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An estimate of the potentially exposed population at the AT&SF site cannot be made at this time due to limited data on the nature and extent of contamination at and around this site.


Figure 1. Planview of drains and canals in
the region around the Santa Fe Railway inactive
plant site.

Figure 2. The Atchison, Topeka and Santa Fe Railway Co.

Figure 3. The South Broadway Community


The AT&SF Tie Treating Plant Public Health Assessment--Public Comment Release--was released for review and comment in July 1994. The written comments received and our responses are summarized in this appendix.

Comment: The site has been proposed to the National Priorities List (NPL), but is not on the NPL.

    Response: The commentor was correct at the time; however, on December 16, 1994, the EPA finalized the AT&SF site on the Superfund NPL. The document has been revised to reflect that fact.

Comment: The wood preserving facility was closed with great care to control access. Substantial time and resources are spent on investigatory and remedial activities. "Former" is a more accurate descriptor of the facility than "abandoned".

    Response: ATSDR concurs; the document has been revised to reflect that fact.

Comment: Although the wood treating facility was dismantled in 1972, the dikes surrounding the wastewater reservoir and sump were left intact. Due to the significant available storage volume for rainfall, it is inaccurate to describe a regular discharge of runoff from the impoundment and sump to an irrigation ditch; it is not known that this ever occurred.

    Response: According to the EPA Hazard Ranking Documentation, runoff from the site enters the irrigation ditch. The document has been revised to reflect that the runoff is general and not specific to the wastewater reservoir and sump. The statement does not imply that runoff occurs regularly.

Comment: Although the document credits the EPA and NMEID with soil sampling efforts, AT&SF has conducted 99.9% of the soil sampling at the site.

    Response: The commentor is correct; the document has been revised to reflect that fact.

Comment: The concentration of polycyclic aromatic hydrocarbons in sump soils was approximately an order of magnitude lower than the sludge.

    Response: The commentor is correct; the document has been revised to reflect that fact.

Comment: Additional activities have occurred since the June 1993 visit, including soil sampling, groundwater sampling from existing wells, installation and analysis of an additional well, and sampling from additional city and private well sampling.

    Response: ATSDR staff have requested and received the additional sampling data. That information will be evaluated and appropriate public health actions will be taken if indicated.

Comment: The bio study was conducted using modified horse troughs, not drums.

    Response: The document has been revised to reflect that fact.

Comment: The use of 1990 Census data for the entire South Valley does not provide information reflective of the smaller population specifically pertinent to the San Jose/South Broadway community.

    Response: The document has been revised to provide information reflective of the San Jose/South Broadway community

Comment: How can 62% of the population be White while 73% is Hispanic?

    Response: Race and ethnicity are two separate questions in the U.S. Census. Hispanic origin refers to people who classify themselves in one of the specific Hispanic origin categories such as "Mexican", "Puerto Rican", "Cuban" or "other Spanish/Hispanic". Persons of "other Spanish/Hispanic" origin include those whose origins are from Spain, the Spanish-speaking countries of Central and South America, and the Dominican Republic. Persons of Hispanic origin may be of any race.

Comment: The area south of the site has not been used for alfalfa production for at least the last five years. In addition, observation indicates that surrounding areas are not used for grazing.

    Response: The comment is consistent with the document, which states the land was used to produce alfalfa and is currently not being used for agricultural purposes. As stated in the Community Health Concerns section, a community member asked ATSDR at the public availability session whether land adjacent to the site could be used for raising crops to be fed to dairy cattle.

Comment: Wells west of the Rio Grande have a very low probability of being affected by activities at the site, which is east of the Rio Grande.

    Response: The commentor is correct; the document has been revised to reflect that fact.

Comment: A tumor registry was identified in the Health Outcome Data section; however, the tumor registry was not investigated, nor was information contained therein related to the San Jose community and the AT&SF contaminated site.

    Response: The rationale for choosing not to use information in the tumor registry is stated in the Health Outcome Data Evaluation section.

Comment: Information in the Community Health Concerns section reflects only those individuals who were aware of the public availability session. Most information in this section is derived from the "Health Perceptions Profile," a study area that extends beyond the perimeter of the AT&SF site.

    Response: ATSDR provided as much advanced notice and advertising of the public availability session as was possible. Efforts included public notices, press releases and advanced notification of the local citizen's group. Release of a public comment version of the document provides community members with an additional opportunity to voice their concerns. ATSDR considers the commentor's identification of the Health Perceptions Profile as the primary source of information as inaccurate. However, as described in the document, because the South Valley site is adjacent to the AT&SF site, and because a significant portion of the respondents to the South Valley profile considered the railroad a health threat, ATSDR stands by its decision to evaluate the additional health concerns stated in the profile. Concerns culled from that source were identified as such.

Comment: The survey mentioned at the end of the Community Health Concerns section was provided by the New Mexico Department of Health. The EPA TAG did not provide any funds.

    Response: The commentor is correct; the document has been revised to reflect that fact.

Comment: Examination of the 1992 TRI reveals, among other things, that 75,304 lbs. of trichloroethane was released by GE within a mile of the AT&SF site.

    Response: ATSDR reexamined the 1987-1992 TRI and included the zip code where the Albuquerque GE facilities are located. We identified the report the commentor mentioned. However, we have seen no information suggesting that trichloroethane has contaminated soil or groundwater on or near the site. Results of our additional search have been added to the document.

Comment: Wastewater associated with the wood treating process was discharged into the wastewater reservoir; domestic sewage from on-site residences was handled by the sump. Of the 3.4 acre total area, approximately 1.2 acres are occupied by the wastewater sump.

    Response: The document has been revised to reflect that information.

Comment: The Off-Site Contamination, Groundwater section should be retitled "Private well identification and sampling in San Jose".

    Response: The section's title remains. However, the document has been revised to reflect the fact that the source of information on off-site contamination of groundwater is from private well water.

Comment: The commentor is not aware of any NMEID sampling of surface water, and notes that EPA has questioned the usefulness of soil samples taken from ditches south of the site due to quality assurance and quality control concerns.

    Response: ATSDR stands by its statement that, according to the EPA Hazard Ranking System Report, NMEID sampling conducted in 1987 indicates that creosote constituents may have migrated from the site to surface water; that no quantitative data was provided; and that further documentation is required to establish that surface water is indeed contaminated.

Comment: Table 3 describing exposure pathways is missing; table 3 describes data on the quality of public water wells.

    Response: The document previously incorrectly labelled two separate tables as Table 3. Table 4 describes exposure pathways.

Comment: What is the rationale for including public health implications of contaminants that may not be site related?

    Response: As a public health agency, ATSDR evaluates information from sites to identify potential public health hazards, such as exposure to dangerous levels of chemical contamination. If a contaminant is found on or near a site, we are concerned about its potential health impact regardless of its source. However, it is explicitly stated when the source is suspected to be one other than the site.

Comment: My siblings and I were born and raised in one of the homes provided by the Tie Plant. We ate from a garden we grew on the property and showered in community showers located 200-300 feet from the creosote pit. We played in barrels full of creosote. We chewed on hardened creosote. We have the following health problems: acute rheumatoid arthritis, lymphocytic colitis, hypothyroidism, high blood pressure, brain tumor, female disorders. We can provide medical records.

    Response: The scenarios you describe suggest that you all have been exposed to creosote. Unfortunately, there is insufficient information to estimate doses each of you may have received. However, studies show that eating food contaminated with a high level of creosote causes a burning in the mouth a throat. Both brief exposures to large amounts of coal tar creosote and longer exposures to lower levels tend to result in rashes, chemical burns or severe irritation of the skin and eyes. Longer exposures to vapors of creosote irritate the respiratory tract. Ultimately, long term exposure can result in skin cancer (17). There is no indication in the literature that exposure to creosote results in arthritis, lymphocytic colitis, hypothyroidism, high blood pressure, brain tumors or female disorders. That you have medical records suggests you have consulted with physicians regarding your health concerns. ATSDR recommends continuing your relationships with the physicians to obtain appropriate medical care.

Comment: The assumption that water found in on-site monitoring wells will be used for irrigation purposes in incorrect.

    Response: As no controls exist to prevent irrigation of crops with local groundwater, ATSDR considers the evaluation of this possibility appropriate.

Comment: The conclusion, "people may be exposed to contaminated drinking water in private water wells in the nearby San Jose community," is not supported by reliable data, reducing the value of the document as an assessment tool.

    Response: ATSDR stands by its conclusion.

Comment: Recommendations by the public should be utilized by ATSDR prior to conducting an assessment of AT&SF and other sites.

    Response: Recommendations are generated as a result of conducting an assessment; without assessing a site, recommendations cannot be made. Community input is gathered at the beginning of the public health assessment process when the public availability session is held. Recommendations made in response to the Public Comment release are incorporated into the final public health assessment.

Comment: Please provide community health education regarding potential health effects of exposure. Special emphasis should be given to people who fish from or play around the adjacent ditches.

    Response: Community health education activities have been recommended at this site. ATSDR Division of Health Education is pursuing identifying a local agency to conduct such activities.

Comment: Collect more data from drinking water wells.

    Response: ATSDR has recommended that contaminated drinking water wells be identified. Some additional sampling has already occurred.

Comment: Will this site ever be treated?

    Response: Remediation and removal activities are scheduled by the EPA; ATSDR cannot affect the decisions regarding how to remediate or remove contamination when the site poses an indeterminate public health hazard.

Comment: If there is a class action suit in process, what do we do to get included in this suit?

    Response: ATSDR has no information on pending legal actions and cannot advise people on legal matters. ATSDR suggests contacting an attorney to resolve legal questions.

Comment: Because the document lacked sufficient environmental data to proceed in a manner that is complete and valuable, ATSDR should not use resources made available through Superfund to conduct this and other ineffectual health assessments.

    Response: ATSDR is required by the Superfund law (Comprehensive Environmental Response, Compensation, and Liability Act of 1980 [CERCLA]) as amended by Superfund Amendments and Reauthorization Act of 1986 (SARA) to conduct a public health assessment of each hazardous waste site proposed for the National Priorities List (NPL) within one year of its proposal. Legally ATSDR cannot wait for the collection of sufficient environmental data before conducting the assessment. One effect of the public health assessment process can be to identify critical data gaps and to stimulate environmental agencies to respond by collecting and analyzing appropriate samples.

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