Oak Ridge Reservation: Public Health Assessment Work Group
Public Health Assessment Work Group
October 20, 2003 - Meeting Minutes
ORRHES Members attending:
Bob Craig (Chair), Tony Malinauskas, David Johnson, James Lewis, LC Manley, Pete Malmquist, Susan Kaplan, Charles Washington, George Gartseff, Kowetha Davidson, and Peggy Adkins
Public Members and Others:
Tim Joseph, Gordon Blaylock, Roger Macklin, and Al Brooks
Jack Hanley, Paul Charp, Bill Taylor, Lorine Spencer, Marilyn Palmer, Melissa Fish, Terrie Sterling, Libby Howze, Theresa NeSmith, Subha Chandar, and Michael Hatcher
There were four items on the agenda for discussion.
- Review October 6, 2003 meeting minutes
- ATSDR responses to Y-12 Uranium PHA public comments by Jack Hanley and Paul Charp
- ATSDR proposed plan for Iodine-131 Public Health Assessment by Paul Charp
- Other business as necessary
Previous Meeting Minutes
Tony Malinauskas made the motion to approve the Draft minutes for the October 6, 2003 PHAWG meeting. LC Manley seconded the motion. The meeting minutes for October 6, 2003 were approved unanimously.
ATSDR Responses to Y-12 Uranium PHA Public Comments
Jack Hanley presented the Presentation Outline to the group. Jack read aloud the seven components of the presentation. Jack Hanley also provided a review of the process that ATSDR and ORRHES went through for the Y-12 Uranium Public Health Assessment.
Jack Hanley provided an overview of the public comments that ATSDR received regarding the Y-12 Uranium PHA. Jack explained that the public comment period was from May 5, 2003 through June 20, 2003. Comments were received from 12 parties including 5 organizations and agencies and 7 individuals. ATSDR received and responded to over 150 comments (not including comments relating to spelling or sentence syntax). For comments that questioned the validity of statements made in the PHA, ATSDR verified or corrected the statements.
Bob Craig asked if of the 150 comments, if EPA Headquarters comments and EPA Region 4 comments would be separated and identified. Jack Hanley responded that the mailing that the PHAWG members received had all of the comments mixed together without specific agencies or organizations being identified. However, Jack Hanley told the group that there has been a request to identify the comments of each federal agency. Thus, in the final version, ATSDR will identify the specific comments made by the various federal agencies. As clarification, Jack Hanley told the group that ATSDR would not identify the specific comments made by various organizations—only comments made by federal agencies.
EPA Headquarters Summary Comment 1: ATSDR should provide concise summaries of primary data sources and more detailed discussions of its own assessments and conclusions.
Jack Hanley explained that the Summary Comment 1 relates to the original comments 14, 33, 38, 43, 50, 52, 56, 143, and 144 in the draft Appendix XXX that PHAWG members received prior to the meeting.
Jack Hanley told the group that the ATSDR response to EPA Summary Comment 1 is that it is not ATSDR’s policy to provide raw data from primary sources that are publicly available. Jack Hanley listed the primary sources used for evaluation of past exposures as well as the primary sources used for the evaluation of current exposures. Jack told the group that page 36 of the Y-12 Uranium PHA provides short summaries of the FAMU and EPA sampling and that ATSDR will add summary briefs of the ChemRisk, FAMU, and EPA reports in an appendix.
In response to the second portion of the EPA Summary Comment 1, Jack Hanley said that ATSDR provided detailed summaries of the data and discussions of ATSDR’s own evaluations throughout the PHA and in the Appendices. Two examples that Jack pointed out were the uranium enrichment discussion on pages 85-88 and the linear regression analysis in Appendix E of the Y-12 Uranium PHA.
Al Brooks and Tony Malinauskas suggested that ATSDR’s response could be better stated and more accurate if it were similar to the following: It is not ATSDR’s policy to provide copies of raw data from primary sources that are publicly available. But ATSDR does supply references to the data used; which is usual technical practice.
EPA Headquarter Summary Comment 2- ATSDR should change the title of the PHA to reflect the principal subject (i.e., Scarboro) or expand the scope of the assessment to include other Oak Ridge communities.
The Summary Comment 2 relates to the original comments 65 and 66 in the draft Appendix XXX that PHAWG members received prior to the meeting.
After some discussion about K-25 and uranium hexafluoride, Jack Hanley reminded the group that ATSDR will conduct a separate PHA that is concerned with K-25 and fluorides.
Peggy Adkins asked that someone explain how ATSDR could say that the area between Kingston and Oak Ridge was not affected by the Y-12 Uranium releases. Jack Hanley told the group that ATSDR believes the city of Oak Ridge is the only established community adjacent to the Oak Ridge Reservation that could have been impacted by Y-12 uranium releases and that Scarboro is a representative community for the city of Oak Ridge and therefore the conclusions are valid for the people living near the Y-12 Plant, including the city of Oak Ridge.
Jack Hanley pointed out that the Task 6 team identified Scarboro as the reference location using air dispersion modeling and Scarboro was considered the most suitable for screening both a maximally and typically exposed individual.
Jack Hanley told the group that the predominant wind direction at the Y-12 facility is southwest or northeast, up and down Bear Creek and Union Valley between Pine Ridge and Chestnut Ridge. Therefore, most of the uranium would deposit up and down the valley near the Y-12 facility. No one lives in Bear Creek or Union Valley. Paul Charp said that the wind would be blowing away from the city of Oak Ridge.
Peggy Adkins added that the wind blowing away from Oak Ridge would be blowing toward Kingston—to the area between Oak Ridge and Kingston. Peggy also added that the ridges do not completely stop the wind.
Jack Hanley said that based on the flat terrain model, most of the uranium falls near the facility, thus, ChemRisk and Oak Ridge Health Agreement Steering Panel (ORHASP) decided that doses to the Scarboro community are most likely the highest of any other Oak Ridge community.
Tim Joseph asked if ChemRisk created a deposition map which showed uranium fallout. Jack Hanley responded that it is likely that ChemRisk did create such a map. If so, Tim Joseph suggests that ATSDR locate the map and use it.
Paul Charp pointed out that even if uranium did get out of the stacks and ejected into the atmosphere—because of slow wind speed—most of the uranium would likely settle out before it even reached Pine Ridge.
Al Brooks added that in the valley, the winds tend to stay in the valley until the wind velocity gets very high—then the wind goes over the hills.
LC Manley commented about flyover patterns. LC Manley stated that uranium should give some evidence of a pattern and the pattern should be able to be followed.
Al Brooks stated that there is evidence that flyovers are sensitive enough to detect any significant uranium contamination in the area studied.
Peggy Adkins asked if anyone had a topographical map that shows terrain. Peggy would like the group to have a raised map when approaching this issue.
Michelle Arbogast told the group that there are maps like Peggy Adkins is referring to available in the field office.
Jack Hanley told the group that ATSDR presented data from other locations when the data was available. The evaluation of current exposure via the air, surface water, and vegetables include other locations surrounding the Y-12 plant (see Figures 19, 20, and 23 in the PHA).
Jack Hanley told the group that an issue had been brought up about the Woodland community possibly receiving higher uranium emissions than the Scarboro community. To evaluate this potential, ATSDR compared the ambient air monitoring data for Station 46 (Scarboro) to Station 40 (located on the Y-12 plant near Bear Creek Road and Scarboro Road, near the gap in Pine Ridge). The average air concentrations at Station 40 were, on average, 20% higher than Station 46 and for one year almost twice those at Station 46. Assuming, therefore, that the Woodland community was exposed to the uranium concentrations at Station 40 in Bear Creek valley (which is unlikely), they could have received up to twice the amount of uranium emissions as Scarboro. However, even if the Woodland community were to have received double the emissions and dose of Scarboro, the exposures would be way below ATSDR’s comparison value and still be too low to be of health concern.
In response to a question about Station 41, Michelle Arbogast stated that the uranium air concentrations at Scarboro were on average, 2.7 times higher than Station 41.
Jack Hanley reminded the group that after receiving comments, ATSDR looked at the water samples at Bear Creek, Lower East Fork Poplar Creek, and Upper East Fork Poplar Creek—on site and off site—rather than just focusing on Scarboro. ATSDR also looked at the vegetable data from various locations, some of which included monitoring stations, private gardens in Scarboro, private gardens near Station 40, and private gardens near Claxton.
Al Brooks asked if ATSDR had looked at the screening data that came from the lower East Fork Poplar Creek sediment. Al said that the sediment contained elements other than mercury.
Jack Hanley responded that ATSDR has looked at the Remedial Investigation/Feasibility Study at East Fork Poplar Creek.
In response to an issue that Al Brooks raised about sampling data for vegetables in the floodplain, Jack Hanley said that he did not find data for vegetables in the floodplain.
Paul Charp said that Task 6 used East Fork Poplar Creek floodplain soil data as a replacement for not having any historical Scarboro soil data.
Al Brooks stated that there have been complaints about not having comparison data—is there comparison data? Jack Hanley replied that yes, there is comparison data and that Task 6 used higher levels from the floodplain in their analysis when evaluating Scarboro.
EPA Headquarters Summary Comment 6- For current uranium exposures, ATSDR should present missing data sources, provide explicit calculations of intakes and doses, modify selected exposure parameter values, include additional exposure pathways, and present cancer risk estimates.
The Summary Comment 6 relates to the original comments 32-58 in the draft Appendix XXX that PHAWG members received prior to the meeting.
Jack Hanley explained that the portion of the summary comment relating to providing missing data sources could be referred back to ATSDR’s response to EPA summary comment 1 for a discussion of data sources.
In regards to providing explicit calculations of intakes and doses, Jack Hanley explained that ATSDR would add an appendix to the final PHA, which will provide the equations and parameters used in the exposure evaluation.
Jack Hanley told the group that it was suggested that ATSDR use default consumption parameters out of the EPA Exposure Factor handbook. Jack Hanley told the group that ATSDR has responded by stating that ChemRisk was very familiar with the EPA Exposure Factor handbook. However, ChemRisk worked with and talked with local community members along the floodplain and used site-specific parameters and tried to be more realistic in the level 2 than in the level 1 where they used default parameters.
Jack Hanley said that it was also suggested that ATSDR look at other pathways. However, some of the pathways suggested are not realistic to current exposure scenarios (i.e., air-to-pasture, grass-to-meat/milk pathway, homegrown fruit, and irrigation). Jack Hanley explained that EPA, when writing risk assessments, has to look at all pathways as part of their methodology and guidelines. Looking at all the pathways is appropriate for EPA’s purpose. But ATSDR’s purpose is to find out where people are actually being exposed.
Charles Washington said that it is important to include the years because the operating capacity differed during various years. Charles asked if ATSDR would be including the years the analyses were done. Jack Hanley said yes and added that the years at various operating capacities were evaluated.
In explaining cancer risk estimates, Jack Hanley read through a table comparing the ATSDR Public Health Assessment to the EPA Risk Assessment. Jack Hanley felt that it was important that the group understand that there are deliberate differences between the EPA’s Risk Assessment and ATSDR’s Public Health Assessment. Jack provided a summary of the description, the purpose, the goal, exposures and pathways evaluated, the result, and methods for both the ATSDR Public Health Assessment and the EPA Risk Assessment.
Al Brooks felt that the environmental standards for many contaminants and situations are more stringent than for public health work. Al Brooks also said that animals in the wild need better conditions to survive than humans.
Gordon Blaylock disagreed with Al and said that animals living in the soil get higher doses/concentrations than humans.
Al Brooks said that the drinking water standard might be higher than the comparable environmental standard for water because of food chain enrichment. Gordon Blaylock asked Al to provide an example. Al Brooks said that he feels mercury in East Fork Poplar Creek is an example. Jack Hanley added that one reason for keeping the clean-up level low in East Fork Poplar Creek was because of effects on the shrews and wrens. [There was additional conversation about concentration values between Al Brooks and Gordon Blaylock that was inaudible.]
Tony Malinauskas asked if the screening levels are consistent with risk analysis, which would show that the hazard presents an acceptable risk.
Paul Charp said that in some cases the minimal risk level (MRL) is set on a no-observed-adverse-effect level divided by a series of uncertainty factors.
Kowetha Davidson said that if using an animal study, a safety factor of 10 is used. To account for sensitivity in the human population, another factor of 10 is used. [Kowetha went on to discuss animal studies and EPA values but the details of her discussion were largely inaudible].
Jack Hanley briefly discussed Reference Dose and MRL. Jack said that ATSDR uses the Reference Dose and MRL for screening and EPA uses Reference Dose for policy and regulation. After screening, if a dose was found to be above the Reference Dose, ATSDR would look into the situation further. EPA would not; they would use their Reference Dose and come up with a guideline or regulation based on the Reference Dose level.
Jack Hanley told the group that ATSDR is trying to arrange for DHAC’s Associate Director for Science, Allan Susten, to present detailed material regarding toxicology to the group.
Jack Hanley reminded the group that ATSDR is not involved with compensation. James Lewis asked if there had ever been a purchase of land due to the land being contaminated by a federal facility. Some group members replied that it was possible that at some point and at some place that a land purchase had been made due to contamination. Susan Kaplan made reference to the government’s settlement of the lawsuit filed by Wayne Clark and Mel Sturm regarding EFPC land.
Jack Hanley said that the PHA report presents conclusions about the actual existence and level of health threat, if any, posed by a site, and recommends ways to stop or reduce exposures. However, because of uncertainties, a definitive answer on whether health effects actually will or will not occur is not possible. There are no certainties; ATSDR is providing its best professional judgment.
Al Brooks provided his view of the EPA approach versus the ATSDR approach. Al provided an example of the EPA approach at East Fork Poplar Creek. Al Brooks said that when EPA is missing data EPA takes what is “convenient” or “handy”. When EPA is involved in remediation efforts, they try to make the situation unquestionably safe for the most sensitive individual. If this philosophy is not controlled, it leads to safety factors ranging from one thousand to one million. Public health people try to be more realistic than EPA because there are other places to spend public health money. Al Brooks feels that the group should not expect EPA and ATSDR to agree.
James Lewis said that ATSDR’s PHA Guidance Manual states that ATSDR evaluates health outcome data. Does EPA use health outcome data in any of their evaluations?
Jack Hanley said that EPA does not use health outcome data at site-specific locations. Jack provided an example of the Cancer Incidence Review that ATSDR is currently working on. Instead, EPA evaluates epidemiological studies but does not typically perform its own epidemiological work in site-specific locations.
Kowetha Davidson added that it is EPA’s policy to error on the side of conservatism, which is why EPA uses conservative assumptions. One example is that EPA assumes that humans are always 10 times more sensitive than animals, but that is not always the case.
James Lewis asked if ATSDR was the agency that evaluates health outcome data. Jack Hanley replied, primarily yes.
James Lewis said that it is important that people understand which agency “makes the call” regarding health outcome data.
Paul Charp and Jack Hanley discussed some key points involved in the way that the CERCLA Legislation is written. Paul added that ATSDR was established to address the public health issues associated with Superfund sites.
EPA Headquarters Summary Comment 3- For past uranium exposures, we believe that ATSDR has underestimated the radiation dose for the inhalation pathway.
The Summary Comment 3 relates to the original comment 19 in the draft Appendix XXX that PHAWG members received prior to the meeting.
Paul Charp told the group that even if ATSDR had used the specific recommendations from the EPA comments, the dose calculated would still be well below the level of health concern. Paul added that instead of relying solely on EPA’s Exposure Factors Handbook, ATSDR looks at site-specific exposure information and actual inhalation rates for the South Eastern United States.
Paul Charp added that the comment regarding default exposure assumptions used in the Task 6 report should have been provided to the Task 6 team during the 1998 public comment period for the Task 6 report because ATSDR was not the author.
EPA Headquarters Summary Comment 4- For past uranium exposures, ATSDR’s assertion that estimated doses are overestimated due to “conservative and overly protective assumptions and approaches” is not based on a quantitative sensitivity and uncertainty analysis, and is largely unsubstantiated. ATSDR should conduct a formal uncertainty analysis to determine the distribution of possible doses and risks to Scarboro residents.
The Summary Comment 4 relates to the original comments 20-30 and 141 in the draft Appendix XXX that PHAWG members received prior to the meeting.
Paul Charp explained that the issue of conducting an uncertainty analysis was raised by an ORRHES member at the April 22, 2003 meeting and addressed by ATSDR in a written response provided to ORRHES at the June 2, 2003 meeting. Paul told the group that ATSDR defended its position using A Guide for Uncertainty Analysis in Dose and Risk Assessments Related To Environmental Contamination, issued in 1996 which stated that if a conservatively based screening calculation is performed and this screening calculation indicates the risk is “clearly below regulatory or risk levels of concern,” and the possibility of exposure is low, then a quantitative uncertainty analysis may not be necessary. Paul added that the dose to Scarboro was well below the EPA CERCLA Guidance for clean up as well as other federal regulations for radiation exposure.
Paul Charp stated that since the Task 6 screening evaluation of air, soil, and surface water pathways resulted in a total past uranium radiation well below the ATSDR radiogenic cancer comparison value, ATSDR does not believe the evaluation of Y-12 uranium releases requires a further nonconservative screening or a refined evaluation with uncertainty and sensitivity analysis.
EPA Headquarters Summary Comment 5- For past uranium exposures, ATSDR should address the recommendations of several previous reviewers and incorporate improvements, especially formal sensitivity and uncertainty analyses and additional core sampling data.
The Summary Comment 5 relates to the original comments 6, 16, 17, and 141 in the draft Appendix XXX that PHAWG members received prior to the meeting.
Paul Charp explained that independent internationally recognized technical experts hired by ATSDR concluded that the Task 6 report was technically sound and applicable to decision-making; supported by and developed on the basis of information in the reports; had no major or significant problems with respect to the study design or the scientific approaches used; and was adequate for public health decision-making.
Paul Charp also told the group that in 2001, EPA Region IV collected uranium core samples from two locations in Scarboro. The EPA Region IV report stated that (1.) none of the results of the uranium analysis, including those for the uranium soil cores, were elevated above background, (2.) the results of the EPA and FAMU sampling efforts are consistent in their findings, and (3.) EPA “does not propose to conduct any further environmental sampling in the Scarboro community. Based on EPA’s results, the Scarboro community is safe. Therefore, additional sampling to determine current exposure is not warranted.”
Susan Kaplan asked if the samples collected in 2001 by EPA Region IV were homogenized. Jack Hanley said that EPA took two core samples and most likely both samples were homogenized.
Paul Charp said that he agreed with Susan Kaplan. Paul said that he would not want to take a deep core sample (where the contamination has not gone deep into the soil) and homogenize it because the sample would be diluted. Paul provided an example in California where if the 130 cm soil sample had been homogenized, nothing would have been found. But because the sampling was done in intervals, ATSDR proved that the plutonium came from the sewage plant and not from air dispersion.
Paul Charp said that when ATSDR requests soil samples, ATSDR always requests the top two inches of soil because that is the area where children will dig into the soil and ingest soil.
Charles Washington asked if uranium migration was affected by pH level. Paul Charp said that typically, uranium does not migrate in clay very much.
James Lewis asked if ATSDR actually knows what EPA did as far as the evaluation of the soil samples. Paul Charp replied that he did not remember seeing an explanation in the results of the Scarboro sampling. James Lewis suggested that ATSDR actually find out what EPA did concerning the samples so that ATSDR has a definite answer to Susan Kaplan’s question.
Al Brooks said that he believed that EPA said that they homogenized the sample. Jack Hanley said that it is most likely that the soil samples were homogenized. James Lewis would like to know—for sure—whether or not EPA’s soil samples were homogenized.
Al Brooks asked if there is any evidence to show that regarding radiation, twice the background level would demonstrate a hazard. Paul Charp provided an example of Denver, Colorado having a high background radiation level and a lower incidence of cancer rates than other states.
Gordon Blaylock said that nothing is usually found at levels one or two times background, but that does not mean that it does not happen. [There was continued discussion between Gordon Blaylock and Al Brooks but most of the conversation was inaudible].
Kowetha Davidson said that there are many examples in ATSDR’s responses where ATSDR has stated a technical reviewer’s comment but did not state whether ATSDR agreed with the technical reviewer or not. It has been Kowetha’s experience, that when ORNL agrees or disagrees with a technical reviewer, there is usually an explanation provided stating why there is agreement or disagreement.
Jack Hanley provided an example of uranium and clay that had very little migration except where large quantities of acidic material had been dumped.
Tony Malinauskas said that the EPA data is not necessarily suspect because the FAMU data is consistent with the EPA data.
LC Manley said that one reason that EPA came to verify FAMU soil data was because some people felt that FAMU was not competent. LC feels that it is a positive event that EPA came back and that its data verified the FAMU data.
In response to James Lewis’s question about the reason that EPA took the soil samples, Al Brooks said that EPA’s reasons for taking the soil samples changed over time.
EPA Headquarters Summary Comment 7- ATSDR’s health evaluation criteria are less protective than current international, national, and federal radiation protection standards, and the bases for these criteria are inconsistent with widely accepted radiation protection guidance.
The Summary Comment 7 relates to the original comments 67-73 in the draft Appendix XXX that PHAWG members received prior to the meeting.
Paul Charp reminded the group that ATSDR had presented its screening value to the PHAWG and ORRHES numerous times. During those presentations, ATSDR explained its process and its procedures concerning the ATSDR screening value.
Paul Charp discussed a table, which showed how ATSDR’s comparison value compared on an annual basis to other organizations. With the exception of EPA’s cleanup level (15 mrem/year), ATSDR’s radiogenic cancer comparison value (71 mrem/year) is not extremely different from ATSDR’s MRL (100 mrem/year), ICRP’s guidance (100 mrem/year), and NCRP’s guidance (100 mrem/year). Paul Charp explained that the comment from EPA is a misunderstanding of what ATSDR stated in the Y-12 Uranium PHA. Paul stressed that it is 5000 mrem over 70 years and not 5000 mrem over one year.
Kowetha Davidson said that EPA’s values are based on science policy and not science. Paul Charp said that that is one way of putting it.
EPA Headquarters Summary Comment 8- At this time, we do not agree with ATSDR’s final conclusions regarding past uranium exposures.
The Summary Comment 8 relates to the original comment 5 in the draft Appendix XXX that PHAWG members received prior to the meeting.
Paul Charp explained that ATSDR has categorized this site as having no apparent public health hazard from exposure to uranium. ATSDR’s category of no apparent public health hazard means that people could be or were exposed, but the level of exposure would not likely result in adverse health effects.
Paul Charp also pointed out that this particular comment by the EPA Office of Radiation and Indoor Air in Washington, DC contradicts EPA Region IV’s overall conclusion on ATSDR’s PHA. In the March 27, 2003 cover letter to ATSDR, EPA Region IV stated the following: “EPA concurs with the assessment’s conclusion that the available data does not indicate the presence of uranium releases that constitute a past, current or future health threat for the Scarboro community.”
Susan Kaplan asked who is considered more of an expert—Headquarters or Region IV? Jack Hanley said that Region IV knows the site and the community much better than Headquarters. Jack provided an example of Headquarters using default data or standard methodology concerning fish consumption rather than site -specific data, which would have had a tremendous impact on the estimated doses.
Peggy Adkins told the group that she remembered a tornado that caused a barn to be torn down as well as causing huge waves in the water. Peggy wondered if anyone had taken into consideration the bizarre weather conditions and how those conditions could have impacted the soil, water, and air. Peggy added that unless a person was a resident, they would not know about those particular situations.
Jack Hanley said that the Dose Reconstruction estimated annual average doses and in a few situations looked at specific events and specific releases. However, the Dose Reconstruction primarily focused on average doses, thus, short term, acute exposures would not have been evaluated. Al Brooks added that the doses are not necessarily always average; they are cumulative and could perhaps show bizarre events.
Susan Kaplan passed around a copy of her comments (available in the field office with these minutes) concerning the ATSDR response document. Susan would not have passed her comments around, but after listening to the presentation Susan felt that all of her comments and issues were not addressed in the ATSDR comments, especially the issue of homogenization of soil samples. Susan wanted her comments to go into the record as important issues. Susan Kaplan feels that it is very important to clearly explain the issue of the apparent discrepancy between EPA Headquarters and Region IV.
Susan Kaplan also stated that she found two examples of Agency/institutional arrogance in ATSDR’s responses. One example was with comment number 19 in which ATSDR responded that the “comment should have been provided to the Task 6 team during the 1998 public comment period for the Task 6 report”. Susan felt that in this context the comment does not make sense because that was back in 1998. Jack Hanley and Al Brooks responded that EPA had staff that attended those early meetings. Susan’s second concern was ATSDR’s use of “nice academic exercise” in comment number 22. Susan said that there are other things involved besides the very technical issues. ATSDR should be careful so as not to be perceived as extremely arrogant when responding to comments and responses.
James Lewis told the group that he feels there are objective comments and concerns as well as subjective comments and concerns. James Lewis feels that ATSDR does not do as good of a job addressing the subjective issues as they do addressing the objective issues. James feels it is important to critique how ATSDR is addressing and marketing the subjective issues and concerns—not just the objective comments and concerns.
Jack Hanley explained the changes that were made to the Y-12 Uranium PHA as a result of reviewing and evaluating the public comments. However, ATSDR has not changed its conclusion that past and current off-site exposures to uranium released from the Y-12 pose no apparent public health hazard because the estimated doses are not at levels expected to cause adverse health effects. So, after evaluating all of the comments, this site remains in the conclusion category of “no apparent public health hazard”.
Kowetha Davidson said that it is often stated that levels are below what is expected to cause adverse health concerns. Could that statement be quantified so that people have an idea of where they are in relation to what would be considered a health concern?
Jack Hanley responded that Paul Charp would get to Kowetha’s question. Jack went on to explain that ATSDR’s screening level and total past exposure is about 32 times less than the screening value so there is no reason to perform further analysis or additional sampling because the screening analysis shows that it is 32 times less than the screening value.
Jack Hanley presented and explained the five different conclusion categories and follow-up public health actions that ATSDR uses when writing Public Health Assessments. Jack Hanley explained the details associated with the categories of Urgent Public Health Hazard, Public Health Hazard, Indeterminate Public Health Hazard, No Apparent Public Health Hazard, and No Public Health Hazard.
Susan Kaplan asked about the residents tracking system listed under Potential ATSDR Actions for the category of No Apparent Public Health Hazard. Jack Hanley and other ATSDR staff commented that they were not sure exactly what a resident tracking system refers to.
James Lewis showed the group a poster created by ATSDR, which was titled a “Summary of Public Health Implications from ATSDR’s Evaluation of Past and Current Uranium Exposure to Off-Site Populations”. James Lewis explained that under the column of “Is there a public health concern?” the poster says, no. It is important that ATSDR remain consistent with its terminology and provide enough information so that the public will understand what ATSDR/ORRHES is identifying. James Lewis would like to see the Y-12 Uranium brief revised to include “health hazard” instead of “health concern” and would like to see the explanation of the conclusion categories included in the packet.
Jack Hanley, Paul Charp, and James Lewis agreed that instead of saying, “Is there a public health concern?” the statement should read as “Is there a public health hazard?”
Peggy Adkins asked—under the column of “Potential ATSDR Actions”—why ATSDR is only performing health education and not the health investigation or the residents tracking system. Are the other two actions still an option? Jack Hanley said that he would follow-up on Peggy’s question.
Jack Hanley provided a brief overview of the conclusion and recommendation process by explaining Figure 9-1 from the Public Comment Version of the PHA Guidance Manual.
Paul Charp presented and explained the specifics involved in deciding on a conclusion category for the Y-12 Uranium Public Health Assessment. Paul discussed the process involved in deciding that there was “no apparent public health hazard” for both past and current uranium exposures.
Kowetha Davidson said that the inhalation and ingestion doses of uranium
should be added together because ATSDR is speaking about an internal dose
to the kidneys. [Kowetha Davidson included additional feedback but her
comments were inaudible.]
Paul Charp told Kowetha Davidson that because time was running short, he would give her a call or talk to her more in depth about this issue at a later date.
Bob Craig asked what is the next stage involved with the comments. It was decided that the comments would be revisited at a future PHAWG meeting.
Jack Hanley told the group that he planned to come back to the PHAWG with the final comments and then go to ORRHES with the Final Y-12 Uranium PHA during the December Subcommittee meeting.
James Lewis commented ATSDR for doing a good job of explaining and presenting the EPA comments. However, James feels that there are other outstanding issues that need to be looked at collectively for the next PHAWG meeting. James feels that the outstanding issue is the subjective comments that were included in the Appendix XXX Responses to Public Comments on Y-12 Uranium Releases Public Health Assessment.
*Like the rest of the overheads used in this presentation, copies will be made available in the field office upon request.
ATSDR proposed plan for Iodine-131 Public Health Assessment
Paul Charp presented the proposed plan for the Iodine-131 Public Health Assessment. Paul explained the general steps in the process and the estimated time frame for the literature reviews, data acquisition, data review, and the possible need for an expert panel. Paul explained that ATSDR and others are also currently in the process of looking for missing Iodine data.
Bill Taylor told the group that when the Y-12 Uranium final PHA is presented, ATSDR is interested in ORRHES having some type of recommendation to the agency. The resolution would need to be discussed and developed within the PHAWG.
The group decided that all comments on ATSDR responses should be submitted to the PHAWG for discussion at the next PHAWG meeting on November 6, 2003.
Regarding EPA Summary Comment number one, it was suggested that ATSDR’s response could be better stated and more accurate if it were similar to the following: It is not ATSDR’s policy to provide copies of raw data from primary sources that are publicly available. But ATSDR does supply references to the data used; which is good technical practice.
ATSDR will find out what EPA did concerning the evaluation of soil samples so that ATSDR has a definite answer to the question regarding whether or not the Scarboro soil samples were homogenized.
If ChemRisk created a deposition map that showed uranium fallout, ATSDR should locate the map and use it.
ATSDR should consider revising the Y-12 Uranium brief to include the term “health hazard” instead of “health concern” and include additional information such as an explanation of the conclusion categories.
Regarding the potential ATSDR actions, Jack Hanley will follow-up to see why ATSDR is only performing the health education and not the health investigation or the residents tracking system.
The comments regarding the ATSDR responses will be revisited at the November 6th PHAWG meeting.
The meeting was adjourned at 8:15 PM.