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Public Comments and Responses

The Memphis Defense Depot Public Health Assessment (PHA) was available for public review and comment at 4 locations in Memphis, Tennessee. These were the Cherokee Branch (3300 Sharpe Avenue) and Main Branch (1850 Peabody) of the Memphis/Shelby County Public Library, the Memphis/Shelby County Health Department (814 Jefferson Avenue), and Memphis Depot (2163 Airways Boulevard) from December 27, 1999 to March 31, 2000. The public comment period was announced in local newspapers and through a notice send to over 4,500 residents around the Memphis Depot. The notice indicated that a copy of the PHA could be obtained by calling a toll-free number.

The PHA was sent to over 100 individuals or agencies including representatives of all the neighborhood organizations in the DDMT area including DDMT-CCC, all the members of the DDMT Restoration Advisory Board (RAB), and over 30 area residents not associated with any organization. Documents were also sent to 9 local, state, or federal elected officials; the Congress of National Black Churches; and Howard University. The following local, state, or federal agencies were given copies: Memphis Shelby County Health Department, the Tennessee Departments of Environmental Conservation and Health, National Center for Health Statistics (NCHS), U.S. Environmental Protection Agency (EPA), DDMT, Defense Logistics Agency (DLA), and Department of Defense (DOD).

Sixty-five comments on the PHA were received verbally in 2 meetings at the South Memphis Senior Center, 1620 Marjorie in Memphis on February 24, 2000. Comments were also receiving in writing from one private citizen (1), Howard University (15 comments), the Depot Redevelopment Corporation of Memphis and Shelby County [DRC] (4 comments), the Tennessee Department of Environment and Conservation [TDEC] (8 comments) and the Department of Defense [DOD](94 comments). The 170+ comments received and ATSDR's responses to them are described in the following pages. The comments from the public can be found on pages 102 to 148, Howard University on pages 149 to 153, DRC on pages 154 to 155, TDEC on pages 156 to 158, and DOD on pages 159 to 192.

Comments on Working Draft of Final Release of Memphis Depot Public Health Assessement

In late September 2000, the working draft of the Final Release of Memphis Depot Public Health Assessment was distributed to those individuals or agencies who commented on the public comment release of the public health assessment (PHA), attended the February meetings at which the Agency for Toxic Substances and Disease Registry (ATSDR) received public comments on the PHA, or who had a long time involvement with the site. Comments were received only from the Department of Defense. These 13 comments and ATSDR's responses can be found on pages 192 to 195.

Comments Received During Two Public Meetings
On February 24, 2000

The comments in this section were received during two public meetings at the South Memphis Senior Center on February 24, 2000. A court reporter transcribed the comments word for word. The transcripts of these two meetings were edited for this document to focus on the actual comments on the Public Health Assessment. The names of those making comments have been deleted from this document. In editing the comments, some text has added to facilitate the understanding of the comment. These additions are indicated by italics.

During the afternoon meeting, there was the opportunity to provide responses to the comments during the meeting. At least a partial response was given during the meeting. These responses were transcribed and are presented here. Editorial additions to or explanations about comments are indicated in italics. Places where text from the original transcript was deleted are identified by a series of periods like this .... At the evening meeting on February 24, 2000, there was only an limited opportunity for responding to comments because many of the participants choose to leave once they had given their comments. The responses given during this meeting are presented in regular type and the responses written after the meeting are in italics.

Copies of the full transcripts of these meetings are available by contacting John Crellin at 1-888-42-ATSDR (1-888-422-8737), 404-639-0635, or You can write him at ATSDR/DHAC; 1600 Clifton Road; Mail Stop E32; Atlanta, GA 30333.

Comments from the 1 - 3 PM Session on February 24, 2000

1) I am an ex-employee at the Defense Depot. There were several times that warehouses were exposed to the soil and the dirt accumulated over a period of years and it was never disturbed until the last five years when all of the material was being moved. Now, if a person was working in this environment where this dirt had sat and accumulated for a period of 25 or 30 years and then now they are in there for about maybe three years moving this material, is there a possibility, since this dirt has accumulated for so long, that they can reach some kind of contamination?


I didn't have data that would directly address your question. I would need to know what was on that specific stock that was shipped to be able to address your concern and tell you what possible health problems could have been from those levels. And clearly, .... those levels could have been higher than what we found in the soil outside....As discussed starting on page 82, the known concentrations of contaminants in soil on the DDMT Main Facility and Dunn Field were not great enough, given the known exposures, to have resulted in health effects.

2) I understand that according to the best science available, it only goes back to 1989. ...... Now, you've got people that worked over there, bought their homes, raised their families. Is there any kind of way to send a survey out to them concerning maybe the amount of cancer incidence in their family that can be responded to and incorporated into in this study? ..... it would be an effort to show people in the neighborhood that you are trying to give them an opportunity to have a voice in this survey.


...We basically need contaminant data to evaluate whether people could be exposed to site contaminants and whether that exposure could result in health effects... That's why I say that before 1989, we can't make any conclusions whether site contaminants could have caused harm. We need contaminant type of information to be able to make that -- look at pathways and see contaminants in the pathway and be able to trace it back to the Depot...

3) In reference to the survey mentioned by the last speaker, I would like to have incorporated in the document the title and the location of that survey. I have been looking for that survey. I'm not aware that the Memphis/Shelby County Health Department ever completed the survey. I request that I be provided a copy of this survey. Another participant indicated he would like to receive a copy of this survey.


...I will see that you get a copy of it. It was provided to me, and I will provide it to you or anybody else that wants to look at it. The thing about this document is ... that it is essentially a survey of attitudes. It's not a survey of specific health concerns. It basically was asking people, "Are you concerned about the site, are you not concerned about the site, are you getting enough information about the site, do you know enough, do you need to know more." ... The purpose of the survey was basically to aid the Health Department in designing a program to better inform people who lived in the area. These participants were provided copies of this survey on March 16, 2000.

4) ...I have looked at the survey (the speaker was referring to the public health assessment) in detail, and this is one of the -- I guess I am going with an earlier speaker on this, and it's a legitimate and valid problem with the whole study, especially as it concerns the cancer incidence review referenced in the public health assessment. You are going from '90 to '96, and this does not include the years from, what -- when did the Depot start, '40 or '42. So, in essence if you are using a sample between '90 and '96 and excluding all the preceding years, this in essence is not a legitimate or a valid study.


... There's a separate document that will be coming out shortly that looks specifically in detail at the cancer incidence data and I showed you-all the area that data was from -- that we looked at -- we looked at all of the available data, cancer incidence data that was available, and that was only from 1990 to 1996.... It doesn't give ....the Depot a clean bill of health. And frankly, it doesn't really apply to the Depot or any exposure. All it does is say that cancer for this time period for this specific area ... does not appear to be excessive but it doesn't address ... whether there could be an excess of ... cancer ... along Elliston or other specific locations.... Because the data available to us had as evaluated a population of ... 30,000 people and not any smallest population groups, it may not have not been possible to pick up ... specific clusters. I will revise the public health assessment ... to make that clearer ....The public health assessment was revised to address this concern. Go to page 32 to see the revised section.

5) I represent the Defense Logistics Agency who operates the Depot. We have received copies of the documents during the same period of time as the rest of the public. We are reviewing them. Like a lot of the public, we appreciate the extension on the comment period date because we would like to provide comments to the Agency for Toxic Substances and Disease Registry...



6) Since there seems to be a concern about this document, why was there not any extra documents made available so when people come through the door, they can be given a copy as they walk in. And I would like to see this document made more readily available to those people sacrificing their time to come to these public meetings because I believe repositories are nice and libraries are nice and somebody would come up here to see a slide show, it would be nice if they had a document to follow up with the slide show.... But I would like if you have any extra documents that you brought from Atlanta to just be distributed to these people today if they care to have one, so that when they come, they will leave with something rather than having to go to the repository or library or anywhere else. In the future, I would like to have some of these documents. If cost is prohibitive, just stop me now.


(Response given to meeting participants) All you have to do is put a star by your name or say you would like a copy on the attendee list and we will mail you out one in a couple of days. The reason why we didn't bring a bunch of copies is basically ... that we didn't know how many people were going to show up. The copies that ATSDR staff had with them were passed out to meeting participants.

... An invitation to this meeting went to over 4500 people and in it ... people were notified that the document was available for comment... There was a toll free number in that invitation ... for them to request a copy. ....Only 11 requests were received for the document. .... Also, ... if you have questions or comments after the meeting is over, ... you can contact us ... using the toll free number (1-888-422-8737) to contact us.

7) ...If you have questions that you feel need to be addressed by them formally, you probably do need to get that on the record and -- am I clear on this, that if it's asked after this meeting is over with, it will not be addressed formally?


We will try to provide a response today to any question asked or comments made during this meeting. The official response to all questions or comments made today or any received before the comment period ends on March 31, 2000 will come when we make our official response to it. I will respond today the best I can, but in the ATSDR, as any bureaucracy, we go through a review process where the response becomes that of the agency and not any single individual's opinion. .... When the next version of this document comes out, it ... will have ATSDR's responses to the comments.... The document will be changed based on what you say.

8) I have lived right by the Tarrent Branch drainage .... that runs the water from the Defense Depot for about 35 years. And sometimes it would just float in my yard. Could I have been exposed? Also I have lupus. Could that have been caused by contaminants from the Depot?


Part of the problem regarding your question about exposure is we don't know what the levels were onsite .... when your yard was being floated, nor do we know what they were offsite..... We can say -- based on the levels that we know about, basically 1989 on, that the levels were/are .... not high enough to cause you harm. However, ... I don't know what took place 35 years ago and especially when -- before the ditches were lined and the fence was there. Obviously if it flowed into your yard or whatever, we don't know what the levels were or how high or whether they could have caused you harm.

Regarding ... Lupus, ... the scientific data is kind of shaky over whether chemicals can cause it .... I will be frank about it, that I know personally, and I have looked into this personally because my wife has Lupus.

9) (This is the same individual as in comment 8) But I just know that everybody that lived on Elliston, one out of the family has died with cancer, all up and down from Perry back to Bellevue. There's one person or two out of their family is dead, had cancer. I do know that.


.... our goal in the health assessment is to look at data about the site, you know, the contaminant data and see if that connects back to whether or not those levels can cause harm. The problem with your concerns is that ... if we can't connect the site to a concern about excess cancer like you have reported, basically our process and our responsibility as an agency ends. Your concern is one that ... is more appropriately addressed by the State Health Department and the County Health Department... ATSDR along with several area residents has talked with the Tennessee Department of Health (TDH) about the issue of excess cancer in the area around the Memphis Depot. TDH is currently evaluated whether anything can be done to investigate concerns as reported in this comment.

... Unfortunately, ... one out of every three people will have cancer sometime in their life. Most of that occurs when people are 55 or older. .... So they need to look at that specifically and see whether what you observed over the time period that you are speaking of is actually in excess ....

10) (This is the same commenter as in #s 8 & 9.) Well, actually my daughter first came down with Lupus and then I got it. Could we have been exposed to something from it coming over there, because they would turn that water loose and it would just float in my yard a lot of the time.


Again, the evidence on Lupus as far as whether any chemical can cause it is not particularly good.... Mostly with Lupus they don't know what causes it. It's something that is much more common in women than it is in men. It is something that is more common in African-Americans than it is in whites.... We don't know why that is occurring. Also it tends to occur in people in their 30's and it's much less common ... in people that are older than that. That's about all we know about it. Unfortunately, there's a lot more unknown than known.

11) This commenter related this quote from the last paragraph of page 20 of the public health assessment. "Exposure pathways analyses indicate that limited exposure to site contaminants may have occurred through water-borne transport to two areas other than the Rozelle neighborhood. These areas are 1) south of the southeast corner of the Main Facility to the yards on either side of Tarrent Branch, which flows from the west edge of the Main Facility. The number of individuals in these residential areas around the DDMT that could have been exposed is between 500 and 3,000 people." Is there any kind of way to send a survey to them, because the science is not in on these people yet, and incorporate everybody else into that survey?


... Our agency is driven by exposure which is the reason why in the document we are proposing to do an exposure investigation where we actually go out and sample the soil... What we are proposing on doing in the Tarrent Branch area .... is to sample the soil right around the ditch just offsite.... If we found... levels of health concern in those samples, then additional sampling would be done by us or more likely by EPA or DDMT.... once we started identifying the extent of contamination... then we would start doing surveys, health studies, or related investigations that would identify possible site-related health effects.

12) I live on Mallory and have been there 37 years.... Is the only kind of disease you can have from this chemical is cancer?


No. The different chemicals that are onsite can cause a wide variety of things if you were exposed to them....

13) (This is the same individual as in #12) What about a rash, a rash, just break out, you know, you itch a lot. What about that?


It depends on which chemical. Some of them that were on the site -- I would have to look back and get a list of them or whatever -- may cause ... rashes. Usually with rashes you have to be exposed to quite a bit, either you get it on your skin or you would have had to have ingested it.... With some chemicals, if you ingest quite a bit into your body, you become sensitized to it and then just getting a little bit on your skin can cause you to break out in rashes. Again, usually you have to start out with high exposure.... The levels that ... have been found on the site, even if you worked there, wouldn't be high enough ... to cause rashes.

14) On page 35 of the public health assessment it is stated that contaminants buried on Dunn Field have polluted the Fluvial aquifer under and to the west and the north tip of Dunn Field. It is also that stated that a small portion of the shallow aquifer under the Main Facility is contaminated.... Could you tell us the pattern and the depth of this contamination; like is it flowing north, south or east or west ...?


I will have to research this issue and will put it in ... the next version of the public health assessment. Information on the groundwater contamination on and near the Main Facility has been added to the discussion of the groundwater exposure pathway on page 28. An in-depth discussion of this issue can be found in Sections 32 - 35 of Volume II of the Final Memphis Depot Main Installation Remedial Investigation Report which is available from the Depot (11).

15) (This is the same commenter as for #14) So my other question, the contaminated plumes, both near Dunn Field and the Main Facility, and the pathways to these ditches, there's no possible way that they are connected?


Geologists tell me that the answer is most likely no... It is very unlikely that the contaminants in the groundwater could have gotten ... into the ditches. The thing about it, even if it is getting into the ditches ..., the concentrations ... are so low, ... there would not be enough contamination to result in health effects.... If that same level ... is coming up inside the house and your house is built pretty tight, ... the concentrations ... could potentially build up inside the house to a level where it may be a health concern.... That's why we want to do flux sampling in the Rozelle area to see if this process is occurring at all .....

16) One follow-up question. On page 35, you said, "This aquifer provides 95 percent of the drinking water. However, a clear potential exists for the contaminants to move down to the Memphis Sand some time in the future." Have the geologists decided how long that would be in the future?


...I'll need to do research on that ... and will provide an update later when I revise this document. I was not able to identify a specific estimate of when contaminants from DDMT might reach the Allen Well Field. Most of the debate appears to be focused on whether the contaminants might ever reach the Allen Well Field not when. If it operates as designed, the groundwater treatment system that was recently installed at the northwest end of Dunn Field should greatly reduce or eliminate the flow of contaminants and perhaps resolve this issue. Sources for additional information are the Final Memphis Depot Main Installation Remedial Investigation Report and the Remedial Investigation Report for Dunn Field that will be released in the relatively near future (11).

17) All right. This is my last question. As you know, we all have water pipes coming into our home serving water to us. The contaminated plume and the runoff in the ditches, is there any chance ... for those chemicals to saturate those water pipes and get into our drinking water ...?


It's my understanding ... that, ... because the water comes to your house is under pressure, that even if the contamination happened to be up around those pipes or whatever, that if a leak developed in those pipes because the water in your pipes is under pressure, it's going to leak out and the contaminants are not going to leak in....

Comments from the 7 - 9 PM Session on February 24, 2000

18) Commenter 1: The individual comments are numbered and responded to by that number.

  1. I am a member of the Restoration Advisory Board. I am also here tonight as a private citizen from the community. I want to first tell you that I respect you, Dr. Crellin. Beyond that, I want to say that your ATSDR Public Health Assessment is a sham. It is based on a pack of lies, inaccurate information, it doesn't appear that anybody has reached to try to find the truth to report to the community what is needed. I am ashamed of you for trying to put this over on us. I don't understand why you continually try to not hear what we are saying. If you want to find out about the instance of cancer in the area, you got to knock on some doors. Don't go to the Public Health Department of the city of Memphis and pull some old data, fluff it up and try to pass it off as being accurate.

  2. Even that information is inaccurate. I am just going to read a few pages here. I do acknowledge that you say you want our comments. But what I would like you to acknowledge is our comments. You got several photos in here of pictures or maps of the Dunn Field location. I notice what is missing on every one -- there's an absence of a drainage inlet at the foot of Boyle Street as it intersects Hayes. I don't know how you got that. If you drove a bus, and you drove it down Boyle and crossed Hayes, you are going through a drainage ditch ... If you get in your car and drive around Boyle towards Hayes and keep going, before you hit the defense depot, you are going to go into the drainage ditch.
  3. Based on that alone, this entire study is a waste of government money and again another sham. Nothing about this is real. And if it is just something to appease the people, the people are not appeased.

  4. Forgive me if -- don't take it personally. I am just telling you the truth. And then you acknowledge that employees who worked in some of the buildings may have been exposed to carcinogens or dangerous chemicals while working on the main installation.

  5. You say in your report several times that no one had access to the property. You didn't do your research, sir. Because prior to 1966, the Boy Scouts of America were holding annual campground meetings there, the white boys. We had to look through the fence.
  6. Forgive me for not being as prepared as I need to be, but my opening statements are clear enough. This is a sham. You are taking inaccurate, erroneous information and coming to a conclusion. That is a waste of time. If you got a Ph.D., I think you know a little better than that.

  7. I also want to speak about -- you acknowledge that the people in the Rozelle area -- which is a little north of Dunn Field -- may have been exposed to this from 1989 until now. I am concerned about the people on the other side of Dunn Field as well, which would be to the east, where the greatest impact of the population really is, at the foot of Boyle where it crosses Hayes, all along Hayes Road, where the names -- (The commenter listed the names of 5 individuals.) -- all residents of Hayes, some former employees of the defense depot -- all deceased. These men lived on Hayes Road.
  8. Let me take you a little further deeper into the neighborhood. ... (Three more names are mentioned including a father and son.), these men are all deceased. All since 1989. But you know you can't see in your report a need to look east of the defense depot, Dunn Field. I notice in your comments you say that you were going to try to identify things. Maybe you tried, but you identified nothing, resulting in no actions.

  9. I just want to close by saying, you ought to rescind and recall this study, apologize to the people and talk to the people and impact the community before you try to put out a rat -- r-a-t -- sheet to the public.

  10. One other comment, you got in here you talked to so many people from the Defense Depot of Memphis Tennessee. Sir, could you list more than one person from the Defense Depot of Memphis Tennessee? I don't think you know one name in that group or that organization. You haven't done your work, sir.
  11. I just asked you not to try to give me this junk back. I asked you to take it back, recall it honorably. Do the right thing.

    And if you are going to list the Commercial Appeal as a reference, it is enough to say that you haven't done your job... The spouse of one of the deceased individuals I mention before is still alive. The rest of these people, their spouses are deceased. But they have children alive.... One of these decreased residents of the Hayes Road area, before he died took me to his front porch and showed me where all this crap was buried on Dunn Field.

    You just haven't done the job. I just don't know what else to say. It is a sin, it is a shame, and you will not be blessed for this, sir. You will not.


  1. The request by this member of the Memphis Depot Restoration Advisory Board (RAB) to withdraw the Memphis Depot Public Health Assessment was responded to in a letter dated March 9, 2000 from Lisa Hayes, P.E., the Acting Chief of Superfund Site Assessment Branch in the Division of Health Assessment and Consultation of ATSDR. Copies of Ms. Hayes' letter were provided to all the participants of the evening session. Here is the body of the letter. Responses to the rest of the comments made by this RAB member follow this quote.

    • "This is a response to your request that the public comment release of the Memphis Depot Public Health Assessment be withdrawn. You made this request to Dr. John Crellin during a meeting to receive public comments on the Memphis Depot Public Health Assessment on February 24, 2000. At this meeting, you stated that the public health assessment should be withdrawn because it was a "sham and based on a pack of lies". You indicated that the Agency for Toxic Substances and Disease Registry (ATSDR) needed to go door-to-door and talk with residents. You also identified what you considered to be significant mistakes in the public health assessment.

      ATSDR has considered your request and has decided not to withdraw the Memphis Depot Public Health Assessment because we've made it very clear since 1997 what would be produced, what our preliminary conclusions would be, and how we derived those conclusions.

      • Presentations on what ATSDR planned to do were made to the Restoration Advisory Board (RAB) in August 1997, the Greater Memphis Environmental Justice Working Group in February 1998, and public meetings in May 1998.

      • Preliminary conclusions and how they were reached were described at the October 1998 Greater Memphis Environmental Justice Working Group, a January 1999 RAB meeting, and a July 1999 public meeting.

    1. Your suggestion that ATSDR go door-to-door and talk with residents has been made and addressed several times since 1997. Door-to-door surveys do not help document exposure and are not part of the public health assessment process. As explained at the RAB, the Greater Memphis Environmental Justice Working Group, and at public meetings, an ATSDR Public Health Assessment identifies whether exposure to hazardous substances at a site is or has occurred and determines (if exposures are found) whether or not they might cause harm. Once exposure is documented, then a door-to-door survey may be appropriate as a follow-up to the public health assessment to help determine whether harm has occurred.

    1. The Memphis Depot Public Health Assessment was extensively reviewed within ATSDR to insure that it met agency standards and criteria for such evaluations. Drs. Reuben Warren and Jewel Crawford and other members of the ATSDR Memphis team also reviewed the public health assessment and provided comments. Significant components of the document were provided to the Executive Director of DDMT-CCC and Dr. Cynthia Warrick of Howard University prior to release. At the July 1999 public meeting, the map in the public health assessment that describes the drainage around the Memphis Depot was distributed to the participants. All these steps were taken to insure that the public comment release was valid and accurate."
    2. Here are the responses to the rest of this commenter's concerns. They are referenced by the numbers given each concern.

    3. Figure 5 accurately displays the drainage from DDMT. However, Figure 5 identifies only the locations where water is being discharged from DDMT. To avoid confusion, the locations where water flowed onto DDMT were not shown because they not pathways by which people could have been exposed to contaminants from DDMT. The points identified by the commenter are the those two locations where water flows onto DDMT from the area outside of the Depot.

    4. The exposure of workers was mentioned in the document. On page 42 of the public health assessment it is stated "Besides these possible exposures in areas around specific buildings, former workers reportedly could have been exposed to toxic substances because of work practices inside the DDMT buildings that resulted in contact with chemicals..." More information on this issue has been including in this document including a summary of workers' concerns given at a meeting that ATSDR held in 1998.

    5. The issue about access is that area residents could not easily get on the Main Facility or Dunn Field because DDMT has been fenced and guarded since the facility opened in 1942 (68). This is important because the fencing and guards would make it very difficult for anyone other than DDMT workers to have daily or even regular exposure to the chemicals on the facility. This would be especially true for small children. The exposure of Boy Scouts during the annual campground meetings prior to 1966 would be a problem for these boys only if they had direct contact with the chemicals being stored on DDMT by going into the storage areas, opening the containers, and getting the chemical on themselves. Exposure to contaminated soil once a year would not be enough to cause them harm.

    6. ATSDR did not identify a way that the people living in the area east of Dunn Field, especially those individuals living along Hayes Road could have been exposed to the chemicals on Dunn Field other than the dust blowing off the bauxite and fluorspar piles. Water flows from this neighborhood into Dunn Field not from Dunn Field into the neighborhood. Water from Dunn Field does drain into the Rozelle area which is why ATSDR is concerned about that neighborhood. As described on page 37, bauxite and fluorspar are not very toxic.

    7. This concern was responded to in Ms. Hayes's letter and is identified with a 6 in the text of the letter.

    8. ATSDR held about ten meetings with DDMT area residents including a number of individuals who identified themselves as members of DDMT-CCC. It is ATSDR policy not to identify private citizens by name in their documents so a list can not be provided.

19) Commenter 2: Do not use me, the organization of the Defense Depot of Memphis Tennessee Concerned Citizens, because I am not here to represent that organization. And I see the name of the organization slandered all through this booklet, as on page 12, and I want you to take it out because we have no business being there... you talked to me or other or our members of the community. On page 12, you got "All these activities were done with the cooperation and the foreknowledge of the DDMT-CCC." Why were you trying to get credibility on our backs? We didn't approve this document. As a matter of fact, John Crellin had no discussion beforehand with us about this document. We seen this document when everybody else saw it. So whether we disapprove, or whatever, our name don't have any business being in here.

Now, if you had said, "I talked to (the speaker identified herself) on this particular date"; but not saying that I approved or I cooperated or I acknowledged what you was doing. That's a lie. And it is a flat out lie. I know the tactics the ATSDR uses to divide and conquer communities. If they can't get you to work with them, they will go get an innocent group that knows nothing about them and have them -- make them feel they are doing something really worthy in the community to help them push along their document.

This is not -- nothing that I approved of. I seen this the same time everybody else seen it. And going through the community, there's a lot of people that have not seen these documents. And the faces in our community speaks for itself. I am like the previous speaker. I lived on Mallory Street most of my life. And I am ashamed because I see, even when we were trying to tell you what happened, you dropped solid portions, you took those questions and concerns out, and then you turn around and you fixed the questions the way that you wanted them to be.


Regarding the use of the phrase, "DDMT-CCC." ATSDR requires that adequate documentation be made of any comments, documents, or data used in its documents. The phrase "DDMT-CCC member" was used to identify comments received from members of this group so that readers would know that the source of the comment was a community member with specific concerns and knowledge about the situation. The use of this phrase does not mean nor is it implied anywhere in the document that DDMT-CCC endorsed the public health assessment in whole or in part.

Regarding the statement on page 12, "All these activities were done with the cooperation and the foreknowledge of the DDMT-CCC." This statement is true for the activities described in that particular paragraph. Dr. Rueben Warren, Ms. Sandra Coulberson, or other ATSDR staff discussed all the activities described in the paragraph on page 12 with the Executive Director of DDMT-CCC.

Regarding ATSDR not discussing the public health assessment with the commenter before its release. This is simply not true. As described in Ms. Hayes letter on page 111, ATSDR described how the public health assessment would be done on several occasions, indicated what the preliminary conclusions would be in 1998 and 1999, and provided several portions of the document to the commenter.

The commenter is correct that she did not see the whole document before anyone else. However, this is exactly what ATSDR promised to do in February 1998 at the first meeting of the Greater Memphis Environmental Justice Working Group. The commenter raised the concern at that meeting and in her organization's newsletter that DOD had reviewed and approved the 1995 public health assessment before it was released for public comment. To address this concern, John Crellin promised at the first Greater Memphis meeting in 1998 that no one outside of ATSDR would see the document before its release for public comment. That promise was kept.

Regarding the comment that ATSDR was trying to divide and conquer the community. ATSDR, especially through the efforts of Dr. Rueben Warren, has to been trying to unite the community and address its concerns. ATSDR agreed to review the 1995 public health assessment and conduct other activities at the request of DDMT-CCC. Members of this organization were notified of and participated in every meeting that ATSDR held with area residents since the commitment to DDMT-CCC was made in 1997.

Regarding the concern that the community was not given sufficient opportunity to review the public health assessment. The community was given greater notice and a longer opportunity to review the document than for any other public health assessment issued by ATSDR. A notice that the public health assessment was available for review was sent to over 4,500 DDMT area residents. The document was send to over 110 individuals and was available for review at four locations in Memphis. The period to review the document was 90 days while the usual period for ATSDR public health assessments is 30 days.

Facilitator: Could you help by being more specific so the next draft will be better, please?

20) Commenter 2: You got "Short-term exposure in airborne contamination." You say one time only this happened with the Span Dome collapsing. That is a lie. I remember smelling eel and salmon and real funky smells in the community. I can remember summers when we had blisters all over our legs from being out in the grass. I mean blisters where they run and the sores just leaked. And I remember these things as a child. I remember the vegetables in our backyard were, if it rained, when the stench was in the air, that the vegetable leaves would curl up like somebody scalded them. Or they would shrink and the vegetables sometimes would be spotted. I remember that in the Sixties, and I remember it in the late Fifties. I remember the bombs that laid on Perry and Dunn. And I remember seeing the kids up on top of those playing. The DLA said that they didn't have (inaudible) or whatever was on the cases. But the DLA has lied to us before.

I don't know what type of data that you are using, but their data is not correct. The people have the data. And it is in every last one of us. We experience massive sickness. And I don't know if you should call this a public health assessment, because it needs to be identified. And this is one thing that I feel, it shouldn't even be called a public health assessment. It should be called data that I looked at from defense logistics aides. Because you didn't get this from the community. And it has nothing -- this actually has nothing to do with us.


Regarding short-term exposures to DDMT contaminants in the air. On page 27 of the public comment release, it was stated that "Short-term exposure to airborne contaminants from DDMT probably has occurred at least once.." We were able to identify written documentation only of the 1988 span dome incident. The public health assessment does identify several other occasions where residents reported that air releases had occurred. ATSDR was unable to find any additional information on these reports. Without at least some indication on what was released, it is not possible to evaluate whether these releases could have caused health effects.

Regarding the concern that ATSDR did not do the public health assessment properly. As indicated earlier, ATSDR described how it would conduct this public health assessment on several occasions. The document was given a very extensive review within ATSDR, far greater than the typical public health assessment, to insure that it conformed with ATSDR's policies and procedures and published guidance (67). In addition, the commenter participated in a workshop on how public health assessments are done conducted by senior ATSDR staff.

Regarding the data used in this public health assessment. ATSDR reviewed all the data available to it on DDMT including considerable information related by DDMT area residents in developing this public health assessment.

21) Commenter 2: On page 29, where you got all these schools that was tested, the previous speaker and I both serve on the RAB, and if I didn't sit on it, I was there at the meetings. ... Never have I seen a piece of data that stated that they went off site and sampled Alcy and Charjean. I remember them going to Audubon Park. And the lake was contaminated by the defense depot, they claim. And they used some of the clean-up money to clean up the lake.

If that is not racism -- they went out to where the white folks, to where their children had a fishing area. And they cleaned because all the white children didn't need to be contaminated. What about the contamination that flows throughout our community in these ditches that kill our senior citizens?


The commenter was present at a meeting with Howard University and ATSDR in early February 2000 where this issue was discussed. As a result of that discussion, ATSDR provided Howard and the commenter with copies of the data on the sampling of four schools within a mile of DDMT.

22) Commenter 2: I call ATSDR a murderer too. Because you allow this information to go along, you are murderers, also. You are in cahoots with the DOD and you won't listen to us. Because if you had listened, these questions, where you got these questions on the back, would not have been listed like this.

I see where some of the questions are not even clear, and it is not what some of the people have said. And it looks like you picked around these questions and you left things off --

Facilitator: Are there specific ones? It may help --

Commenter 2: -- the drainage ditches that I told you about that came out of the defense depot, there was drains that came off of that site -- and I am not going to say no more after today -- off the Main Facility. And from what I know, it was 21 drains. My information may be clouded. There is a lot of them. But in the Fifties and the Sixties these drains was mud ditches.

Commenter 1: -- Right.

Commenter 2: -- And in the Fifties and the Sixties, these drains was like little puddles that rain would set in and flooded in people's yards. That is what happened in the Fifties and the Sixties. It probably happened in the Forties, because an elderly person said, "Well, it was just water that would rush down our backyard when it rained." So you know after years of corrosion, it turned into ditches. It turned into mud ditches. And you know we played in those ditches because we didn't know. And one day, I can remember looking at the ditch at Mallory and Sparks, over the little bridge, and seeing the water green, yellow, and white. And going down in there and kicking in the water and saying, "That is some cute water." Because a child don't know.

But the most frightening thing that happened to me is when my son said, "Momma, we went down in these ditches, down in the tunnels, and we went everywhere. And we ended up -- guess where we ended up? At Hamilton School?" That is coming from my house.

Facilitator: When was that?

Commenter 2: You said that it didn't happen.

Facilitator: When was that in a time frame?

Commenter 2: This happened in the Eighties. These children still played in these ditches. But, see, you got to understand; it may look like a main ditch coming from the facility, but it is like spouts. It has wells. It has tunnels everywhere, all in our yards and everywhere.


ATSDR agrees with the commenter on the number of discharge points from DDMT as being 21. It does not agree that the ditches coming off DDMT branch and sprout. The surface water drainage follows the natural drainage patterns of the Memphis area and thus the ditches run along the low points of an area. The ditches do not branch out but do merge together. It is true that some of the surface water drainage now goes through pipes/tunnels where once they were open ditches. This is described in the document and indicated on Figure 5. The commenter's son could have very well followed a pipe/tunnel to Hamilton High as there are two that discharge into Cane Creek just downstream from the high school. However, he most likely entered that pipe several blocks north of his house since his home is in a different drainage area than Hamilton High.

23) Commenter 2: So when in 1978 when there was an exposure of DDT and when the defense -- all the animals died in the community, you said we didn't even know what we was talking about. But in 1978, I bet you go to the veterinarians in Memphis, and you will find much information about the animal kingdom of dogs, prized German Sheppards, just in the backyard just died. Couldn't get out.....

Something also happened in the early part of the Eighties, when workers talked about the dead animals that was laying in their sight where they used to jog and play and go to the park, and thought they was getting fresh air; and they was getting contaminated.

Facilitator: One of the things that you will notice in the health assessment is that we really can only put evidence in there if it is referenced and cited and documented. So otherwise it has to have the word "allegedly," or have the format like you saw where it said "Comment." So if you have information where maybe people kept diaries or journals or specific maps of where they saw things happening or anything along --

Commenter 2: I asked these people to call (an individual is named) in Detroit. She was there at the time of the explosion of the Span Dome. But, you know, the DLA told that it was a thunderstorm, that nothing happened. That is a lie. It was not a thunderstorm. But this is what the Government can put on record and say this has happened, but that is real because they wrote it down.

.... We are looking at our people, we are looking at our children coming up with uterine cancer. I took ten kids to Washington, and three of these children are sick. These are friends that grew up together. You can't tell us that the government is doing all they can for us. Because they don't. That is a lie. This is the Tuskegee incident.

Facilitator: That is why we are here.

Commenter 2: If you are here to help us, to get some medical help, get these people out of the community, get the clinic here to treat cancer and everything else we have to pay for, then you do it.

Facilitator: See, this is a process.... --

Commenter 2: The process is not working. And I think that what we end up being is like Oakridge. We are tired. We was the first group that you put together, this working group. But I feel like that Dr. Warren has done everything that he can. But I cannot support the other part of the agency. I feel like they didn't work hard enough.

And when we asked them to work hard enough, maybe they was divided out into too many areas where people couldn't focus on the main things that needed to be done. But as I see it -- and I don't want nobody to take it as an attack on them personally -- but it may be an attack on the agency of not having enough people here to do what they need to do.


Regarding the 1978 incident. Public health assessments evaluate available data to ascertain whether exposure to site-related contaminants could have resulted in health effects. For this situation, ATSDR was unable to identify any information on what the release might have been, and how much was released. Without that information, the public health assessment process can go no further.

Regarding the 1988 Span Dome Incident. In the public health assessment, ATSDR described what was in the report from the Memphis Fire Department and the Commercial Appeal newspaper article about the cause of the Span Dome collapse (5,76).

Regarding medical help. As indicated at the February and October 1998 Memphis Environmental Justice Working Group and July 1999 public meeting, ATSDR has neither the authority or funding to provide medical treatment.

Regarding the process. A review of the 1995 public health assessment is what ATSDR committed to do in 1997 and, because of the large amount of new environmental data, it was decided to conduct a second public health assessment to fulfil that commitment. ATSDR not only communicated that to DDMT-CCC and the RAB, but also has indicated that ATSDR does not have the legislative authority to do what the commenter is requesting that the agency do.

Facilitator: ... I think will be really helpful to make the best use of this time is, you mentioned there was some questions and comments that had been distorted at the end of the document. If you could be specific, tell us how you would word them -- it sounded like maybe some of them were yours -- and give those suggestions to us either in writing -- it doesn't have to be tonight if you want to put more thought into it. That is exactly what gets incorporated into the document and that's --

24) Commenter 2: On page 39, March 1998, it says: "Two residents found two dead birds just off-site of the west boundary of Dunn Field. They were concerned the birds' deaths were due to site contaminants probably released from the nearby location of Dunn Field. A few days before, small vials had been uncovered at the location." The commenter then quoted the end of this section. It says: "It appears unlikely that these birds died because of that incident."

How in the heck do you know? I don't know -- unless you tell me you found these birds and you went ahead and examined these birds, how in the heck can you verify that these birds didn't die because of this chemical warfare material that was found? And that is what it was. I identified and sent pictures off. I sent them to an expert. It was chemical warfare material that was unearthed. And so you tell me -- if you did a check on these birds, you tell me what kind of analysis you did on the canisters they sent to the dump site which was in the Commercial Appeal.

Facilitator: You want a further explanation of how the conclusion was reached; is that correct?

Commenter 2: It is stated clearly that it was nothing wrong. And I want to know if they did an autopsy on these birds.

Because when the explosion happened, at least in 1999, October 30, 1999, then no one went and took air samples. No one took soil samples. I videotaped the ground, so that I could walk back to the places where I saw the burn spots. And the conclusion was, it was fireworks. I never known fireworks to shake the foundation on houses.

And so I'm saying if this is supposed to be the Agency for Toxic Substances and Disease Registry, and if you are doing work on data as it come up, to insure us of our safety, then I think you need to go back to the wheel again, because this is not getting -- this is just one incident. The other question -- I don't have my book -



ATSDR concluded that it was unlikely that birds died due to this incident based on the descriptions of what can be found in the reports on what happened that were made available to the Memphis RAB at March and June 1998 meetings. The amount of material present and therefore the amount released was very small. Based on the reports to the RAB, it is unclear what pictures of this incident that this commenter could have since the materials were uncovered and disposed of before the incident was made public.

Facilitator: Let's move on and do other people's five minutes. But if you could just make a note as to each one that you see as inaccurate, and be as specific as possible as to why and how you would like to see your comments or question rephrased; because that way, the next draft, we can incorporate your thoughts into it.

25) Commenter 2: Another thing, "public health assessment," it needs to be clarified, and I told John that before. And I know that he tried to do a clarification on the flight. But you need to do a clarification -- what is a public health assessment and what do you mean no health impact, because that scientific jargon that he used means something totally different to the community people.

..... There was then a discussion between commenter 1 of the session and the facilitator with some participation from commenter 2 about who would speak next. Commenter 1 then related this - I am not sitting down. Hold it just one minute, ma'am. You haven't read the report. You couldn't have came to the conclusions saying there was no health hazard west of Dunn Field. You say you read the RAB board minutes. You haven't gotten into what our concerns are or you couldn't have possibly put this out. The whole report is bogus. I am finished.


Regarding what a public health assessment is. As indicated before, ATSDR described the public health assessment process to the community on several occasions. In addition, this commenter participated in a special workshop on public health assessments conducted by senior ATSDR staff.

Regarding what no health impact means. In the conclusions section, no health impact is explained as "Currently, no known exposures exist off-site to site contaminants that could result in health effects." This explanation will be included in the Summary section to better communicate ATSDR's conclusion.

Regarding the conclusion in the public health assessment about the west side of Dunn Field. The conclusion about there being no apparent public health assessment is specifically qualified by the statement, "The Rozelle neighborhood, which is that portion of Rozelle Street just west of Dunn Field, is a possible exception to this conclusion."

Facilitator: Thank you. Basically, what I would like to do is just make sure everybody's questions are on the record and then open it up for discussion, so it is not just you speaking to us and we can have interactive dialogue. And you could maybe get a response from Dr. Crellin, who would probably be able to respond much better than I.

26) Commenter 1: We are here to put on record our problems with your report; can't call it an assessment because it wasn't professionally done.

Facilitator: If everybody could be as specific in their comments. I mean I completely understand that you are not pleased in any way with it. But if you see some constructive ways, little steps that the agency could take, because you, being close to the community, you know how to get the information, who to talk to, who might have a record or a log going years back because that's the kind of information we need to cite -

Commenter 1: Ma'am, if you could listen and read, and you just read what I said to the stenographer, if you just read, I got very specific.

Facilitator: And what I heard was we can put in testimonials and comments --

Commenter 1: No. What you heard is you haven't done your job. You haven't come to the community. You haven't done a public health assessment but you are trying to pass one off. That is what you heard. I specifically told you the report is bogus because you don't have all the drainage ditches located on there. You didn't put the reports of the RAB board meeting in there. How much more specific do I need to be to tear this report apart? This report is worthless. It was worth more money before it got printed than it is with the information in it.

Let me just say this to you, ma'am. I don't understand your role here. You seem to be more trying to defend this report: As a facilitator, I would think you would have a neutral position. But you've been exposed as trying to defend the report. And you have done a poor job, also.

Facilitator: Well, I am sorry.

Commenter 1: You should be sorry.

Facilitator: I am trying to be neutral. Basically what I am trying to do is to take away the attacks on the agency and the personal attacks against Dr. Crellin and to try --

Commenter 1: He signed his name to this report. And as a professional, he needs to stand behind it. I don't know nothing about this man. I don't dislike him. His work stinks. That is all I am saying. There is nothing in here of value.

Facilitator: I will let Dr. Crellin respond in a minute.

Commenter 1: I don't need a response.

Facilitator: If you don't need a response, does anybody else have anything that they would like to discuss in their response, because I think there could be some constructive dialogue, as opposed to attacking and getting the divide any greater.

Commenter 1: The truth is never destructive. You got to start with the truth to build anything. You don't seem to be interested in the truth. So don't sit up there and try to color this any other way than you haven't done your job and you are up there trying to get paid for something that you're obviously not qualified to do. So, please, don't go there, because you are not qualified.

Facilitator: It is pretty much like I am here, and we are trying to do our best and --

Commenter 1: Your best ain't good enough. You are sorely lacking as a facilitator.

Facilitator: This is your one chance to enter your public comments in this point in time --

Commenter 1: I thought it wasn't finished until March 31.

Facilitator: It is. But I am taking about this evening, tonight.

Commenter 1: I am excusing myself from this meeting.

Facilitator: Thank you for your comments.

Commenter 1: Don't take any joy in my leaving. Consider this a man trying to keep the peace.

Facilitator: Okay.


As indicated earlier, the public health assessment was what ATSDR said that it was going to do. The document is ATSDR's evaluation of the information available and follows the requirements for a public health assessment mandated by Congress. Extensive efforts were made to identify the community's health concerns and to include them in the document. The document was extensively reviewed within ATSDR. Individuals reviewing the public health assessment included the Director (Rear Admiral Robert Williams) and Assistant Director for Science (Dr. Allan Susten) for the Division of Health Assessment and Consultation, the Associate Administrator for Urban Affairs (Dr. Rueben Warren), and all the members of the ATSDR Memphis team.

27) Commenter 3: I was at the morning meeting. And I raised the same question. And I am going to bring it up again. We had a public survey from the health department that said that 90 percent of the people in that impacted area responded to your survey. I think it is important and necessary that we look at other ways to reach out and document some of these activities or actions or incidents that occurred in the neighborhood and impacted the community that only the people in the neighborhood can tell you about. Whatever we have to do to get more input, surveys sent out, we need do. Because there are a lot of stories as Commenter 1 talked about.

I live on Boyle Street about 100 feet from Hayes. I know all those people personally. I grew up in the neighborhood. I have been there since 1965. And all those gentlemen he described died from cancer. And I would say roughly 80 percent of them worked at the depot in the bad old days during segregation, where whatever you handled, they probably told you, "Boy, don't worry about it. Just do your job to keep your job." That's a fact. I am not making this up. People would talk at the depot. It was segregated. It was in the Sixties. So that people had a legitimate fear of what went on over at the depot. And sometimes people just don't come forward readily enough.

But we need to make this extra effort to get out there and send a survey around and ask people what they saw, when they saw it, and what were the effects of it. It may not be scientific, but it is more information and data that can go in your report. I made this point in the morning, and I am making it again. I am just concerned about the database that the community is happy with. Thank you.


ATSDR has offered to Howard University to distribute such a survey to the about 4,500 individuals on the mailing list that ATSDR recently used to notify the community that the public health assessment was available. The survey would have assisted Howard in its efforts to identify additional locations for off-site sampling. Howard decided not take up ATSDR on its offer because of time constraints but will consider it in the future.

28) Commenter 4: I don't know if I can add much to what has already been said; except, some pretty important points were made. But I had some problems with the health assessment document, too.

And just to give one example -- I am not going to go through everything, because that would take too long -- but, like, on page17, there is a discussion of the cumulative risk from six different polycyclic aromatic hydrocarbons. And the statement is that there is only a comparison value for one of them, and ... I don't see that there is much data that is based on. I think it is very wrong to have something like that where you don't even have data on five of them. You are making a wild guess about what the combined effects might be of exposure to all six of these when there are probably no studies at all dealing with that. And, yet, there is a conclusion made that people are unlikely to have -- let's see. "The actual chance of anyone being harmed is very low or nonexistent." That is a quote from it.


In evaluating the cumulative risk of PAHs, ATSDR used procedures developed by EPA. These procedures have been published and peer reviewed and were not a wild guess.

29) Commenter 4: And that seems to me a typical methodology in this report and other ones done by ATSDR, that uncertainty is stressed when it is a question of -- that you can say, if the level of a certain chemical is above the comparison value, than that doesn't necessarily mean that anyone is hurt. But the opposite is also true. When we don't know for sure someone is going to be hurt from it, you are not stressing the fact that we don't know for sure.


ATSDR establishes its comparison values using a methodology that insures that nearly all the uncertainty is above the comparison value and very little is below. This insures that the public health is protected.

30) Commenter 4: And I think that you have statements in here like: "There is no apparent public health hazard;" and "This does not represent a public health hazard," over and over again; and everyone knows that these statements are going to be taken out of context and used by politicians and decision-makers to justify not doing anything.


As indicated in the ATSDR Public Health Assessment Guidance Manual, these statements are intended to indicate that no action needs to be taken to prevent exposure (67).

31) Commenter 4: So I think this is a biased report. And this is also reflected in the way that official documentation is privileged, as the facilitator was explaining, which I know is the government's position.

For example, on page 27 in what I have, is the discussion of the Span Dome and the release of hazardous substances into the air. And then there is a statement that "Long-term residents have indicated that several other air releases from the depot have occurred; however, ATSDR did not identify other reports of confirmed air releases from DDMT." So anything that is written down in a government document is confirmed: If the people who live here and report it, who observe these things, say it, it is not confirmed. I think there is a real problem with that.


ATSDR uses whatever information is available in its public health assessment, no matter what the source. To evaluate the possible health impact of an air release, at least some sampling data are needed on what and how much was released. It was for this reason, not that they weren't government reports, that the reports from community members weren't evaluated further. This sentence in the public health assessment has revised to make this clear.

32) Commenter 4: Another example of what I think is a bias is on the very next page. There is a discussion of Nonconnah Creek being the nearest off-site body of water with a viable population. And the conclusion is that "Very little or no opportunity was available for residents to catch and eat fish within a mile of the site." The explanation on Nonconnah Creek is, that it has been posted as a no fish consumption area since 1982. Now, I don't think with Audubon Park they decided it was good enough to post "No Fishing" signs. And I am not naive enough to think that just because there are "No Fishing" signs that nobody is going to fish in there. So this conclusion is completely unwarranted.


ATSDR agrees that the discussion of fishing and Nonconnah Creek is unclear and has revised it.

33) Commenter 4: In general, I think that it reflects that there are two totally different world views at work here, the people who live around the community that have the experience of people suffering and dying -- that is what people have been talking about tonight. And you have a report like this that doesn't even take any of that up at all. I know you didn't choose the name public health assessment, but it doesn't deserve to have that name. It just looks like an attempt to prove that the depot was not responsible.


The ATSDR staff working at Memphis have extensive training, experience, and prior success in understanding and responding to the concerns of the community around a site. These staff realize that some DDMT area residents have concluded that most of the death and disease in the area is due to exposure to something from DDMT. However, these same community members refuse to accept that ATSDR is mandated by Congress to first identify whether exposure to site contaminants is or has occurred, then try to link that exposure to excesses of death or disease. As described in this public health assessment, no known exposures exist or have existed off-site since at least 1989 to site contaminants that could result in health effects. In addition, ATSDR's review of the limited amount of data on disease in the DDMT area did not identify any excess of cancer.

34) Commenter 4: And the 1995 public health assessment was even worse. I notice that there are a few things that were admitted in this one that weren't admitted in the other one. I don't think anyone has ever explained why they weren't admitted in the first one. I think all the same problems still exist.


The commenter did not identify what was admitted in this public health assessment that was not admitted in the 1995 public health assessment so we are unable to provide a response.

35) Commenter 4: So the problem is that there are all these different agencies and they have each their own jurisdiction and their own agendas. None of them is the agenda of the health of the people who live in the neighborhood and who worked here.


ATSDR is mandated by Congress to evaluate health problems as related to exposures to contaminants from Superfund Sites.

36) Commenter 4: And I don't understand things like, in the -- what I have as page 42, which is part of the Responses to Community Concerns, and there is a discussion of how workers could have been exposed to toxic substances because of work practices that resulted in contact with chemicals. "Evaluation of these situations is not within the scope and purpose of a Public Health Assessment." That may be true according to the rules that the Agency goes by. But I don't understand why the Agency which is following that agenda would have called the meeting where the workers testified about all these things that happened to them, tried to give them the impression that they were going to do something for them, and, of course, never did. And what this statement says to me is, we are not going to do anything for you. So these are the kinds of concerns I have. I am going to stop now, because I think that is enough to explain it.


The meeting mentioned by this commenter was conducted by ATSDR's Office of Urban Affairs. They are the process of responding to these concerns. For additional information, contact Dr. Jewel Crawford at (404)639-5060 or

Facilitator: Are there any other comments, questions we should get on the record before Dr. Crellin begins to address some of these issues?

37) Commenter 2: If they had any kind of -- the -- everything exists. Everybody knows that. There is no question whether it exists or not. It does exist. It look like everybody chooses to ignore it.

I just have to say this. At least you could help the children, the young people, because they need that type of help. They are exposed -- a lot of these kids, a lot of the families maintain homes and -- a lot of these men and women that worked there, came home and their children were messed up with this type of -- things that they brought home on their clothes and different things like that. And I know that as a fact. And these children do not have -- there is not any places you could go for help. It is just pathetic in Memphis. I could give you some documents on that. It is pathetic here. We don't have any kind of health places to go to get the type of help that these young people need.

You go to the clinics -- actually, you can't hold a job. I feel sorry for the people; because if you go to the clinic, you'll be sitting up there at least four or five hours before somebody will even talk to you. When they wait on you -- I know because I have to take the children to the clinic. And they don't get any kind of response. I am a victim of the same abuse. That is just breaking it down for you so you can understand where I am coming from. And it seems like everybody wants to ignore it. Thanks to the clinics coming back to the school kids in the neighborhood - but you don't have any kind of clinics, any kind of -- it is just pathetic.


ATSDR's Office of Urban Affairs (OUA) is working with the community and many local, state, and federal agencies to enhance the capability of the existing health clinic in Memphis. This commenter is familiar with these efforts and working with OUA.

38) Commenter 1: ... Again this report refers to lack of data available. What about the studies done in Dunn Field and other locations of Defense Depot of Memphis Tennessee? That fact indicates -- solidifies to me and to anybody who may still have a question that you really didn't even try to get to the facts of the matter. I just want to say again, you ought to recall this report. Do the honorable thing. Recall this report. Take your time.


As described in the public health assessment, the earliest report on the levels of contaminants on DDMT is from 1982. These data were too limited in scope to be evaluated in the public health assessment. All the environmental reports on DDMT since this 1982 report were used in this public health assessment.

39) Commenter 1: Mr. Moore -- a man I respect -- I am sure you gave him a car, a hotel for everybody who comes here from Atlanta on a regular basis. Dr. Crellin, I've even seen you driving a -- but according to this report, it doesn't sound like you even mention it. You got a court reporter here. You got some facilitator here. You are spending a lot of money. You got a place for the community -- it is far away from where it should be, by the way. This is not the place to hold a meeting about the defense depot in this community. You are spending the money. Spend it properly. Hire 1,500 gentlemen more, send them to the door to talk to those 5,000 to 6,000 residents and impact the community and do a health assessment for real.


Your suggestion that ATSDR go door-to-door and talk with residents has been made and addressed several times since 1997. Door-to-door surveys do not help document exposure and are not part of the public health assessment process. As explained at the RAB, the Greater Memphis Environmental Justice Working Group, and at public meetings, an ATSDR Public Health Assessment identifies whether exposure to hazardous substances at a site is or has occurred and determines (if exposures are found) whether or not they might cause harm. Once exposure is documented, then a door-to-door survey may be appropriate as a follow-up to the public health assessment to help determine whether harm has occurred.

40) Commenter 2: On page 25, I think you were talking about the Alcy community itself. And I know I raised this issue more than once, about how the off-site dumping, illegal dumping was done -- well, it might have not been illegal. The depot just took barrels of stuff and dumped it over on our Alcy community before it was built. And the residents that lived over there the longest -- most of them are dead. But you may find one or two. And they didn't die at an old age. They died at a young age. There was off-site dumping recorded by some of the workers, and also recorded by (named an individual) when she lived on La Paloma. This individual said in the early Sixties before the Alcy community was leveled, she said they were really doing off-site dumping. She said you could see the trucks roll from the depot, and you could hear the thunder of the drums falling down the ditches. You told me I need to know specifically where the barrels was buried. And I call that an insult. (An individual is named) don't know where the barrels was buried. Because there were so many and so long that no one knows exactly where the barrels were buried. But you should be testing.

And most of all, we was also informed that the school of Alcy community, it was an open pit of chemicals there. Now, I am not a scientist. I don't know how to sink a sampling tool. But I know it would take more than 3 inches of soil to find out what is going on.

If you want to know the truth -- we don't want just sampling in the community, but I think the Alcy community itself, there needs to be an examination of everything that happened over there in that community. Because I think it is a crime that has been committed and I think people actually know about it that are from that depot, if they are still alive.


The reference to the Alcy neighborhood on page 25 is actually a discussion of the surface water drainage in the area not of illegal dumping. ATSDR has had a number of discussions with this commenter about illegal dumping. ATSDR does not have the expertise nor the responsibility to identify illegal dumping. The agency has encouraged the commenter to provide any information she has on the specific locations where such dumping might have occurred to the Tennessee Department of Environmental and Conservation (TDEC) or the U.S. Environmental Protection Agency (EPA). They are the agencies with the responsibility and technical expertise to investigate such reports.

ATSDR does conduct limited environmental sampling to identify ongoing exposure to site contaminants. Ongoing exposures occur because of contact with surface soil which ATSDR considers to be the first three inches of soil.

41) Commenter 2: Now, you couldn't get (an individual is named who is a RAB member and a former worker) to tell the truth about anything. He is going to lie to the end because he worked at the depot for 32 years. But that is what the depot used as the archive. And I want to know why in the hell you-all can't use the community as the archive. We are the archive also. These reports, they are verbal reports, but they are our archives.


ATSDR considers the community a valuable and valid archive in evaluating the possible health impact of a site. ATSDR conducts a careful evaluation whenever it receives specific information on possible exposures from community members. For example, ATSDR recently decided to fund medical evaluations of possible arsenic exposures in Fort Valley, Georgia based largely on information provided by community residents. In June 2000, ATSDR conducted a exposure investigation in one neighborhood of Fort Valley based on information from community members.

In the Memphis situation, Howard University is conducting interviews with DDMT area residents to gather information on locations in the community where exposure to DDMT contaminants might be occurring. ATSDR has agreed to consider conducting environmental sampling at the locations that Howard proposes.

42) Commenter 2: Now, if this lady states that there was dumping being done there, when she lived on La Paloma, it was being done. She also states to witnessing the blowing down, the explosion of the Span Dome. I thought it was in 1985.


This incident occurred in 1988 according to the reports on it from the Memphis Fire Department and the Commercial Appeal (5,76).

43) Commenter 2: I see you have no report of the airplane crashing in Dunn Field in 1985. Now, I feel like that was a cover-up. Why is this not in the report? It was an explosion of some type. The plane burned. And instead of them removing the plane, they buried, plane and all. We asked, "What was on that plane that it was so critical for you-all to bury it?" Jet fuel for one thing. And I doubt if it all burned up.


The commenter has raised this issue at the Memphis Depot Restoration Advisory Board (RAB) and was been provided a detailed response. ATSDR did not identify any more information on this crash than what has already been provided to the commenter.

44) Commenter 5: ... I moved out there in 1954, right across the street from the bauxite piles on Dunn Field.. When I moved out there, all that stuff was bolted up. On a Wednesday all of this from those things that they had covered up, it wasn't covered then. It was only laid over there. And we couldn't leave our windows open when it was a windy day or our house would be filled with white dust coming in. I was a witness to that. We went through something like that. And a lot of people moved out because they came down with different diseases, that they couldn't sleep at night. They would have to sit up. And I am -- and I am a witness -- in fact, I had cancer. I come down with cancer in 1998. Of course, I had been suffering with different things. But I am still under the doctor's care. And I know that when the people started complaining, that is when they covered those things up. And when they went there, they dig it out, root it out, from Dunn back to Person Street. It is a vacant lot out there now. But when they was uncovering it and moving it, we come through something then. Because on a windy day we couldn't go outdoors. I know people have suffered out there. I just want to give you my information.


Thanks for the information. It will be referred to in the body of the public health assessment.

45) Commenter 6: I lived out there all of my life. I was born and reared there. Your first dump site was at Parkway and -- Parkway. Your next dump site was where Hamilton used to be up now. Then the entire area was military. Where you see Hamilton School, now the Diablo School, they were on the barracks.

My father worked for the railroad, the IC Railroad. Then they would breathe those -- when all these different things would come in. There was a train that derailed with mustard gas on it. I'm learning more about that now. At that time the only hospital in Memphis was College Chapel that would serve Black people. So with this, my father came home to us. You should have been at our house; it was just nothing but -- we couldn't hardly breathe in the house. They shipped my father out to Illinois -- let's see -- to Redwell Hospital. That's where he lived for the next I don't know how many years. And my mother could see him. He passed away.

Also my brother worked there, too. But it was something about that area that we didn't -- all we could see as little kids and things were people had to be protected, with -- they were dressed all in white. All you could see is maybe where they would look out of their eyes when they would go in and out of the place at times.

We never knew what was going on and nobody ever said anything. And then all at once everybody deserted the area because we lived there. Later on they started the area which is called Alcy, over in that part of the neighborhood, there be an odor. There are houses on all the dump sites. At times -- they are as far as the cemetery. There were three cemeteries. They just covered all the stuff in those ditches. So nobody never questioned it. Nobody never -- you know. But the intelligent people, I guess you would say, that knew what was going on, they tried to help. They tried to help us and they did help us. I lived -- I mean that was my residence in the neighborhood, but I didn't spend all my life just sitting there. They would move us out and move us back.


Thanks for the information.

46) Commenter 7: I live on the corner of Alcy and Manchester. When we first moved there in 1962, we were in the county. The county is on one side and the city is on the other. And no city -- there's a cove. You know, that wasn't through streets. But since we been there -- and that was a city dump. Where my residence is right now, that was a dump. And every house from that corner on the south side of Manchester, every house have a crack in it right now all the way down to that coal, where that coal was. And honest to goodness, we are sitting on a rat foundation. They are as big as cats right now. And I just wish you'd come out there right now. They move my bricks just like a man would do. That is all I have to say about that. It is a pity.


Thanks for the information.

47) Commenter 1: The south end of Dunn Field where they had the flurospar and bauxite piles that (named commenter 5) spoke about that has been removed, and when was gone they installed an above ground sprinkler system to ... help ... grow grass. In the heat of the summer, most of the grass won't grow. Something must be wrong. The sprinkler system is still there. The grass that did grow turned brown. They never cut it. I wonder why they won't cut what would come up. Huge bald spots where the grass never came up with an elaborate above ground sprinkler system on. Something is wrong with that ground too.


This commenter as a member of the Memphis RAB has brought this issue with the DDMT staff and it has been addressed.

48) Commenter 3: It is really not a question. Basically I will just be brief. Is there any way in this public health assessment that we can send out a notice to residents or former workers stating that if you have witnessed, have seen any illegal dumping activities or anything that you deem that may have contributed to your health problems, send out to the people affected in that area, so that they can respond in writing those incidents that are documented by their own eyesight that they saw, so that they can incorporate this into the health study.

This is just a statement that we might want to send out, a statement asking people to come forward and voluntarily give this information that all these ladies and all these people in town evidenced that they have seen, so that we could adequately explore Dunn Field, the depot, and the illegal dumping that was done at the depot. Thank you.


As indicated earlier in these responses to comments, ATSDR has offered Howard University the use of its mailing list to essentially accomplish what the commenter is suggesting. Howard decided not to use the list at this time because of time constraints but will consider its use in the future.

49) Commenter 2: I want to respond to that. When Jeff Kellam did the 1995 health assessment, there were only a few of these that went out. I want to know how many of these went out to the community. I want to know what -- where did they go.

I want to know exactly where did these booklets (referring to the public health assessment) go because people I asked -- even (she named commenter 1) didn't even have one. I asked people who received these brown documents. And when Jeff Kellam did the first health assessment, we challenged him because just on my street, there were only two books. And I think it is about 30 homes on my street. And I think it is a lack of communication.

I am not going to get out and do your job. I stopped having meetings with DDMT-CCC because I felt like the ATSDR should do their own. If they want to talk to people, they need to go door to door and talk to them. I stopped, and I wasn't going to cooperate. That is the reason why I didn't call a mass meeting. And I would never do it for ATSDR.


ATSDR made extensive efforts to notify the community that the public health assessment was available for public review and comment and to distribute copies to those expressing an interest in receiving one. The document was available for review at 4 locations in Memphis, Tennessee from December 27, 1999 to March 31, 2000. The public comment period was announced in local newspapers and through a notice send to over 4,500 residents around the Memphis Depot. The notice indicated that a copy of the PHA could be obtained by calling a toll-free number.

The public health assessment was sent to over 100 individuals or agencies including representatives of all the neighborhood organizations in the DDMT area including DDMT-CCC, all the members of the DDMT Restoration Advisory Board (RAB), and over 30 area residents not associated with any organization. Documents were also sent to 9 local, state, or federal elected officials; the Congress of National Black Churches; and Howard University. The following local, state, or federal agencies were given copies: Memphis Shelby County Health Department, the Tennessee Departments of Environmental Conservation and Health, National Center for Health Statistics (NCHS), U.S. Environmental Protection Agency (EPA), DDMT, Defense Logistics Agency (DLA), and Department of Defense (DOD).

50) Commenter 2: If you talking about getting us some health care in here and talking about setting up a clinic, if your talking about giving us the service that we need with doctors that can deal with these type of impacts, then we can talk. Other than that, with this bull that you are trying to pass down, giving these people a false sense of security, saying that everything is okay since 1989. And I want to know what happened since 1989 that make us so healthy, happy, to live in this community.


As indicated in the public health assessment, the community has not been exposed to significant amounts of site contaminants since at least 1989. In addition, the effort to clean up and reuse the Depot is well under way.

51) Commenter 2: And I want to know, are you looking at the schools, are you doing any documenting of the students that is coming down with this type of illness that live in this community? Are you doing any type of study, tissue sampling of the students that is going to this high school of the contaminated ditch? Dunn was -- from this book, going back to the testing of that school, Dunn was the only school I can remember any testing was -- Audubon Park was supposed to have the contamination from the depot. That was like a charge, a recharge system. That was my understanding back in 1980 -- 1996, was it? -- when they did the testing at Audubon Park.

Commenter 1: It might have been 1996.

Commenter 2: 1996 or 1997.

Commenter 1: But they haven't -- if they had read the report, they would have the correct date.


The testing of students at Dunn School would be done by ATSDR only if there were evidence of ongoing or past exposure to DDMT contaminants. There is no indication of a long-term exposure pathway from DDMT to anyone at Dunn Elementary School. In addition, the soil samples taken at Dunn School in 1995 did not identify any chemicals at levels above what is typical for the Memphis area.

52) Commenter 2: That is right. Why wasn't the concerns placed in the book from the community people that came out from the time that we have a court reporter. I know back when the RAB first started ...we didn't have a court reporter. And also documents from the concerns of people, I want to know why it wasn't included when ATSDR made site visits; and whomever was in the community at the time go back and do what you call a trip report. I think that is what you all call it. Do you all call it a trip report?


All the trip reports of visits related to DDMT since 1997 are referenced in the public health assessment and are provided to this commenter on an ongoing basis.

Facilitator: Yes.

53) Commenter 2: Because during the time of DERTF in 1996, Dr. Hughart -- I think that was his name, .... He was from ATSDR. Chris Kartman took the group, the staff from ATSDR, and the Army -- there was a lady that dealt with environmental health from the army, from the DERTF meeting and took them back in the office.

And her statement was "I want you to work with the community, but I don't want you to find nothing." And I see -- and Dr. Hughart sent me that statement. Dr. Hughart sent me that statement. ... And I feel like that you did a very good job working with the community and doing nothing.


The ATSDR staff working on DDMT since 1997 never received any instructions from anyone, including the Department of Defense or related agencies or its contractors, on how to conduct its activities or what conclusions to reach. The health assessor assigned to this site, John Crellin, had no previous involvement with Department of Defense sites. As can be observed by the number and tone of the nearly 100 comments submitted by the Department of Defense, that agency is no more pleased with this public health assessment than the commenter. DOD has not funded the activities that ATSDR has conducted related to DDMT since 1997.

54) Commenter 2: -- and that is what we got -- what that is what I was telling you, until you clarify this booklet, this is the most dangerous book that can go out.


DR. CRELLIN: This is a public comment draft, and it very much means, especially the way that I write it, that we want the public comments. The comments that we get, can and do change the document. We would have liked to -- in most other sites that we work with, the sites that I worked that are not federal sites, I like to have constant interaction with the citizens as I am writing the document. That is the method I much prefer.

When we started this process in February of 1998, I announced at that time that we would be unable to do that step-by-step process because we had -- first, (referring to commenter 2 by name), you had concerns that we were handing the document to the depot before it was released and getting their approval. Essentially that --

Commenter 2: I really thought that we --

DR. CRELLIN: (Identified commenter 2 by name), may I finish my statement -- that was the process that actually does occur. I find it extremely distasteful. And I made my concern about this known within the agency. But we were bound by a written agreement with DOD that anytime a document is released by ... ATSDR ... that the federal people would get a document at the same time that everybody else did. And so as I announced in February of 1998, what we did is that, when I sent the document to you, basically the people of the depot were fedexed the same document at the same time. The first time they'd ever seen the whole document is the first time that you had ever seen the whole document.

I did discuss specific parts and shared specific parts of the document with you (commenter 2), including the community health concerns. We talked about the document in some detail, including the conclusions in July of 1999. We did that, in part, with the interjection of Dr. Warren ... to get some information out to give you all the opportunity to comment at that time. At that meeting, I received very few comments. I was hoping that people --

55) Commenter 2: Each time you come into the community and each time we ask the question, when we get the question back, it is twisted around or when we ask the question that we ask -- like we asked the question about the data that came out of that office, and I don't know how those two things sound alike. Maybe I have so much of a southern drawl you may not understand me that clearly. But the questions would be so distorted that it made people so angry they didn't want to come. Why is it every time that we ask something, when we look at it on paper, it is a totally different definition or a totally different statement from what we said? And that was the problem.


DR. CRELLIN: This is the opportunity, if you find that things have been distorted, this is the opportunity for you to ask for them to be corrected. Most of the comments that are in the document -- there are 25 comments listed there -- about twenty of those comments were compiled in some initial meetings that we did where Michael Grayson was involved. And I remember that Michael compiled those, put those in the list. And he sent them to you and asked for your comments on them. And I took those comments from that list and compiled the list that is in there. I also sent that whole section to you, (commenter 2 was referred to by name). I was hoping that you would respond back and correct the record if you felt --

56) Commenter 2: I don't remember getting it. I got a few questions; and like the first page, the first ten questions was missing. And I think I made a statement, I said, What is this?

(A community member is mentioned by name), a concern about her yard sinking; that is the first place I took you on the tour of the community -- was to (the individual is named again) house, where she was talking about a hole in her yard that she could never fill. And she was constantly putting grass, dirt, anything, trimmings from her yard. And that every time -- like in a few days that hole -- something was there. I didn't see that in the concerns at all. And that is what I am saying. Earlier concerns -- I get tired of going back over the same thing. And I am pretty sure the community people, too, that they get tired of going back over and over and over. People are just not going to meet like that.

Once we say something, it is over with. And I don't know -- I don't know about this agency anymore. I don't. We didn't have faith in the beginning, so it wasn't a disappointment because of what had happened earlier. But at least we was thinking that -- and I know Barry Johnson is gone. He is the one that said this needs a look at. You know I just feel sorry for you all that you can't see things the way that we do. And it looks like that you are looking through rose-colored glasses.


The concern from this individual was mentioned in concern #25 on page 42 of the document.

57) Commenter 2: It is, they got the data. We don't want to hear what the community is saying; their data, since it is verbal, it doesn't mean anything. If we write it down, it still don't mean anything. The tapes of the workers, they made statements of how they poured chemicals down the drains, how they poured chemicals in the pond, and, apparently, it doesn't mean anything.

DR. CRELLIN: As far as the statements from the workers, I did not -- was not given a copy of that tape or allowed to see that tape until about ten days ago. And so I did not have the opportunity to incorporate that into --

Commenter 2: But you did see the tape of the workers before.

DR. CRELLIN: Until 2 weeks ago, no, I did not.

Commenter 2: I am talking about now. You have seen the full tape?

DR. CRELLIN: Yes, I have seen the full tape, yes.

Commenter 2: Okay. That's fine.

DR. CRELLIN: I protested about it, and I finally got a copy from --

Commenter 2: I want to tell you, they ain't going to meet with you no more. They are not going to meet with anyone anymore, unless they read -

DR. CRELLIN: They don't want --

Commenter 2: The response came to me, "(Commenter 2 identified herself), they wouldn't help us then, so why are we wasting our time now?"

Commenter 8: ATSDR did that meeting. Aren't you working together? Isn't it one agency? Are we supposed to believe that they care about us? They wouldn't even give us the tape. (Commenter 2 was named) tried to get --

Commenter 2: I got it now.

Commenter 8: How long did it take you to get that tape?

Commenter 2: Over six months.

Commenter 8: What's going on? They wouldn't give you this tape until ten days ago?

DR. CRELLIN: I don't know. You have to ask the people at --


As indicated in the response to comment 41, ATSDR considers the community a valuable and valid archive in evaluating the possible health impact of a site. ATSDR conducts a careful evaluation whenever it receives specific information on possible exposures from community members.

Now that the health assessor has had the opportunity to review the video of the meeting with the former DDMT workers, a summary of these concerns is included on page 43 of this document.

58) Commenter 2: See, what has happened with workers is there has been retaliation on government jobs. And we heard this all over the country. Fordor (phonetic) was one example, and Oakridge especially, and Paducah; these are called the whistle blowers, when an employee stands up and says, "You are wrong," they are blackballed from decent government jobs. And the retaliation is so severe all over this country that even we have asked ATSDR to intervene and to give that as a comment to the Labor Board to ask the Labor Board to come forward. I know you can't do anything about it. But you can give a recommendation, and somebody will look at it. And they will say "Dag, people come in and talk" -- that is the reason why they won't talk. They are afraid of the retaliation. Because (a former worker was named) was massively persecuted by the DLA before -- she had to just quit. And it wasn't her; it was other workers that when they you found out there was talking, they don't have a decent job now. Since that place closed, they don't have decent government jobs now. But the white folks have.


ATSDR's Office of Urban Affairs is working with the former DDMT employees.

Commenters 1, 2, 4, 5, 7, and 8 plus 3 other individuals began to leave the meeting indicating that they were leaving in protest.

DR. CRELLIN: ... Before you go, (commenter 1 was identified by name),... Could you please -- you mentioned a comment about another drainage than this one existing now. And I didn't quite understand where it was. Could you point to that on the map and show me where it is?

59) Commenter 1: (Indicating a location on a map of the DDMT area that was being projected on a wall in the meeting room.) Right there. This is Boyle Avenue. You keep going. There is a huge drainage ditch. It is big enough for a horse to get in.

DR. CRELLIN: Thank you.

Commenter 2: These drainage ditches here (indicating the drainage from the northeast corner of the DDMT Main Facility), you got them going that way, but they come down. And they used to flood.... My husband used to work over here and the lane used to flood. You got it like it is going one way. And it doesn't go that way. It goes underground. It's got spires that goes all the way out to the community now. But it used to just go over the people.


These concerns about drainage by these two commenters were responded to on pages 112 and 117.

DR. CRELLIN: (Identifying commenter 3 by name), I addressed your comment this afternoon. Did I need to say more than what I said this afternoon?

60) Commenter 3: Fine with me.


DR. CRELLIN: The idea about sending a list -- you made a comment about sending -- to send something out to have people send their concerns back, or whatever. I'll think about that. That is a constructive idea. I'm not sure how far -- again, the problem gets back to what impact does it have now upon the situation, other than the -- yes, it does document a lot of concerns. But as far as the purpose of the agency -- and basically we deal with now and the future, my division. But I will have to think about it. It seems like a worthwhile thing to do, as far as to see how much concern we have from people. It includes basically everybody that is within a half mile of the site. (This question was directed to the community involvement specialist for DDMT.) Isn't your mailing list everybody within a quarter mile or half mile --

DDMT community involvement specialist: A mile.


61) Commenter 3: My statement along that line, as you see, there are obviously strong, strong feelings about the study. A lot of people have put a lot more work in on this study than I have. And I respect (naming commenter 1 and 2). They have been active since 1995. And I respect their concerns, and I am sure they are legitimate. And my only concern is we have to make every effort, extra effort, and above effort to try to reach out and touch the community in more than normal methods. And that is why I would like that sent out to former residents, current residents on the mailing list to let them know, You don't have to worry about losing your job, the depot is closed now; you don't have to worry about somebody saying this or that. Bring us your concerns, send it to them, and we will try our best to address it.


As indicated earlier in these responses to comments, ATSDR has offered Howard University the use of its mailing list to essentially accomplish what the commenter is suggesting. Howard decided not to use the list at this time because of time constraints but will consider its use in the future.

62) Commenter 9: ... What about the hazardous waste material in the area? Has there been --

DR. CRELLIN: In which area?

Commenter 9: The defense depot area, over by Ball Road.


DR. CRELLIN: The buildings that I am displaying here (pointing to a map being projected on the wall that displayed information similar to that on Figure 2) -- and you see I am not displaying all the buildings that used to be there -- these are essentially the buildings where at least sometime in the past hazardous materials were handled. And one of the things that I do here is that with data that we have about the site, it basically shows the different places where arsenic was sampled on the site and the levels that were found. (This information is similar to that on Figure G1.) And that is in the document. It just doesn't relate all these things together.

Commenter 9: Was it a high content?

DR. CRELLIN: Of the arsenic?

Commenter 9: Yes.

DR. CRELLIN: There were a few locations, but, overall, no. Compared to other sites that I worked on in other places I have been, the levels of arsenic aren't especially high. There are lots of locations that have arsenic.

63) Commenter 9: Would it be feasible to build there or invest in the area --

DR. CRELLIN: On Ball Road or on the site itself?

Commenter 9: No. Ball Road area?

DR. CRELLIN: Would it be feasible to --

Commenter 9: -- feasible to invest money, per se, community centers, churches, day-care centers?


DR. CRELLIN: The data available to us, as far as the site having an impact on the neighborhood along Ball Road and basically south of the site, yes, you could build things there. Again, based on as far as the site data and what the site -- it doesn't mean that there aren't other sources of contamination or other reasons to build or either to not build there. But as far as the site, no there is no reason not to build there.

64) Commenter 9: What is the overall conclusion? That there is no contamination that could affect -- you know -- as to the -


DR. CRELLIN: The best data that we have and the data available to us indicates that, you know, the people off-site that -- from the data we have basically since 1989 -- that the levels weren't high enough to -- the levels of the site contaminants weren't high enough to harm the people that lived off the site. Before that, there is lots of uncertainty. And one of the things -- we had a number of people here before you came that expressed in quite a bit of detail their concerns about what happened in the past, their encounter with things that happened in the past, where they thought they saw chemicals coming down ditches in the area and that things were different. And in part, that is why we concluded that, because of those stories and, in part, because we simply don't know what the environmental levels were on the site or off the site much prior to 1989 -- that is why we concluded that we just can't make conclusions about that.

65) Commenter 9: A lot of people in the area had cancer. My brother-in-law died with cancer. And he lived at Ketchum and Crosby. All those houses are gone now. Two friends across the street, they got cancer. On that street it was like ten people developed cancer. But it was at Ketchum and Crosby, from Ketchum and Crosby up to Pecan Circle, off of Ketchum. And that was back -- he died in 1982.


Thanks for the information.

Facilitator: Then I guess we will officially close the meeting. But Dr. Crellin can stay later if you have any last minute things. Or if there are any notes to hand in, just pass them up front. And of course, until the 31st, submit written comments, if you have any other questions or comments, to the agency. Thank you very much for attending.

Comments Received in Writing from the Public

These comments were submitted in writing from a member of the Memphis RAB who worked for the Depot and lived in the area for many years.

For the record, I found the Agency for Toxic Substances and Disease Registry (ATSDR) Public Hea1th Assessment update to be thorough and comprehensive - it certainly addresses all areas of major concern.

I find that you have presented your findings very clearly, along with supporting figures, charts and tables. I was impressed with your response to the Community Health concerns, pages 31 through 42.

First of all, would like to present some background information to address an issue that is re- occurring continually. Is the general public raising the health issue question (cancer cluster area) in the surrounding Depot community? This issue causes me great concern and I try to look at it in an objective way, being a good listener with an open mind.

.... I retired from the Defense Depot Memphis ... after 27 years of highly dedicated work for the U.S. Department of Defense. Over this period of time, I have vast knowledge of what has transpired there. Also, in the early years, especially before the Environmental Protection Agency was formed in 1970, I feel at times I worked under adverse environmental working conditions. ... From 1964 to 1996 (32 years), I lived within one mile of the Defense Depot Memphis.

In review of my comments on July 10, 1996, regarding the "Environmental Baseline Survey Report,'' potential contamination areas, I quote:

"Looking at many of the general purpose warehouses, and under visual evidence of contamination, the phrase "Potential Fumigation'' is used. In addition, another phrase "No data exists to determine if buildings were fumigated or the impact of fumigations''. The buildings were fumigated two timed a year (some say fogged) by highly trained personnel during warm months (April through September) and the majority (95%) was conducted over the weekend (usually Saturday and Sunday). Occasionally, some residue was noticeable on material (on top of cardboard cartons), and also in transportation aisles. If you could see a small area that looked slightly white, this had to be cleaned up because it was slick and could cause an accident.

"In warehouse 549, Section 5, regarding fumigation chamber (Methyl Bromide) when used clothing and bedding was returned from bases for credit, it was mandatory to process this material through the gas compression chamber before reissue as condition "B" material.''

For 19 years, I worked in warehouse 630, just west of the building was the dipping vat where pallets were treated with Pentachlorophenol (PCP).

Every 10 years, the foundation of the 20 typicals were treated with chlordane and every year along the transportation aisles beneath the pallets the building was treated with pesticides (Chlordane, DDT or Dieldrin) until such times their use was banned.

I have tried to compare myself working within the Defense Depot to citizens living in the surrounding community. I feel that I had an opportunity to come into contact through dermal, ingestion or inhaling exposure, however based upon the toxicity level at the contaminants they were low, therefore it appears unlikely that my workplace posed a threat to my health. I must say with all my honesty that I have been blessed with good health.

Reflecting back to previous meetings, the citizens of the Defense Depot Community seemingly reiterate that the U.S. Army built the Depot in the very early 1940's and encroached upon the community in an environmental way, that has harmed the community health wise by indicating the high rate of cancer cases reported in the area.

In my review of the environmental test data made available by the United States Environmental Protection Agency (EPA), the Tennessee Department of Environment and Conservation (TDEC) and the U.S. Engineers (Environmental Contractors) from sampling locations offside, it shows contamination at a low level and considering a long term risk assessment (period of 30 years), it's highly unlikely there is a health risk threat to citizens of the community.

On June 14, 1996, Mr. Larry J. Smith, Director of the Mid-South Peace and Justice Center and also the Community Co-chair of the RAB, wrote a letter to Dr. Dan J. Spariosu, U.S. Environmental Protection Agency, Region 4, outlining how the Depot community became segregated by a method called redlining. Enclosed is a copy of the letter.

As a strong rebuttal to redlining by Banks, there is another side to this issue in the form of a drab to the Mayor of the City of Memphis and the City Council, to adopt into an ordinance for the Memphis landmarks Commission. The Memphis City Council Agenda for November 4, 1997, in reference to Item #58, showed the vote was unanimous to adopt the ordinance.

"Despite a vast number of rehabilitations in Midtown and several high profile downtown development projects, population continues to shift to suburbia. Out migration from the urban core has exacerbated residential segregation according to economic class. Core areas have increased concentrations of lower income populations, although there are numerous exceptions to this generalization with enclaves of high and low-income populations in all areas. An important result of this population shift has been the tendency of businesses to follow the higher income population. Retail and consumer service businesses have been especially likely to leave the urban core for regional and strip malls, arterial nodes, ribbon developments, and specialized functional areas. These offer greater visibility and convenience to the suburban consumer.''

"Historically, Memphis has not had a particularly strong industrial base. However, today Memphis is seen as attractive for industry because of its location, competitive wage rates, and quality of life. Unfortunately, to date, industry has largely located outside the urban core. The result has been that low income inner city residents have been less likely to enjoy the benefits of the new employment opportunities.''

To be very candid, one can contribute their best work in reviving the conscience of the people on matters of social justice and in drawing their attention to the past policies of the U.S. Department of Defense, the United States Environmental Protection Agency and the Tennessee Department of Environment and Conservation so that the ordinary man and woman might remain economically and environmentally free in spite of great combinations of wealth or poverty.

Always remember, an individual should remain unafraid of tradition, and unafraid of change and accept the scientific data made available by the Base Realignment and Closure (BRAC) Base Cleanup Team (BCT) and face reality and often times the truth is painful to bear; only then the residents of the Defense Depot Memphis Community can put forth their most strenuous action as human dynamo in search of their common goals.

I trust that the ATSDR'' Public Hea1th Assessment update will bring a closure to health issues reported within the Depot community that will be truly acceptable by all concerned.

Being a concerned citizen and also a Restoration Advisor Board Member at DDMT, I consider it an honor and a privilege to have the opportunity to comment on this very important public health assessment update.

Here is the attachment to these comments.

June 14, 1996

Mr. Dan J. Spariosu
3.45 Courtland Street N.E.
Atlanta Georgia 30365

Re: Environmental Justice Issues relating to the Depot

The subject of environmental justice has become a buzz word over the last couple of years, but the issue has been around for a long time. When you talk about Memphis, you cannot discuss the term without understanding segregation and how it was implemented. One method was called red lining. It was an open and understood practice for banks to either cut off mortgage money in a neighborhood or conversely only offer African Americans mortgage money in a certain neighborhood. This is where the term ''red lining'' comes from. If you lived on one side or the other of the line, you either did or did not get credit, depending of on the bank's plans for your community.

In 1942 the Depot was located in an area known as Civil District 8. It had 1,716 people of unknown race living in a large area running from Person south to Nonconnah and from Airways over to Mississippi Blvd. In 1950, the civil district had been changed to census tract 78 and it had 2,626 black and 2,764 white. If this trend continued a "normal'' growth pattern could be assumed. Meaning people lived where they wanted to with no outside influence due to their race. But this is not the case, by 1960 the population was 10,342 black and 2,637 white; and by in 1970, it was 15,943 and 1,838 white. In 1980, census tracts 78.20 and 78.10 were born. 78.10 became the industrial tract with 4,648 blacks and 92 whites occupying it and 78.20 became the black residential area with 10,595 blacks and 741 whites in it. In 1990, tract 78.20 had nearly become de-populated, 561 blacks and 65 whites and 78.10 was declining at 4,150 blacks and 22 whites.

Race lines are not a comfortable thing for White people to reminisce about. As time goes by and the races move further and further apart the old lines become blurred and forgotten. The races lived much closer together in 1950 than they do now. But segregation was no less a fact, a quick look at census tracts 60 and 75 which adjoin each other will illustrate this. In 1950, census tract 75 was 243 blacks and 1,739 whites and census tract 60 was 2,407 blacks and 502 whites. Between 1960 and 1970, something happened. The whites not only left census tract 60 but a huge migration took place in census 75 so that by 1970, census tract 75 was 3,381 black and 137 white. Red line!

1950 census tract 75 was 243 black and 1,739 white.

1970 census tract 75 was 3,381 black and 137 white.

I have set the stage for the development of the community around the Depot to show that environmental justice is not just a lot of whining but a reality tied to racism in all its forms. The idea that the African American community wanted to live around the Depot is blind to fact that African Americans lived where they were permitted and no where else. Noxious and dangerous industries were cited in black neighborhoods or black neighborhoods were constructed next to noxious dangerous industries, what is the difference in a segregated society?

I also mention all the above to put the decisions that must be made today into context. What is to be done with the Depot site should not be planned with the assumption that the nearby community is happy with the way things were and will blindly accept what is proposed in the future. The economic well-being of the larger community does not have to come at the expense of the nearby community.

The primary EJ issues regarding the Depot are,

1. the level of clean up and investigation proposed for the entire site,

2. the fate of Dunn field and those who live next to it and,

3. the types of uses the facility will be put to in the future.

In reverse order,

A newsletter should be sent to everyone within one half mile of the facility. Ms. Sue Estes has the list and has done a fine job of this before. This newsletter should lay out the options for reuse of the facility and what is being seriously considered for the site. Also it should invite the public to let the reuse committee know of their concerns. I personally think a commitment should be made to allow only non-polluting industries on the site.

New emphasis should be placed on the clean up and removal actions once planned for Dunn Field. The piles of fluorspar and bauxite should be removed at all cost. These piles serve as a constant reminder of what was left behind by the Defense Department when they left town. The residents who must look at those piles everyday should not have this view to remind them.

In regards to the portions of the site that will be reused, a thorough and vigorous investigation should be performed for each parcel deemed suitable for leasing or sale. This will insure that property is not occupied over contaminated sites. It will also avoid the confusion and delay in determining the source of the contamination if the occupier also happens to have toxic substances on site. If a commitment is made to use only non polluting companies then this is less of a problem.

The Dunn Field removal action should be given equal funding and priority with the base reuse efforts. Vigorous contacts should be made regarding the final disposition of the chemical test kits buried in Dunn Field. The removal action should then move forward with all haste.

Larry J. Smith
Cc-chair RAB Memphis Depot

cc: Ms. Chris Kartman, Ms. Sue Estes

End of attachment


Thanks for the information and for the complement. Some of the information provided will be referred to the public health assessment.

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