Re: Seeking feedback on experiences with ATSDR

[Laura Olah <olah@speagle.com>]

Hi Susan,
I'm glad your experience has been positive.  Having personally heard from
dozens of communities across the U.S., I believe Doris' situation is the
norm and not the exception.  Following is our organization's comments in
response to a recent health assessment of our community; I hope this is
helpful.
Laura

Mary Young
Wisconsin Division of Public Health
1414 East Washington Ave., Room 96
Madison, WI  53703


RE: Public Comment Draft PUBLIC HEALTH ASSESSMENT
       Badger Army Ammunition Plant, Sauk County, Wisconsin
       September 1998

October 26, 1998

Dear Ms. Young:

Thank you for forwarding a copy of the Comment Draft PUBLIC HEALTH
ASSESSMENT for Badger Army Ammunition Plant, Sauk County, Wisconsin,
September 1998. This letter is our comment on this document.

We have reviewed the Comment Draft PUBLIC HEALTH ASSESSMENT for Badger Army
Ammunition Plant, Sauk County, Wisconsin, September 1998 and find there was
entirely inadequate contact with our community – the population being
studied.  This lack of contact contradicts ATSDR policy and objectives
including "involvement of communities throughout the public health
assessment process," "identifying community health concerns," and
"identifying and evaluating exposure pathways."  (Source: ATSDR – Community
Health Assessment Workshop Manual, August 1992.)

To the contrary, WDOH spent innumerable hours soliciting input and
incorporating data and conclusions presented by representatives of the U.S.
Army (the polluter and responsible party) and consultants under contract
with the U.S. Army; this, despite repeated requests by community members to
initiate outreach to the affected community, their physicians, and current
and former workers – many of whom live in the adjacent rural communities.
Prior to September 1998 – the date of this report -- no press releases were
published, no public informational meetings have been held, and no
discussions were held with stakeholders. The result, therefore, is an
appalling absence of even the most basic understanding of local concerns and
conditions. Moreover, the design of the Health Assessment is a predominant
and contributing factor to its failure.

Virtually no resources were devoted to interviewing residents as to current
health problems and concerns that they associate with their proximity to the
Badger Army Ammunition Plant and their exposure to air, fugitive dust and
emissions, and surface soils; associated and multiple routes of exposure
were not assessed.   Assessment of risk from current, pending, and
anticipated cleanup activities is also noticeably absent.

Significant and long-standing community concerns, such as past and multiple
routes of exposures, were also not addressed.  Moreover, the WDOH has
concentrated on the wrong type of illnesses, e.g. focusing on death studies
when many health problems and community concerns have been nonlethal, such
as respiratory illnesses or reproductive problems.
Had WDOH devoted even moderate resources to outreach, these environmental
health concerns would have been quickly evident to the health assessor/s.

Also absent are consideration of chloroform detected in the Priebe well for
the first time in June 1992, and exceeding the PAL in February 1993; carbon
tetrachloride detected above the PAL in the well of S Ramer; elevated
manganese levels reported in private drinking water wells at the Dairy
Forage Research Center and in Walch’s well; elevated nitrates reported in
Zimmer’s well, greater than 10 ppm, the ES; elevated nitrates reported in
private drinking water wells at Weigand’s Bay North -- some as high as 40
ppm; TCE reported in the Sorn well.  Facility-wide and persistent
exceedances of the drinking water standard for nitrates and several toxic
metals such as lead, cadmium, and chromium were not addressed.  Again, even
moderate consultation with the community would have readily disclosed this.

This assessment also fails to address known environmental exposures from
emissions from the Old Acid Area, the Power Plants, Oleum Plants, and Open
Burning and Open Detonation (OB/OD) of waste propellants and other hazardous
waste; activities acknowledged and described in your own report.  Interviews
with the tens of thousands of former workers at Badger Army Ammunition
Plant, many of whom live in the adjacent communities, have not been
conducted, nor has sufficient pertinent information been included in this or
previous assessments.  Numerous and relevant studies and data were not
considered and incorporated in the WDOH assessment including USAEHA-EA
Preliminary Air Pollution Engineering Survey, Badger Army Ammunition Plant,
Baraboo, Wisconsin, October 1968; Air Pollution Engineering Source and
Atmospheric Sampling Survey; Sanitary Engineering Survey and Industrial
Waste Special Study; Waste Quality Engineering Study, NPDES Permit No. WI
0002755; Development of Methods to Minimize Environmental Contamination,
Picatinny Arsenal.

In 1995, the WDOH, acting as an agent for ATSDR, conducted and published a
health assessment of residents near the Sauk County Superfund Landfill.  The
WDOH study, approved by ATSDR, was based exclusively on documentation and
data presented by Sauk County (the owner/operator of the landfill and the
responsible party)  and contractors hired by the County -- absolutely none
of the data or concerns presented by community members were included in the
report and predictably the conclusions of the report echoed, almost
verbatim, the claims of the polluter that no health problems or risks were
associated with their site.

Aware of the WDOH’s track record in this regard, CSWAB representatives have
repeatedly appealed to WDOH representatives for nearly a year, to let the
community know of its intent, the scope of its work, and the availability of
its staff.  WDOH has flatly and repeatedly refused.

We believe community health assessment should be controlled, or at least
directed, by the stakeholders -- the families and workers at risk.  WDOH did
not meet with the community to discuss potential health studies PRIOR to
developing scope, methodology, and nature of the study that it intended to
conduct, and as consistent with ATSDR policy.  The initial discussion about
a study could have educated and engaged the community in dialogue regarding
possible types of studies that could be conducted in view of what is known –
instead this opportunity was discarded and dismissed.

This assessment failed in every regard to honor ATSDR’s promised commitment
to community involvement.  ATSDR’s Community Health Assessment Workshop
Manual dated August 1992 says: "ATSDR intends to involve the community in
the public health assessment process at the earliest opportunity by
maintaining better communication with the community and other involved
parties throughout the process…"

Moreover, erroneously designed reports may influence concerned residents and
workers to discontinue actively monitoring the site including associated air
and groundwater contamination, and to resume daily activities and patterns
that may be placing them and their children at increased risk for cancer and
other disease or illness.  Consequently, inferior assessments such as this,
place the community at more risk than no assessment at all.

Sincerely,


LAURA OLAH
Executive Director

cc: Dr. Barry L. Johnson, ATSDR, Office of the Assistant Administrator, 1600
Clifton Rd.,  (E28), Atlanta, GA 30333
Ms. Doris Bradshaw, Board of Scientific Counselors Subcommittee, ATSDR



Susan Gawarecki wrote:

> Quite the contrary to Doris' problems, we have had very good experience
> with ATSDR regarding DOE pollution impacts on the communities
> surrounding and downstream of Oak Ridge.  They have always been willing
> to meet with our group, and we have worked cooperatively on a number of
> projects.  My impression has been that the technical people are quite
> concerned with doing quality science and want to be effective in their
> public outreach.
>
> Some of the work we've done with ATSDR includes:
> - Creating a brochure describing the nature of the fish advisory on
> Lower Watts Bar Reservior, the relative risks of eating various types of
> fish,  and how to prepare fish in the lowest risk manner for PCB
> ingestion.  Tenn. Wildlife Resources Agency also blessed the brochure.
> - Re an exposure assessment for PCBs and mercury for fish & turtle
> eaters on LWBR--we commented on the plan, helped publicize the need for
> participants, and reviewed the results of the study.
> - Are in the process of helping plan the format of a series of public
> meetings to determine a public health agenda for Oak Ridge, relative to
> potential exposures from DOE facilites.
>
> Our main point of contact at ATSDR is Jack Hanley, and we have also
> worked with other members of the agency.
>
> It has been my observation that ATSDR does have to supplement its budget
> appropriation with cooperative work that includes financial support from
> other agencies, so money may play a role in what it is willing or able
> to take on.
>
> I'm curious about the nature of the problems Memphis stakeholders are
> having and their contact(s) at the agency.
>
> --Susan Gawarecki

--
Laura Olah, Executive Director
Citizens for Safe Water Around Badger
E12629 Weigand's Bay South
Merrimac, Wisconsin  53561
olah@speagle.com
Phone (608)643-3124 Fax (608)643-0005
Website  http://www.speagle.com/cswab