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FACILITY NO. TN6210020933

September 7, 2004

Appendix E : ATSDR Glossary of Environmental Health Terms

The Agency for Toxic Substances and Disease Registry (ATSDR) is a federal public health agency with headquarters in Atlanta, Georgia, and 10 regional offices in the United States. ATSDR's mission is to serve the public by using the best science, taking responsive public health actions, and providing trusted health information to prevent harmful exposures and diseases related to toxic substances. ATSDR is not a regulatory agency, unlike the U.S. Environmental Protection Agency (EPA), which is the federal agency that develops and enforces environmental laws to protect the environment and human health.

This glossary defines words used by ATSDR in communications with the public. It is not a complete dictionary of environmental health terms. If you have questions or comments, call ATSDR's toll-free telephone number, 1-888-42-ATSDR (1-888-422-8737).

Occurring over a short time [compare with chronic].

Acute exposure
Contact with a substance that occurs once or for only a short time (up to 14 days) [compare with intermediate duration exposure and chronic exposure].

Adverse health effect
A change in body function or cell structure that might lead to disease or health problems

Surrounding (for example, ambient air).

Background level
An average or expected amount of a substance or radioactive material in a specific environment, or typical amounts of substances that occur naturally in an environment.

Decomposition or breakdown of a substance through the action of microorganisms (such as bacteria or fungi) or other natural physical processes (such as sunlight).

Any one of a group of diseases that occur when cells in the body become abnormal and grow or multiply out of control.

Cancer risk
A theoretical risk for getting cancer if exposed to a substance every day for 70 years (a lifetime exposure). The true risk might be lower.

A substance that causes cancer.

CERCLA [see Comprehensive Environmental Response, Compensation, and Liability Act of 1980]

Occurring over a long time [compare with acute].

Chronic exposure
Contact with a substance that occurs over a long time (more than 1 year) [compare with acute exposure and intermediate duration exposure]

Comparison value (CV)
Calculated concentration of a substance in air, water, food, or soil that is unlikely to cause harmful (adverse) health effects in exposed people. The CV is used as a screening level during the public health assessment process. Substances found in amounts greater than their CVs might be selected for further evaluation in the public health assessment process.

Completed exposure pathway [see exposure pathway].

Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA)
CERCLA, also known as Superfund, is the federal law that concerns the removal or cleanup of hazardous substances in the environment and at hazardous waste sites. ATSDR, which was created by CERCLA, is responsible for assessing health issues and supporting public health activities related to hazardous waste sites or other environmental releases of hazardous substances. This law was later amended by the Superfund Amendments and Reauthorization Act (SARA).

The amount of a substance present in a certain amount of soil, water, air, food, blood, hair, urine, breath, or any other media.

A substance that is either present in an environment where it does not belong or is present at levels that might cause harmful (adverse) health effects.

Referring to the skin. For example, dermal absorption means passing through the skin.

Dermal contact
Contact with (touching) the skin [see route of exposure].

Detection limit
The lowest concentration of a chemical that can reliably be distinguished from a zero concentration.

United States Department of Defense.

Dose (for chemicals that are not radioactive)
The amount of a substance to which a person is exposed over some time period. Dose is a measurement of exposure. Dose is often expressed as milligram (amount) per kilogram (a measure of body weight) per day (a measure of time) when people eat or drink contaminated water, food, or soil. In general, the greater the dose, the greater the likelihood of an effect. An "exposure dose" is how much of a substance is encountered in the environment. An "absorbed dose" is the amount of a substance that actually got into the body through the eyes, skin, stomach, intestines, or lungs.

Environmental media
Soil, water, air, biota (plants and animals), or any other parts of the environment that can contain contaminants.

Environmental media and transport mechanism
Environmental media include water, air, soil, and biota (plants and animals). Transport mechanisms move contaminants from the source to points where human exposure can occur. The environmental media and transport mechanism is the second part of an exposure pathway.

United States Environmental Protection Agency.

The study of the distribution and determinants of disease or health status in a population; the study of the occurrence and causes of health effects in humans.

Contact with a substance by swallowing, breathing, or touching the skin or eyes. Exposure may be short-term [acute exposure], of intermediate duration, or long-term [chronic exposure].

Exposure pathway
The route a substance takes from its source (where it began) to its end point (where it ends), and how people can come into contact with (or get exposed to) it. An exposure pathway has five parts: a source of contamination (such as an abandoned business); an environmental media and transport mechanism (such as movement through groundwater); a point of exposure (such as a private well); a route of exposure (eating, drinking, breathing, or touching), and a receptor population (people potentially or actually exposed). When all five parts are present, the exposure pathway is termed a completed exposure pathway.

Feasibility study
A study by EPA to determine the best way to clean up environmental contamination. A number of factors are considered, including health risk, costs, and what methods will work well.

Water beneath the earth's surface in the spaces between soil particles and between rock surfaces [compare with surface water].

A source of potential harm from past, current, or future exposures.

Hazardous waste
Potentially harmful substances that have been released or discarded into the environment.

Health consultation
A review of available information or collection of new data to respond to a specific health question or request for information about a potential environmental hazard. Health consultations are focused on a specific exposure issue. Health consultations are therefore more limited than a public health assessment, which reviews the exposure potential of each pathway and chemical [compare with public health assessment].

Indeterminate public health hazard
The category used in ATSDR's public health assessment documents when a professional judgment about the level of health hazard cannot be made because information critical to such a decision is lacking.

The act of swallowing something through eating, drinking, or mouthing objects. A hazardous substance can enter the body this way [see route of exposure].

The act of breathing. A hazardous substance can enter the body this way [see route of exposure].

Intermediate duration exposure
Contact with a substance that occurs for more than 14 days and less than a year [compare with acute exposure and chronic exposure].

Lowest-observed-adverse-effect level (LOAEL)
The lowest tested dose of a substance that has been reported to cause harmful (adverse) health effects in people or animals.

Moving from one location to another.

Minimal risk level (MRL)
An ATSDR estimate of daily human exposure to a hazardous substance at or below which that substance is unlikely to pose a measurable risk of harmful (adverse), noncancerous effects. MRLs are calculated for a route of exposure (inhalation or oral) over a specified time period (acute, intermediate, or chronic). MRLs should not be used as predictors of harmful (adverse) health effects [see reference dose].

National Priorities List for Uncontrolled Hazardous Waste Sites (National Priorities List or NPL)
EPA's list of the most serious uncontrolled or abandoned hazardous waste sites in the United States. The NPL is updated on a regular basis.

No apparent public health hazard
A category used in ATSDR's public health assessments for sites where human exposure to contaminated media might be occurring, might have occurred in the past, or might occur in the future, but where the exposure is not expected to cause any harmful health effects.

No-observed-adverse-effect level (NOAEL)
The highest tested dose of a substance that has been reported to have no harmful (adverse) health effects on people or animals.

No public health hazard
A category used in ATSDR's public health assessment documents for sites where people have never and will never come into contact with harmful amounts of site-related substances.

NPL [see National Priorities List for Uncontrolled Hazardous Waste Sites]

A volume of a substance that moves from its source to places farther away from the source. Plumes can be described by the volume of air or water they occupy and the direction they move. For example, a plume can be a column of smoke from a chimney or a substance moving with groundwater.

Point of exposure
The place where someone can come into contact with a substance present in the environment [see exposure pathway].

A group or number of people living within a specified area or sharing similar characteristics (such as occupation or age).

Parts per billion.

Parts per million.

Public availability session
An informal, drop-by meeting at which community members can meet one-on-one with ATSDR staff members to discuss health and site-related concerns.

Public comment period
An opportunity for the public to comment on agency findings or proposed activities contained in draft reports or documents. The public comment period is a limited time period during which comments will be accepted.

Public health action
A list of steps to protect public health.

Public health assessment (PHA)
An ATSDR document that examines hazardous substances, health outcomes, and community concerns at a hazardous waste site to determine whether people could be harmed from coming into contact with those substances. The PHA also lists actions that need to be taken to protect public health [compare with health consultation].

Public health hazard
A category used in ATSDR's public health assessments for sites that pose a public health hazard because of long-term exposures (greater than 1 year) to sufficiently high levels of hazardous substances or radionuclides that could result in harmful health effects.

Public health hazard categories
Public health hazard categories are statements about whether people could be harmed by conditions present at the site in the past, present, or future. One or more hazard categories might be appropriate for each site. The five public health hazard categories are no public health hazard, no apparent public health hazard, indeterminate public health hazard, public health hazard, and urgent public health hazard.

Public meeting
A public forum with community members for communication about a site.

RCRA [see Resource Conservation and Recovery Act (1976, 1984)]

Reference dose (RfD)
An EPA estimate, with uncertainty or safety factors built in, of the daily lifetime dose of a substance that is unlikely to cause harm in humans.

Remedial investigation
The CERCLA process of determining the type and extent of hazardous material contamination at a site.

Resource Conservation and Recovery Act (1976, 1984) (RCRA)
This Act regulates management and disposal of hazardous wastes currently generated, treated, stored, disposed of, or distributed.

RCRA Facility Assessment. An assessment required by RCRA to identify potential and actual releases of hazardous chemicals.

RfD [see reference dose]

Route of exposure
The way people come into contact with a hazardous substance. Three routes of exposure are breathing [inhalation], eating or drinking [ingestion], or contact with the skin [dermal contact].

Safety factor [see uncertainty factor]

SARA [see Superfund Amendments and Reauthorization Act]

A portion or piece of a whole. A selected subset of a population or subset of whatever is being studied. For example, in a study of people the sample is a number of people chosen from a larger population [see population]. An environmental sample (for example, a small amount of soil or water) might be collected to measure contamination in the environment at a specific location.

Source of contamination
The place where a hazardous substance comes from, such as a landfill, waste pond, incinerator, storage tank, or drum. A source of contamination is the first part of an exposure pathway.

Special populations
People who might be more sensitive or susceptible to exposure to hazardous substances because of factors such as age, occupation, sex, or behaviors (for example, cigarette smoking). Children, pregnant women, and older people are often considered special populations.

A chemical.

Superfund [see Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) and Superfund Amendments and Reauthorization Act (SARA)

Superfund Amendments and Reauthorization Act (SARA)
In 1986, SARA amended the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) and expanded the health-related responsibilities of ATSDR. CERCLA and SARA direct ATSDR to look into the health effects from substance exposures at hazardous waste sites and to perform activities including health education, health studies, surveillance, health consultations, and toxicological profiles.

Surface water
Water on the surface of the earth, such as in lakes, rivers, streams, ponds, and springs [compare with groundwater].

Toxicological profile
An ATSDR document that examines, summarizes, and interprets information about a hazardous substance to determine harmful levels of exposure and associated health effects. A toxicological profile also identifies significant gaps in knowledge on the substance and describes areas where further research is needed.

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

Urgent public health hazard
A category used in ATSDR's public health assessments for sites where short-term exposures (less than 1 year) to hazardous substances or conditions could result in harmful health effects that require rapid intervention.

Volatile organic compounds (VOCs)
Organic compounds that evaporate readily into the air. VOCs include substances such as benzene, toluene, methylene chloride, and methyl chloroform.

Other glossaries and dictionaries:
  • Environmental Protection Agency (

  • National Center for Environmental Health (CDC) (

  • National Library of Medicine (NIH) (

  • For more information on the work of ATSDR, please contact:
    Office of Policy and External Affairs
    Agency for Toxic Substances and Disease Registry
    1600 Clifton Road, N.E. (MS E-60)
    Atlanta, GA 30333
    Telephone: (404) 498-0080

Appendix F : Response to Public Comments

The Public Health Assessment (PHA) for the Volunteer Army Ammunition Plant was published on May 20, 2004 and available for public review through July 7, 2004. Copies of the PHA document were mailed to the residents who attended and signed in at the Public Availability Session on June 14, 2001. Copies were also provided to the residents and agencies that are members of the Volunteer Army Ammunition Plant Restoration Advisory Board (RAB). ATSDR also provided an overview of the evaluation process and the results, and addressed questions from the community during the RAB meeting on June 17, 2004.

ATSDR received four sets of written comments, some of whom were past employees. The following section provides both the comments we received and the ATSDR response. Some of the comments paraphrase or summarize the original submission.

1) The PHA is not what I expected. I thought it would finally address the medical consequences of actions at VAAP. I suggest you look into the actual maladies that have resulted from VAAP operations. This might be accomplished by analyzing doctor and hospital records in Hamilton County to compare them with a county without the benefit of VAAP. You might use a population of local school children to study the long term effect of exposure to VAAP. Long-term effects could be studied by observing the adult conditions of the children who were exposed at the schools. Workers at the plant could be studied to see if statistically some diseases were induced by plant operations.

The purpose of this public health assessment (PHA) was to identify the potential exposure of local residents to environmental contaminants released at VAAP and evaluate if those exposures would be expected to affect public health. This PHA uses information about the past activities at VAAP and the results of environmental sampling conducted at VAAP and the surrounding area to evaluate the potential exposure of local residents to contaminants released by VAAP to the air, soil and groundwater. Results indicate that the most significant potential exposures were eliminated approximately 10 to 30 years ago when the Army began supplying bottled water to neighboring residents because some private groundwater wells had been impacted by VAAP-related contaminants and when the TNT and ammonia nitrate production ended (please see text for details). Unfortunately the available environmental information is not sufficient to identify if local residents were exposed to contaminants at levels that are known to cause health effects.

One of the primary reasons ATSDR conducts health studies of communities is when the results can be used to prevent or mitigate a known or suspected exposure that could cause health effects (ATSDR 1996). For the community surrounding VAAP, the potential exposures of concern have been eliminated. In addition, to provide useful information the health study must be able to identify and evaluate the relationship between the exposure dose (the concentration of the contaminant the community was exposed to and the time duration and frequency of the exposure) and the potential health effect (ATSDR 1996). For the VAAP community, there is not enough information available to estimate the potential exposure dose. As a result it is not possible to identify if a relationship exists between the potential past exposure of the VAAP community and the health concerns of the community.

While it is unfortunate that more information is not available that could be used to complete a meaningful health study, it is important to remember that the most significant potential exposures have been eliminated.

2) The conclusions of the PHA state there is an indeterminate health problem for some exposures at VAAP. This infers that we still do not know the condition we must remediate. Because of the long-term exposure to people of the area, the people provide the primary study vehicle to see if any actual medical problems were caused. If none were caused in the fifty or so years since the plant operated, can we conclude that they are not likely to be caused in the future now that the plant is closed?

The 'indeterminate' categorization is applied to the potential exposure situations that could not be fully evaluated due to insufficient information. Two of these potential exposures have been eliminated. With the end of TNT and ammonia nitrate production, the potential exposure to the 'acid clouds' was eliminated in the mid-1970's and early-1980's. The potential exposure to VAAP-related contaminants was eliminated in the mid-1990's when the Army began supplying bottled water to local residents using private groundwater wells impacted by VAAP-related contaminants. The only current potential exposure for residents that was categorized as 'indeterminate' was for swimming pools filled from groundwater wells. It was not possible to completely evaluate if children who swam daily in a pool filled from a groundwater well with the highest measured concentration of lead could be exposed to lead at higher than recommended levels. In this case, parents of children who swim frequently in pools filled from groundwater wells with high concentrations of lead may want to consider testing the pool water for the lead concentration.

Results of this evaluation indicate there no current exposures to the local community from VAAP-related contaminants that would be expected to cause health problems. Based on environmental investigations and remediations planned and completed by the Army in conjunction with the Tennessee Department of Environmental Quality, EPA and Restoration Advisory Board, ATSDR expects that the future users of VAAP will also not be exposed to VAAP-related contaminants at levels that could cause health problems.

3) The public needs to know if VAAP operations did cause human damage or can cause human damage in the future.

The available information indicates there are no current exposures to the local community from VAAP-related contaminants that would be expected to cause health problems. In addition it is also expected that future users of VAAP, following the complete transfer of the property, will not be exposed to VAAP-related contaminants at levels that could cause health problems. However, there is not enough information to evaluate whether people were exposed in the past at levels that would have caused illness or harmful effects.

In order to provide some additional perspective on the health status of Hamilton County compared with other portions of the state and Tennessee as a whole, ATSDR reviewed site-specific cancer mortality data compiled by the National Center for Health Statistics (NCHS). Cancer was selected as the health outcome indicator of choice because it is one of the most reliable and often used datasets for surveillance and reporting is mandatory throughout the state. ATSDR selected only those cancer sites that, based on the literature, may be linked to some of the contaminants detected at VAAP. It is important to emphasize that it is not possible to identify if any environmental or personal behavioral factors influenced the reported cancer rates, or link county level mortality data to historical contaminant releases at VAAP. We have, however, provided this information as a way of identifying any unusual observations, patterns, or large differences among the selected counties and/or the selected cancer sites. The available data suggests that the cancer mortality rate for Hamilton County is similar to other large Tennessee counties and the state in general.

Table 1 is based on available demographic and socio-economic information for each of the counties in Tennessee. ATSDR gathered this information to identify the similarities and differences between Hamilton County and two other counties in Tennessee. Table 2 presents standardized mortality rates for males and females from bladder and lung cancer, leukemia, and non-Hodgkin lymphoma for each of the three counties and the entire state. These four cancer types were chosen because some research suggests the risk for those cancers may be higher for people exposed to very high concentrations of some of the chemicals identified in VAAP environmental samples. The mortality rates in Hamilton County for the cancer sites shown are generally very similar to those of the other two counties as well as the state as a whole.

It is important to remember that while some research suggests the risk developing these cancers may be increased for people exposed to very high concentration of some of the chemicals identified in VAAP environmental samples, it is not possible to identify if a particular case of cancer could be the result of environmental exposure to one or more of these chemicals. Additionally, there are other established risk factors that may contribute to the development of the selected cancers. For example, cigarette smoking increases the risk of both bladder and lung cancer, and possibly leukemia and non-Hodgkin's Lymphoma. Many occupations are also associated with an increased risk for one or more of these cancers including industries associated with chemical manufacturing or use of large amounts of chemicals (synthetic dyes and rubber, pesticides, and solvents). In addition, personal factors such as a genetic predisposition or personal disease history may increase a person's risk factor for a specific disease. People with suppressed immune systems (due to HIV/AIDS or a solid organ transplant) may be at higher risk to leukemia or Non-Hodgkin's Lymphoma (American Cancer Society 2003, 2004a and 2004b, Freeman Hospital 1996, Lung Cancer 2004).

Table 1: Population and Demographics for Selected Tennessee Counties
County Characteristics: Measures of size, population density, and industrial and commercial activity.
Based on the 2000 Census Figures1
Hamilton Davidson Shelby Tennessee
[sq. miles]
542 502 755 41,217
Total Population 307,896 569,891 906,178 5,689,283
Population Density
567.6 1,134.6 1,189.4 138.0
Population Increase (1990 to 2000)
7.8% 11.6% 8.6% 16.7%
Manufacturer's Shipments (1997)
5,496,190 6,721,810 11,758,677 98,503,080
Per-capita Retail Sales(1997)
11,084 14,440 10,359 9,448
Per-capita Income(1997) $21,596 $23,069 $20,856 $19,393
1. Data from U.S. Census Bureau, State and County Quick Facts (

Table 2: Reported Site-Specific Cancer Mortality Data for Selected Tennessee Counties
County Characteristics: Measures of age adjusted mortality rates.
Based on the National Vital Statistics System1
Hamilton Davidson Shelby Tennessee
Lung Cancer
Non-Hodgkin Lymphoma
1. Mortality data are provided by the National Vital Statistics System ( at the National Center for Health Statistics of the Centers for Disease Control and Prevention. Population counts for denominators in the calculation of rates are from the U.S. Census Bureau. Data represent the Annual Death Rate per 100,000 people reported between 1997 and 2001.

4) The following comments were accompanied by copies of various newspaper articles, a letter detailing the waste water pollutant criteria agreed to by the Army and a copy of the 1963 water quality criteria for the state of California for explosives, nitrotoluene and TNT.

As a lifelong resident of the Tyner community and a twelve year employee of VAAP, I have considerable interest in this report.

The primary missions of the Volunteer Army Ammunition Plant were production of nitric and sulfuric acid, manufacture of trinitrotoluene and storage of military items during peacetime in case of future war. The magazines were mainly filled with TNT but sometimes contained other explosives and other items.

My parents and grandparents reported that World War II was the worst pollution, because acid clouds ate screen off the windows. Tyner was rural in the 1940's so the number of households affected was small. By the Korean War, scrubbers had been installed on the sulfuric acid plants so acidity was lessened. The brown oxides of nitrogen fumes vented from TNT production facilities were stinging and irritating when you went through a concentrated fog area. The oxides of nitrogen fumes usually went north up Waconda Valley or south down Hickory Valley. They did not often go east or west.

VAAP discharge process waste water effluent into Waconda Bay where there were numerous fish kills normally resulting from acid spills perhaps aided by over neutralization with lime which created a high basic reading that was just as deadly as the acid. An acidic ph of 2 required an accuracy of 1 in 10,000 to achieve neutrality or about 1 in 400 to stay in state guidelines of ph 6.5 to 8.5. It was impossible to instantaneously follow all the swings in an acid spill and prevent fish kills. The instrument mechanic foreman excitedly came in one day in 1970 saying we needed to control from a downstream ph probe (feed back). The chart recording the feed back probe would swing widely above and below neutrality (ph 7) but when buffered thru the two acre pond on the north side of Highway 58, water entering Chickamauga Lake would not vary a tenth of a ph unit from 7 in 24 hours even when significant acid spills occurred. Sediment and calcium sulfate from the neutralization would then fill the little reservoir. I believe a second buffering pond was added later so fish kills would not result when the pond was being cleaned.

The purification process washed TNT with sodium sulfate which reacted with unstable isomers to produce redwater whose spills sometimes completely colored Waconda Bay. It apparently took no more than one part per million concentration to cause this effect. I remember it was generally felt that most water soluble nitrobody was light sensitive and would turn red if exposed to bright sunlight.

Farmers Chemical apparently did not contribute significantly to the air pollution problem. Their waste water effluent went southward into Fryar's Branch in the Chickamauga Creek drainage. During most of their operation their waste water appeared to be untreated. I frequently hunted in the swamp just south of the Southern rail line (now CSX). Flow in the main creek had a brownish tint and a chemical odor. I doubted that there were any fish in the creek down to where it emptied into Chickamauga Creek near the airport. It was reported in the community that a herd of cows died from drinking from Fryar's Brach near Shallowford Road and Farmers Chemical had to pay damages. Farmers did not normally discharge to Waconda, buy when they cleaned their tanks the acid sludge was sent down the stream to 410-6 Neutralizer. Farmers acid sludge was very difficult to treat because the glassy looking water contained flocculated iron that turned muddy brown with lime was added.

The batch TNT lines had big wooden tubs filled with water located beside the process buildings to drown runaway charges. The discharge flowed onto the ground putting acid and nitrobody (that did not settle in the tub) on or into the soil. Most of the acid fumes from the batch process was vented directly into the atmosphere. The continuous TNT lines were constructed in the mid-1970's and included a collection and piping system to transport acidic water to a neutralization system. Virtually all the process acid fumes were collected and sent to the acid and fume recovery building. Elimination of the oxides of nitrogen was a costly operation. Burning them might create more nitrogen oxide because normal flame temperatures cause some nitrogen in the air to ionize. When the exhaust gases of TVA's Widows Creek steam plant stratify, the nitrogen oxide concentrates to make brown haze two or three thousand feet above the plant. This phenomenon is observable from the Interstate 24 bridge across Nickajack Lake several times a year. The modernized acid and fume recovery unit used a two stage combustion process that reduced flame temperature and minimized nitrogen ionization, but efficiency of steam production also suffered.

I am still amazed that the politicians abandoned the extensive storage network and the $100 million invested in modernized facilities at Volunteer Army Ammunition Plant.

Discharge of pollution into the air and water from VAAP ended long ago. There is little need to research long term health implications from VAAP's operation. The workers at the plant had the most contact with the contaminants. They not only were out in the acid fogs (that developed late at night and burned away by mid-morning) but also absorbed fumes and dusts inside the operating buildings when ambient conditions carried pollutants high into the sky. The twenty seven years since TNT production ceased in 1977 have not shown that former plant workers had health issues any different from those affecting the general population.

Chattanooga had at least two dozen foundries operating in 1970. Many had heavy emissions that created a particulate smog that affected the downtown and denser populated areas. There were other plants like the Alton Park herbicide facility that added contaminants. It would be difficult to determine responsibility for effects of pollution. There were also many companies fouling the water. Fish kills would occasionally originate well south of the Georgia line and wipe out all fish downstream to Chickamauga Creek's mouth just below Chickamauga Dam.

I have been asking for plant records with a particular interest in pictures of the residences that stood on the grounds in 1941. If VAAP land is cleaned up and no longer needed for Government use, it should be returned to the heirs of the individuals who had to sacrifice it to the Army in 1941 for $16.50 per acre including the value of houses and improvements which was well below market value (Hamilton Count Deed Book 824, page 373 - Condemnation of approximately 6,200 acres for $102,305.00 - September 29, 1941). Universally, the response was that such records were probably destroyed as if they were TNT contaminated waste. However, the comment at the June 17th Restoration Advisory Board meeting about one off site well showing lead contamination evoked my curiosity. I knew there had been a few small lead lined sumps on plant whose material was probably recycled long ago. Another former VAAP employee said when he first came on the plant there was an older fellow who had worked during initial construction in 1941 and 1942 who said tons of material like copper and lead were put in the ground for stabilization. Too bad the construction drawings, notes and records that should have been near the acquisition files were probably also destroyed. If they were available there might be clues about contaminants from initial construction and where they may be located.

The significant remaining known hazardous substance at VAAP is the nitrobody saturating soils starting 12 to 14 feet deep in the middle of the TNT valley. There is no practical way to hasten the breakdown. It is not presently threatening anyone and does not appear to be flowing off the site boundary in harmful concentrations. The erratic flow nature through karst geology makes assurances of removal of the nitrobody improbable. The massive effort to achieve quick removal should be ended. Samples should be analyzed every five years to document the natural attenuation.

Chattanooga Times, April 18, 1969 - Volunteer Plant May Be Affected by TCC Walkout.
Chattanooga Times, May 27, 1969 - Children Living in VAAP Area Prone to Illness
Chattanooga Times, Jan. 21, 1970 - Record Attained by Air Pollution
Chattanooga Times, March 12, 1970 - Chattanooga Ranks Strong First In Nation in Dirty Air Category
Chattanooga Times, Sept 11, 1970 - Better Than 10,000 Fish Are Killed In Chickamauga Creek in Last 2 Days
Chattanooga Times, Sept 4, 1970 - Plant Damage in Alton Park; Herbicide Blamed, Effects Widespread
Chattanooga Times, Sept 15, 1970 - Industry Cited As Contributor in Plant Death/Death of Plants Laid to Industry
Chattanooga Times, Sept 18, 1970 - City is Chosen for Study on Air Pollution Effects/Pollution Study to be Made Here
Chattanooga Times, Sept 26, 1970 - Respiratory Death Rate Blamed on Air Pollution; Oct 6 Meeting Will Give Citizens Opportunity to Express Opinions on Standards to Clear Skies of Contaminants
Chattanooga Times, Oct 3, 1970 - Smog Conditions Return to City
Chattanooga Times, Oct 7, 1970 - Area Air Quality Aims Too Low, State Group is Told at Hearing/Air Quality Goals Are Too Low, State Group Told
Chattanooga Times, Oct 11, 1970 - Pollution of the Air Changing Our Climate
Chattanooga Times, Oct 16, 1970 - Major Fish Kill Held Due in South Chickamauga/Fish Kill Due in Chickamauga
Chattanooga Times, Oct 16, 1970 - VAAP Denies Creek Soiled; Treated Waste Goes into Waconda Bay
Chattanooga Times, March 13, 1971 - Alert is Called as Air Pollution Becomes Heavy
Chattanooga Times Free Press, June 30, 2004 - Area Counties Cited for Unhealthy Air; Ruling by the U.S. Environmental Protection Agency Gives Violators, Including Seven Tri-State Counties, Until February to Submit Cleanup Plans/Pollution: Tri-State Counties Cited for Particles
Tennessee Division of Stream Pollution Control letter - April 15, 1971 - Re: Waste Treatment for VAAP Chattanooga, Tennessee
Water Quality Criteria (CA - 1963) - Sections on Explosives, Nitrotoluene, Toluene, and Trinitrotoluene

ATSDR used this information to update several sections of the PHA. The information from the letter was referenced as Public Comment 2004a. The information from the attachments was referenced to the specific article. The table at the end of this section summarizes the basic information presented in each attachment relevant to the VAAP Public Health Assessment.

Of particular interest were the articles describing planned or accomplished 'health studies' for the VAAP area. ATSDR was able to use that information to obtain copies of some of the study reports and EPA summaries. This information was used to update the sections discussing possible health effects from the acid cloud exposures.

Table 3: Summary of Information Presented in each Reference
Reference Information Relevant to the VAAP Public Health Assessment
Chattanooga Times
April 18, 1969
Suggests that ~75% of the oleum used at VAAP was actually made at Copperhill and transported to VAAP. This could reduce the estimate amount of sulfur oxide emissions described in the acid cloud evaluations (Appendix C).
Chattanooga Times
May 27, 1969
Results of evaluations on 2nd graders from areas with high concentrations of NO2 (VAAP) or particulates, and 'clean air' indicate VAAP students had more colds, coughs, sore throats and breathing problems while students from high particulate areas had more colds, coughs and sore throats than 'clean area' children.
Chattanooga Times
January 21, 1970
An air monitoring station on S. Broad St. reported a record high 24-hr concentration of particulates (788 µg/m3) on Jan 13, 1970. Downtown Chattanooga consistently has high ambient concentrations of particulates.
Chattanooga Times
March 12, 1970
Chattanooga is considered to be one of the nation's sites with the highest level of particulate air pollution. In addition it appears that the Farmers Chemical Co that was operating a fertilizer manufacturing plant on VAAP was trying to reuse some of the sulfuric acid that had been used to manufacture TNT.
Chattanooga Times
September 11, 1970
Approximately 10,000 fish were killed in South Chickamauga Creek due to poor water quality. A sport fishing group filed suit against 16 companies for pollution. One pipe dumping waste water to the creek apparently had no dissolved oxygen.
Chattanooga Times
September 4, 1970
Vegetation in Alton Park (~8 miles west of VAAP) appears to be damaged by herbicide in the air - possibly released from the S. Chattanooga area.
Chattanooga Times
September 15, 1970
Results of the investigation of the Alton Park vegetation damage indicates a manufacturing plant located in that area was the likely source of a release to a marshy area that connects to Chattanooga Creek.
Chattanooga Times
September 18, 1970
Some Chattanooga area residents were expected to participate in an air pollution effects study. (It is not certain if this particular study was completed.)
Chattanooga Times
September 26, 1970
The mortality rate from respiratory disease for the Chattanooga/Hamilton County area is 20% above the national average and attributed to the local air pollution. Suspended particulates appear to be highest concern.
Chattanooga Times
October 3, 1970
The high suspended particulate concentrations appear to affect the entire Chattanooga area and be exacerbated by frequent inversions.
Chattanooga Times
October 7, 1970
Strong community support for stricter air quality standards.
Chattanooga Times
October 11, 1970
Smog, heavy enough to reduce visibility and cause car accidents, occurs now east of the Ridge in areas that were unaffected in ~ 1935.
Chattanooga Times
October 16, 1970
The State Steam Pollution Control Board warned that the dissolved oxygen levels in the S. Chickamauga Creek were very low and could cause a fish kill. VAAP and Farmers Chemical were listed as waste water contributors.
Chattanooga News-Free Press
October 16, 1970
VAAP announced that they do not discharge effluent to Friar's Branch but is treated and released to Waconda Bay.
Chattanooga Times
March 13, 1971
The Air Pollution Control Bureau issued an air alert due to the high level of particulates.
Chattanooga Times Free Press
June 30, 2004
EPA ruled that seven tri-state counties, including Hamilton, have or contribute to unhealthy levels of fine particulates. The suspected sources are coal-fired power plants.
TN Div or Stream Pollution Control
April 15, 1971
Identified pollutant concentration criteria for VAAP effluent proposed in 1971.
CA Water Quality Criteria
Identified expected pollutant concentrations in TNT waste water, surface water after specific dilutions, and concentration which could kill fish.

5) The following comments were referenced to the page, paragraphs and lines on the public comment version of the document.

1 1 4 The original property area procured for the Army as Volunteer AAP was considerably more than the 7,000 acres noted.
3 1 7 (same as first comment.)
ATSDR: The estimated size of 7,000 acres was based on information from different sources. The 2003 Installation Action Plan (Army 2003a) indicated VAAP occupied 5,489 acres at that time and that 975.95 acres were transferred to Hamilton County in 2000. The Chattanooga Times Free Press Article (June 12, 2000) indicated that 75 acres were transferred for the soccer field and 600 acres were transferred for housing construction. 5,489 + 976 + 75 + 600 = 7,140.
3 2 8 The CFII area was originally operated as part of Volunteer AAP, but after the 1962 this area was leased from the Government. The manufacturing activities within this area were primarily commercial, although the contractor did conduct some operations in support of Volunteer AAP manufacturing activities.
9 1 8 TNT Production Process Emissions of SO2. The production of sellite (sodium sulfite)[ Na2SO3 ] was part of a pollution control process for scrubbing the SO2 from tail gasses by a Na2CO3 (sodium carbonate [soda ash]) solution at the oleum production facilities prior to these gases being released to the atmosphere. The quantity of SO2 that passed through the oleum production unit (converter and absorbers) and the sellite scrubber was generally quite small, but could be increased to allow production of more sellite if needed.
i 2 i "Drowning a charge" was an automated safety feature on the continuous (CIL) process lines, although the operation could be accomplished manually by the operator. In the batch lines, the operation was always a manually initiated operation. In addition to the "emergency" function, the "drowning system" was periodically exercised (activated) to assure that the system would function in case of an emergency. The periodic testing of the drowning system was probably a more frequent event than the emergency use of the system.
i 5 6 Nature and Extent of Contamination The PHA noted that there was no quantitative air emissions data available. It would seem that a more accurate statement would be to indicate minimal available data is available at this time (2004). This data was generated by the installation and provided to the Hamilton County Health Department, local air pollution regulatory agencies, and the State of Tennessee air pollution control agency.
10 1 1 During the discussion of NOX emissions from the installation, the common inference is that all such emissions were from the government operations. It should be noted that the same process facilities (ammonia oxidation process facilities for nitric acid production) were used for production of ammonium nitrate fertilizer as were used for the production of nitric acid used for the TNT nitration process. It is fair to say that much or most of the NOX fumes were from the government (TNT production related) operations, but the NOX emissions were not exclusively related to the TNT production operations.
i 6 8 Groundwater Use and Drinking Water Supplies: Eastside Utilities supplies potable water to parts of Hamilton County and some of the smaller local water suppliers, but this firm does not supply water to facilities within the City of Chattanooga except for Volunteer AAP property.
i 4 i In this paragraph (and others) there is reference to trespassers. Another group of individuals who were present on the installation were hunters who participated in state-sponsored deer hunts. (Other references on page 21, para 1 and 5)
33 4 4 TNT and fertilizer production operations completely ended in 1982, although TNT related production operations ended in 1977.
Table 2
49 Site Name - Description
1 8 Barring should be bearing
1 4 Operational History
Acid produced at the North Acid area (CFI Area) was used at all (any) of the 16 lines operational during WW II, Lines 1- 6 during Korea, and Lines 1 - 6 and 13 - 16 during Viet Nam. [All of the TNT production lines were interconnected to the various acid production facilities and associated acid tankage so any TNT line could utilize acid from any of the various plants.]
2 8 The metals contamination sources would include the corrosion of process equipment and associated acid transfer lines as well as the corrosion effect of the various acids on the metal storage tanks (structures).
50 Table 2; Site VAAP-2
Operational History
1 - The CFI area originally included two separate acid production areas - the North area and South Area. The process facilities of the South area were generally demolished or unused during the Korean operation and subsequent facility operations. The North Acid Area portion of the CFI area was the primary support for TNT production support acid during the Korean operation.
2 1 The site (the CFI area) was established in 1941, and was operated as an acid production source for TNT production support from 1941 to 1946, and then from 1951 to 1956 in support of the Korean conflict TNT production operations. The fertilizer production activity was established in this area in 1962.
2 2, 3 An ammonia plant, a commercial AOP (ammonia oxidation process) nitric acid plant and a urea fertilizer production unit were constructed at this site. [The urea facility did not impact the production of ammonia as they are independent processes.]
2 11 There was no TNT production conducted in the area designated as the CFI area; The facilities in this area consisted of facilities for acid production and storage or plant support facilities (such as the plant steam generation facilities).
52 Site VAAP-5
Operational History
1 3, 16 All of the explosive storage magazines located in this area have been demolished as of 2004.
58 Site VAAP-31
Operational History
1 6/8 The plant laundry facility in this area was converted to use as the installation pesticide storage and mixing facility.
59 Site VAAP-32
Site Name
1 11/14 The redwater evaporator building was demolished (by on-site burning) in April 2004
59 Site VAAP-32
Operational History
1 13 The installation originally (WW II) had 16 production lines in service. During the Korean operation only 6 lines were placed in service, and during Viet Nam there were 10 TNT lines in service.
60 Site VAAP-33
Site Name / Description
1 13/15 Facilities in the new acid area have been partially removed as the result of government property sales.
Operational History
1 19/21 The industrial liquid treatment plant did receive waste process liquids from the acid production facilities located in the new acid area. This operation was the source of the gypsum sludge noted in VAAP-23 (Operational History).
65 Table 4 The legends (or data) shown in the table are incorrect - the minimum detected and maximum detected values are obviously reversed.
67 Table 4 In the data presented, several frequency of detection values are misleading. The table indicates only one (1) detection (times detected), but the data indicates a maximum and minimum concentration (and they are not the same).
ATSDR: The table headings for Table 5 were incorrect. The corrected table headings indicate that the column shows the number of times a chemical was measured at a concentration above the ATSDR CV and the number of times that the chemical was detected. This column does not show the number of times the chemical was sampled for.
81 Figure 5. The Site Location Map indicating the location within Tennessee is incorrect. This map indicates the site of Volunteer AAP to be located someplace around Knoxville.
A-2 8 The remaining Government acid facilities in the North acid portion of the CFI acid area were dismantled in 1997. Many of the acid facilities in this area had previously been removed, but there were a number of acid production and handling facilities remaining on the property at this time. [Note: the overall CFI area included two separate acid production areas. Most of the south area facilities were demolished in the 1950's and 1960's.]
A-3 1 In the 1990's, the burning grounds were used for thermal decontamination treatment of items contaminated with TNT or waste materials contaminated by TNT or other explosive materials during TNT production operations. This would include decontamination of metal items from the facilities or building materials that were removed from facilities that were being demolished. As the installation's TNT production was terminated in 1977, there were no TNT wastes per se being generated at this time.
B-1 5 2 The water from the acid washer (post-nitration) contained both nitric and sulfuric acids rather than only sulfuric acid.
6 2 The water from the acid washer (post-nitration) contained both nitric and sulfuric acids rather than only sulfuric acid.
6 6 There were some other TNT production facilities that used SO2 to assist in pH control in the sellite purification reactors, but this use of SO2 was not standard practice at Volunteer AAP.
B-2 1 1 The purified TNT is washed with hot water, melted, dried, and flaked. The TNT is cooled only when it is being flaked. Other facilities may have crystallized TNT, but this was never done at Volunteer AAP.
B-2 Table B-1: Pink water did not contain a significant nitric/sulfuric acid concentration. If the mixture was highly acidic it would be yellow water rather than pink water.
B-2 3 2 The waste acids are a result of the TNT nitration, not the purification process. The purified TNT slurry is dried and flaked, which may result in pink water contamination, but not the others. Yellow water is generated in the pre-selliting (purification) washing, while red water is generated from the purification process. Yellow water will never turn pink until it is neutralized. Pink water is generally from cleanup or activities when TNT contacts (and dissolves) in non-acidic water. Pink water is initially clear (colorless) but becomes pink after exposure to sunlight or UV radiation. Pink water never becomes red water by concentration, and red water never becomes pink water by dilution - they are chemically different materials and come from different actions.
B-3 2 3 Redwater was transferred from the TNT lines to the redwater plant in "pipelines" only after the continuous lines were constructed. Prior operations utilized untraced open top flumes for this transfer operation. The dried residue of redwater can ignite, but there was no inference to tracing that relates to that - the steam tracing was the prevent the redwater from becoming solid within the lines. Further, the condensate from tracing was never included in the volume of redwater being transferred - it was clean water, and would be directly discharged from the tracing system. The steam or condensate would never be considered as increasing the probability of a spill or leak.
B-3 4 Acids necessary for the TNT production operations were produced in the East Acid Area, New Acid Area and CFI Area. (North acid area during Viet Nam and Korea, and both North and South areas during WW II).
B-3 5 The main production process for nitric acid is the Ammonia Oxidation Process (AOP) rather than the Direct Strong Nitric Process). The DSN was in the New Acid Area, and was used only during latter portion of the Viet Nam support operations. The AOP process produces 60% nitric acid by absorbing the nitrogen oxides in water or weak nitric acid.
B-3 6 2 The sulfur is burned in air to form sulfur dioxide, and subsequently passed over the catalyst to produce sulfur trioxide.

ATSDR used this information to update many sections of the text and were referenced as Public Comment 2004b.

6) What information is available to describe the health of VAAP-area during the time period when VAAP was actively producing TNT in the 1960's to 1970's?

During the PHA process several VAAP-area residents mentioned that previous studies had been conducted during the late 1960's and early 1970's that measured the pulmonary function (the 'breathing' tests) and respiratory illness rates of VAAP-area school children compared to other Chattanooga-area children who did not live near VAAP. Based on information provided by community members (see comment #4) ATSDR was able to identify several studies that were used by EPA to identify and evaluate health effects related to air pollutants.

Many of these studies also provided brief descriptions of air sampling data (Shy et al 1970a, Shy in Warner and Stevens 1973, Warner and Stevens 1973, Love et al 1982). The information presented in these studies illustrate the average annual concentration of various air pollutants in the VAAP-area, other Chattanooga areas, and other US cites and is summarized in table 4. The average annual concentration of suspended nitrate and suspended sulfate were slightly higher for the VAAP area than the other Chattanooga areas, but within the range measured in other US cities. The measured VAAP-area concentrations were actually less than many of the major US cities. The 90th percentile of the annual average concentrations of suspended nitrate and suspended sulfate were higher in the VAAP-area compared to the other Chattanooga areas, similar information was not identified for the other US cities. This information suggests that the average concentrations of the suspended nitrate and suspend sulfate in the VAAP-area were typically within the levels measured for industrialized areas, but were periodically higher than the levels in other Chattanooga areas.

Table 4: Summary of Air Sampling Results
Air Sampling Results: Range measured average and 90th percentile concentrations for the VAAP-area, other Chattanooga areas, and other US cities.
Analyte VAAP-area Chattanooga-area Other Areas
Suspended Nitrate
Average [g/m3]
90th Percentile [g/m3]
3.8 - 7.2 1
8.0 - 14.8 1
1.6 - 2.6 1
3.1 - 5.9 1
2.7 - 12.6 2
Suspended Sulfate
Average [g/m3]
90th Percentile [g/m3]
10.0 - 13.2 1
19.2 - 22.6 1
9.8 - 10.7 1
15.6 - 17.3 1
7.7 - 22.2 2
Total Suspended Particulates (TSP)
Average [g/m3]
90th Percentile [g/m3]
63 - 96 1
108 - 183 1
62 - 99 1
112 - 181 1
27 - 55 4
Sulfur Dioxide
Annual Average [ppm]
24-hr 2nd Max [ppm]
0.032 - 0.047 3
0.004 - 0.015 4
0.014 - 0.092 4
Nitrogen Dioxide
w/VAAP Operating
24-hr Average [g/m3]
24-hr 90th Percentile [g/m3]
37 - 91 5
78 - 220 5
276 1
41 - 56 5
62 - 78 5
64 - 185 1
Nitrogen Dioxide
w/oVAAP Operating
24-hr Average [g/m3]
24-hr 90th Percentile [g/m3]
22 - 36 5
38 - 55 5
40 - 59 5
62 - 87 5
64 - 185 1
1. Shy et al 1970a
2. Shy in Warner and Stevens 1973
3. Warner and Stevens 1973
4. PDEP 2001, Appendix A Data Tables
5. Love et al 1982
6. NA = not available

There is no obvious difference between the annual average and 90th percentile concentration of total suspended particulates for the VAAP-area compared to the other Chattanooga areas, but the average concentration in both the VAAP-area and the other Chattanooga areas appear to be higher than other US cities. The range of ambient sulfur dioxide is within the range of maximum sulfur dioxide concentrations measured in Pennsylvania between 1991 and 2001. The reported VAAP-area sulfur dioxide concentrations are slightly above the current annual average National Ambient Air Quality Standards but well under the 24-hour standard.

Nitrogen dioxide concentrations were reported for the VAAP-area and other Chattanooga areas for two different time periods; when the plant was actively producing TNT and when production was on-hold during a supplier strike. The results suggest that VAAP-operations significantly contributed to the ambient concentrations of nitrogen dioxide in the VAAP-area, however it likely did not significantly affect the air quality for other Chattanooga areas. The range of the average 24-hr concentration was slightly lower when VAAP was not operational and the 90th percentile concentration was significantly lower. The ambient concentrations of nitrogen dioxide for the other Chattanooga-area sites when VAAP was not operational is essentially the same as when it was operational.

These sampling results suggests that all of Chattanooga, including the VAAP-area, were affected by air emissions and that the source was likely different for various areas in the Chattanooga region. The results also suggest that the VAAP-area periodically had high ambient concentrations of suspended nitrates and sulfates, likely from the release of acid mists; however it is not possible to identify if the resulting exposures would be expected to cause respiratory illness.

One of the original 'health' studies (Shy 1970, Shy et al 1970a and 1970b) measured the 0.75-second forced expiratory volume (the 'breathing test') for children and the respiratory illness rate for children and other family members believed to be living in areas with a high measured ambient concentration of NO2. These values were compared with others measured in people who were believed to be living in areas with lower measured levels of NO2. However, subsequent improvements in air monitoring technology identified that the original NO2 measurements were not accurate enough to sufficiently define the differences in NO2 concentrations within the various areas (EPA 1982).

Some differences were observed in the pulmonary function of the children between the areas, the actual reduction of the pulmonary function in the children from the VAAP area was very small and the reduction was not consistent. Typically the VAAP-area children's pulmonary function value was between the values measured for the children in the two different control areas (Shy et al 1970a).

Shy et al (1970b) contacted VAAP-area families who had a child in second grade at one of three VAAP-area schools once every two weeks between November 4, 1968 and April 26, 1969. Families were asked to report the frequency and severity of acute respiratory illness during each of the twelve 2-week periods. Each VAAP-area family segment (2nd graders, their siblings, mothers and fathers) had a slightly higher acute respiratory rate compared to the other study areas. However the rates varied significantly between the bi-weekly reporting periods; the respiratory illness rates for VAAP-area families exceeded that of the three other reporting areas for only 5 of the 12 reporting periods.

Pearlman et al (1971) conducted a follow-up study of 1st and 2nd graders and Caucasian infants born during 1966, 1967 and 1968. The researcher considered VAAP-area children and children from two other Chattanooga areas. They questioned parents concerning the the child's frequency of bronchitis (including bronchiolitis), croup, and pneumonia over a 3-year period beginning July 1966. The results were highly variable but suggest that the illness frequency for the VAAP-area 1st and 2nd graders was within the range of the other two areas. In most cases the illness rate for the infants was also within the range set by the other two areas. One exception was for repeated cases of lower respiratory illness and bronchitis for infants with 1 or 2 years of exposure to the VAAP-area. Infants with 3 years of exposure were within or close to the range set by the other two areas.

An additional study (Love et al 1982) looked at respiratory illness rates for the same areas described in Pearlman et al (1971) during 1972-73. Each family segment (mothers, fathers, school children and pre-school children) in all of the Chattanooga areas showed higher illness rates during the early portion of 1972 (January - May) compared to late 1972 (September - December) and early 1973 (January - April). The respiratory illness rates for most of the family segments in the VAAP-area were slightly higher than those from the other Chattanooga areas during the early portion of 1972. During late 1972 and early 1973 the respiratory illness rates for each VAAP-area family segment was similar to those from the other Chattanooga areas. The reduction in illness rates was reported to correspond with a significant reduction in emissions that occurred during the second half of 1972 (EPA 1993).

Although a small decrease in pulmonary function and increase in respiratory illness rate was reported for the VAAP area during the late 1960's to early 1970's, the actual increase was small and a specific cause was not well identified. It is possible that these health effects were influenced by the emissions from VAAP, the health effects considered in the Chattanooga studies are consistent with the health effects the could be possible following exposure to compounds believed to be present in the VAAP acid clouds (see Appendix C for details). However, it is not possible to identify if VAAP emissions were the sole cause of the reported health effects. Other common activities and exposures can also cause reductions in pulmonary function and increases in respiratory disease rates. Potential confounding factors include parental occupational exposures, potential exposures to dust and chemicals from hobbies, family size, and nutritional status. The researchers believe they were able to account for the majority of these factors during their analyses, however these factors illustrate the difficulty of trying to identify a specific cause for a small increase in respiratory illness.

The reduction in the respiratory illness rate reported from September 1972 through April 1973, corresponding with the reduction in emissions, suggests that the health effects may be influenced by the ambient pollutant levels and that improvement in the air quality likely led to improvements in the measured levels of pulmonary function and respiratory illness rates.

7) Please provide some clarification about the potential lead exposure from swimming in pools filled from groundwater wells. The lead concentrations measured in the groundwater well samples used to evaluate this concern did not necessarily originate from VAAP manufacturing or storage activities. The lead concentrations may have been influenced by natural conditions or leached from old pipes or equipment.

ATSDR added some additional information to the text to clarify that the source of lead in the residential groundwater well is not known.


American Cancer Society. 2003. Detailed Guide: Leukemia - Childrens; What are the Risk Factors for Leukemia? Revised September 17, 2003.Available at: for_leukemia_24.aspAccessed on: August 2, 2004.

American Cancer Society. 2004a. Detailed Guide: Bladder Cancer; What are the Risk Factors for Bladder Cancer? Revised January 1, 2004.Available at: bladder_cancer_44.asp?sitearea=criAccessed on: August 2, 2004.

American Cancer Society. 2004b. Detailed Guide: Lymphoma, Non-Hodgkin's Type; What are the Risk Factors for Non-Hodgkin's Lymphoma? Revised June, 2004.Available at: for_non-Hodgkins_lymphoma_32.asp?rnav=criAccessed on: August 2, 2004.

ATSDR. 1996. Guidance for ATSDR Health Studies.Available at: on: July 28, 2004.

Cal/EPA. 1997. Health Effects of Exposure to Environmental Tobacco Smoke. Office of Environmental Health Hazard Assessment; California Environmental Protection Agency. Available at: on August 4, 2004.

EPA. 1982. Air Quality Criteria for Oxides of Nitrogen. EPA-600/8-82-026. September 1982.

EPA. 1993. Air Quality Criteria for Oxides of Nitrogen Volume III of III. EPA-600/8-91/049cF. August 1993.

Freeman Hospital. 1996. Understanding Bladder Cancer. Freeman Hospital, High Heaton, Newcastle upon Tyne, NE7 7DN, UK. Available at: on: August 2, 2004.

Love, GJ, SP Lan, CM Shy, and WB Riggan. 1982. Acute respiratory illness in families exposed to nitrogen dioxide ambient air pollution in Chattanooga, Tennessee. Arch. Environ. Health. Volume 37. Pages 75-80.

Lung Cancer. 2004. Lung Cancer 101; Risk Factors. March 11, 2004. Available at: Accessed on: August 2, 2004.

Pearlman, ME, JF Finkles, JP Creason, CM Shy, MM Young, and RJM Horton. 1971. Nitrogen dioxide and lower respiratory illness. Pediatrics. Volume 47. Pages 391-398.

Shy, CM. 1970. The Chattanooga study. J. Air Pollut. Control Assoc. Volume 20. Pages 832-833.

Shy, CM, JP Creason, ME Pearlman, KE McClain, FB Benson, and MM Young. 1970a. The Chattanooga school children study: effects of community exposure to nitrogen dioxide. I. Methods, description of pollutant exposure, and results of ventilatory function testing. J. Air Pollut. Control Assoc. Volume 20. Pages 539-545.

Shy, CM, JP Creason, ME Pearlman, KE McClain, FB Benson, and MM Young. 1970b. The Chattanooga school children study: effects of community exposure to nitrogen dioxide. II. Incidence of acute respiratory illness. J. Air Pollut. Control Assoc. Volume 20. Pages 582-588.

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