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Oak Ridge Reservation

ORRHES Meeting Minutes
June 28, 2005

Presentation/Discussion: Impacts on Oak Ridge Landowners of Off-Site Releases to the Environment from the Y-12 Plant and Associated Long-Term Stewardship Issues (Continued)


Dr. Cember asked if Ms. Kaplan was referring to the 400 ppm cleanup limit for mercury. She answered that this was correct.

After providing a definition on bioavailability, Charles Washington asked what form of mercury Ms. Kaplan was referring to. She said it would depend on what forms were in the soil. Dr. Davidson explained that these were only general definitions.

Mr. Washington asked whether Ms. Kaplan believed that the DOE official could estimate the mercury concentration based on seeing the black band. Ms. Kaplan indicated that the comment was not made to her–it was in the newspaper. She explained that she was providing issues heard by other people, which was why she was raising the issue.

Regarding the Bruner Site data, Don Creasia asked whether anyone had looked at all of the peaks to determine if they represented different forms of mercury. Ms. Kaplan was not sure, but Dr. Craig said this had not been done. As she understood it, Ms. Kaplan said, these types of analyses are expensive and controversial as to the appropriate methods to use. She indicated that similar to ATSDR, these sampling methods assumed that the mercury was the more toxic form of mercuric chloride.

Mr. Lewis asked if the Bruner Site data stratification had been done before or after the major sampling occurred; Ms. Kaplan said it had been was done before.

Referring to the photographs of posted signs, Dr. Cember asked whether Ms. Kaplan had analyzed fish, as the sign indicated that fish were not safe for human consumption. Ms. Kaplan indicated that this is discussed in the ITSPA report, adding that information presented at the "State of the Creek Address" delved into fish and biota data.

Ms. Kaplan provided a handout, which she stated included comments from EPA headquarters in red printing; she stated that these were the Office of Radiation and Indoor Air's (ORIA) responses to her questions for the June 2004 meeting. Ms. Sonnenburg asked for clarification about the handout. Ms. Kaplan said that it contained the responses she received from EPA headquarters in response to her questions. She said that the handout detailed comments made by the EPA representatives who came to speak to ORRHES in June 2004. Ms. Kaplan stated that she had assumed these would be made available, and that she continued to ask for them to be made available from EPA. In addition, Ms. Kaplan said, she provided EPA Region IV's response to her report, which was sent to her by Jon Richards and discussed concerns about her including the EPA responses (provided in the handout) in her report.

Mr. Richards clarified that Ms. Kaplan had a draft copy of working responses to her questions, provided to her by Lowell Ralston on April 30, 2004. He explained that he, Jeff Crane, Bonnie Gitlin, and Mr. Ralston had worked together on these responses–the responses Ms. Kaplan received after the meeting as a final document in December. Ms. Kaplan said that their responses are in italics in the document. Mr. Richards reiterated that the responses constituted a draft, working document. He indicated that all of the actual technical content seen in red was provided in the slides that everyone received during and after the meeting. He said he was concerned that Ms. Kaplan was mischaracterizing this letter: he said it was not EPA Region IV responses in black, but EPA ORIA and Region IV responses in black. According to Mr. Richards, everyone received a package in August and a final copy in December of the official responses from Region IV and ORIA together. According to Mr. Richards, these were not two separate responses as was being suggested by saying that Region IV comments were in black and ORIA comments were in red. He said that this was not true. Ms. Kaplan apologized if she was confused, adding that the technical material was in response to her questions.

Mr. Lewis recalled when Mr. Ralston attended their meeting; in his opinion, he made some interesting comments. Ms. Kaplan said that Mr. Ralston did not give a talk–she said she believed that he had not been allowed to respond to her questions and that Ms. Gitlin gave a talk. She said that the subcommittee had requested that Mr. Ralston talk, but he was not permitted to do so. Mr. Richards said that Ms. Kaplan's statements were incorrect; Ms. Kaplan replied that they were not there to argue. According to Mr. Richards, Ms. Kaplan was making false statements. She repeated that Mr. Ralston had not been allowed to stand up and give a talk. Mr. Richards continued that this was not true, stating that Mr. Ralston had stood up and talked. Ms. Kaplan asked if Mr. Ralston had spoken in response to her questions. Mr. Richards said that Mr. Ralston had not, but that he had gone through some of his slides and provided each slide to everyone. According to Ms. Kaplan, she asked Ms. Gitlin for permission to include this information in her report, including the responses from Mr. Ralston to the questions she had submitted to EPA. In her opinion, she said, she took the appropriate steps to include this material in the document.

In his opinion, Mr. Lewis said, the sampling technique seemed to be the crux of the issue. He questioned whether core samples instead of homogenized samples should have been used. Dr. Cember expressed his belief that the question was really whether studies on populations or animals show hazards associated with peak or average concentrations of contaminants. Dr. Taylor explained that he was continuing to evaluate these issues, and his findings would be presented in the mercury PHA. Ms. Kaplan indicated that she was raising these questions and concerns because she did not have the answers, expressing her belief that ATSDR will need to address these issues.

Dr. Evans explained that exposure limits in soil are always based on average concentrations. He indicated that exposures are to average concentrations because they are dealing with exposures that may occur over lifetimes. He stated that soil, as a medium, is formed of discrete particles. Therefore, any soil sample is a composite, and the question is how big of a composite was taken. In this particular case, he said, the composite was large enough to cover the entire area. According to Dr. Evans, it is appropriate to use this sampling technique and 400 ppm as the level for an average exposure. He expressed his belief that it is appropriate to compare an average to an average. Ms. Kaplan said she could point out an exposure that is not an average, such as her children who dig. Dr. Evans explained that this was the point of using an average–there will always be values below and above the average. The point, however, is that exposures occur over many years and occur to the average. According to Dr. Evans, the average is the factor to consider when referring to exposure and in terms of environmental assessment.

L.C. Manley asked how much of a contaminant is diffused following deposition where a contaminant could move deeper years later. Dr. Evans answered that one reason to conduct whole core sampling is because of material deposited during flood events. Following Mr. Manley's question about how to get peak values, Dr. Evans replied that exposure limits are based on average values–not peak values.

Dr. Davidson said that she would have more concerns if she saw very high concentrations at the top rather than low values moving to higher values as the depth increases. She said she believed that you cannot be exposed to high concentrations below the surface unless you go through the upper layers. Ms. Kaplan responded that this meant that the sample becomes homogenized by digging unless there is a band and a child is digging down, but stated that one cannot assume that this would always be homogenized. Dr. Davidson indicated that what you would bring up would include everything from the top down to the bottom as well, adding that there would be no doubt that you would be exposed to high concentrations if there were high detections at the top.

Dr. Blaylock explained that EPA's usual methodology considers the average for cleanup. In his opinion, however, EPA is typically concerned about other types of contamination. He said that the type of contamination caused by floods is unusual because a high concentration is deposited, which is filled in, and then another high concentration is deposited. To his knowledge, he said, DOE and EPA agreed that EPA's usual methodology was the one to use; he noted, though, that it was difficult to find additional information on this methodology. Ms. Kaplan indicated she had received the sampling report that weekend.

Mr. Hanley said that he had the sampling and analysis plan that was developed. He said that DOE (working with EPA) prepared the plan; EPA Region IV and EPA headquarters, as well as EPA's Las Vegas Laboratory, were involved. He added that EPA and TDEC reviewed and approved the plan. Mr. Hanley explained that EPA uses averages in its risk assessment, and the purpose of using core samples comes from risk assessment. He added that this was an issue that would be clarified, addressed, and evaluated more closely in the PHA. To her knowledge, Ms. Kaplan said, only about five of 3,000 samples were evaluated in 1-inch increments. She said it was important to understand that: in her opinion, they could not have an accurate idea of the contamination by only looking at five samples.

Mr. Washington said it was important to realize what took place at Love Canal, New York, where samples were not collected in this way (instead, core samples were used). Analysts saw peaks of high amounts at Love Canal, he said, and in his opinion this indicated that an unusual oxidation of mercury was occurring. As a chemist, he said, one would suspect that depending on the acidity of the soil and other factors, other layers would be expected to have mercury also. He added that this could change over periods of time depending on what is in the soil.

In her opinion, Peggy Adkins said, this was the most practical and helpful presentation that she had seen in a long time. She expressed her appreciation to Ms. Kaplan for bringing these issues to the forefront. She expressed her belief that anyone who has planted has been dealing in the area of highest concentration. (Ms. Kaplan interjected "potential" highest concentration.) Ms. Sonnenburg asked whether the contamination on the map went further downstream. Ms. Kaplan said that the contamination goes down to Watts Bar, but only EFPC was sampled for this particular study. Ms. Sonnenburg asked if the Watts Bar Reservoir had been studied. According to Ms. Sonnenburg, there is a great deal of flooding in the lower areas that goes into their yards and about 6 feet over their dock. Mr. Richards answered that significant levels of cesium and mercury have been detected in the deep channels in sediment. One of his previous project managers was looking over Watts Bar when an evaluation was conducted to assess growing gardens with deep channel sediment containing mercury and cesium. He said the report contains the detailed information about the sampling conducted in the area. In her opinion, Ms. Kaplan said, some of the recommendations written by ORSSAB were interesting to her and she included them in her report. She explained her interpretation that samples were pulled from along the swimming area in Kingston and averaged, and asked if this was correct. Mr. Richards was not sure, but said this would be in DOE's report on the Watts Bar Reservoir, adding that the report was one of the FFA commitments. Janice Stokes expressed her belief that EPA was also associated with the report. Mr. Richards replied that DOE prepares the report, and EPA and TDEC review it.

Dr. Blaylock explained that there are several detailed reports on mercury and cesium 137, and on radionuclides traveling from White Oak Creek to the Clinch River to Watts Bar Reservoir. According to Dr. Blaylock, this has been well documented, particularly regarding radionuclides taken by core segmented samples. He said that mercury goes further than Watts Bar, noting that it is diluted as it goes downstream. He added that cesium and mercury are present in the deep sediments, and that the same is true for the Clinch River. He said there is some on the banks, but that it is usually less than 17 picocuries. Ms. Sonnenburg asked if she should be concerned about flooding where she lives, over the Meigs County border. Dr. Blaylock expressed that he personally would not be concerned.

Dr. Cember said he understood the exposure pathway through fish and the bioconcentration and biotransformation from inorganic to methyl mercury, which was much more toxic than inorganic mercury. He questioned, however, the human exposure pathway for mercury that is 8 inches below ground. Ms. Kaplan replied that she has sons who dig. Dr. Cember asked how the mercury gets into their bodies. Ms. Kaplan explained that they could get it on their hands, and also indicated one of her concerns was associated with people who eat dirt (pica behavior). She noted that such people might not constitute a large group, and questioned whether this was an issue to be concerned about.

When evaluating the cleanup level (180 ppm originally and then 400 ppm) in the floodplain soil for inorganic mercury, Mr. Hanley explained, ATSDR used a residential scenario. In addition, the most sensitive population (young children), the most highly soluble form (mercuric chloride), and the most probable exposure routes (hand-to-mouth ingestion and playing in dirt) were considered and exposure was assumed to occur every day to 400 ppm. Ms. Kaplan noted that ATSDR did not use 1,600 ppm. Mr. Hanley said that ATSDR concluded that 400 ppm of mercury in the EFPC floodplain was protective of public health. Dr. Cember stated that the evaluation considered exposure day after day to 400 ppm, indicating that sometimes exposure could be to 1,600 ppm and sometimes less, with an average of 400 ppm. Mr. Hanley noted that this was correct.

Ms. Stokes said that she herself is a classic example of a Watts Bar Lake resident of Kingston. According to Ms. Stokes, her legs broke by themselves last March: she had stepped into a hole, and when she removed her legs from the hole, a substance resembling tarnished silver remained on her legs for more than a week that could not be washed off. She stated that many experts have told her that this was probably mercury. She expressed her belief that it is also in the Clinch River, within the water intake for the City of Kingston. She said that she lived on the lake and had a dock at Southwest Point, at the confluence of the Clinch and Tennessee Rivers. According to Ms. Stokes, unless you owned lakefront property, the only area for swimming in the 1950s and 1960s was at the City Park.

In her opinion, she said, there have been many deaths that cannot be attributed to anything, including her 16-year-old neighbor who died of a heart attack and three neighbors having kidney cancer. She expressed her concern that they continue to study the contaminants when contaminants are known to cause effects, and questioned why they do not study the people. In her opinion, this was ridiculous–it had gone on for 12 years with ATSDR and even before that. She stated that the chemicals have not killed her yet, but expressed her belief that they have certainly disabled her. Ms. Stokes expressed her belief that if the agency could not see the health effects she and other people have and the health effects caused by these elements, then ATSDR was wasting its time and taxpayers' money and she did not appreciate it. She stated that she was here after 12/13 years asking them again to study the people.

In her opinion, Ms. Stokes said, Ms. Kaplan had done a wonderful service for this board. She expressed her belief that some honorable and caring people serve on ORRHES, but that some other members are serving their own interests. She expressed her opinion that the subcommittee consisted of people with conflicts of interest in real estate, as DOE contractors, and via other connections. According to Ms. Stokes, she and other people had raised the same issues as Ms. Kaplan 10 years ago during the EFPC studies. She said that these issues continue to arise, and in her opinion they will not go away because the contamination remains. She said that her generation learned these lessons the hard way and so will the next generation. She expressed her belief that the contamination will stay because mercury sinks and evaporates into a gas at 72º. She said she would guarantee that there has been some volatilization of mercury, using an example to express her belief that volatilization would occur with the low water level in EFPC on a 100º day in mid-August.

She expressed her belief that people in power gather that the public can be deceived and blown off by intellectual jargon, but mercury and other chemicals are in EFPC. According to Ms. Stokes, a board member had a 2-year-old child enrolled in a day care near the creek, and the child played next to the creek and had seizures. She asked to be looked in the eye and told that they cared, expressing her belief that they did not. In her opinion, she said, they needed to take action and stop wasting nearly 2 million dollars a year because it was preposterous. She thanked Ms. Kaplan for what she had done for the community, expressing her belief that Ms. Kaplan was also a victim. In her opinion, she said, others look at those who are concerned as though they can be blown off, but they cannot be.

Mr. Lewis expressed his viewpoint that this amounted to a discussion about the public and protecting public health versus a child playing in the dirt, a landowner, and those who excavate land. Based on his observations, he said, this is not an issue from the general public perspective, but an issue regarding whether there is a concern for an individual landowner living in the floodplain. In his opinion, he said, there is probably no issue if everything stays the same. However, the question remains on addressing these issues for an individual, such as someone who has a child or wants to sell property and notify people of what could be there. He said that he continues to hear that this is about the public, but repeated that this appeared to be an individual issue.

In terms of public disclosure of real estate, Ms. Kaplan replied, a person may buy a piece of property that has a 1-year warranty from a developer. When that person becomes aware of the problem, according to Ms. Kaplan, the owner could be responsible to inform a buyer even though the owner was never informed. She questioned who was educating people on these issues. She said she had spoken with a lawyer who said that this was a possibility even if you were not informed. Ms. Kaplan indicated that the tri-party agreement said that the area was cleaned up because it was remediated to 400 ppm on average. She said, however, that she could not alleviate her concern that 1,600 ppm or 3,000 ppm, even if it is 6 to 8 inches down, is still an issue.

Ms. Smith said that she had researched this history and looked at the data on mercury levels in floodplain soils. In addition, she said, treatability studies were conducted as part of the feasibility study on this subject. In her opinion, she said, the findings were quite interesting. She stated that a number of studies were conducted to investigate what it would take for mercury to come out of soil. She referred to Ms. Stokes' comment that mercury would volatize at a low value; according to Ms. Smith, soil was roasted to incredibly high temperatures and mercury did not come out until very high temperatures were reached. Also, she said, plants were grown in mercury-contaminated soil so that the vegetables and leaves could be analyzed for mercury, but the practical evaluation of the availability of mercury in that soil using various methods of extraction indicated that mercury was not coming out–it was not available. To her, the findings suggested that plants were not being exposed to mercury and it was not coming out of the air. In her opinion, Ms. Stokes' fears were similar to those that many of them had when they first heard about the mercury here. She expressed her belief, however, that some people who had these fears stopped being afraid after these investigations occurred because the information indicated they were not being exposed to what they had thought they were.

Ms. Stokes expressed her belief that there were mercury rings and mercury in the trees. She asked whether Ms. Kaplan's report discusses the update on leaves and trees causing evaporation. Ms. Kaplan said that this was not included. Ms. Stokes indicated that information on this topic had been presented to the ORSSAB and could be found in the minutes.

Ms. Kaplan stated that her primary concern is that levels of mercury are rising in fish, which in her opinion indicated that the mercury was being transformed somewhere. Ms. Smith replied that her information was hearsay, but she was told that fish were being exposed to what was being released into the water from the Y-12 Plant–not to mercury in soil. She indicated that the plant still releases certain amounts of mercury in very small concentrations in water. Fish are exposed to water over time; according to Ms. Smith, more natural organic matter in water helps keep the mercury in the solution in a form that is available to fish. Thus, she said, it is associated with very low concentrations in water itself. According to Ms. Smith, material deposited in the floodplain does not typically erode away but is buried and remains there. To her knowledge, she said, this material is not coming out of the floodplain into the water; rather, material is entering the water from the Y-12 Plant. Ms. Kaplan questioned that if this was true, then mercury would show up in the fish that closer to the creek. However, according to Ms. Kaplan, findings show that these fish are well downstream of Y-12; she said this was why she expressed this concern at the "State of the Creek Address." As she understood it, Ms. Kaplan said, this mercury could be coming from the soil. Ms. Smith expressed her belief that they did not know where the mercury was coming from. Ms. Kaplan said that she had asked this question and been told that it was a possibility.

Ms. Sonnenburg asked Dr. Taylor if he could address some of Ms. Stokes's request by evaluating individuals and looking at particular areas of concern (as indicated by members of the public) for the mercury PHA. Dr. Taylor replied that this would not be part of his work. Mr. Brooks indicated that it had already been done twice for people eating fish–once in Oak Ridge and once in Watts Bar Reservoir. Ms. Kaplan said that this examined urine and hair. Ms. Stokes expressed her belief that people were found to have mercury contamination; Ms. Kaplan said that to her knowledge there was only one person. Mr. Hanley explained that the Tennessee Department of Health (TDOH) and NCEH drew urine samples and tested people living near Oak Ridge in 1984–1985; the findings would be discussed and presented in the PHA. Also, Mr. Hanley said, it was determined that the most likely exposure would be from fish down in the Clinch River and Watts Bar Reservoir, and a study on this was conducted in 1997.

Ms. Sonnenburg expressed an interest in hearing from some of the other experts. She questioned whether one could detect mercury levels in bones and blood by evaluating urine: she had been told that this did not work. According to Ms. Adkins, she has heavy levels of mercury poisoning. She expressed her belief that mercury does not show up in hair or urine unless it has been agitated by chelation–after other toxins are removed from the body–and it could take 2 to 3 years for mercury to show up even if present in high levels. She indicated her belief that mercury is not easy to detect and is reluctant to show up even though it causes damage and embeds in the deep tissues of the brain. According to Ms. Adkins, she had been tested at the University of Tennessee (UT) and was told she was fine. Ms. Sonnenburg asked how she had been tested. Ms. Adkins said she was tested via urine and hair, but mercury did not show up. However, after chelation, according to Ms. Adkins, mercury showed up in huge levels about 3 years after other toxins had been removed. Ms. Sonnenburg said she was told that urine testing shows nothing for people who eat fish, and questioned why urine was tested when the substance could be in all parts of the body and not show up. Mr. Hanley said that the study conducted in 1994 included urine analyses, but the 1997 study included blood samples. Ms. Sonnenburg said she believed that the 1997 study included mostly urine sampling; Mr. Hanley said that she was incorrect. Ms. Kaplan said that she has summaries of these studies in her report, and Mr. Hanley said that summaries were also on the ORRHES Web site.

Michael Quick is with the International Chemical Workers Union Council (ICWUC)/International Association of Machinists and Aerospace Workers (IAM) Center for Workers Safety, teaches HAZWOPER training to BWXT employees, and is a longtime Oak Ridge resident. In his opinion, he said, the 400 ppm level seems to have been deemed safe provided there is no disturbance of soil or anything else. He expressed his belief that this was a good presentation of the report. He asked what happens if soil is disturbed by tree-planting, digging, gardening, or other such activities. He said that if someone buys the property, even if contamination is 6 inches below ground, these activities would have changed something in his opinion. He stated that this might be safe if nothing changes; however, he asked what happens if these activities occur and changes do take place. He asked what the degree of threat would be for people living downstream and people doing the work. Ms. Kaplan indicated that she had statements related to his comments that she would discuss so they would be incorporated into the record.

In his opinion, Mr. Quick said, it appeared to be a common sense approach to notify residents living there now and if plans change. He questioned why there was reluctance for notification, saying that as a resident he found it difficult to see the reason. He asked if it was because developers or the city itself were trying to revamp the area's image and feared having this issue resurface. In his opinion, Mr. Quick said, it was a no-brainer that people living there should be warned.

Mr. Hanley expressed his belief that the question regarding mercury changing over time was good, noting that this issue would be further evaluated in the PHA. He indicated that mercury had been evaluated in the 1990s. He elaborated on the three different forms of mercury. Elemental mercury, which is associated with vapor problems, was detected in air (above soil) at concentrations about 2,000 times below levels where health effects have been observed. Organic mercury, which is the more toxic form that bioaccumulates in fish, was basically detected in soil at background levels. Most of the mercury is inorganic–what ATSDR refers to as inorganic salts. According to Mr. Hanley, the form could not be identified and the mercury was determined to be relatively unavailable, as it would not come out of soils and therefore would be difficult for DOE to extract. Mr. Hanley indicated that they would evaluate the issue dealing with change over time and see if this could be added to the discussion in the PHA. In his opinion, he said, Ms. Kaplan's report brings up many issues. He indicated that the answers exist, but this was an opportunity for ATSDR to bring these answers to the forefront and clarify them so that the public can be informed about past decisions, findings, and why ATSDR determined that this was protective of health.

Mr. Cardwell asked whether mercury poisoning would stay in the system forever or if it would work itself out. Dr. Blaylock answered that organic mercury will usually pass through the system with little taken up. On the other hand, he said, methyl mercury goes into the blood stream, usually accumulates in the brain, and remains for a long time–causing permanent damage, such as tremors.

Ms. Stokes said she had experience with mercury because she has been poisoned with it. She said she has conducted research on the substance for probably about 10 years, and that studies on mercury date back several years. She expressed her belief that mercury has been a poisoning element since its existence. As she understood it, she said, if an acute dose of mercury is taken into the body, it will show up in the urine; however, with a chronic dose, mercury will not come out in blood or urine except in minute traces. In her opinion, she said, it probably indicates that the person has a huge body burden of mercury if traces of mercury are detected in blood or urine. Ms. Stokes expressed her belief that fish absorb mercury through water and eating biota, and then turn the mercury into methyl mercury once the substance is in their bodies.

According to Ms. Stokes, there was a scientist working with trimethyl mercury who died a few months after the chemical went through her glove. To describe trimethyl mercury's toxicity, Ms. used the example of elemental mercury in a thermometer. She said that a pin-size drop would be enough to poison a child even if it were vacuumed up; she based this statement, she said, on studies of identical twins exposed where one died and one survived. In her opinion, she said, it did not mean that contamination did not cause a death if two people are exposed and only one dies. Instead, she said, this indicated that one person's nutrition, susceptibility to poisons, and other factors were better. She cautioned the group to remember that these toxins affect people differently.

Ms. Sonnenburg asked about blood tests. Ms. Stokes repeated her opinion that a person probably had a heavy body burden if any trace was found in blood samples. She agreed with Ms. Adkins, expressing her belief that a higher level would be shown if the body is agitated by chemicals and that a trace would have to be used if it was not agitated.

Mr. Brooks said that he lives next to the floodplain. He explained that he had horses that currently grazed on the floodplain and had their hair and feces sampled. He also grew tomatoes on the floodplain; these were sampled as well. According to Mr. Brooks, the samples showed nothing. He indicated that he would not pursue all of the technical issues of the report, but would rebut some of the statements regarding public participation, particularly his own. He read from page 7 of the report, "He [Brooks] said the mercury in the floodplain is essentially innocuous because it is one of the most insoluble compounds known." Mr. Brooks said that this was not the only reason, noting that data in the literature are never mentioned in the report. According to Mr. Brooks, there are studies on the uptake of mercury in humans (noting a study related to mercury sulfides and the mineral cinnabar, used in Chinese traditional medicine to calm nerves), which found that uptake was minimal. In his opinion, he said, this report leaves out and selects information to support a decision, but does not include information in literature or that has been presented at various meetings. Therefore, he believed, the report is biased.

Mr. Brooks referred to a quote from a letter to Joe LaGrone published in The Oak Ridger that the report states was upsetting to some: "I would especially like to thank Mr. David Page and many others of the DOE and the contractor staff who assisted me in the presentation of the opposition view during the last several months." He then brought up a quote provided in the report, cited as personal notes from a property owner regarding Mr. Brooks's statements: "To me [this was] an extraordinary disclosure: DOE coaching a person or persons to appear at a formal public meeting to pressure EPA and the State of Tennessee to accept higher cleanup limits when such higher limits accrue direct benefits to DOE." Mr. Brooks said he was unaware that being civil was a sin. Regarding the implication that he and DOE had the same objectives, Mr. Brooks expressed his belief that he and DOE both had concerns that the risk analysis for mercury had been calculated incorrectly. In fact, he said, there was evidence in DOE reports of original computations being changed to those mandated by EPA. Further, he said, Mr. Page had assisted him, but in his opinion the report's use of the word "coached" suggests a personal insult to his integrity. As far as he and EPA having the same objectives, Mr. Brooks said that the cost was estimated at over 1 billion dollars. According to Mr. Brooks, Fred Maienschein had estimated a safety factor of 500,000, and he and DOE had expressed their opinions that this was wasting money.

Mr. Brooks commented on the plural use of "persons," saying that he had spoken for himself alone. He added that anyone familiar with Mr. Maienschein, Josh Johnson, and himself would know that being coached is not a possibility. He explained that Mr. Page's assistance was limited to providing names of risk assessors and a toxicologist for him to speak with about risk calculations and to answer his questions about the project. Also, according to Mr. Brooks, he asked SAIC to provide him with a disk of mercury levels to avoid rekeying several thousand numbers and had also discussed how the data were massaged. He stated that he never suggested any remediation levels or direction of efforts, and was never asked to.

Mr. Brooks referred to another statement in the report from page 9: "Something here appears to be all wrong. Al Brooks spoke nine times at the meeting, more times and more pages of transcript than anyone else." According to Mr. Brooks, this statement asks whether the meetings were manipulated–a serious charge against a professional person. He said that asking someone for assistance should not be classified as conspiracy or collusion, adding that this assistance was available to anyone who asked politely. Ms. Kaplan made a correction that he had spoken 14 times. Mr. Brooks stated he was not aware that there was a set time limit for speaking at public meetings. In his opinion, he said, the report makes no mention as to whether the comments made by himself and other members of the public were valid or not. According to Mr. Brooks, both Almer Akin of EPA and Fred Saffron of SAIC said that public claims were technically correct though EPA calculated these things differently–incorporating safety factors into the input data–from a position based on EPA's congressional mandate, which in his opinion was a political and not a scientific position.

Mr. Brooks expressed his belief that EPA's method to calculate risk had been a bone of contention on the Lower EFPC project. According to Mr. Brooks, the basic error was that EPA had no mercuric sulfide data (except for minimal data in scientific literature) and used mercuric sulfide–the most soluble known form of mercury compounds–in its calculations and substituted these values for the most insoluble. In his opinion, he said, this produced very biased data, which was what they had been opposed to.

To conclude, Mr. Brooks said, he felt that the worst transgressions of the ITPSA report are not in impugning him, as he is now retired and his past colleagues (including what he referred to as the friendly opposition) know he is not coachable. In his opinion, he said, the real damage would be to current DOE employees who have been maligned and have no way to respond because DOE does not respond to reports of this nature. He expressed his belief that DOE made every effort to be open with the public, but that this report accuses them of manipulation and conspiracy. He said he could not see how this could lead to either improved public participation or an improved environmental management program; in his opinion, it was non-productive.

He continued by saying that the allegation of conspiracy is ludicrous, and questioned exactly whom he conspired with–DOE, including Mr. Page? According to Mr. Brooks, he was openly opposed to DOE as long as the agency appeared responsible for distorted risk assessment, and thereafter opposed to DOE's silence and EPA's risk assessment shortcomings. He noted that co-conspirators do not oppose each other, as he had done. He asked if this was implying that he conspired with the public, and recalled that the vast majority of the public had commented that the 180 ppm level was too low. In his opinion, he said, this report is divisive: it divides DOE from the public, inhibits trust on false ground, and clouds ATSDR's PHAs because they use DOE data.

Mr. Brooks asked how he might know who harbors such low opinions of his effort and give them an explanation, given that anonymous sources are cited in the report. In his opinion, he said, both unidentified large landowners in table 9 are easy to figure out; he said he was human enough to ponder which one was poorly informed. He expressed his belief that the public and science have been divided, adding that all views opposed to EPA risk assessment were based on published or project data that represented thousands of hours of determined work. However, in his opinion, the report brushes this aside by labeling it as manipulation or worse, thus reducing its status to opinion.

Mr. Brooks suggested that this report be read with caution and that, in his opinion, the lack of citations, incompleteness of citations, and anonymity of quotes will guide the reader. He said that the reference link on the Internet would provide an idea of the scope of the problem and the diverse opinions of EPA risk assessment. He says he refers to about 47 papers that have been accumulated and read during this process, containing all of the information that rarely comes out in the public–much of which he considered to substantiate the claim that 400 ppm is adequate. He stated that people indicate that the level was first 10 ppm, then changed to 400 ppm. He expressed his belief, however, that the first level was actually 720 ppm: it was then dropped 10 ppm, and gradually increased. According to Mr. Brooks, these levels changed as new information became available about the nature of mercury and how insoluble it was.

Mr. Brooks explained that the risk had not changed, and therefore they asked themselves how you could go from the most soluble compound to the insoluble compound without changing the risk. According to Mr. Brooks, they found that EPA substituted the one known value for inorganic mercury (mercuric chloride) for any unknown compound, but this did not change the risk level. He said that this was the reason for their work, not because there was manipulation from DOE. Mr. Brooks stated that they were pressured by their knowledge of science and to reach a reasonable solution for EFPC. Mr. Brooks added his opinion that the report also deals with many technical issues that are not completely stated and that contrary data exist to many of the report's claims. He expressed his belief that this matter was not as cut-and-dried as the report would make it seem.

Ms. Stokes referred to Ms. Sonnenburg's question about studying individuals, and expressed her belief that the reply was that ATSDR does not do that type of work. She questioned who would do this type of work because, in her opinion, it was needed here. She asked if they should request that ORRHES be dissolved and the money put into where they could get the best product. She asked if TDOH could do this work, noting that she has had different experiences with the agency over the years and had seen what she considered to be good work. In her opinion, she said, the contaminants have been studied and identified (Y-12 releases into EFPC, X-10 releases into Beer Creek, and K-25 releases into Poplar Creek, all leading to the Clinch River).

Ms. Stokes asked what they could do to learn who has been affected and how to keep health effects from occurring again. She said that they could possibly contact an agency other than ATSDR, since in her opinion ATSDR is certainly not doing what they need in the community. According to Ms. Stokes, ATSDR has been asked to leave different places because it continues to have inconclusive results. She expressed her concern that there has always been a question of objectivity and questions about the agency's data collection methods. In her opinion, she said, ATSDR used flawed data that was questioned when first presented. She expressed concern about conflicts of interest and findings that say there has never been and never will be harm to the public from uranium and mercury. She said that if people found this to be true, then she had property to sell them. In her opinion, she said, ATSDR had a lot of good and smart people, but a terrible history of developing proper results for humans.

Dr. Cibulas expressed his belief that Ms. Stokes had raised some very important questions. He said that he would not go into too much detail on the agency's mandate, capabilities, and responsibilities. However, he explained that ATSDR conducts health assessments as a first step in evaluating exposures, and can identify concerns and make recommendations that generally drive any follow-up steps for individuals who have been exposed. The agency can also conduct exposure investigations; two have been conducted here for fish and biological monitoring. When these studies identify exposures considered to be of concern, this generally extends beyond their particular division, which was why Dr. Taylor indicated that he was not able to follow up on these types of studies: it is not part of the public health assessment process. When these types of exposures are found, DHAC can ask the Division of Health Studies (DHS) to become involved. Through these means, ATSDR can conduct health studies on people who were identified as exposed, conduct surveillance, and place people on registries.

Ms. Stokes expressed her belief that Congress took this responsibility away from ATSDR. Dr. Cibulas denied this, saying that ATSDR has always had the mandate and responsibility of conducting follow-up health studies on individuals who they have found are at risk of exposure as a result of exposure investigations and PHAs. He stated that this was never a mandated responsibility that was taken away from the agency. ATSDR does not, however, set up clinics, provide physicians to communities, or provide primary care.

Ms. Stokes asked if ATSDR has ever offered funding to help people get screening. Dr. Cibulas replied that ATSDR has a cooperative agreement with and provides some funding for a number of clinics across the United States–a group called the Association of Occupational and Environmental Clinics (AOECs). ATSDR can refer individuals who are looking for this type of support and medical care to these clinics. Ms. Stokes asked how much it costs to fund the clinics. Dr. Cibulas expressed his belief that the agency provides about $500,000 a year to help fund these clinics. In her opinion, Ms. Stokes said, it would be cheaper to set up a clinic to help evaluate people than to keep this subcommittee for another 2 to 3 years. She claimed that the cost of a clinic would be about one-third of the 2-million-dollar budget for Oak Ridge (site activities and the ORRHES). Dr. Cibulas explained that $500,000 was not the total support for one clinic; other federal agencies also provided funding. He could not provide the total amount spent for supporting the clinics, but said that he would provide her with this information.

Janet Michel wondered how many years this community has been asking for monitoring of people and some type of clinic. According to her, they were always told that this could not be done. Ms. Stokes said that she personally started requesting a clinic in 1992, but that requests dated back to the 1980s. Dr. Davidson explained that the ORRHES conducted an extensive evaluation to determine whether the community qualified for an AOEC clinic, but it did not qualify. In her opinion, Ms. Stokes said, there was no way for this subcommittee to be unbiased when examining these issues because its members are heavily tied to industry and area real estate. She expressed her belief that their loyalty would not be to the people because they had been trained and employed by DOE and probably had their college tuition paid for by DOE.

Dr. Davidson replied that the ORRHES encompasses a diverse group of individuals with varied backgrounds–it is not a homogenous group. Though some of its members were employed at ORNL, none to her knowledge were DOE employees. Ms. Stokes said everyone here knew what she was saying, telling attendees not pretend they did not know that this was a biased board. In her opinion, the ORRHES was biased toward industry and finding no significant findings in health reports. According to Ms. Stokes, this particular site is in the middle of an approximate 23,000-person city and was the closest city to any nuclear weapons site in the United States (except possibly for one in Colorado). In other areas, she said, nuclear sites are hundreds of miles away from populated areas. She said that they did not have to believe her, but that they could find the truth themselves if they researched it.

Ms. Michel said she was not aware that an evaluation had been conducted that found that the community was not eligible for monitoring or a clinic. She asked if this evaluation was available for the public to review. Dr. Davidson expressed her belief that this information could be found in earlier meeting minutes, noting that Pete Malmquist had been the head of the group that conducted the evaluation. Dr. Malmquist confirmed that he had chaired that group, which had indeed conducted this evaluation several years ago. He said that they had worked through TDOH and had received assistance from Brenda Vowell. He explained that they had looked at the possibility of piggybacking through one of the clinics in Lake City, Oliver Springs, or Wartburg; however, they did not qualify for this clinic. According to Dr. Malmquist, they had considered and evaluated all of the available possibilities.

Also, Dr. Malmquist expressed his resentment toward being called biased. He said that he is a retired veterinarian from Roane County who never worked for DOE or anyone else. In his opinion, he said, he is not the least bit biased and served as the Chairman of the Board of Health in Roane County for 25 years. He stated that his interests are in public health, noting there is a difference between individuals and the public.

Ms. Michel questioned what was meant by not qualifying for a clinic, particularly referring to how Dr. Cibulas said that ATSDR could provide one. Dr. Malmquist said he had not heard Dr. Cibulas say that ATSDR would provide a clinic; rather, he said, Dr. Cibulas had indicated that ATSDR could provide a way to go to individual clinics. Ms. Stokes pointed out that Dr. Malmquist was a veterinarian, and expressed her belief that many medical doctors would say that humans were not consistent with animals. Dr. Malmquist said that they had not looked at animals in this evaluation. They had evaluated the possibility of getting a clinic in this area for people. According to Dr. Malmquist, they had looked very hard to get a clinic here, but they had not qualified under any guidelines that could be found.

According to Ms. Stokes, there was a cluster of five cases of amyotrophic lateral sclerosis (ALS, or Lou Gehrig's disease) on one street, but they did not qualify for assistance because the cases were not reported in the same year.

To support Dr. Malmquist's comments, Mr. Lewis said that they had gotten the Health Resources and Services Administration (HRSA) involved in the process. HRSA had come to Oak Ridge and looked at evaluating all areas to see if they qualified for this type of clinic. They had identified several AOECs (with the closest one being in Meharry, Tennessee). Mr. Lewis recalled that a grant of about $500,000 was being given to HRSA. As part of the effort, Mr. Lewis said, he had questioned why UT would not look at something like this. If they had returned to this issue, Mr. Lewis might have prepared a recommendation to see if the State of Tennessee would look at UT becoming an AOEC clinic. Ms. Michel recalled HRSA saying that Oak Ridge was not a medically underserved community, which she considered to be the key phrase. In her opinion, she said, the problem with this community is that physicians are afraid to test people for contamination in their bodies and the one physician who tested people was run out of the community. She expressed her belief that this was why no one tests, adding her opinion that UT does not become involved because UT Battelle runs ORNL. According to Ms. Michel, an organization she is involved with had an EPA technical assistance grant at UT, and UT became worried and did not want involvement with them because of UT Battelle.

Mr. Hanley indicated that Mr. Lewis and Dr. Malmquist presented the subcommittee members' evaluation to the ORRHES at an August 2002 meeting. He said that more information on the evaluation, the calculations computed, and HRSA criteria are available in the Oak Ridge Field Office. Dr. Taylor could provide her with the files, including the meeting minutes and handouts. According to Mr. Hanley, a program review was conducted to examine the mandates of ATSDR, DOE, and the state to determine whether there was any way to have a clinic funded; none of these entities, however, have a mandate to provide medical care. Mr. Hanley said that all of this information was included in the evaluation, expressing his belief that the information was clearly presented to ORRHES and the subcommittee made a recommendation on this issue at that time.

In her opinion, Ms. Michel said, there was also a disconnect because there were people who wanted medical care, but also those who only wanted to be tested and monitored. She asked Dr. Cibulas about his comments regarding providing monitoring in other communities, and asked what the difference was between other communities and this community that did not qualify. Dr. Cibulas explained that ATSDR would conduct health studies through its Division of Health Studies, which comes into a community if significant exposures and health concerns have been identified. For these individuals, he said, ATSDR will conduct follow-up epidemiological investigations, but they had to be exposure-driven to qualify for this type of investigation. He explained that a PHA is the first step in trying to identify if significant exposures exist that warrant this type of epidemiological investigation–where there is actually a probability of looking at cause and effect.

Ms. Stokes said the community did not need ATSDR here and that they should go home. Dr. Davidson reminded meeting attendees that they needed to be respectful of one another. Ms. Stokes apologized, but said that in her opinion, this has gone on for years. Dr. Davidson said that she understood, but that they still had to maintain respect for each other.

In her opinion, Ms. Kaplan said, this still remains a controversial issue. She asked that she be permitted to go through some of the quotes from her report to give actual statements that Mr. Brooks made in 1995 and put things into context regarding what people were thinking at that time. She expressed her belief that people were very upset about the domination of a public meeting by a couple of individuals. In her opinion, she said, DOE needed to be careful about the appearance of conflict of interest. She said that she had tried to tell the story and asked for an opportunity to tell the rest of the story. Dr. Davidson polled the subcommittee to ensure that members would stay until the agenda was completed to ensure they had a quorum. The group held discussions about staying and enough individuals agreed to remain until the agenda was completed.

Ms. Sonnenburg said that she had spoken with public members at the break who wanted to speak and asked for time to do so. She expressed interest in hearing from individuals who had not spoken yet.

Dr. Cember stated that he had two facts to share. He conducted a study years ago on the distribution, deposition, and clearance of mercury in rats and dogs. In one case, he was using mercuric chloride and was trying to inject the substance into the belly of a rat. The rat kicked him, and he injected the chemical into his pinky instead of into the rat. He had his assistant check him with a sensitive scintillation counter. All of the mercury had essentially concentrated in his kidneys. An x was been placed on his back in indelible ink to measure the daily activity. After about 3 months of measurement, the mercury level was immeasurable. When he plotted the data on a semi-log plot, it fell on a straight line with an 11-day half-life; this was the effective life considering elimination from the body and radioactive decay. He said that a tiny amount came out in his urine, but most of the mercury was eliminated in his feces.

Dr. Cember detailed another study he conducted analyzing excretion via urine and feces. He explained that the method of analysis for urine means that you cannot distinguish if what comes out in cells is sloughed off from the kidneys or eliminated as a liquid. When the cells were filtered out, Dr. Cember found that 96% of the mercury in urine was in cells that had sloughed off. He said that he saw this in animals that had gotten relatively high amounts of mercury. With low amounts, they had less coming out in the urine and more in the feces. Through additional studies, he determined that elimination in urine is a pathological process that occurs when cells in the renal tubules are poisoned by mercury; mercury kills those cells and they are sloughed off. He said that mercury will only be found in urine when there is a large enough amount of mercury to damage the cells in the kidneys. He also found that significant amounts of mercury are secreted by cellular mucosa. According to Dr. Cember, he had nice data on the elimination via the gastrointestinal tract. Regarding how mercury is carried in the body, he said that it is not only carried in the blood. He explained that mercury binds to and is carried by plasma proteins (globulins and albumins). If you separated the globulins and albumins and removed them from the blood, he said this would be a more sensitive analysis than a gross analysis of blood.

Dr. Cember said that mercury clears out of the body. He explained that when conducting these types of studies, he needed to use an amount of mercury that was non-toxic to the rat to obtain proper data. Dr. Cember said that the small amounts he received were cleared rapidly; nothing was detected in his head or anywhere else. He said that it could be measured in his body in the first few days, but after that, it was essentially only seen in the kidneys. He had used bichloride of mercury, which he said maybe different than other mercury compounds.

Regarding solubility, Dr. Cember said he had done some work with sulfide. He noted that this substance was extremely insoluble in water, but relatively soluble in the stomach. Because of the large amount of hydrochloric acid in the stomach, if enough sulfide is ingested it will dissolve so that it can be absorbed into the blood and transported throughout the body. He referred to Ms. Stokes's question about why they are not studying individuals or people, offering what he characterized as an educated guess. He said that enormous amounts of clinical and epidemiological data are available on mercury poisoning. Occupational data are available, including data related to Mad Hatter's disease (a classic example of mercuric nitrate exposure that caused disease in workers manufacturing felt). In addition, about 20 years ago, a chemical company in Japan was disposing of enormous amounts of mercury into Minamata Bay. He said that a large number of people living around this developed crippling diseases, and there are lots of data about these exposures.

Dr. Cember said that there are also a lot of data related to these exposures, and also data showing the occupational exposure limit of 0.1 milligram per cubic meter (mg/m3) of air. He said that data have documented workers having tremors after 2 years of exposure at the OSHA limit when monitored at the average value (0.1 mg/m3). According to Dr. Cember, there is a voluminous amount of data that all lead to dose-response relationships, and therefore, scientists know what average type of dose will produce certain types of effects. In his opinion, he said, this was why contaminants are looked at instead of individuals. He said that if the level of a contaminant is so low related to what is known about the dose-response curve, health effects would not be expected among people. He said this was based on enormous amounts of data on the dose-response curves. He stated that he would guesstimate that it would be a waste of money to look at people when contaminants would be so low that no health effects would be expected; he gathered that this was why there were looking at contaminants and not going further.

Mr. Lewis asked that they summarize what they have done here and where they are going. He expressed concern that they spend so much time, questioning what their specific objectives are. Likening Dr. Cember speaking to E.F. Hutton speaking, he said that Dr. Cember should be at the head of the table so people can get responses to their questions at the time they are asked: people lose interest, he said, when they have to wait for answers. According to Mr. Lewis, they needed to figure out how to free these resources and use this knowledge and talent to respond to these issues in a timely manner. Dr. Davidson expressed her belief that Dr. Cember had just done this. Mr. Lewis expressed concern that they might have missed the opportunity if Dr. Cember had not spoken up.

Regarding the quote Ms. Kaplan provided from the June 1995 EFPC public meeting, to which she added Mr. Maienschein's name in brackets, Mr. Brooks said she should have included about 30 more names.

Ms. Stokes asked who recommended changing the cleanup level to 1,200 ppm. Ms. Kaplan was referring to a quote from Mr. Brooks, she said, noting her opinion that he was a highly respected member of the community, an outspoken individual, a former ORRHES member, a community activist, and a retired scientist from ORNL. She expressed her belief that Mr. Brooks had led the charge on changing the cleanup level to 400 ppm.

Ms. Smith elaborated on her quote that Ms. Kaplan presented from the June 1995 EFPC public meeting. According to Ms. Smith, at one time in the CERCLA process for EFPC, the preferred alternative for many people was to have DOE buy their contaminated property and turn the area into a public park. She stated that the idea was to preclude, through land use controls, certain types of uses that would cause distribution of the soil. To her recollection, someone at DOE had said that DOE did not have the legal authority to do this and further someone at EPA Region IV asserted to her that this action would not be sufficiently protective. In her opinion, she said, since this was a floodplain, it did not make much sense to use taxpayer money to turn it into buildable land, particularly when contamination was present. She expressed her belief that by January 1995, it was clear that the direction was to go toward cleanup instead of imposing land use controls. In her opinion, she said, the preferred alternative (a public park) still would have been a good option. Ms. Kaplan agreed but spoke of a need to focus on the future, adding her opinion that many of these issues have not been well documented.

Dr. Davidson noted that many mercury-related issues had been discussed at the meeting so far, including issues brought up by public attendees with some responses being provided during the meeting. She noted that ATSDR is currently preparing the mercury PHA, and that the three people mainly involved in preparing the report–Mr. Hanley, Dr. Taylor, and Dr. Cibulas–were present at the meeting.

Pat Hunter introduced herself as affiliated with Clean Air Friends–Clean Air Kids from Loudon County. She thanked Mr. Lewis for inviting them to the meeting and stated that she liked what she had heard from Ms. Kaplan. She expressed her belief that whether you live in Loudon County or Oak Ridge, they needed to look at contaminants that they find are causing major problems. According to Ms. Hunter, their children in Loudon County were sick. In her opinion, Ms. Stokes had made some excellent points regarding agencies evaluating these health issues relative to these contaminants. She expressed her belief that, when looking at these data to see whether things are safe or not, for those who are monitors and are getting sick, one must evaluate these issues realistically. She said that today it is the older population, but that they owed it to the children to look at these issues and resolve them–not to push them off or forget about them.

Ms. Hunter expressed her hope that this agency and subcommittee will look at mercury, uranium, and health issues. She asked that the agency look at the health issues of people in these communities because, in her opinion, they were becoming sick and these issues needed to be addressed. She said that for employers, insurance will cost more, and similar types of issues will trickle down. She stated that if children are getting sick with developmental problems, then they too will suffer throughout their lives and in everyday life. In her opinion, she said, they would be doing a great disservice by ignoring these problems and saying the chances are one in a million. She expressed her belief that there is something wrong with the air, soil, or water when people in the community are developing cancer, and she referred to this situation as a wake up call.

Ms. Adkins asked the attendees to imagine that, from the time that they were conceived until they were 23 years old, they were impacted by springs affected by mercury every time they ate, drank water, washed a wound, showered, swam, and ate fish. For months, Ms. Adkins said, she has been working on a project compiling information. She has met with people individually who are helping her map where toxic wastes were buried, including mercury and other contaminants. She has had maps made (she presented these to the group) on which she is marking where items were buried based on her interviews. According to Ms. Adkins, some burial sites were 300 feet deep. She said that some of her sources told her that when they went back to check on the sites 5 years later, the substances had drained into the bedrock of the earth in that area. She said she was relentless in her search and asked anyone who knows where things were buried to contact her.

Dr. Cember asked if these were substances buried on or off site. Ms. Adkins said it was both. She also had a topographical map of the same area, showing the ridges. According to Ms. Adkins, when she shows where the releases from the plumes occurred, you will be able to see the ridges and where the toxins were carried. She expressed her belief that they should be able to know the kinds of illnesses related to the toxins and be able to trace them to the illnesses from the areas where contaminants were disposed of.

Ms. Adkins indicated that she also had a regular map and was making red dots to indicate the burial sites and dumping grounds used for toxins. She said that she has recorded what was dumped into each one. In her opinion, she said, you could see where things were buried on the limestone slab and where they were carried. For example, she pointed to the pink slab on her map, indicating her opinion that this was where a lot of waste from K-25 and possibly Y-12 was dumped and buried. She expressed her belief that this was the most porous of all of the slabs. According to Ms. Adkins, mercury and other contaminants sank below 300 feet. She said she was referencing people she considered to be very credible sources who said that contaminants would stay on this limestone slab. In her opinion, she said, they should be able to track where people should be sick based on where the contaminants were dumped. She expressed her belief that they will be able to see pathways, not just around water but in underground sources as well.

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