Oak Ridge Reservation: Public Health Assessment Work Group
Public Health Assessment Work Group
March 15, 2004 - Meeting Minutes
ORRHES Members attending:
Bob Craig (Chair), Tony Malinauskas, LC Manley, Pete Malmquist (telephone), Jeff Hill, Kowetha Davidson, James Lewis, and George Gartseff
Public Members attending:
Luther Gibson, Joy Sager, Danny Sanders, Susanne Sanders, Janet Michel, Tim Joseph, Joan Seaman (telephone), Jenine Anderson (telephone), and Susan Gawarecki
ATSDR Staff attending:
Bill Taylor, Melissa Fish, Mark Evans, Marilyn Horton (telephone), Paul Charp (telephone), Jack Hanley (telephone), and Loretta Bush (telephone)
The purpose of the meeting was to discuss the TSCA Incinerator Public Health Assessment.
LC Manley moved that the February 17, 2004 Draft PHAWG minutes be approved. Tony Malinauskas seconded the motion. The motion passed. The draft meeting minutes for February 17, 2004 were approved.
Cancer Incidence Update
Pete Malmquist provided the work group with an update regarding the Cancer Incidence Review. Dee Williamson still has not received all of the information that she needs from the State of Tennessee. However, Dee Williamson hopes to have something for the PHAWG during the month of April.
TSCA Incinerator Presentation
The power point slides used in the TSCA Incinerator presentation are available for review in the Field Office.
Power Point Slide 1-ATSDR Public Health Assessment for the TSCA Incinerator
John Wilhelmi introduced himself as a chemical engineer who works for a company called ERG. ERG is a contractor to ATSDR. For the last 15 years John has evaluated air quality issues for a wide range of industrial operations including incinerators. John is attending tonight's meeting to inform the group about the status and approach that will be used in the TSCA Incinerator Public Health Assessment. In addition, John welcomes any feedback that the group might have and encouraged people to ask questions as they arise.
John Wilhelmi clarified that TSCA is an acronym for the Toxic Substances Control Act.
Power Point Slide 2-Outline
John Wilhelmi provided the group with an outline of what his discussion would include. John indicated that his presentation would discuss the goal of the TSCA Public Health Assessment, the air exposure pathway, and three types of information sources; then he would end with a summary.
Power Point Slide 3-Goal of the PHA
John Wilhelmi said that the goal of the TSCA PHA is to evaluate the public health implications of off-site exposure to contaminants released from the TSCA Incinerator. John emphasized that the focus would be on environmental health such as residential exposures. The TSCA Incinerator PHA is not an evaluation of occupational exposures. While not ruling out other possible exposures, the focus of the TSCA Incinerator PHA will mostly be on the air exposure pathway considering direct (breathing in something that is already in the air) and indirect exposures (one example is an air contaminant that finds its way into the food chain).
Power Point Slide 4-Background
John Wilhelmi provided some background regarding the TSCA Incinerator. John pointed out that the construction of the incinerator was completed in the late 1980s and that routine operations have occurred since 1990. The TSCA Incinerator went through a very thorough permit application and review process which is ongoing.
John Wilhelmi told the group that the permitting authorities have set operational limits beyond which the incinerator is not allowed to process. The TSCA Incinerator is only allowed to process a certain amount and certain types of waste. The permitting authorities have set operational limits that are meant to be protective of the environment. In addition, the TSCA Incinerator is operated under close scrutiny.
Regarding typical operation levels, John Wilhelmi said that in the 1990s a Blue Ribbon Panel (i.e., the Independent Panel hired by the Governor of Tennessee to evaluate the TSCA Incinerator's operations) found that the TSCA Incinerator was operating at less than five percent of the maximum allowed treatment rate for solids and less than 35 percent of the maximum allowed treatment rate for liquids. This is an important point because of the fact that the permits are set at rates that are believed to be protective of health and the environment with a certain margin of safety. Obviously the TSCA Incinerator is not coming close to operating at the maximum allowed levels.
John Wilhelmi reminded the group that the TSCA Incinerator is well designed, well tested, and operated under close scrutiny.
Power Point Slide 5-Air Exposure Pathway
John Wilhelmi defined the terms "emissions", "fate and transport", and "ambient air monitoring" because together these terms make up the air exposure pathway.
Emissions-the start of analysis; what is coming out of the stack or vents; visible or not visible
Fate and Transport-the piece between emissions and exposure; how pollutants move, degrade, and fall out of the air
Ambient Air Monitoring-measurement of what is in the air that people might breathe; a relatively direct indicator of exposure
Power Point Slide 6-The Bigger Picture
John Wilhelmi explained that besides emissions, fate and transport, and ambient air monitoring there are numerous other issues that will be considered. The bigger picture includes demographic data such as where people live and spend their time, community concerns, toxicological evaluations, radiological evaluations, and data for other media such as soil, surface water, and sediment.
Tony Malinauskas asked if the TSCA Incinerator is unique. John Wilhelmi replied that the TSCA Incinerator is very unique in that it is the only incinerator permitted to receive and treat radioactive and hazardous wastes, including wastes containing PCB's.
There were some comments made among work group attendees as to whether or not the DSSI Incinerator in Oak Ridge was considered an incinerator or a boiler. Some people said that it was considered a boiler and others thought that the distinction depended on a personal definition of what an incinerator is.
Power Point Slide 7-Relevant Guidance
John Wilhelmi told the group that there are two documents that ATSDR is basing its approach onone is published by ATSDR (Public Health Reviews of Hazardous Waste Thermal Treatment Technologies: A Guidance Manual for Public Health Assessors) and the other by EPA (Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities-draft).
John Wilhelmi pointed out a quote that he found in the ATSDR document that is relevant to the TSCA Incinerator discussion. The quote reads, "Thermal treatment technologies are inherently neither safe nor unsafe; whether they are safe depends on how they are designed and operated." John added that this is an important concept because he is not coming into the TSCA Public Health Assessment project with any pre-conceived notions that all incinerators are safe or unsafe. The safety of an incinerator depends on how the incinerator is designed and operated.
Power Point Slide 8-Information Sources
John Wilhelmi explained that his task is to gather as many reports as possible relating to the key inputs of the TSCA Incinerator Public Health Assessment. John told the group that there are large volumes of information available and that he is considering information from many different sourcesnot just DOE, EPA or State data.
Power Point Slide 9-How Do Incinerators Work?
John Wilhelmi provided information as to how incinerators operate. John said that waste materials (mainly the organic components) are combusted in the incinerator. The TSCA Incinerator has a primary chamber (rotary kiln) that operates at 1,800 degrees Fahrenheit and a second chamber (afterburner) where the gasses are fed through and some liquid wastes are injected that operates at 2,200 degrees Fahrenheit. The purpose of the combustion is to break up the toxic materials into generally benign materials. What is not destroyed during the combustion process passes through air pollution controls that collectively remove particles and certain gasses.
As John Wilhelmi previously mentioned, there are many design considerations and it is common for people to talk about the three "T's". The three "T's" include temperature, time, and turbulence.
Temperature- Is the temperature high enough to achieve a safe combustion level?
Time- Is the time the waste is in the incinerator long enough to achieve the combustion level I want?
Turbulence- Am I mixing my waste enough to be sure that it all experiences the high temperatures?
John Wilhelmi told the group that incinerators operate with the ultimate goal of destroying waste materials and if all waste cannot be destroyed, the goal is to reduce the volume and toxicity of waste materials.
Power Point Slide 10-Emissions Data
John Wilhelmi told the group that DOE cannot dump whatever it wants into the incinerator. Waste has to pass specific test criteria before it is placed into the incinerator and treated. There is also continuous emissions monitoring where sensors are placed in the stack to measure what is coming out.
Of the emissions data that John Wilhelmi is considering one data source is trial burn data. Before incinerators can operate and in the case of the TSCA Incinerator, every ten years DOE must demonstrate that the incinerator destroyed waste to a specific efficiency required by law. For PCB's the requirement is 99.9999 percent. During a trial burn, the operation parameters are set up as to challenge the incinerator (i.e. lower temperature). Trial burn data are used to measure the destruction and removal efficiency of the incinerator. The efficiency level requirements will vary among different contaminants.
Kowetha Davidson asked if the TSCA incinerator normally operates with the same parameters that are used in the trial burn.
John Wilhelmi replied that a purpose of the trial burn is to set the minimum operating requirements. Through the trial burn, the data are looked at and they can say that the incinerator needs to operate at X level when treating X contaminant.
In response to a comment, John Wilhelmi told the group that there are a series of mechanisms in place so that if the incinerator itself realizes that the temperature is not sufficient, that too much waste is going in, or that the exit velocity of the stack is not what it should bethe TSCA Incinerator will automatically shut off.
Other data sources include periodic stack tests and continuous emissions monitoring. Every five years DOE is required to demonstrate to the State of Tennessee that it is not exceeding permitted emission rates for metals, particulate matter, and certain acids. There is also continuous emissions'-monitoring where sensors are placed in the stack to measure what is coming out. There are some sensors for oxygen, carbon monoxide, and carbon dioxide which indicate whether or not the incinerator is combusting the waste properly. If readings get too high, the TSCA Incinerator automatically shuts down. There is also semi-continuous monitoring for radionuclides. For this, air is continuously taken from the stack and is periodically sampled for radioactive constituents.
Regarding semi-continuous emissions monitoring for radionuclides, Joan Seaman voiced interest in the radiological elements because they are not destroyed, they will be volatilized or oxidized. There will be emissions of radionuclides.
John Wilhelmi responded that the fate of the radionuclides is that some may end up in the ash, some may end up in the waste water, and some will end up in the air. The stack at the TSCA Incinerator is equipped with a device that continually samples the air. Then the samples that are collected are analyzedthey are integrated samples.
Joan Seaman indicated that she and others in Colorado are concerned about the vaporization because the community in Colorado is not being informed about the vaporization regarding plutonium. Are there HEPA filters on the TSCA Incinerator?
John Wilhelmi responded that there are not HEPA filters; there are a series of scrubbers and an electrostatic precipitator. The final TSCA Incinerator Public Health Assessment will consider waste characterization data so that various concerns can be put into perspective.
Joan Seaman asked if the report will consider upsets in emissions and mechanical failures.
John Wilhelmi replied that yes, the report would consider upsets in emissions and mechanical failures. John told the group that there is a thermal relief vent that opens under certain, relatively rare conditions. To date, most of the thermal relief vent openings occurred during power outages. There are samples that are collected during those times as well as estimates that have been made regarding what has been released.
Joan Seaman asked whether there would be a monitor at the thermal relief vent release.
John Wilhelmi responded that he did not think there was a monitor at the vent itself but there are off-site monitors that are triggered when the vent is open.
Joan Seaman made the observation that there is no way for the community to know when someone has opened the thermal relief vent. She also pointed out that the thermal relief vent will bypass the pollution controls and continuous monitoring that are in place.
John Wilhelmi said that there is a relief vent that opens after the incineration has occurred and before it passes through the air pollution controlsand in the last 15 years that vent has been opened approximately 15 times. When that occurs, off-site samples are collected. Thus, it is not a complete unknown as to when the valve has been opened.
Janet Michel told the group that in the mid 1990s all the directors at the Lawrence Livermore National Lab put together a white paper regarding incineration saying that they would not approve any incineration of radionuclides at the Lawrence Livermore site because of the same issues that Joan Seaman had just mentioned.
John Wilhelmi said that he would like to see the report. Janet Michel will get the report to him. John added that some wastes are not meant for incineration and he did not know the reasons that Lawrence Livermore directors had for not incinerating. John also reminded the group that there are risk-based waste acceptance criteria that limit what the TSCA incinerator can and cannot incinerate.
Janet Michel also pointed out that during the same time period of the Lawrence Livermore white paper, there was a UCLA paper written by the Air Toxics lab making the same type of recommendations as the Lawrence Livermore white paper about not incinerating metallic type waste.
John Wilhelmi told the group that all of the comments are very well taken and that he will locate the references that were mentioned. He also re-stated the idea that all incinerators are not safe or unsafe, it is how they are operated and how they are designed that determines what can and cannot be incinerated.
LC Manley asked what types of solids are incinerated.
John Wilhelmi responded that the TSCA Incinerator incinerates personal protective equipment, sludge, and waste materials with trace metals. DOE does not fill the incinerator with metal slabs.
Tony Malinauskas asked if it would be constructive to look at typical emissions from a coal fire plant [the rest of the comment could not be heard due to proximity of the microphone on the audio device to the PowerPoint projector].
John Wilhelmi responded that it is often constructive to consider emissions from other sources for perspective. However, he reminded the group that the PHA ultimately will focus on the TSCA Incinerator and that the air quality impacts from other sources will be accounted for implicitly in the ambient air monitoring data. Meaning, the ambient air monitoring data characterizes the influences from all sources of air pollution, not just the impact from a single source.
James Lewis made the observation that coal fired plants have made changes over time regarding their operating procedures and that concerns have been raised regarding coal fired plants releases.
John Wilhelmi responded that he would consider what James mentioned. While the PHA will focus on the TSCA Incinerator, air quality impacts from all other sources in the area are implicitly accounted for in the ambient air monitoring data.
Power Point Slide 11-Fate and Transport Data
John Wilhelmi reminded the group that fate and transport refers to how things move through the air. Regarding fate and transport data, there are meteorological data that are continuously collected at multiple sites at K-25 and dispersion modeling analyses (DOE's permit application and Blue Ribbon Panel). John told the group that fate and transport analyses are used to inform the placement of ambient air monitoring stations. Thus, the air monitoring stations are not just randomly placed; the locations of maximum impact from modeling studies are considered.
Power Point Slide 12-Ambient Air Monitoring Data
John Wilhelmi pointed out that the final piece of the puzzle is the ambient air monitoring data which provides a reasonably direct account of exposure levels.
John Wilhelmi said that the ambient air monitoring data include DOE's routine environmental surveillance network (particulate matter, metals, radionuclides, radiation, selected organic compounds), TDEC's environmental monitoring network (metals, radiation), and EPA's environmental radiation data. For all three of these data sources, the location of monitors and other processes are evaluated.
In response to a question about the quality of these three data sources, John Wilhelmi said that so far that data seems to be of high quality and he has confidence that the location of the monitors and other considerations were appropriate. However, John noted that he will evaluate the monitoring program in far greater detail to determine whether changes need to be made.
Tony Malinauskas asked if monitoring stations monitor continuously.
John Wilhelmi responded that the monitoring depends on the contaminant. John said that there is almost always a six day schedule for particulate matter and metals (this same schedule is used all across the country). To the best of John's memory, he said that the monitoring for radioactive contaminants is continuous and analyzed periodically. John added that the monitoring schedule for the contaminants would be documented in the TSCA Incinerator Public Health Assessment.
John Wilhelmi reminded the group that he would welcome any other information that the group knows of regarding air monitoring or the TSCA Incinerator.
It was suggested that the Tennessee Valley Authority could serve as another source of information.
Power Point Slide 13-DOE Air Monitoring Locations
John Wilhelmi showed a map with the DOE air monitoring locations that have been used at some point from 1990 to the present. Not all are operating today but there is still reasonable coverage.
Power Point Slide 14-EPA Air Monitoring Locations
John Wilhelmi showed a map with the EPA air monitoring locations. EPA has one main air monitoring station that is part of a nation wide network in which they use the same methodology across the nation for gross alpha and gross beta in the air. The utility of this is that what is measured here can be compared to what is measured at other parts of the reservation and the country.
Power Point Slide 15-TDEC Air Monitoring Locations
John Wilhelmi showed a map with the TDEC air monitoring locations. The two locations are operating north and south of the incinerator and are currently operating today under consistent methods.
Kowetha Davidson asked if the two locations are populated areas.
John Wilhelmi replied that the two monitoring locations are placed where the air mass will pass through and on into the populated areas. Presumably the air quality impact measured at the stations will be higher than what would reach the more populated locations.
Kowetha Davidson said that when she first came to Tennessee there was an issue regarding Bull Run and fly ash. She remembers that they raised the height of the stack. Thus, resulting in dispersion over a wider area so that there is not as much of an impact measured close to the source. Could this be happening regarding the TSCA Incinerator?
John Wilhelmi replied that he knows there is a minimum stack height set and he has no reason to believe that the stack has been artificially elevated to send contaminants long distances or beyond the monitoring locations. John added information from modeling studies was typically used to decide upon the locations of the air monitoring stations.
John Wilhelmi told the group that the purpose of the TSCA Incinerator Public Health Assessment is not only to review current conditions but also to consider if ATSDR needs to make recommendations in order to fill data gaps.
Power Point Slide 16-Data Evaluation
John Wilhelmi explained that in order for a data evaluation (TSCA Incinerator PHA) to result in scientifically defensible conclusions, the three elements of the air pathway (emissions data, fate and transport data, and ambient air monitoring data) must all be considered together.
Power Point Slide 17-Other Considerations
John Wilhelmi told the group that other considerations regarding the TSCA Incinerator PHA include design and operational concerns. Examples of these other considerations that John will evaluate include waste acceptance criteria, waste handling, fugitive emissions, sophisticated process controls, automatic waste feed cut-off system, thermal relief vent, and air pollution controls.
Power Point Slide 18-Community Concerns
John Wilhelmi made the point that the TSCA Incinerator PHA must address community concerns or else it will prove to be a useless exercise. John explained that he has received concerns regarding the TSCA Incinerator from ATSDR's community concerns database as well as from TDEC's document titled "Responses to 101 Questions". John provided a few examples of concerns from each of the two sources (exposure to emissions, whether 99.9999% efficiency is achieved, non-routine operations, fate of ash and other residuals).
John Wilhelmi told the group that he is very interested in any other concerns that people have or know of regarding the TSCA Incinerator. He urged the group to contact him or other ATSDR staff with any concerns regarding the TSCA Incinerator.
Jeff Hill observed that in gathering data relating to the TSCA Incinerator, John mentioned three main sources. Jeff said that it seems that someone is always looking at the same results that have been looked at time and time again. We are always relying on other samples. Jeff Hill thought that it would be interesting and useful for ATSDR (instead of relying on other samples) to take their own sample and model that sample so that the information from the three sources can be backed up.
James Lewis wondered if there would be a need for ATSDR to do its own sampling if John is using three different sources that all show the same results.
Responding to Jeff Hill's question, John Wilhelmi said that as a scientist he would love to conduct additional studies. However, he first would like to review the available data before recommending further study. If sufficient information is available on the TSCA Incinerator, then further study would not necessarily be the best use of resources.
Kowetha Davidson asked if the TSCA data has been collected in such a way that what goes into the incinerator, what comes out of the incinerator in emissions, and what is recorded at the monitoring stations can all be analyzed together to see if they match up.
John Wilhelmi responded that he would look closely at the available information to determine whether such mass balance analyses can be conducted, though he acknowledged that the presence of emissions sources other than TSCA Incinerator would likely confound such analyses.
Kowetha Davidson stated that there are concerns that people have about particular contaminantsfor example, PCBs. She was wondering if there would be a way that those concerns would be able to be specifically addressed.
John Wilhelmi said that he will look at what is going into the TSCA Incinerator and comparing it to what is being measured to find out if there is adequate coverage. John emphasized that he wants sampling that results in reliable conclusions.
There was discussion regarding the original permit for the TSCA Incinerator as well as the amount of waste that is shipped into Oak Ridge and shipped out of Oak Ridge. [However, the details could not be heard on the audio].
In response to James Lewis's comments regarding community concerns, John Wilhelmi said that he has looked at the Tennessean newspaper articles, the community concerns database, and TDEC's document titled "Responses to 101 Questions". John is making every effort to answer the questions and concerns that have emerged from his review of the three sources. John's goal is to be transparent in the entire PHA process.
James Lewis would like to see TDEC's document titled "Responses to 101 Questions". John Wilhelmi will send a copy to the Field Office.
Kowetha Davidson reminded the group that anyone with any additional sources of information should get that information to John or to ATSDR.
Power Point Slide 19-Summary
John Wilhelmi reminded the group that the TSCA Incinerator operations are closely regulated. There is extensive data available to help characterize air quality impacts. The TSCA Incinerator PHA will synthesize and interpret trends and patterns among the various data sources and identify any data gaps that need to be filled.
Responding to a question regarding the TSCA Incinerator PHA timeline, Jack Hanley said that ATSDR is still aiming for the target date listed in the project plan.
Danny Sanders said that he began attending ATSDR meetings because he is concerned and interested in issues relating to the Happy Valley community (existed just outside the gate of K-25) from the 1940s. Danny feels that the questions that he submitted to ATSDR over a year ago deserve to be addressed and he is still waiting for a response.
Mark Evans was introduced as the person working on the K-25 Public Health Assessment.
Both James Lewis and Danny Sanders made the observation that ATSDR seems to mostly focus on the current issues and the historical issues do not get much attention.
James Lewis said that the general public is interested in public health issues and not just exposurepeople want a response to their health issues.
The meeting was adjourned at 7:30 PM.
Votes/Specific Actions Taken in the Meeting
The draft meeting minutes for the February 17, 2004 PHAWG meeting were approved.
John Wilhelmi will contact Janet Michel (if the reports she mentioned are not available from DOE) to get a copy of the Lawrence Livermore report and the UCLA report that she mentioned during the meeting.
John Wilhelmi will send a copy of TDEC's document titled "Responses to 101 Questions" to the Oak Ridge Field Office.
John Wilhelmi will consider and respond to the questions and issues raised by Joan Seaman in the TSCA Incinerator PHA.