristics similar to PCBs. If he had 150 55-gallon drums (about 150,000 pounds) of PCBs and fed this into the incinerator, then the small amount in his jar would represent the amount of PCBs that would remain. He said that 150,000 pounds is slightly less than the incinerator has treated over its history, and the substance in the jar showed the amount that would have escaped untreated into the atmosphere.
Charles Washington asked if this was irrespective of the waste being in solid or liquid form. John Wilhelmi said that this was correct.
John Wilhelmi concluded the discussion on organics by saying that these are largely destroyed, though there are some trace amounts of by-products emitted.
Susan Kaplan asked about metals. John Wilhelmi said that metals and radionuclides fed into the incinerator are not destroyed in either combustion chamber. They are largely collected in residuals, including ash, wastewater, and sludge, from air pollution controls. He noted that the efficiency of the collection varies based on the constituents entered into the incinerator, but that trace amounts of metals and radionuclides are emitted.
John Wilhelmi summarized that the incinerator basically destroys most of the wastes, and primarily non-hazardous emissions remain. Metals and radionuclides are mostly sequestered in residuals and will not be emitted in the air; however, some trace amounts are released via the stack gases.
Charles Washington asked about the temperatures in the afterburner. John Wilhelmi replied that the afterburner generally operates at 2200ºF when burning PCBs.
John Wilhelmi evaluated two types of air emissions: routine emissions coming out of the stack gas and non-routine emissions that occur during infrequent episodes or process upsets when the thermal relief vent is opened. Mr. Wilhelmi believed that non-routine emissions had occurred 18 times since the incinerator began operations, which he considered a "fairly good track record." Mr. Wilhelmi said that the significance of the openings during these non-routine events is that the gases from the incinerator are vented directly to the atmosphere. During these upsets, the gases do not pass through air pollution controls because the temperature cannot be controlled, and could consequently destroy the air pollution controls. He noted that episodic and routine releases from the main stack were evaluated in the TSCA Incinerator PHA.
Barbara Sonnenburg asked if there was a way to measure the radionuclides being released from the stack. John Wilhelmi responded that this is done, but not in "real time." He did not believe that instantaneous measurements could be collected. Ms. Sonnenburg asked if these were measured more than once a year. Mr. Wilhelmi explained that samples were collected weekly, and that these were used in DOE's modeling studies and considered in the PHA. He thought a problem existed when there are shorter sampling durations because there are higher detection limits. Therefore, detections are more difficult to identify. He said that a significant amount of air has to be collected in order to detect these contaminants. He noted that shorter duration samples could be collected, but the likelihood of detecting something is reduced.
Barbara Sonnenburg asked if measurements were collected below in the scrubbers and other places where radionuclides go in the incinerator. John Wilhelmi said that the most relevant measurement is of the emissions that are coming out of the stack. Ms. Sonnenburg realized this, but thought that if it was known approximately what goes into the incinerator, then measurements could be collected for what is released out of the bottom to determine what is coming out of the top. Mr. Wilhelmi did not believe that the measurements conducted here were done with the purpose of characterizing what goes out of the top because this is already in the measurements from the stack. He said that DOE has to measure in these residuals to know how to manage the waste. He addressed the original question, which asked if there were measurements of the radionuclides that are going out of the stack. Mr. Wilhelmi said that there are and have been these measurements throughout the incinerator's operational history.
John Wilhelmi made three points about the incinerator's background. First, he noted that the date of construction and permitting of the incinerator were pertinent to this evaluation. He said that the incinerator was designed, constructed, and permitted within the past 20 years during the time when fairly extensive environmental regulations have been in place. These aspects of the incinerator gave Mr. Wilhelmi assurances that things were operated safely. Second, the incinerator has been extensively studied throughout its history. Finally, Mr. Wilhelmi presented a graph showing the amount of waste treated at the incinerator during 1991-2002. The graph depicted an increase in the amount of waste treated in the mid-1990s, and a significant decrease since this time. Mr. Wilhelmi pointed out that the amount of waste treated today is about 5% of what environmental regulations indicate this incinerator can safely treat.
John Wilhelmi presented an illustration to demonstrate how the PHA's evaluation of the air exposure pathway considered emissions (i.e., what is coming out of the stack), the fate and transport (i.e., how emissions move through the air, react in air, and deposit from air), and the air sampling and monitoring (i.e., measurements of what it is in air). Mr. Wilhelmi explained that the air exposure pathway was evaluated because the PHA focuses on the route by which contaminants from the incinerator would most likely reach areas where people live.
Through an evaluation of the available data and guidance documents, John Wilhelmi identified eight groups of contaminants to evaluate in the PHA. The contaminants included:
- Volatile organic compounds (VOCs)
- Particulate matter (PM)
- Acidic gases
- Dioxins and furans
- Polycyclic aromatic hydrocarbons (PAHs)
John Wilhelmi explained that VOCs and PCBs are organic constituents largely destroyed in the incinerator. He said that PM, acidic gases, dioxins and furans, and PAHs are formed as combustion by-products in most incinerators. He added that radionuclides and metals are waste constituents that the incinerator can capture, but it cannot destroy them.
John Wilhelmi explained that there are stack emissions and fugitive emissions. To evaluate emissions, Mr. Wilhelmi analyzed various sources of emissions data. These data include trial burns (1988, 1989, and 2001), which are conducted to evaluate the effectiveness of the incinerator. He also evaluated performance tests (1988, 1990, 1995, and 2000), which are performed to demonstrate the incinerator's compliance with state emission limits. In addition, Mr. Wilhelmi reviewed continuous emissions sampling and monitoring data, which are conducted for oxygen, carbon monoxide, carbon dioxide, radionuclides, metals, and PM. He noted that there is a large volume of data available.
John Wilhelmi presented a brief summary on emissions. He noted that the strengths included having information available on every contaminant group evaluated and data that characterize the incinerator's performance. He said that Appendix A of the PHA includes extensive detail on the sampling methods for people who want more information. He also noted the limitations pertaining to emissions, including that no information exists on the actual exposures (because people are not exposed at the stack) and available data do not characterize emissions during episodic events.
John Wilhelmi explained that fate and transport are usually characterized through dispersion modeling studies. He said that metrological data are continuously collected at multiple sites at ETTP. He noted that the main studies used for the dispersion modeling analyses included the Governor of Tennessee's Independent Panel Report and multiple DOE studies. The DOE studies were conducted primarily to verify compliance with National Emissions Standards for Hazardous Air Pollutants (NESHAPs).
John Wilhelmi summarized the fate and transport discussion. He noted that the strengths of fate and transport data include reasonable accounts of air quality impacts, which are most important at locations and times where no samples are available. These data also help provide information on air sampling programs (e.g., equipment location). Ideally, he said that you want to measure where air quality impacts are expected to be the greatest. He stated two limitations with fate and transport data: a) no information is available on episodic events and b) modeling studies only provide estimates on air quality impactsnot direct measurements.
John Wilhelmi next discussed air sampling and monitoring. He explained that air sampling consists of discrete measurements at different times, whereas monitoring comprises more routine measurements collected at set frequencies. Many studies have been conducted on various constituents that include:
- DOE: PM, PCBs, metals, dioxins and furans, and radionuclides
- EPA: radionuclides
- TDEC: metals and radionuclides
- Tennessee Valley Authority (TVA): nitrogen dioxide, ozone, and sulfur dioxide
John Wilhelmi found it beneficial that there was redundancy among some of the measurements for different studies. For example, he pointed out that both DOE and EPA measured radionuclides and at relatively close locations, which provides an opportunity to compare the measurements in order to gauge their accuracy. He added that DOE and TDEC measure metals at co-located locations. Mr. Wilhelmi presented a figure to show each agency's monitoring and sampling locations.
Barbara Sonnenburg believed that the air generally flows to the north and east. John Wilhelmi replied that this was correct; the air largely flows along the axis of the valleys in a northeast to southwest direction and vice versa. Ms. Sonnenburg questioned why such a large number of stations are located to the northwest and southwest, but only one lies to the east. Mr. Wilhelmi clarified that these stations are not used exclusively to monitor the air quality impacts of the incinerator; they are also used to monitor other activities at ETTP. He added that he was comforted by the fact that the air mass must first pass where monitors are located before reaching the location of any residents. He recognized that the coverage was not perfect, but he was comforted knowing that the emissions will pass through monitoring stations before going in any directions toward residential areas.
Barbara Sonnenburg asked if John Wilhelmi was comforted even with only one monitoring station to the east. Mr. Wilhelmi clarified whether Ms. Sonnenburg wanted to know why there were not more stations. She said that this was her question. Mr. Wilhelmi explained that modeling studies show that these monitoring stations are already located in areas that would receive the largest impact. He continued that it was a plausible argument that measuring in locations expected to receive lower impacts would not necessarily be needed.
Barbara Sonnenburg referred to the power plant in Kingston, Tennessee, where the air goes up for a long time and then filters down. She asked if emissions from the incinerator could possibly go up over the stations and then down into residential areas. John Wilhelmi thought that this was a good question and speculated that this could happen at times. He noted that modeling was conducted over a year before these monitoring stations were put in place to establish where the greatest impacts would be expected to occur, and as a result, stations were installed in areas where the greatest air quality impacts were anticipated. Regarding Ms. Sonnenburg's comment on the Kingston Power Plant, Mr. Wilhelmi said that comparisons could be difficult because the power plant stacks are so tall and modeling conducted to place these stations considers the stack height of the incinerator and metrological conditions.
Barbara Sonnenburg wanted to know if the emissions could rise and go over the stations. John Wilhelmi said that the stations were not capturing emissions every second of each day, and that the emissions would go over at times. However, on average over the course of a year, Mr. Wilhelmi stated that these monitoring stations are located where the maximum ground level impacts are expected to occur. Bob Craig added that the stacks in Kingston are extremely tall and that the emissions from the TSCA Incinerator appeared to go straight out for the most part. He also made the point that the emissions were heavily modeled and monitoring stations were placed in areas found to have the highest concentrations. Ms. Sonnenburg said that Dr. Craig's comments were reassuring. Mr. Wilhelmi believed that the stacks at the incinerator are about 100 feet tall.
Kowetha Davidson stated that more dilution would occur as you move further away from the source. Therefore, concentrations will continue to decrease because of the effect of dilution. Charles Washington replied, "Dilution is not a solution." John Wilhelmi noted that both of these comments were correct. Mr. Washington had some knowledge of these monitoring stations because he helped build them. He detailed that the fallout of emissions that occurs depends on the particular contaminant. For instance, PM will fallout in one location and VOCs could fallout in a different place. In addition, he said that some radionuclides will be liquefied and some will be gases when they come out depending on what happens to them inside the chamber. He added that it would also depend on what is present in the air because other compounds could be formed.
John Wilhelmi said that when something is released from the stack, it will go in different directions. He noted that it is not realistic to be able to monitor everywhere, and therefore, decisions have been made for monitoring locations based on extensive modeling on points of maximum impact areas. He added that dilution will also play a role as you move further away from the source.
James Lewis asked about Question B2 on page 68 of the PHA. Mr. Lewis thought that the PHA needed to show the magnitude coming out of the stack and noted that the page indicates that a small amount (i.e., 83 pounds) is coming out. He asked for an estimate of the maximum amount released from the TSCA Incinerator compared to TVA. John Wilhelmi explained that Mr. Lewis was referring to a portion of the document that compared incinerator releases to other area sources, most notably to the local power plants. Mr. Wilhelmi said that a dramatic difference is seen, but that there is also a different quality in pollutants and the types of pollutants that dominate the difference. Mr. Wilhelmi was unsure of the maximum amount from the TSCA Incinerator off the top of his head, but noted that this is discussed in the PHA. However, he said that most of the comparisons were for smaller periods of time (e.g., pounds per day and shorter averaging times). He could figure out the numbers over a longer period of time if this was recommended. Mr. Lewis believed that this would be helpful and applauded Mr. Wilhelmi for adding this requested information into the PHA.
Don Box said that page 68 of the PHA mentions the number of pounds coming from the power plant. Mr. Box thought that the general public would be unaware of the radionuclides coming out of the plant and thought it might help to show this. He noted that the small amounts from the TSCA Incinerator really do not compare with the large amounts from the steam plants.
John Wilhelmi encouraged the group to read more of page 68. He tried to frame the comparisons in a meaningful way, but also used caution because comparing emissions rates can be misleading when comparing emissions from high and low stacks. He had looked at local sources because ultimately the air that people breathe is impacted by all local sourcesnot solely the TSCA Incinerator.
Herman Cember referred to where 83 pounds was compared to almost 6,000,000 pounds. He said that the fraction of emissions from each one per cubic meter of air would be important in the site of interest instead of the total pounds emitted. John Wilhelmi said that Dr. Cember made a good point. He added that this was also why he pulled together the emission, fate and transport, and monitoring and sampling data because it completes the picture. He stated that emissions data alone could steer a conclusion in the wrong direction.
John Wilhelmi reported the notable findings from the PHA. He said that most contaminants were found at levels below health-based comparison values (CVs), which indicates that air concentrations are safe. This also reflects the contribution of local sources. He explained that arsenic, cadmium, and chromium were the only substances that required a further in-depth health evaluation. Based on his experience, Mr. Wilhelmi said that these contaminants were not unique to this site; he has found these at almost all sites where he has evaluated ambient air monitoring. He conducted a toxicological evaluation on these metals and found that the measured levels were not of health concern. Mr. Wilhelmi also noted that the results appear to be of known and high quality data. In addition, sampling has occurred during episodic release events, when one would expect emissions (at least over a short time) to be highest.
Charles Washington asked about the accumulation of fallout in relation to people who were born here, grew up here, and still live here. John Wilhelmi said that the incinerator only began operating in 1991, so the exposure is limited for these individuals. Mr. Washington asked if Mr. Wilhelmi was also referring to steam plants. Mr. Wilhelmi did not know the specific information on steam plants because the document focused on the health impacts from the incinerator. He explained that he considered other sources because he has to interpret the samples collected, but he did not know the history of the steam plant. He noted, however, that the health-based CVs have lifetime exposure programmed into them.
Herman Cember asked if you could determine whether contamination came from the incinerator or other sources when the samples were collected. John Wilhelmi said that mostly you could not, but in some instances with radionuclides you could. Mr. Wilhelmi stated that having multiple monitoring locations helps because you can look at spatial variations. For instance, there was virtually no spatial variation for arsenic, cadmium, and chromium, which implied to him that the incinerator is not the predominant source. If it was the predominant source, Mr. Wilhelmi said that you would see the highest concentrations in nearby downwind locations; however, this did not really occur for these substances. Mr. Wilhelmi continued that, in general, measurements in air do not have footprints. If contaminants are unique to the source, then you could feel confident that it came from there. Although, many contaminants measured came from a large number of emission sources. Mr. Wilhelmi said that it was important to note that the measurements below CVs, regardless of the source, were not unhealthy exposures.
James Lewis did not want them to lost sight of Charles Washington's comments. He said that there might be some issues when you look back at other sources in the past, though Mr. Lewis did not believe that this was an issue for TSCA.
Barbara Sonnenburg asked whether there are any differences in the places measured on the sides of the incinerator, and if you could measure radionuclides going toward or away form the incinerator because towards it might be from other sources. John Wilhelmi had not looked at this primarily because he used conservative health-based screening values and all measurements for radionuclides were below these values. Therefore, he did not try to determine where the radionuclides originated. He mentioned that the highest measurements in the network he evaluated were seen downwind of the incinerator, but these were still an order of magnitude below the CVs.
Barbara Sonnenburg said that the levels could be lower this year, but asked if this number was added onto radionuclide exposure that people already received. She said that this could have accumulated and asked if this would have been significant. John Wilhelmi could look at this, but he did not look at exposure prior to 1991. Kowetha Davidson noted that they needed to consider if any of these constituents accumulate in the body because very few of these substances will stay in the body. Mr. Wilhelmi believed that Appendix C in the PHA presented comparisons of measurements collected in areas immediately downwind of the incinerator to Knoxville and Nashville; he recalled the differences being negligible.
John Wilhelmi summarized the monitoring and sampling. He noted that Appendix A in the PHA contained detailed information on emissions, Appendix B presented information on modeling, and Appendix C had the monitoring methods (e.g., years monitored and comparisons to CVs). The monitoring and sampling showed that nearly every pollutant was below CVs, and that only arsenic, cadmium, and chromium required further evaluation. He detailed three strengths of the data: a) show more direct indicators of exposure, b) capture contributions from all sources (not just the incinerator), and c) provide excellent spatial and temporal coverage. Mr. Wilhelmi stated that these data contain no significant limitations.
Herman Cember asked if you could take pollutants that elicit similar biological effects (e.g., mercury, manganese, and lead all affect the central nervous system) and sum them together to determine if an adverse health effect would occur. John Wilhelmi said that ATSDR has a mixtures guideline for measurements, but he did not consider this because he looked more at the relative CVs. He added that the concentrations were considerably below the CVs with a fairly safe margin. Dr. Cember said that this is something that the public might ask about and that it should be addressed. Mr. Wilhelmi agreed.
Bill Cibulas pointed out that ATSDR has a mixtures research program experienced in dealing with the issues of combined effects of contaminants. Dr. Cibulas said that generally if a contaminant is well below the guidance values, then combined effects will probably not be seen. When you reach levels where health effects begin to be seen from single chemicals, however, Dr. Cibulas said that additive or synergistic effects might start to be visible. Herman Cember believed that this was something that the public might ask and therefore the issue should be clarified and addressed. Dr. Cibulas agreed. John Wilhelmi stated that this would be included among the public comments before the final version of the document is released.
John Wilhelmi next presented a synthesis slide to show the eight contaminants for which emissions, fate and transport, and air sampling or monitoring data are available. These data are available for all of the contaminants, except for air sampling or monitoring data for VOCs, acidic gases, and PAHs. Mr. Wilhelmi would not consider these to be "critical gaps," and believed that this was an "incredibly complete" compilation of data.
John Wilhelmi read the following conclusions:
- The TSCA Incinerator releases trace levels of contaminants into the environment, but in amounts far below levels associated with health effects.
- Regional air quality in the Knoxville area is sometimes poor. This does not result from a single source, but from industrial and mobile sources over a broad area.
- Mr. Wilhelmi noted that these air quality problems are not unique to Knoxville; they occur in many parts of the country and occur mainly due to ozone and fine particulates.
- An opportunity exists to verify the quality of DOE's ambient air monitoring for metals.
James Lewis asked if John Wilhelmi found few data gaps. Mr. Wilhelmi said that he speaks in terms of "critical data gaps," and he did not believe there were any for contaminants in air.
Barbara Sonnenburg asked if agencies collected data with their own equipment or evaluated the data collected by DOE. She wondered if the agencies assumed these data were correct. John Wilhelmi knew that DOE and TDEC have side-by-side stations for ambient monitoring of metals in air.
Barbara Sonnenburg explained that she had served on the Air Pollution Control Board for 14 years. During her time there, she had continuously asked how they knew the quantity of radionuclides burned and what might go up the stack. According to Ms. Sonnenburg, the board said that the only way to know was to measure what comes into the incinerator by reading shipping documents. Ms. Sonnenburg stated that they assumed what they were told was correct, which she believed was inefficient. She thought that the current process sounded more advanced than in the past. Mr. Wilhelmi said that there is continuous sampling of radionuclides coming off the stack gases. He was unsure of the origin of the information Ms. Sonnenburg had heard.
Herman Cember said that he was previously a member of the Illinois Department of Nuclear Safety, which had a completely independent system for measuring what was coming out of reactors, and DOE also had measurements. Dr. Cember said that these measurements were always in agreement. Barbara Sonnenburg said that these comments were reassuring. John Wilhelmi added that the PHA includes a table showing side-by-side DOE and EPA radionuclide measurements collected off site, and noted that there is "excellent agreement."
Jon Richards was a former EPA Permit Inspector before TDEC took over the TSCA monitoring program. In this position, he said he conducted several inspections on a regular basis. He stated that EPA had required that DOE monitor at the stack and model assuming that the pollution control equipment was not functioning. He noted that DOE modeled what was coming out. Mr. Richards stated that EPA also conducted its own sampling of soil around the incinerator.
John Wilhelmi thanked the ORRHES members for their comments. He showed a figure that detailed the supporting lines of evidence for the PHA's main conclusion. The figure had five pillars, which would be included in the PHA's executive summary. Mr. Wilhelmi believed that these multiple, independent lines of evidence supported the main conclusions in the PHA.
Herman Cember said that the information in the PHA was "technically fine," but that it needed to be shaped more for the public. He referred to question A.2. in the PHA that said, "Are the workers at the incinerator at risk from their occupational exposures?" Dr. Cember believed that a "yes or no answer" needed to be provided first, and then information to support the answer could be added. Kowetha Davidson explained that the document will be sent through the EEWG for further review, the work group would then provide comments and recommendations to ORRHES, and the subcommittee would submit a recommendation to ATSDR. Dr. Davidson asked that Dr. Cember provide his comments to the EEWG so they would be incorporated into the comments from the work group.
John Wilhelmi said that a fact sheet geared to explain the PHA findings to the public would be released when the final document is released. Kowetha Davidson noted that different people would look at the document in different ways, and that they wanted to bring the different views together.
Herman Cember suggested that they have an elementary school teacher (i.e., English teacher or social studies teacher) read the PHA and provide comments in order to ensure that the document is understandable for the public.
Susan Kaplan said that ATSDR had "skirted issues" with regards to EPA's comments on the Y-12 PHA. She believed it was important for them to see EPA's comments and how ATSDR addressed them. She knew that this was part of the data validation process, but noted that this version of the document was not available to the public. Jack Hanley explained that ATSDR received no comments from EPA Region IV or EPA's ORIA on the TSCA Incinerator DVD PHA. The agencies were planning to provide their comments during the public comment period. Ms. Kaplan said that, as a general rule, she would like ORRHES to receive the comments from EPA's ORIA. She had ORIA's comments from the Y-12 PHA, but did not believe that they had been provided to ORRHES and she thought they should be for future PHAs. Mr. Hanley explained that the detailed comments on the Y-12 PHA from EPA Region IV and ORIA, as well as ATSDR's responses, had been handed out to all ORRHES members. In addition, all of the comments and responses were available to the public.
James Lewis directed his comments to Bill Cibulas. He said that ATSDR presented a fact sheet for this PHA to the Community Concerns and Communications Work Group (CCCWG). He believed that these types of documents should be reviewed internally before being sent to the work group. He thought that more problems would be created for the public if ATSDR continued to produce documents that leave more questions than answers. He had found it interesting and unique that EPA had worked with a literacy group at CDC to prepare documents to discuss asthma with the public. Mr. Lewis added, "We've been here 4 ½ years screaming about the same thing...so something needs to be done internally." He suggested that people review the work group minutes to see Dick Gammage's comments on the ATSDR-prepared fact sheet. He added that they needed to be reaching various audiences.
Bill Cibulas responded to James Lewis. Dr. Cibulas understood the subcommittee's desire to see the documents as soon as they are available. He said that the PHAs were not available until they are released for public comment, but that ATSDR was bringing the document's contents to the EEWG as soon as possible. He explained that ATSDR has been served well by not releasing the documents until they have undergone final agency review and clearance (after the DVD process) and after the agency has signed off on the documents. He understood these concerns and thought that the issue went back to their conversation on the public comment period time frame. Dr. Cibulas also replied to the issue of readability. He noted that the PHA serves a number of audiences, including both technical and lay people, and that the documents normally "meet the mark." Dr. Cibulas pointed out that this was the reason why community and health education were important so that the agency could reach the target audience with health messages if identified as a need in the PHAs. He explained that it is difficult to develop products that fit all of their needs, but they want to develop products that disseminate health messages that are useful and appropriate for the target audience.
James Lewis said he was not "attacking the entire document." He was also referring to responding to concerns, fact sheets, and other communication tools. He thought that ATSDR should put its focus into needed areas so that issues were appropriately addressed. He did not, however, think that this had been done.
Barbara Sonnenburg emphasized Charles Washington's comments. She wanted the document to say that health problems would not result from the amounts accumulated over the years. John Wilhelmi said that the data tell them that health problems would not be expected. Ms. Sonnenburg asked if they could tell what accumulates over 15 years will not cause harm. Mr. Wilhelmi said that the CVs used to select the contaminants of concern (COCs) assume lifetime exposure. Ms. Sonnenburg wanted to ensure that this information was included in the PHA. Mr. Wilhelmi believed that it was in the PHA, but he would make sure it was incorporated if it was not already in the document.
John Wilhelmi discussed the community concerns for the PHA. He had circulated a draft list at the EEWG in November 2004 before proceeding with the document. He explained that the community concerns were identified through ATSDR's community concerns database, TDEC's "Responses to 101 Questions," comments made during work group meetings, and a review of site documents. Mr. Wilhelmi organized the comments into four topics and addressed them in question and answer format in Section V of the PHA.
John Wilhelmi detailed the three health-based recommendations made in the PHA:
- DOE, EPA, and TDEC should continue to operate their routine monitoring networks.
- TDEC should achieve lower detection limits in its metals monitoring network.
- Mr. Wilhelmi explained that he had tried to conduct a comparison to gauge the accuracy of the measurements in order to independently validate the quality of the monitoring data; however, this could not be done because TDEC's methods are not sensitive enough.
- TDEC should continue to issue warnings on days with poor air quality, and residents should heed these warnings.
- Regular air quality is more specific to ozone and fine particulates.
James Lewis questioned the use of the word "continue" and asked if there was any reason to suspect that these monitoring efforts would stop. John Wilhelmi had no doubt that these efforts would continue. He had made the conclusion that occasionally air quality is poor. Therefore, this left in his mind that he should address this and that the public should know when poor air quality is an issue. Mr. Wilhelmi said that they are basically congratulating the agencies for what they have done and supporting their future efforts.
John Wilhelmi also described the three communications-based recommendations in the PHA:
- TDEC should issue annual fact sheets that document the environmental status of the TSCA Incinerator (e.g., findings of monitoring, how many inspections occurred, and whether the amount of waste treated increased or decreased).
- After lowering detection limits, TDEC should compare its metals monitoring data to DOE's metals monitoring data.
- Both DOE and TDEC should improve the annual reporting of their environmental monitoring networks.
James Lewis asked if the recording data did not compare to DOE. John Wilhelmi replied that DOE uses more sensitive methods than TDEC. As a result, TDEC has many non-detects and it is not possible to see whether these are consistent with DOE's measurements. Mr. Wilhelmi explained that it would be preferred for TDEC to add more sensitive methods so that there could be a side-by-side comparison as they have for DOE and EPA with the radionuclide data. Bob Craig asked whether TDEC's methods are protective of public health; Mr. Wilhelmi said that they are protective of public health. He continued that TDEC would be able to detect a very large increase in the amount of metals being emitted, whereas DOE's more sensitive methods can detect finer nuances.
Tony Malinauskas asked if ATSDR would issue a four-page easily understood summary document for the public that outlines the results on all of the PHAs. Dr. Malinauskas said that the PHA was for the technical community. Herman Cember noted that he was referring to the community concerns and questions in the PHA, which he felt should be addressed so that the community can receive answers. Dr. Malinauskas agreed with Dr. Cember.
James Lewis said that they had originally discussed having a 10-page summary, but that they would not be having a 10-page summary for this PHA. Jack Hanley said that when the Y-12 PHA was released to ORRHES, ATSDR worked with the subcommittee during the DVD to create summary documents for the general public. ATSDR had planned to follow this same procedure for the TSCA Incinerator PHA, but the work group did not have the PHA to review when the summary was discussed and was unable to provide specific comments. Mr. Hanley explained that they would develop future four-page summary documents with the CCCWG during the public comment period. Mr. Hanley added that the CCCWG would receive a revised copy of the four-page summary document.
Jeff Hill thought it would be valuable to have a draft four-page summary available at the ORRHES meeting when the next PHA is released. Jack Hanley said that they had prepared a four-page summary document, which was shared with the CCCWG. However, the CCCWG found the summary document to be too general and that it left more questions than it answered. Mr. Hanley had needed more specific details and information to revise the document, and noted that they are currently updating the document based on the CCCWG's comments. Now that ORRHES has the PHA, ATSDR would approach the CCCWG again to tweak and make additional edits (as needed) to the summary document.
Jeff Hill asked if ORRHES would see the draft summary document before it is released. Jack Hanley said that they could have another meeting and noted that it would be beneficial for ORRHES to review it. Kowetha Davidson suggested discussing the document at the next ORRHES meeting when they vote on the comments for the TSCA Incinerator PHA. Mr. Hill thought that they needed to consider the number of PHAs remaining and that it was taking two work group meetings to review the product. He believed that the process was taking longer than needed. Mr. Hanley stated that when they share the draft PHA with the ORRHES members, they could also share the draft summary document. Mr. Hill wanted to have at least one version of the summary document reviewed by the work group prior to being brought to ORRHES. Mr. Hanley replied that they would work with work group members to figure out the most effective process.