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Sunflower Army Ammunition Plant
DeSoto, Kansas

December 1995

Prepared by:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Federal Facilities Assessment Branch


ATSDR staff conducted an initial site visit at Sunflower Army Ammunition Plant (SAAP) inDeSoto, Kansas from September 11-13, 1995. The purpose of the trip was to obtain informationnecessary to determine if immediate ATSDR public health actions are appropriate for the site,and to prioritize the site for a public health assessment. We toured the site and met with SAAPpersonnel, on-site contractors with Alliant Techsystems, and representatives from the U.S.Environmental Protection Agency and the Kansas Department of Health and Environment. Weidentified the following questions, which will be addressed in the public health assessmentprocess.

  • Are cattle that graze on SAAP property accumulating nitroguanidine or other chemical contaminants that could be harmful to people who eat beef from those cattle?

  • Have groundwater contaminants from SAAP affected any potable water sources?

  • Could people be exposed to harmful levels of site-related contaminants in Kill Creek and Captain Creek?

  • Could people be exposed to harmful levels of site-related contaminants in the northeastcorner of the site, where an old landfill is located, if that area is used as a JohnsonCounty recreational area in the future?


SAAP is a Government-owned, contractor-operated installation operated by Hercules, Inc.Operations at SAAP began in 1942. The majority of the installation has been in standby, inactivestatus since 1971.

The primary mission of the installation was to manufacture smokeless powder and propellants.Other operations included manufacture and regeneration of nitric and sulfuric acid, andmunitions testing. The majority of the site's infrastructure is still in place.

SAAP covers 9,065 acres and is located in a sparsely-populated rural area near the small town ofDeSoto. Most of the land use surrounding the site is agricultural.

The site is on a broad ridge between Captain Creek on the west and Kill Creek on the east, bothof which are perennial streams.

Possible sources of contamination at SAAP include production line areas, magazine storageareas, and approximately 70 solid waste management units (SWMUs).

Past sampling events, including the 1988 remedial investigation, have indicated the presence ofhazardous substances at the site, primarily inorganic compounds, explosives and nitratecompounds. Contaminants have been detected in on-site soil and sediment and in groundwaterunder the site. Five surface impoundment SWMUs (settling/blender ponds) were the sourcesselected for EPA's Hazard Ranking Score evaluation.


Nitroguanidine in Cattle

Much of the site property is leased to area farmers for grazing cattle or producing hay. A citizenof a community approximately 30 miles from the site is concerned that cattle are ingestingnitroguanidine and other chemicals and that people are being exposed through the foodchain byeating that beef.

On the site tour, we learned that cattle are only kept on the site for about 120 days before beingsent elsewhere. We further noted that cattle are fenced off from areas where the highestconcentrations of nitroguanidine and other chemical contaminants are likely to be found.

No tissue sampling of cattle from the site has been done. We acquired a study of tissue samplingin deer that lived on a site similar to SAAP. We will use that study and other relevant data to helpdetermine whether or not there may be a public health risk from eating beef from cattle thatgrazed at SAAP. We will make a determination of what public health actions are necessary, ifany, following a review of those documents. That review should be completed in early 1996.


We learned from discussions with a geologist with the Kansas Department of Health and Environment (KDHE) and Alliant Techsystems staff that groundwater under the site does not appear to flow off site. Instead, groundwater comes to the surface at various points on site and also empties into Kill Creek on SAAP's eastern border and Captain Creek on the western border.

Groundwater under the site is not used for domestic purposes. No groundwater sampling hasbeen done beyond SAAP's boundaries, and there are no good records of the number of privatewells in the area. We will review sampling data for both on-site groundwater and surface waterfrom the creeks into which groundwater flows to determine whether contaminants are present atlevels that could potentially affect off-site potable water sources. That evaluation is scheduled forfiscal year 1996.

Kill Creek and Captain Creek

KDHE has issued fishing advisories for many Kansas water bodies due to pesticide runoff fromfarmlands. Kill Creek and Captain Creek are reportedly included in those advisories; we willverify this with KDHE.

Fishing reportedly does occur in the creeks. However, from observations on the site tour, it doesnot appear that subsistence fishing would be possible for either creek because the creeks are notbig enough to support large numbers of edible-sized fish. There are not many houses adjacent tothe creeks, so it is unlikely that many children, if any, play or swim in the creeks. We will reviewboth surface water and sediment data from the creeks to determine whether contaminants arepresent at levels of potential public health concern. That work will be done in fiscal year 1996.

Northeast Landfill Area

An old landfill on the northeast corner of the site is located on a 300-acre parcel of land that isproposed to be transferred to Johnson County for use as a recreational area. We will reviewenvironmental sampling data for that area to determine if any contaminant levels are of potential public health concern.


Based on available data, we have determined that the following issues do not currently pose apublic health concern. We will, therefore, not evaluate them further unless future information indicates that we should.

Air Releases

All burning at SAAP is carried out according to strict safety protocols, and only on days when wind does not carry a substantial amount of smoke off site. The area around the site isvery sparsely populated, and no houses are near the burn areas. There is, therefore, very littlechance that human exposures to airborne contaminants from SAAP have occurred or will occurat levels of health concern.

On-Site Soil and Sediment

SAAP is securely fenced and has very good security, so that trespassing is not likely. Areas withthe most soil and sediment contamination are fenced. Human exposures to contaminated soil andsediment are, therefore, not likely.

Physical Hazards

Since site security is good, it is unlikely that anyone other than site personnel would be in thearea of any physical hazards. We assume that site personnel have been trained in and follow proper safety protocols when they are near any hazards.


Besides the concern of one area resident about nitroguanidine in cattle, we have identified nospecific environmental or public health concerns related to SAAP. Some general concerns aboutthe possible presence of harmful chemicals on the site and the efficiency of site cleanup effortswere expressed in some interviews conducted for the Community Relations Plan; those concernsshould be addressed in our future documents.

We will make additional citizen contact to learn of any new health concerns throughout thepublic health assessment process. Any concerns that people have should be directed to:

Program Evaluation, Records, and Information Services Branch
(Sunflower Army Ammunition Plant)
ATSDR, Division of Health Assessment and Consultation
1600 Clifton Road NE, MS E-56
Atlanta, GA 30333

or contact Jerome Joyce, ATSDR Regional Representative, Region VII, Kansas City, Kansas, at (913) 551-7828.

Initial Site Visit Information

Service: U.S. Army
Size: 9,065 acres
Installation Status: Standby
Installation Mission: Manufacturing of propellants

ATSDR Actions:

Initial Site Visit: September 11-13, 1995
ATSDR Site Ranking: E

Persons Met With

Thomas Stutz, Commander's Representative
Ralph Burns, Environmental Office
James Turrentine, Chemical Engineer
Joe Betteken, Alliant Techsystems
Tim Davis, Alliant Techsystems
Charles Jarrett, Alliant Techsystems
Bob Anderson, Alliant Techsystems
Kathleen Buchi, USACHPPM
Steve Wharton, US EPA
Randy Carlson, KDHE


ATSDR health assessors conduct site visits at all hazardous waste sites that are proposed or listedon the Environmental Protection Agency's National Priorities List (NPL), including Departmentof Defense facilities such as SAAP. During the site visits, the health assessors collect availableinformation to be included in the public health assessment (PHA). The information that iscollected documents the nature and extent of contamination, identifies site-related health issuesof concern to the community, and provides insight into the health status of the community.

Because current resources at ATSDR are inadequate to write PHAs for all of the Federalfacilities listed on the NPL, ATSDR has developed an interim site ranking scheme (see theFederal Register, 57 FR 37382, August 18, 1992) as a planning tool to identify facilities that posethe greatest public health hazard. That action ensures that ATSDR's resources can be directed tothe most critical sites first.

Using the interim Site Ranking Scheme, ATSDR assigns points for contaminated media,populations within one mile of the site, possible human exposures, and community healthconcerns. The points are totaled to give sites a single numerical score from 0 to 140 points. The140-point scale is divided into five Site Ranking Categories based on their numerical ranges:Category A - 140-80; Category B - 79-55; Category C - 54-35; Category D - 34-20; and CategoryE - 19-0. The higher the score the greater the relative hazard, and therefore the higher priority in the PHA process.



February 27, 1996

U.S. Department of Health and Human Services
Public Health Service
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Atlanta, Georgia








This health consultation addresses a community concern that beef, from cattle grazed onSunflower Army Ammunition Plant (SFAAP), could be contaminated with harmful levels ofnitroguanidine (NQ) or other chemicals associated with past production activities at this facility.After inspecting site conditions at the SFAAP, considering currently available information aboutthe nature and extent of environmental contamination on the installation, and reviewing pertinentscientific literature, we conclude that uptake of nitroguanidine by beef cattle is unlikely.However, it is not known if other chemicals may be present in grazing areas that couldcontaminate beef. We concur with the Army's proposed plan to sample soil, vegetation, andsurface water in graze lands. If chemicals that are known to bioaccumulate in animals aredetected in grazing areas, sampling of cattle may be needed. Details supporting our conclusions are presented here.


During our initial site scoping visit to the SFAAP in September 1995, we toured the installationand observed cattle grazing areas. Cattle, weighing on average about 500 pounds, graze onSFAAP for approximately 3 months. During that time they gain between 200-300 pounds. Thecattle are then moved to finish pastures or feedlots where they remain until they weigh between1,100-1,200 pounds. Once the cattle reach this optimum weight, they are sold to processingplants.

Much of the plant property is leased for agriculture, and cattle do graze in some areas wherenitroguanidine-containing wastewater was used to irrigate pastures over a two-year period, fromthe fall of 1986 through the fall of 1988. A study was done to evaluate the land treatment systemat SFAAP and to determine the effect of the existing system on the soil and groundwater. Theprocess wastewater contained detectable quantities of the explosive NQ, guanidine nitrate (GN isan intermediate material in the NQ production process), nitrate-nitrogen, sulfates, and low levelsof cadmium, chromium and lead. However, soil samples, from irrigated areas that received thehighest cumulative wastewater loading, contained no accumulation of wastewater constituentsexcept for nitrogen and salinity levels. The levels of nitrogen and salinity detected in these soilsamples would have no effect on cattle that graze in the area. Grasses, which utilize the nitrogenfrom the wastewater, grow more lush. When these grasses decay, the nitrogen is returned to thesoil. Possible effects of increased salinity are plant toxicity and decrease soil permeability. Theconcentrations of metals detected in soils were comparable to background surface soilsNitroguanidine and guanidine nitrate levels in surface soils were also very low (below 2 parts permillion).

Most contamination on SFAAP is associated with areas designated as Solid Waste ManagementUnits (SWMUs). Some of the SWMUs are within grazing areas, but fences keep cattle fromentering these contaminated parcels. Although the dewatered blender ponds (SWMU 13) are notfenced, steep banks and cattle guards at the entrance make it unlikely that cattle would stray intothis area from adjacent grazing land. Moreover, chemical concentrations in background soils areconsistent with levels detected in soils and sludge samples from SWMU 13.

Available information does not suggest that grazing areas on SFAAP would contain significantlevels of chemical contamination. There may be some runoff from SWMUs that could transportcontaminants into adjacent grazing land. The Army is planning additional sampling this year toaddress the concern about grazing areas. They propose sampling of soil and vegetation in thenortheast, central and west grazing areas to determine what type of contaminants, if any, arepresent. The vegetation sampling will provide information about potential uptake ofcontaminants in plants. Analysis will include explosives, metals, polyaromatic hydrocarbons(PAHs), polychlorinated biphenyls (PCBs) and pesticides. Dioxin will also be analyzed insamples from the west grazing area, which is near the burning grounds where dioxin waspreviously detected. And finally, surface water and sediment samples will be collected wherecattle have access to ponds and streams. If chemicals known to concentrate in tissue are presentat concentrations exceeding background levels, sampling of beef cattle may be needed.


Concerns about the safety of consuming meat, primarily from game harvested from contaminatedareas on ammunition plants in the U.S., have prompted a number of biota investigations. Wereview the findings of several of these studies and also provide information concerning thepotential for nitroguanidine uptake in tissue.

Biota Studies:


Biota studies at ammunition plants in the U.S. indicate little or no uptake of explosives in animaltissues. Deer were the target species sampled in all of these studies. These studies evaluatedHMX, RDX, dinitrotoluene (DNT), trinitrotoluene (TNT) and its metabolites (1,3-dinitrobenzene, 1,3,5-trinitrobenzene, 2-A-4,6- dinitrotoluene, and 4-A-2,6-dinitrotoluene). Theexplosives levels in deer meat were at or below the analytical detections limits, and do not pose ahealth threat to people who consume the meat. Although no cattle studies were done, we expectexplosives levels in beef would be comparable to those found in venison since both cattle anddeer are ruminants.

At Badger Army Ammunition Plant (BAAP) in Baraboo, Wisconsin, deer tissues (liver, muscleand heart) were analyzed for dinitrotoluene (DNT). None of the tissues from the 12 deer takenfrom BAAP contained 2,4-DNT or 2,6-DNT at or above the 0.1 part per million (ppm) detectionlimit.

Liver and muscle from deer, quail and rabbit harvested from the Alabama Army AmmunitionPlant were analyzed for TNT and 9 metabolites. None of these tissues contained explosiveslevels above the detection limit of 0.2 ppm.

Deer studies at Joliet Army Ammunition Plant (JAAP), Illinois, address concerns aboutenvironmental contamination in the explosive manufacturing area and the load, assemble andpack (LAP) area. No bioaccumulation of explosives were detected in venison, liver and kidneysfrom deer harvested from JAAP.

Muscle and liver from deer harvested from the Aberdeen Proving Ground and background sitesin Maryland contained no detectable levels of explosives. The analysis included 2,4,6-TNT andits metabolites (1,3-DNB, 1,3,5-TNB, 2-A-4,6-DNT, and 4-A-2,6-DNT), RDX, HMX, 2,4-DNT,and 2,6-DNT.

None of the ammunition plant studies have included analysis for nitroguanidine (NQ) in animaltissue. However, because NQ-containing wastewater was land applied at SFAAP, a laboratorystudy was done to assess effects on local vegetation. There was some evidence that NQ, at leastin soybeans, is absorbed by roots and translocated to the leaves, where it induces chlorosis(growth inhibition and leaf damage) and is metabolized. In the same study it was unclear if therewas uptake of NQ in grasses (tall fescue and smooth bromegrass) because little or no effects wereseen in these plants.

Laboratory studies on the effects of nitroguanidine on animals has also been investigated. Animalexperiments indicate that NQ is unlikely to accumulate in tissue because the chemical is notextensively metabolized. [ pV-2] Experiments in rats given nitroguanidine orally, demonstratedthat virtually 100% of the unmetabolized chemical is excreted in the urine within 48 hours. TheNQ was initially concentrated in the gastrointestinal tract, then distributed in the blood to themajor organs. However, within 48 hours after dosing, less than 0.02% of the administered doseremained in any major organ. [ pV-2] These findings suggest that even if NQ is detected in soilsand/or vegetation in grazing areas on SFAAP, it appears improbable that tissue accumulation inbeef would occur. Because the unmetabolized compound is quickly eliminated in urine,deposition of NQ in meat is not expected, particularly since the cattle are slaughtered monthsafter they grazed on SFAAP.

No studies of health effects of nitroguanidine in humans have been reported in the literature.[pVII-1,] No chronic toxicity or carcinogenicity studies are available for NQ, therefore it isclassified in Group D; Not classified as to human carcinogenicity. [ pXI-1]

Other Chemicals

Some biota studies also evaluated uptake of organochlorine pesticides (DDT, DDD, DDE),polychlorinated biphenyls (PCBs) and metals because these chemicals can be stored in tissues. AtJoliet Army Ammunition Plant, Aberdeen Proving Ground (APG), and respective off-postbackground locations for both sites, no uptake of PCBs or organochlorine pesticides occurred indeer tissues. Arsenic was detected in venison, and in deer liver from APG, in deer harvested fromboth on-post and off-post locations. However, none of the arsenic levels pose a health threat topeople who consume the meat. In a deer study conducted in New Jersey, cadmium levels in liversfrom older deer prompted the issuance of a health advisory. Based on these studies, it appearsthat metals can accumulate in deer tissues; however the levels may or may not pose a health threat.


  1. Nitroguanidine is not expected to accumulate in beef because animal studies indicate thechemical is not extensively metabolized. Moreover, evaluation of the effects of irrigatingpasture land on SFAAP with NQ wastewater demonstrated no accumulation ofconstituents that pose an uptake concern in cattle.

  2. Numerous biota studies demonstrate that uptake of explosives in animal tissue,particularly deer, does not occur. Because deer and cattle are both ruminants they havesimilar metabolic processes; therefore, it is equally unlikely for cattle to accumulateexplosives in their tissues.

  3. Studies have shown that some uptake of metals in deer does occur. At SFAAP, the NQwastewater used to irrigate pasture land contained detectable levels of cadmium,chromium and lead. However, the metals concentrations in soil samples from irrigatedareas are comparable to background levels of metals in soil, which do not pose a healththreat.

  4. We concur with the Army's proposed sampling plan to analyze explosives, metals, PAHs,PCBs, pesticides and dioxin levels in surface soils, vegetation and surface water ingrazing areas on SFAAP. If chemicals known to bioaccumulate in animal tissue aredetected in grazing areas, and they occur at levels consistently above backgroundconcentrations, the Army should sample cattle that graze in those areas of the plant.

If further clarification is needed or if additional information becomes available for review, please do not hesitate to contact this office at 404-639-6070.

Lorna L. Bozeman, M.S.


  1. Parker MS. Letter to Secretary Glickman, Department of Agriculture regarding possiblecontamination of beef cattle grazed on Sunflower Army Ammunition Plant, DeSoto,Kansas. April 20, 1995.

  2. Burns & McDonnell. Memorandum from Dennis Degner, Burns & McDonnell to DonMeier, CEMRK-EP-EC concerning Field Sampling Plan for Grazing Study. January 8,1996.

  3. Burns & McDonnell. Letter from Dennis Degner, Burns & McDonnell to Ralph Burns,Sunflower Army Ammunition Plant concerning Summary of Recommended SamplingStrategy for the Grazing Study. January 17, 1996.

  4. Swanson JK. Memorandum for Record, Subject: Jack Meyers Stocker and Feeder CattleOperation on Sunflower Army Ammunition Plant. Department of the Army, SunflowerArmy Ammunition Plant. June 12, 1995.

  5. US Army Environmental Hygiene Agency. Final Report, Water Quality EngineeringStudy No. 32-24-0820-89, Land Treatment System Evaluation, Sunflower ArmyAmmunition Plant, DeSoto, Kansas. May 9-21, 1988.

  6. U.S. Environmental Protection Agency, Criteria and Standards Division, Office ofDrinking Water. Health Advisory for Nitroguanidine (NQ). May 1990.

  7. Law Environmental, Inc. Data Summary Tables - Background Surface Soils and SWMU13 Subsurface Soils and Sludge - Sunflower Army Ammunition Plant, DeSoto, Kansas.January and August 1995.

  8. Shugart LR. Dinitrotoluene in Deer Tissues, Final Report. Environmental SciencesDivision, Oak Ridge National Laboratory. September 30, 1991.

  9. Shugart LR, Griest WH, Tan E, Guizman C, Caton JE, Ho CH and Tomkins BA. TNTMetabolites in Animal Tissues, Oak Ridge National Laboratory Final Report. ORNL/M-1336, December 1990.

  10. U.S. Army Environmental Hygiene Agency. Draft Final Health Risk Assessment fromConsumption of Deer Muscle and Liver from Joliet Army Ammunition Plant. January 14,1994.

  11. U.S. Army Center for Health Promotion and Preventive Medicine. Draft Field Study No.75-23-YS50-94, Health Risk Assessment of Consuming Deer from Aberdeen ProvingGround, Maryland. October 1994.

  12. Burrows EP. Environmental Microbiology and Effects of Nitroguanidine (NQ) onPhysiology of Plants. Proceedings for the 13th Annual Environmental Quality R & DSymposium, Williamsburg, Virginia. Hosted by U.S. Army Toxic and HazardousMaterials Agency. November 15-17, 1988.

  13. Literature Review for Nitroguanidine. National Technical Information System. July 19,1995.

  14. Stanley W, Roscoe DE and Hazen HE. Cadmium Contamination of Deer Livers in NewJersey: Human Health Risk Assessment. The Science of the Total Environment 107:71-82. 1991.


CREG: Cancer Risk Evaluation Guide, a highly conservative value that would be expected to cause no more than one excess cancer in a million persons exposed over time.
DWEL: Drinking Water Equivalency Level, a lifetime exposure level at which adverse, noncarcinogenic health effects would not be expected to occur.
EMEG: Environmental Media Evaluation Guide, a media-specific comparison value that is used to select contaminants of concern. Levels below the EMEG are not expected to cause adverse noncarcinogenic health effects.
LTHA: Lifetime Health Advisory is the concentration of a chemical in drinking water that is not expected to cause any adverse noncarcinogenic health effects for a lifetime of exposure.
MCL: Maximum Contaminant Level, the enforceable drinking water regulation that is protective of public health over a lifetime at an exposure rate of 2 liters of water per day.
RBC: Risk-based Concentration, a contaminant concentration that is not expected to cause adverse health effects over long-term exposure.
RMEG: Reference Dose Media Evaluation Guide, a lifetime exposure level at which adverse, noncarcinogenic health effects would not be expected to occur.
SMCL: Secondary Maximum Contaminant Level, a non-enforceable guideline that regulates contaminants that may cause cosmetic or aesthetic effects in drinking water.
SSL: Soil Screening Level, an estimate of a contaminant concentration that would not be expected to cause noncancerous health effects over a specified duration of exposure or to cause less than one excess cancer in a million (10-6) persons exposed over a 70-year life span.


Acute Exposure:
Contact with a chemical that happens once or only for a limited period of time. ATSDR defines acute exposures as those that might last up to 14 days.

Adverse Health Effect:
A change in body function or the structures of cells that can lead to disease or health problems.

The Agency for Toxic Substances and Disease Registry. ATSDR is a federal health agency in Atlanta, Georgia that deals with hazardous substance and waste site issues. ATSDR gives people information about harmful chemicals in their environment and tells people how to protect themselves from coming into contact with chemicals.

Background Level:
An average or expected amount of a chemical in a specific environment. Or, amounts of chemicals that occur naturally in a specific-environment.

Used in public health, things that humans would eat - including animals, fish and plants.

A group of diseases which occur when cells in the body become abnormal and grow, or multiply, out of control

Any substance shown to cause tumors or cancer in experimental studies.

Chronic Exposure:
A contact with a substance or chemical that happens over a long period of time. ATSDR considers exposures of more than one year to be chronic.

Comparison Value (CVs):
Concentrations or the amount of substances in air, water, food, and soil that are unlikely, upon exposure, to cause adverse health effects. Comparison values are used by health assessors to select which substances and environmental media (air, water, food and soil) need additional evaluation while health concerns or effects are investigated.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):
CERCLA was put into place in 1980. It is also known as Superfund. This act concerns releases of hazardous substances into the environment, and the cleanup of these substances and hazardous waste sites. ATSDR was created by this act and is responsible for looking into the health issues related to hazardous waste sites.

A belief or worry that chemicals in the environment might cause harm to people.

How much or the amount of a substance present in a certain amount of soil, water, air, or food.

Dermal Contact:
A chemical getting onto your skin. (see Route of Exposure).

The amount of a substance to which a person may be exposed, usually on a daily basis. Dose is often explained as "amount of substance(s) per body weight per day".

The amount of time (days, months, years) that a person is exposed to a chemical.

Environmental Contaminant:
A substance (chemical) that gets into a system (person, animal, or the environment) in amounts higher than that found in Background Level, or what would be expected.

Environmental Media:
Usually refers to the air, water, and soil in which chemicals of interest are found. Sometimes refers to the plants and animals that are eaten by humans. Environmental Media is the second part of an Exposure Pathway.

U.S. Environmental Protection Agency (EPA):
The federal agency that develops and enforces environmental laws to protect the environment and the public's health.

The study of the different factors that determine how often, in how many people, and in which people will disease occur.

Coming into contact with a chemical substance.(For the three ways people can come in contact with substances, see Route of Exposure.)

Exposure Assessment:
The process of finding the ways people come in contact with chemicals, how often and how long they come in contact with chemicals, and the amounts of chemicals with which they come in contact.

Exposure Pathway:
A description of the way that a chemical moves from its source (where it began) to where and how people can come into contact with (or get exposed to) the chemical.

ATSDR defines an exposure pathway as having 5 parts:

  1. Source of Contamination,
  2. Environmental Media and Transport Mechanism,
  3. Point of Exposure,
  4. Route of Exposure, and
  5. Receptor Population.

When all 5 parts of an exposure pathway are present, it is called a Completed Exposure Pathway. Each of these 5 terms is defined in this Glossary.

How often a person is exposed to a chemical over time; for example, every day, once a week, twice a month.

Hazardous Waste:
Substances that have been released or thrown away into the environment and, under certain conditions, could be harmful to people who come into contact with them.

Health Effect:
ATSDR deals only with Adverse Health Effects (see definition in this Glossary).

Indeterminate Public Health Hazard:
The category is used in Public Health Assessment documents for sites where important information is lacking (missing or has not yet been gathered) about site-related chemical exposures.

Swallowing something, as in eating or drinking. It is a way a chemical can enter your body (See Route of Exposure).

Breathing. It is a way a chemical can enter your body (See Route of Exposure).

Metal-bearing Wastes:
Wastes and/or used materials that contain significant quantities of metal pollutants, but not significant quantities of oil and grease (generally less than 100 ppb), from manufacturing or processing facilities or other commercial operations. Examples of these wastes are: spent electroplating baths and sludges, metal finishing rinse water and sludges, chromate wastes, air pollution control blow down water and sludges, spent anodizing solutions, incineration air pollution control waste waters, waste liquid mercury, cyanide containing wastes greater than 136 ppb, and waste acids and bases with or without metals.

Minimal Risk Level. An estimate of daily human exposure - by a specified route and length of time -- to a dose of chemical that is expected to be without a measurable risk of adverse, noncancerous effects. An MRL should not be used as a predictor of adverse health effects.

The National Priorities List. (Which is part of Superfund.) A list kept by the U.S. Environmental Protection Agency (EPA) of the most serious, uncontrolled or abandoned hazardous waste sites in the country. An NPL site needs to be cleaned up or is being looked at to see if people can be exposed to chemicals from the site.

No Apparent Public Health Hazard:
The category is used in ATSDR's Public Health Assessment documents for sites where exposure to site-related chemicals may have occurred in the past or is still occurring but the exposures are not at levels expected to cause adverse health effects.

No Public Health Hazard:
The category is used in ATSDR's Public Health Assessment documents for sites where there is evidence of an absence of exposure to site-related chemicals.

Oily Wastes:
Wastes and/or used materials that contain oil and grease (generally at or in excess of 100 ppb), from manufacturing or processing facilities or other commercial operations. Examples of these wastes are: used oils, oil-water emulsions or mixtures, lubricants, coolants, contaminated groundwater clean-up from petroleum sources, used petroleum products, oil spill clean-up, bilge water, rinse/wash waters from petroleum sources, interceptor wastes, off-specification fuels, underground storage remediation waste, and tank clean out from petroleum or oily sources.

Organic Wastes:
Wastes and/or used materials that contain organic pollutants, but not significant quantities of oil and grease (generally less than 100 ppb), from manufacturing or processing facilities or other commercial operations. Examples of these wastes are: landfill leachate, contaminated groundwater clean-up from non-petroleum sources, solvent-bearing wastes, off-specification organic product, still bottoms, used glycols, wastewater from paint washes, wastewater from adhesives and/or epoxies, wastewater from chemical product operations, and tank clean-out from organic non-petroleum sources.

A line or column of air or water containing chemicals moving from the source to areas further away. A plume can be a column or clouds of smoke from a chimney or contaminated underground water sources or contaminated surface water (such as lakes, ponds and streams).

Point of Exposure:
The place where someone can come into contact with a contaminated environmental medium (air, water, food or soil). For examples: the area of a playground that has contaminated dirt, a contaminated spring used for drinking water, the location where fruits or vegetables are grown in contaminated soil, or the backyard area where someone might breathe contaminated air.

A group of people living in a certain area; or the number of people in a certain area.

Public Health Assessment(s):
Public Health Assessment. A report or document that looks at chemicals at a hazardous waste site and tells if people could be harmed from coming into contact with those chemicals. The PHA also tells if possible further public health actions are needed.

Public Health Hazard:
The category is used in PHAs for sites that have certain physical features or evidence of chronic, site-related chemical exposure that could result in adverse health effects.

Public Health Hazard Criteria:
PHA categories given to a site which tell whether people could be harmed by conditions present at the site. Each are defined in the Glossary. The categories are:

  1. Urgent Public Health Hazard
  2. Public Health Hazard
  3. Indeterminate Public Health Hazard
  4. No Apparent Public Health Hazard
  5. No Public Health Hazard

Receptor Population:
People who live or work in the path of one or more chemicals, and who could come into contact with them (See Exposure Pathway).

Route of Exposure:
The way a chemical can get into a person's body. There are three exposure routes:
- breathing (also called inhalation),
- eating or drinking (also called ingestion), and
- or getting something on the skin (also called dermal contact).
Source (of Contamination):
The place where a chemical comes from, such as a landfill, pond, creek, incinerator, tank, or drum. Contaminant source is the first part of an Exposure Pathway.

Harmful. Any substance or chemical can be toxic at a certain dose (amount). The dose is what determines the potential harm of a chemical and whether it would cause someone to get sick.

The study of the harmful effects of chemicals on humans or animals.

Abnormal growth of tissue or cells that have formed a lump or mass.

Urgent Public Health Hazard:
This category is used in ATSDR's Public Health Assessment documents for sites that have certain physical features or evidence of short-term (less than 1 year), site-related chemical exposure that could result in adverse health effects and require quick intervention to stop people from being exposed.


Click here to view Appendix D Part 1 in PDF format (PDF, 229KB)

Click here to view Appendix D Part 2 in PDF format (PDF, 501KB)


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The Agency for Toxic Substances and Disease Registry (ATSDR) received the followingcomments during the public comment period (September 19 to November 26, 2001) for theSunflower Army Ammunition Plant (SFAAP) Public Health Assessment (PHA) (September2001). For comments that questioned the validity of statements made in the PHA, ATSDRverified or corrected the statements. The list of comments does not include editorial comments, such as word spelling or sentence syntax.

  1. Comment: Fish sample data are available for Kill Creek, just south of DeSoto and downstream from SFAAP, on EPA's STORET database.
  2. Response: Thank you for the information. ATSDR downloaded the data and incorporatedit into the PHA (please see the exposure from eating fish from Kill Creek or Captain Creeksection).

  3. Comment: The Wonderful World of Oz theme park is no longer being considered for development at SFAAP.
  4. Response: Thank you for the information. Reference to the proposed sale of SFAAP to OzEntertainment has been changed in the PHA.

  5. Comment: More people have worked inside SFAAP than have been exposed from livingoff the plant. Should there be some consideration for present and former SFAAP employeesin the health assessment?
  6. Response: ATSDR was created in 1980 to protect the public from hazardous wastes andenvironmental releases. This mission excludes consideration of workers exposed tochemicals used in the normal course of their employment. Instead, the health of workers isprotected under the Occupational Safety and Health Act, which Congress passed in 1970.This act requires that employers provide "employment and a place of employment whichare free from recognized hazards that are causing or are likely to cause death or seriousphysical harm to employees" (section 5(a)(1)). To enforce the new legislation, the actcreated three government entities dedicated to protecting workers: Occupational Safety andHealth Administration (OSHA), National Institute of Occupational Safety and Health(NIOSH), and the Occupational Safety and Health Review Commission (OSHRC). OSHAsets and enforces standards and regulations to prevent injury or harm to workers at theirjob. This includes setting standards for exposures to chemicals and regulations forproviding workers with the proper equipment to protect themselves, such as respirators.OSHA regulations must be followed or the employer can be assessed fines. NIOSH gathersand analyzes information about injuries and illnesses in the workplace and recommendsstandards to OSHA. OSHRC is the entity that settles disputes arising from enforcement ofOSHA regulations. As required, the Army and contractors at SFAAP follow OSHAstandards and guidelines to protect their worker population.

  7. Comment: Should exposure to dioxins be addressed in the Cattle Grazing Concern?
  8. Response: ATSDR has updated this community concern to include a discussion specificfor dioxin exposure from consuming beef from cattle grazed at SFAAP. Dioxins were oneof several families of chemicals evaluated during the grazing study by the Department ofDefense (Burns & McDonnell 2002). ATSDR reviewed the sampling and analysisprocedures, the methods used to evaluate exposure, and the results of the grazing study inaddition to the toxicologic literature for dioxins and agrees that dioxins are not expected tobe at levels that would produce adverse health effects in people consuming beef from cattlegrazed at SFAAP.

  9. Comment: SFAAP management is faced with a serious dilemma given that explosiveresidues contaminate some of their structures, making asbestos and lead removal byhumans impractical, if not dangerous. Should published robotic techniques (Oak RidgeNational Laboratory) be investigated for use in removing the asbestos- and lead-contaminated structures given that SFAAP management has dual concerns of workerssafety versus community impacts?
  10. Response: Whenever safe to do so, lead and/or asbestos were removed by conventionalmethods from the buildings prior to ignition. These methods insure that any remaining leadand asbestos-containing materials are minimal in volume (KU 2001). In addition, controlsystems (e.g., strict meteorological conditions, water curtains, fire retardant, and closemonitoring by personnel) were used to limit deposition of lead- and asbestos-containingmaterials to the site. The Department of the Army (Army) and the U.S. Army IndustrialOperations Command, the authorities for the removal response actions, could best answerquestions regarding the use of robotic techniques at SFAAP.

  11. Comment: In 1997, the SFAAP's consultants conducted tethered balloon air sampling forthree burns which guided the construction of computer models that would be used forhundreds of subsequent building burns. No quality assurance program was found to beinstituted that would demonstrate the similarity between the original three burns and themany that followed. When various explosions occurred, no new data were collected. Usingdispersion models would be infeasible because 'steady-state' conditions cannot besatisfied.
  12. Response: If the results from the test burns had shown that asbestos and/or lead were atconcentrations of concern downwind from the site, further sampling would have beenconducted during future open burns (CHPPM 1997). However, because asbestos was neverdetected and lead was not detected at levels of concern at the fenceline, the U.S.Environmental Protection Agency (EPA) and the Kansas Department of Health andEnvironment (KDHE) were in agreement with the Army that further sampling was notwarranted. The buildings that were chosen for the test burns represented worst-casescenarios for lead and asbestos contamination. In addition, most of the buildings were ofsimilar design, structure, and build (personal communication with SpecPro representative,2/8/02). Therefore, while there was no formal quality assurance program, the sampling thatwas conducted at the three test burns was determined to adequately represent the conditionsof future open burnings.

    There were incidences where debris from the open burnings was transported off site (e.g.,when buildings not slated to be burned caught fire as a result of an explosion at thecontrolled burn and when the water curtain pump failed). In these instances SFAAP andAlliant Techsystems met with KDHE to discuss the issue of potential lead and asbestosreleases and implemented measures to prevent these kinds of events from occurring again(e.g., the wind speed and air stability criteria were adjusted to be more conservative and abackup pump system was installed) [KDHE 2001a, 2001b].

  13. The effectiveness of the fire containment devices, although commendable, is largelyundocumented.
  14. Response: While the effectiveness of fire containment devices to contain ash and debrishas not been documented specifically for SFAAP, the methods employed by SFAAP (e.g.,strict meteorological conditions, water curtains, fire retardant) are commonly used,recommended practices for containing airborne particles. Several regulators (EPA andKDHE) and experts in the fields of atmospheric science and meteorology developed thesemethods to be effective in minimizing impacts to the neighboring community. Theseexperts determined that (1) burning under strict meteorological conditions favorsdeposition of material on SFAAP property and disperses the smoke plume quickly, (2) theuse of water curtains limit material suspension and localize material deposition bydecreasing the plume's buoyancy and by removing suspended particles from the plume,and (3) fire retardants promote a high temperature burn that incinerates many of thesuspended particles (KU 2001; personal communications with KDHE representative and aCertified Consulting Meteorologist, 2/14/02).

  15. Comment: Various citizens have deposition samples of asbestos materials from theirproperties which they believe have originated from various test burns. No reference eversuggests the preference of modeling over actual samples. The citizen groups should not berequired to conduct air or other sampling to prove their point; the presence of asbestos in their yards is prima facie evidence of contamination.
  16. Response: In August 2001, KDHE responded to residents' concerns that lead and asbestoshave been deposited on their properties during open burnings at SFAAP by proposing toconduct an initial biased sampling of debris, visible waste, and other areas in yards nearestto or directly adjacent to SFAAP. They projected that the sampling area will be expandedto encompass additional impacted areas if the initial sampling indicates a potential impactto residential yards (KDHE 2001d). However, the residents declined to have their soilsampled (personal communication with KDHE representative, 12/01).

  17. Comment: A proper risk assessment should be performed to determine whether thedeposited asbestos levels are of any health significance. Because of its refractoryproperties, asbestos can be considered as representative of other airborne volatile andsemi-volatile materials to which people were exposed.
  18. Response: If soil samples are obtained by KDHE (mentioned above), then ATSDR canevaluate the levels of asbestos and lead (if any) that are present in soil of their yards fortheir potential to adversely affect public health.

  19. Comment: The U.S. Army Corps of Engineers (USACE) has been instrumental inreviewing solid waste management data, however, USACE approvals for the burns eitherfrom the standpoint of worker safety or the general public is lacking. Generally, USACEenjoys a good reputation for risk assessments and is the appropriate entity within theDepartment of the Army for advanced technical review. The Resource ConservationRecovery Act (solid waste management unit) data are probably in much better shape thanthe burn data.
  20. Response: The U.S. Army Center for Health Promotion and Preventative Medicine(CHPPM) helped to develop the sampling strategy and participated in the ambient airsampling efforts at SFAAP. In addition, EPA and KDHE provided review and oversight.The aerial sampling events followed procedures established by the American NationalStandards, Specifications, and Guidelines for Quality System for Environmental DataCollection and Environmental Technology Programs. The project was managed by tworegistered Environmental Professional Engineers, with a combined experience of over 65years, who developed the model that established criteria for wind speed, wind direction,and air stability to prevent asbestos-containing material from leaving the boundaries of theplant during a building burn. Quality assurance and quality control (QA/QC) was overseenby a certified physical engineer who for seven years was Director of MonitoringSystems/Quality Assurance at EPA Headquarters (EnviroVisions 1997).

  21. Comment: Very little data currently exist regarding sensitive populations potentiallyexposed to levels of airborne asbestos or lead near the SFAAP burns. ATSDR has askedfor comments about health problems but has itself conducted no epidemiologic study.There is a clear lack of agreement concerning burn data. Thus, it would be difficult for aclinician to reasonably comment on etiology in the case of asbestosis for an adult or anelevated blood lead level in a child. No physicians were found to have evaluated the healthconclusions associated with the SFAAP-based studies. Perhaps ATSDR could provide ahelpful clinician to assist discussions in public meetings: reasonably, this person could beeither a physician or a nurse epidemiologist. The addition of USACE scientists and anATSDR epidemiologist would go a long way to satisfying public concerns. As things nowstand, the health impacts of the burns are unknown.
  22. Response: ATSDR evaluated the currently available air sampling data and determined thatenough information existed to conclude that when proper burning procedures are followed,the people who live around SFAAP (including sensitive persons) are not being exposed toharmful levels of airborne asbestos or lead generated during the open burning. Please seethe discussion on the Air Pathway for more details.

    One of the purposes of the public health assessment process is to identify future actions toprevent adverse human health effects resulting from exposure to hazardous substances inthe environment. However, the available information does not indicate that the openburnings are causing exposures that could result in adverse health effects among thecommunity. Without documentation of the existence of an exposed population, the designof an epidemiological study is not appropriate.

  23. Comment: Not all relevant data, particularly regarding hazardous materials leaving theSunflower site during burning procedures, has been considered. We therefore call intoquestion the conclusions based on apparent incomplete data, and request ATSDR toconsider all relevant data and carefully reconsider its conclusions regarding the past,current, and future impact on health of people who live and work in the community fromreleases of environmental contaminants from SFAAP. We request ATSDR to re-examinedata and conclusions regarding asbestos (and lead) leaving the site, the healthimplications of the wells near the site, and the health impact of consumption of meatproducts from animals grazing on the site.
  24. Response: ATSDR drew its conclusions based on the currently available data, our bestprofessional judgement, and a conservative evaluation process. ATSDR determiend thatadequate information was available to support the conclusions. If additional data becomeavailable that could suggest potential exposure, then if requested, ATSDR can evaluate this new information.

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