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The Adak Restoration Advisory Board (RAB) met for its regular monthly meeting on August 18, 1999 at 7:00 p.m. The RAB met at the Holiday Inn, located at 239 West Fourth Avenue, Anchorage, Alaska.
The following RAB members were present:
Bill Arterburn
Jason Bourdokofsky
Chris Cora, USEPA
Roy Ehrhart, II
Mary Grisco
John Martin, USFW
Pam Miller
Mike Mitchell
Ed Nash
Kevin Oates, ADEC
Richard Stoll, Co-Chair
Cathy Villa, Adak community*
The following RAB members were absent:
Elary Gromoff, Co-Chair
Flory Lekanof
*Participated telephonically.
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The following visitors and guests were present:
Dr. David Carpenter, SUNY Albany
Susan Christianson
Bill Rohrer, URSG
*Jennifer Fadden, Adak community
Cdr. Christopher Floro, NAF Adak
*Duke Freewell, Adak community
Chris Gates
H. Glenzer, CIRCAC
Francine Gomes
Steve Grabacki
John Grady
Krista Graham, OASIS
*Don Hobbs, Adak community
*Michael Hochstein, Adak community
*Lt. Tom Borien
David Krievsaldt, Adak community
Agafon Krukof, Adak community
Norrell Lantzen, Comarco Systems
Leonard Malone, Adak community
Keith Martin, Adak community
Mark Murphy, EFA NW
Jeannette Romig, OASIS
Dr. Ron Scudato, SUNY Oswego
*Scott Shock, Adak community
Jordan Stout, USFWS
*Jeff Tranzelli, SUNY Oswego
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The summary of discussions during RAB meetings is not intended as a transcript of the meeting. A recording of the RAB meeting is obtained at every meeting and in the event that a more complete transcript of a discussion is needed for a specific issue, this recording can be accessed. While participants at RAB meetings are strongly encouraged to review the meeting minutes prior to finalization of the minutes, it is recognized that there is the possibility that participants in the discussions have not reviewed the minutes to confirm that they accurately reflect the content of the discussion.
- Welcome, Introductions, and Meeting Purpose
Mr. Stoll called the meeting to order at 7:03 p.m. A quorum was present. An agenda item was added to the Public Comment section to allow showing of a video provided by Chris Gates of the Finger Bay area. Dr. Scudato's report time was also increased. The agenda was unanimously approved as amended.
- Approval of the July 14, 1999 meeting minutes.
IT WAS MOVED by Mr. Nash AND SECONDED by Mr. Ehrhart that the minutes of the July 14, 1999 meeting be approved as written. THE MOTION PASSED with unanimous consent.
- General Announcements
There were no general announcements.
- Administrative Issues - New RAB Members on Adak.
Cathy Villa submitted an application to serve on the RAB. IT WAS MOVED by Mr. Ehrhart AND SECONDED by Mr. Nash that Cathy Villa become a RAB member. THE MOTION PASSED with unanimous consent.
Concerns, Issues, and Questions
Mr. Stoll discussed the venue of meetings and membership on the RAB due to OUB. The Adak community council applied for second class city status, and that should be approved by early next year. Mr. Stoll suggested that greater participation should be engendered of people on-island. Mr. Murphy had suggested previously that some meetings should be held on Adak, and Mr. Stoll concurred. Unfortunately, travel issues created problems. Mr. Stoll suggested that a portion of future meetings be held on island. Mr. Nash said he felt that was appropriate, and that he had participated on the RAB because at first there were no civilian representatives on Adak. Mr. Nash suggested that perhaps he could resign so that Adak community members would take over. Mr. Nash was concerned that the RAB's institutional knowledge should not be lost. Mr. Stoll said he was not suggesting that anyone resign, and there was valuable continuity with the Anchorage RAB members. Ms. Miller agreed that RAB meetings should be held on Adak, perhaps on an alternating schedule. It would be beneficial for the RAB members visit Adak to look at closed out sites, see the long-term monitoring and meet face-to-face with the community and new RAB members. Mr. Stoll emphasized that the RAB takes individual input from anyone, not just RAB members. The Adak community at large needs to be enfranchised in the process.
Mr. Bourdokofsky said that he felt uncomfortable supporting the no further action decisions without visiting Adak. Mr. Stoll said he agreed that the RAB's members concerns about making a site visit were extremely valid, but there is no transportation funding available. Mr. Krukoff said he was encouraged by the discussions, and looked forward to transitioning the RAB to Adak. Mr. Keith Martin said he felt participation on Adak would continue to increase. Mr. Stoll asked the RAB to consider how often and when meetings should be held on Adak. Mr. Ehrhart reiterated Mr. Gromoff's conviction that meetings should continue on a monthly basis, and felt that no decrease in the number of meetings should be discussed until Mr. Gromoff was present. Mr. Ehrhart also expressed concern that handouts be timely distributed. Ms. Graham said that handouts had been faxed to Adak.
Mr. Stoll said that Mr. Gromoff would continue to be co-chair even when meetings are held on Adak. Ms. Miller suggested that every other meeting be held on Adak. Mr. Krukoff said that would be a good beginning and was more optimistic than they expected. Mr. Krukoff felt it would be valuable to continue to have some meetings in Anchorage in order to utilize the expertise of the Anchorage members. Mr. Arterburn agreed that meetings on Adak made sense and encouraged Adak residents to become involved. Ms. Graham pointed out that a teleconference could be set up to allow members to call in from different locations. Mr. Stoll suggested that specific instructions be included in the minutes on how to participate telephonically, and that also a meeting place be reserved in Anchorage.
IT WAS MOVED by Mr. Arterburn AND SECONDED by Ms. Grisco that the September 15, 1999 RAB meeting be held on Adak. THE MOTION PASSED with unanimous consent.
Mr. Ehrhart requested that all new RAB members be provided with a binder of bylaws, abbreviations, maps, acronyms, and other relevant information.
Mr. Ehrhart requested that for future meetings that more and better microphone placement was needed to make teleconferenced meetings successful. Many of the comments from Adak could not be heard. Cdr. Floro said those in Adak were around a conference table, and they had had some discussions offline. Mr. Ehrhart said he could not hear Ms. Villa very well, and that the sound quality level was not acceptable.
The Adak community was dissatisfied with the Navy's answers to the community's questions submitted in March/April 1999. Mr. Oates said he spent a lot of time with Mr. Darrington, Mr. Krukoff and Adak community members on-island and a lot of the concerns were dealt with. Mr. Oates inquired if there were remaining concerns. Ms. Villa said she felt there were a lot of issues to discuss, but that she needed more time. Mr. Stoll said Navy and regulatory agency personnel will be on Adak in September and available to discuss concerns.
- PROJECT UPDATES AND QUESTIONS AND ANSWERS
- Review of ROD Decision Making Process.
Mr. Murphy reviewed the process that led to the remedial decisions that were made for the OUA ROD. OUA consisted of over 200 separate petroleum and non-petroleum contaminated sites. The investigations on those sites began in 1986.
Mr. Murphy presented a flow chart denominated as Figure 4-1, Generalized Process for Environmental Evaluations on Adak. NAF Adak was listed on the National Priorities List (NPL) in 1994. At that time there were 26 petroleum and 58 CERCLA (non-petroleum contaminated) sites. The CERCLA sites were evaluated first, by a PSE (preliminary source evaluation) which was based on existing information on the sites. That information was used to decide whether further investigations were needed, remedial action could be initiated, or if the site required no further action. Those sites went through a second phase (PSE2) that included additional field sampling in order to make a decision on the need for further remedial action or investigation. The RI/FS (Remedial Investigation and Feasibility Study) was conducted from 1996 to 1998. The RI/FS recommendations led to a proposed plan for the CERCLA sites that was submitted for public comment in 1999, and the final ROD (Record of Decision) which is in the process of being finalized now.
The petroleum sites went through a different evaluation process. On most of those sites, tank removals and on-site remediation occurred from 1993 through 1997. Wherever there were petroleum releases, UST, or petroleum pipeline sites, the source and contaminated soils were removed. During the petroleum site investigation, another 102 sites were added to the list. Eventually, all the petroleum sites were evaluated in a focus feasibility study begun in 1997 that summarized the actions and investigations that occurred. A separate proposed plan for the petroleum sites was prepared, submitted for public comment, and is now in the process of being finalized.
The OUA sites are grouped in the ROD as follows: Table 4-1, No Further Action CERCLA Sites; Table 4-2, No Further Action Petroleum Sites; Table 7-1, CERCLA Sites that Require Remedial Action (Excluding Institutional Control Only Sites); Table 7-2, CERCLA Sites that Require Institutional Controls Due to Adverse Risk; and Table 7-4, Petroleum Sites that Require Remedial Action. Detailed reports on all investigations are available in detail in the information repository.
Mr. Murphy discussed SWMU 3, known as the Clam Lagoon Landfill, as an example of the process for No Further Action CERCLA Sites. SWMU 3 was identified by historical reviews and literature searches as early as 1986. EPA did a visual site inspection that again identified the site as potentially requiring some level of investigation or remediation in 1991. When Adak was listed on the NPL, the project managers determined this site required a PSE and that was done in 1993. The PSE1 report determined there was a basis for further evaluation. A PSE2 was undertaken which consisted of geophysical surveys and sediment and soil samples that were analyzed for volatiles, semi-volatiles, metals and total petroleum hydrocarbons. The PSE2 was completed in 1995. Five to 10 empty rusted drums that were used for erosion control were found. Sample results found no chemicals of concern in soil or sediments. The basis for the no further action recommendation was that there was no evidence of waste disposal or landfill activities, and the chemical concentrations were less than human health and ecological risk thresholds that would require additional action.
Mr. Murphy explained that background concentrations are the level of metals that naturally exist in sediments, soils or surface water, regardless of the existence of any contamination. Mr. Oates said that background concentrations were evaluated in several ways. One was that organic chemicals were not considered background. Anything that is a manmade compound should not be found. For example, if there was some level of PCB's throughout the Aleutians that did not factor into the risk assessment or risk management decisions. Some metals, by nature, will occur in the environment. Discounting background concentrations was not allowed in terms of the overall risk evaluation. For example, if 5 parts per million of background was expected, and 10 parts per million were found in a receptor, the 5 parts of background would not be subtracted from the total.
Dr. Scudato inquired whether some of the no further action sites contained contamination. Mr. Murphy said that some did. Dr. Scudato asked what percentage of the sites contained contamination. Mr. Murphy said he had not done any statistical analysis and could not say. Ms. Miller asked about Table 4-1, which indicates many sites were closed out based solely on a visual inspection. Mr. Murphy said in some cases, the level of documentation seemed to support such a decision. Mr. Cora pointed out that Clam Lagoon was sampled, and suggested that the Human Health Risk (Unrestricted Use) and Rationale column in Table 4-1 should be expanded. Mr. Murphy said that a lot more work was done at SWMU 3 than just visual inspection. Test pits were dug and various media was sampled. All those results were used to support the no further action decision. Table 4-1 may not be a complete summary. Likewise, SWMU 66, the Palisades Lake PCB Spill, more work was done than just a visual inspection. Mr. Gates asked if the community has more information concerning no further action sites, if the Navy would re-investigate. Mr. Murphy said that would depend on the information provided.
Mr. Murphy discussed Kuluk Bay Housing (UST HST-6C), as an example of the process for No Further Action Petroleum Sites. A UST oil/water separator and 45 cubic yards of contaminated soil were removed in 1995. Soil samples were collected and analyzed for diesel range organics. In 1996 and 1997, groundwater and soil samples were analyzed for benzene, toluene, ethylene, xylene, gasoline and diesel range organics and polycyclic aromatic hydrocarbons (PAH's). The 1995 soil samples had diesel range organics maximum concentration of 6,000 parts per million. The 1996 and 1997 soil and groundwater samples were non-detects. Because the diesel range organics in soils was greater than 200 parts per million, ADEC method 1 criteria could not be used, and therefore, method 4, site specific risk assessment was applied to the site. The results of the evaluation were that because the source and contaminated soil were removed and clean fill was replaced at the site, no petroleum or petroleum-related compounds were found in the groundwater, and based on the method 4 evaluation, there was no basis for believing that was an unacceptable human health or ecological risk. No further action decisions were not based on historical or archival data alone.
Mr. Murphy said that all regulated underground fuel tanks were removed on time. Mr. Oates said there was a consent agreement with the State of Alaska regarding the active fuel facilities to address, among other things, compliance with OP90.
Mr. Murphy discussed SWMU 29, known as the Finger Bay Landfill, as an example of the process for institutional controls. This site had a similar history and process to SWMU 3. The site was identified as early as 1986. The Navy performed site inspections in 1989 that sampled surface water, sediment and soils. The Navy did a RCRA facility assessment in 1991 that also identified the site. After Adak was listed on the NPL, a PSE was performed in 1993. The PSE concluded that additional evaluation was needed. Test pits were excavated. Sediments, soils and groundwater samples were analyzed. That data was used in a risk evaluation done 1995. The results concluded that human health risk from exposure to subsurface soil and sediment was 3 x 10-5, which falls within EPA's acceptable range. The ecological risk was determined to be 170, which is higher than acceptable for exposure to subsurface soil and sediment by burrowing receptors such as rats. The soil cover was adequate to prevent those kinds of exposure pathways therefore, institutional controls would prevent unacceptable risk from occurring. Institutional controls selected were to restrict land use (no residential development or excavation) and to maintain the existing soil cover.
Dr. Scudato asked if off-site migration was considered. Mr. Murphy said it was. Monitoring wells were drilled in the landfill as well as down gradient. Surface water and sediment samples were taken down gradient of the landfill. Mr. Gates asked if a site that did not make an ecological attainment, and institutional controls are used to keep people out, is the ecological problem being dealt with. Mr. Murphy said the ecological non-attainment was for receptors that might be exposed to the waste materials. That was determined not to be a viable pathway as long as the soil cover was maintained.
Mr. Murphy discussed SWMU 4 as an example of the process for CERCLA Sites that Require Remedial Action (Excluding Institutional Control Only Sites). SWMU 4 followed virtually the same process of SWMU 29. The initial assessment was done in 1986, a RCRA assessment was done by the Navy, and then a PSE1 and PSE2 was done. The ecological hazard index was 130, and the human health cancer risk was in the EPA acceptable range. At SWMU 4 it was determined that soil cover was not adequate to protect receptors from the landfill debris. Therefore, the site was recommended for remedial action. The remedial action consisted of placing an engineered cover (clean fill), revegetation, recontouring to improve drainage and institutional controls identical to those at SWMU 29. No groundwater monitoring is not being done based on the assessment results.
Mr. Murphy discussed NMCB (Naval Mobile Construction Battalion maintenance building) as an example of the process for Petroleum Sites that Require Remedial Action. Reconnaissance was done as early at 1990. Soil samples were collected and analyzed. Test pits, groundwater and soil samples were analyzed from 1993 to 1997. Tank closures were instituted at the site. Free product was observed in 10 wells, and diesel and gasoline range petroleum was detected in soil and groundwater samples. Free product is continuing to be recovered until it is removed to the extent practicable. At that point, the site will be evaluated by the focus feasibility approach; the same process used at all other petroleum sites. The result of that evaluation will determine whether additional remedial action should be taken, or if the site can be monitored on a long-term basis. Mr. Oates explained that Sid Boyd of EFA NW had called him several months ago and said the Navy wanted to take a proactive stance and evaluate the data now. The Navy is attempting to use new technology to close-out the sites earlier than anticipated. Mr. Oates was encouraged by the Navy's proactive attitude.
- Dr. Scudato's Report.
Dr. Scudato is the director of the Environmental Research Center at the State University of New York at Oswego. He is serving as technical advisor to the RAB. Dr. Scudato submitted a report to Messrs. Stoll and Gromoff dated August 12, 1999. The ROD was used as the basis for Dr. Scudato's comments, but is not intended to be all inclusive. The report addresses the remedial actions proposed for Adak. Dr. Scudato discussed an article found in Environmental Science and Technology that questions whether risk based cleanup will work at Navy facilities. The article reviews some of the processes used by the Navy and focused on whether risk based assessments are the most effective way to evaluate sites in order to establish some form of remedial standards. Dr. Scudato paraphrased one section of the report: according to the NRC report potentially rapid site closeout under RBCA (risk based assessments) or any purely risk based method comes at a significant price. Their most significant weakness is that risk based methods leave contamination in place because of their reliance on engineering and institutional controls. Leaving contamination in place complicates waste site cleanup. For example, unidentified and potentially harmful substances remain on site. Dr. Scudato said this mirrored some of his concerns regarding risk based analysis for Adak and throughout the world. Mr. Cora said that the Navy is not using RBCA at Adak. The Navy is using a Superfund based methodology that is a nationally approved procedure that's gone through peer reviews. RBCA is a program that allows the Navy to do its own internal prioritization. EPA does not support RBCA and it was not used at Adak. Mr. Oates added that at one point the Navy did want to use RBCA at the petroleum sites and the parties came very close to a formal dispute over the issue. There is still some language in the focus feasibility studies that talk about the RBCA methodology. ADEC did not accept RBCA.
Mr. Tranzelli is a geologist who works with Dr. Scudato at SUNY Oswego. Mr. Tranzelli said there is a great need at Adak is the application of Geographic Information Systems (GIS). These systems are used to display all types of information on a base map to correlate samples or contaminate concentrations with geographic database or registry. One good example of a GIS was a CD made by the Cook Inlet Keepers Associations that has 150 different layers such as salmon concentrations, contaminants, forestry information, etc. Particularly relevant to Adak is the use of institutional controls. GIS can ameliorate the lack of record keeping, reconstruction of historical records, loss of paper or computer files and provide a permanent record.
Mr. Tranzelli said he was confused by the lack of consistent site ranking. At previous projects, there has been a prioritization scheme. This type of information should be readily accessible in the ROD. The sites should be ranked in a specific order as to their concern to environmental and human health. The prioritization will allow everyone to focus on the most important sites.
Mr. Tranzelli said institutional controls are a less preferred method than actually removing contaminants. Mr. Tranzelli said he is concerned that in some instances there may be a tendency for the contaminants to leave either in groundwater, volatilization, or if the cover is eventually contravened. In those cases, institutional controls may not adequately safeguard human safety and ecological concerns.
Mr. Tranzelli said that in New York they are struggling with the disposal of contaminated sediments, particularly related to dredge sediments from the Hudson River where there has been a massive PCB problem for 30-40 years. Mr. Tranzelli is opposed to disposal of contaminated sediments in open water or marine dumping. Mr. Murphy said that none of the remedial decisions in the ROD identify open water disposal of sediments or contaminated material. CERCLA requires that alternatives are analyzed, and open water dumping was one of those alternatives but it was never selected as a remedy.
Mr. Tranzelli said that he would like to see cleanup money spent efficiently. Consolidation of certain sites would be one way to this end, particularly where contaminants are left in place. It may be more cost effective to manage one site rather than several smaller sites, especially in terms of monitoring. Mr. Tranzelli suggested that consolidation be considered in order to reduce costs and provide more cleanup.
In a number of the no action sites and other sites where capping has been chosen, one way to eliminate all questions and uncertainty is to remove the contamination and consolidate it. Ms. Miller asked about the potential of a consolidated containment site being used as a reactor site to promote further cleanup, rather than relying on natural attenuation. Mr. Tranzelli said that could be possible and reduce the remedial and cleanup costs much lower. It was pointed out that consolidation in itself increases costs, and an economic analysis was needed. Mr. Tranzelli agreed and suggested simply that the analysis be done.
Mr. Murphy said that Adak is a very large place, and many of the contaminated sites are not necessarily geographically contiguous. There would be a lot of logistical and cost considerations in relation to any proposed consolidation plan. Mr. Murphy said an alternatives analysis was done in the RI/FS and some level of consideration was given to site consolidation there.
Mr. Tranzelli said that many of the sites had PCB's, specifically aroclor 1260, sometimes aroclor 1254. It is in the sediment samples from the coves and some of the landfills. Most of the work has been done on aroclor matching and little, if any, congener specific PCB analysis has been done. PCB's are a group of compounds that react differently, their solubilities range over six orders of magnitude, they partition in the environment, and they each have unique health affects. Any risk assessment or health considerations based on aroclor matching does not take into account some of the other potential health affects that may be associated with exposure to PCB's. Mr. Tranzelli strongly felt that in some instances the congener specific PCB data sampling is needed to round out the investigations. Mr. Murphy said there are long-term monitoring plans are being implemented that include congener specific analysis of media, specifically shellfish and fish tissues. Mr. Murphy also said there is an extensive GIS system for Adak that contains the majority of the site contaminants. URS Greiner manages that data. The data is not now available online due to the large size of the files. Mr. Cora said that site ranking was addressed to some extent in the PSE process and asked how ranking would be done. Mr. Tranzelli said he did not know how that could be done at Adak. Mr. Oates said that at Adak, many times when a site was found, it was immediately remediated, meaning the worst sites were handled first. Mr. Mitchell agreed that there was a need for a state-of-the-art GIS system and encouraged the Navy to consult with others. It is vital for the community to have access to this kind of information.
Dr. David Carpenter, a physician from the State University of New York at Albany, has been very involved in the human health effects of PCB's, metals and other environmental contaminants. There have been recent developments that PCB's are much more toxic then had been previously appreciated. Well-documented health effects of PCB exposure are cancer, suppression of the immune system, neuro-behavioral effects which include a reduction of IQ and change in attention span, and things that are generally described as endocrine disruption (changes to hormonal systems in the body).
The EPA risks are based only on consideration of cancer. Mr. Cora explained the EPA standard is the potential of being exposed, leading to a probability of an increased amount of cancer in 5 people out of 100,000. That is not the equivalent of saying that 5 out of 100,000 will get cancer. Dr. Carpenter said the usual standard is 1 in 1,000,000. That is an excessive risk according to NIH. Some of the other effects, particularly the neuro-behavioral and endocrine disruptive effects, appear to occur at much lower concentrations and exposures. These potential exposures are not incorporated in any of EPA's judgment of health hazards. Mr. Cora said he believed EPA did hazard quotients of PCB's on non-cancer effects. Mr. Oates added that it is common for any contaminant, whether metal or organic, where there is toxicological information that shows that something targets a particular organ, there would also be a hazard quotient observed over expected effect. Dr. Carpenter said EPA is aware of the issues, but the usual numbers given are based only on the consideration of the cancer. Mr. Oates said at Adak both carcinogenic and non-carcinogenic effects for humans were looked at. For non-carcinogenic effects, for the most part, there was a hazard index of less than 1, which means there is a toxicological benchmark that is being measured against. The measured concentration was less than the no observed effect level. There were other cases where it was higher.
Dr. Carpenter said PCB's, especially the dioxin-like PCB's, are potent suppressors of the immune system. There is a fair amount of evidence that infections seen in marine mammals that are exposed to xenobiotics, a general term for organic pollutants. The marine mammals are dying off because they are unable to fight infections. One does not normally associate the frequency or duration of a cold or an infection as being related to environmental exposures, but it may be. This can be a major factor in any exposed population.
There is very strong evidence that PCB exposure causes cancer. NIH classifies PCB's as a probable carcinogen on the basis of definitive evidence that PCB's cause cancer in animals, and suggestive (but not conclusive) evidence that PCB's are carcinogenic in people. In 5 of the 6 studies of occupational exposure to PCB's there was a statistically significant elevation in cancer. In the animal studies, the cancers that are particularly elevated are those of the liver, gallbladder and biliary tracts. Those cancers did not appear statistically significant in all of the studies. There were other cancers present: cancer of the gastro-intestinal tract, melanoma and lymphoma. These studies suggest that PCB's are general carcinogens. The studies did not mention the concentration of the exposure, which is a major weakness of all the studies. These were death certificate studies and the exposure was estimated by the job title of the individual.
There have been two recent important studies that are not occupational where exposure was determined by measuring the levels of PCB's in blood. The average half life of PCB's in the human body vary. Some people give values as short as two years; most people give values of 10 to 12 years. PCB's accumulate in body fat and everyone has PCB's in his or her body. On average for people attending the meeting, there would be 4 to 5 parts per billion in blood.
There was a study published in 1997 by Rothman that evaluated people with non-Hodgkin's lymphoma. Blood concentrations were studied of ill people as well as non-diseased people. There was a dose dependent increase in the risk of non-Hodgkin's lymphoma. The higher the PCB's in blood, the greater the likelihood the disease would be developed. An odds ratio of 1.0 means there is no added risk. As that number increases, that means that there is an increased risk. An odds ratio of 2.7 means you're 2.7 times as likely to develop the disease as someone that has no risk.
The Rothman study included anglers, people who ate fish in New York, about 160 women with breast cancer, and an equal number of women without breast cancer. If they divided the women based on PCB levels, there was a slight increase in the incidence of breast cancer, but it was not statistically significant. The human liver tries to breakdown PCB's, but it is not very successful. The liver produces enzymes to breakdown PCB's. Not everyone has exactly the same enzymes. About 15% of the population have a very slight difference in enzyme P4501A1. It is a single amino acid change in that enzyme. People with that particular polymorphism might have more breast cancer, but it was not a statistically significant relationship. The P4501A1 enzyme is also the enzyme that breaks down estrogen. Breast cancer is usually estrogen dependent. In women that had high PCB's and had this genetic polymorphism, there was almost a three-fold increase in the risk of breast cancer, which is statistically significant. PCB's probably promote all kinds of cancer, but the results are not all statistically significant.
In human populations, it is very difficult to prove the effects of PCB's. There have been four studies that show that children exposed to PCB's before birth suffer from reduced intelligence. These results came from a study in Taiwan where expectant mothers ingested PCB contaminated cooking oil over a number of months. The adults did not become very sick, but children born to these mothers had some pigmentation problems and reduced IQ. Prenatal exposure to PCB's is irreversible. These are very similar results to studies done of children exposed to lead. Another study was done on children whose mothers were exposed to contaminated fish from Lake Michigan. PCB's were the likely contaminant. The most highly exposed children studied at 11 years of age had an aggregate decrement of 6.2 IQ points. Animal experiments showed totally consistent results. There were behavioral deficits including retarded learning, persevereative behavior and inability to inhibit appropriate responsiveness. Animals exposed to PCB's seem to be less able to deal with frustration. This suggests that children exposed to PCB's develop an attention deficit/hyperactivity type disorder.
As an example concerning concentrations, Dr. Carpenter discussed thyroxin (T4), a hormone released by the thyroid gland that controls the body's metabolism. Thyroxin is not that structurally different from PCB's. Thyroxin has iodine molecules instead of chlorines on fixed positions. PCB's interfere with thyroid function, and they do so because of their structural similarity. If a child is hypothyroid at birth, the child becomes a cretin - profoundly retarded and small in stature. If an adult becomes hypothyroid, the adult becomes fat and dull, sleeps a lot and has no energy. Hypothyroid children have lower IQ's, they never perform as well, and have a host of problems.
There is increasing evidence that PCB exposure causes neuro-behavioral effects. A study of Mohawk children between ages 8 and 16 on the Canadian-U.S. border was done. The Mohawk stopped eating fish in about 1988. After 1990, elevated levels of PCB's could not be detected in breast milk. There was a statistically significant relationship between the PCB concentration in the children and their levels of thyroid hormone. The thyroid hormone levels were within what is officially the normal range. But the study showed that PCB's altered thyroid hormone levels.
Chemicals are either estrogenic or anti-estrogenic. Dioxin is anti-estrogenic. Dioxin exposure will tend to masculinize a developing female, or even an adult female. PCB's are complex because some of them are like dioxin; they are anti-estrogenic. Others, especially their metabolites, are estrogenic. They tend to feminize the developing male infant. When animals are exposed to PCB mixtures, feminization of the developing male infant is the dominant force. In Dr. Carpenter's personal ranking of the health effects is PCB's, the anti-estrogenic is probably not as serious as the thyroid hormone disruption and the central nervous system hormone disruption because they have these opposing actions. This is one of the reasons why it is so important to know the specific congeners that are present. There is now fairly good characterization of each of the PCB's whether they are estrogenic or anti-estrogenic. The values that have been set for fish advisories is usually done state by state and were set 20 years ago, with some revisions. With the exception of cancer, these other effects are new observations that for the most part have not been incorporated into standard settings and concerns about exposures. PCB compounds are migrating to the Arctic and Antarctic through contaminated sediments. That is why there are high levels in marine and land mammals. There is a potential for major threats to human health. Threats to the intelligence and behavior of the next generation are at the top of Dr. Carpenter's list. Effects can occur at the very low concentrations that already present in most humans.
Mr. Cora said EPA does not disagree that PCB's are a risk. Mr. Cora suggested that Dr. Carpenter review the risk assessment and the conversion factors to determine whether the wrong remedies are being selected. Global deposition and global transfer cannot be addressed in this forum. Mr. Cora stressed that decisions for Adak are being made based on releases from the site to the environment, and whether those releases are being adequately remediated.
Dr. Carpenter said he did not feel EPA was adequately addressing the non-cancer affects. The threat to human health should be driving the remediation activities. The threat to human health is best documented by measuring the PCB exposure of people that have been at Adak. Dr. Carpenter said he believed that more likely than not that people who had been on Adak for any length of time are loaded with PCB's. People from the Adak community wanted to know how Dr. Carpenter could make such a sweeping claim. Dr. Carpenter said his opinion derived from his work at many other sites. There are multiple routes of exposure. For example, PCB's are in the fish tissue will be stored in body fat. Even if the fish is not eaten, there are other routes of exposure. PCB's are volatile and can be absorbed through the lungs and skin. In general, people at PCB contaminated sites have significantly elevated PCB serum levels relative to people that do not live near those sites. Dr. Carpenter said he had no specific information about Adak but he felt this should be a major concern. Mr. Murphy said those pathways were analyzed as part of the risk assessment. Dr. Carpenter said PCB levels in blood should be determined. Blood testing is a very simple way to document exposure. Mr. Cora pointed out that on the East Coast there are much higher PCB levels in the sediments and fish than on Adak and was concerned that a false impression that PCB's on Adak were pervasive was being given.
Mr. Keith Martin said a biologist had told him that the PCB levels in salmon and fish in Finger Bay and Sweeper Cove are 1,000 times higher than allowed for human consumption. Dr. Carpenter said that the levels of PCB's in the people that live on Adak, as well as fish, must be considered. Mr. Murphy said that the biologists he was referring to are working as part of the long-term monitoring program of fish and shellfish tissues. The published data is available and should be considered rather than anecdotal statements that have not been corroborated for authenticity. Mr. Keith Martin said the biologist urged him to bring the elevated PCB levels found in fish tissues up to the RAB. Even though signs are posted, people are still eating the fish. Dr. Carpenter said that fish advisories in New York did not stop people from eating the fish. Mr. Arterburn asked Dr. Carpenter if he would review the study concerning subsistence users and PCB contamination in fish. Dr. Carpenter said there is no question that subsistence food gatherers are very highly exposed. Mr. Oates suggested the Circumpolar Conference might provide valuable information to Dr. Carpenter. Suzanne Marcy of EPA acts as a clearinghouse for all Alaska organizations, EPA, and the Canadian and Scandinavian governments to compile as much information as possible. Recently, ADEC hosted an intern who looked at Alaskan subsistence issues. One of the issues was the subtle effect on unborn children or small children from nursing. Mr. Oates said another thing being looked at is whether certain species bioaccumulate contaminants in certain organs. Perhaps a liver might be a traditional food that should be avoided, but the rest of the animal would be fine.
Mr. Stoll inquired about FDA guidelines for fish. Dr. Carpenter said that state guidelines are often based on FDA rules that were last revised about 20 years ago. Since then, new studies have given additional information. Dr. Carpenter said he would like to see the advisory levels lowered because PCB's are very toxic. Mr. Murphy asked Dr. Carpenter if he had compared his proposed advisory levels to the concentrations in the fish tissues at Adak. Dr. Carpenter said he had not had access to that information.
Ms. Miller said she felt that reliance on the current risk assessments methods is inadequate to protect the environment and human health because they do not take into account the low level effects on the human endocrine system, on vulnerable populations, and the possibility that PCB's on Adak are a lot more volatile than previously understood. Ms. Miller said she advocates a more precautionary approach than a purely risk based approach. Ms. Miller did not believe the statistics are accurate and are not based on sound science. The current research should be re-evaluated.
Mr. Bourdokofsky said he understood that as long as sediments were not disturbed there would be no risk. Mr. Cora said that was not the remedy. It was felt the sediments in Sweeper Cove do not present an unacceptable risk. The average concentration was 100 parts per billion in sediments (not fish tissue). The maximum concentration was 400 parts per billion in sediments. The highest concentration in fish found was 341 parts per billion. The risk based standard goal would be 30 parts per billion. The general standard for fish was 2 parts per million. Therefore, the concentration in fish is already below FDA standards. Dr. Carpenter agreed that the concentrations in sediment are not extraordinarily high, but he was concerned about the concentration levels in fish. Mr. Oates said the highest concentrations seemed to be in Rock Sole and Blue Mussels. The migratory fish seem to be less of a problem.
Mr. Ehrhart expressed concern that Anchorage panel was too defensive regarding the comments made by Dr. Scudato and his colleagues and requested that everyone be open-minded, and explain to new attendees the previous processes.
- National RAB Caucus and BECT and BTAG Meeting Briefings.
Due to the full agenda and to allow additional time for Dr. Scudato's report, Ms. Miller deferred her presentations until the next meeting.
- Public Comments.
Mr. Gates said that at the last meeting he presented a letter from the Adak Reuse Corporation (ARC) to ADEC Commissioner Brown asking for assistance in slowing down the ROD until more investigation was done. In particular, ARC was interested in more sampling in Finger Bay due to previous industrial and ship repair activities. ARC was told that unless there was additional evidence, there was no reason to re-open the record. A dive team from the Coast Guard took an underwater video in July 1999 at Finger Bay which showed quite a few large steel plate objects 10' x 12' x 2' in size at an approximate depth of 20'. The objects were covered with sea life and unidentifiable to the dive team. Ms. Gomes said she had seen drawings of a dry dock in Finger Bay. Mr. Gates said that there were 600 to 700 creosote piles found in Finger Bay that also needed attention. Mr. Gates inquired whether the video was sufficient evidence to reopen the record. Mr. Cora said the risk would have to be evaluated before a determination could be made. Mr. Cora reiterated that the program cannot guaranty there is no risk in the environment. The focus is on sites that pose an unacceptable risk. Monitoring is ongoing. If high levels of contaminants are discovered, re-evaluation will be undertaken. Mr. Murphy said it was known industrial activities occurred in Finger Bay and the large metal structures filmed by the divers were not a surprise. That does not mean there is no basis for further evaluation.
An Adak community member said that over the last few months he had tried to find an avenue for the Indian Environmental Program to enter the discussion. This participation would make a big difference in how things are presented and deal with some of the on-island concerns. Mr. Cora said that EPA currently has a government-to-government relationship with the United Aleut Nation.
- Set Date and Tenative Topics for Next Meeting
Ms. Miller suggested that EPA and ADEC discuss whether there are enough monitoring stations in place to identify problems and to also review the sampling data. The RAB has consistently raised concerns that the monitoring is too superficial to identify problems, particularly monitoring in Finger Bay. Mr. Cora said no long-term monitoring plan has been set yet.
Ms. Miller would like a report on the UXO dispute resolution process. Mr. Oates suggested that a discussion of what happened in Seattle and what tasks have been undertaken would be helpful. Mr. Murphy said a newsletter is under development that will be sent to the RAB that should help in distributing information. Mr. Stoll said Mr. Lekanof and Mr. Gromoff attended the Seattle meeting and that they could provide additional information to the RAB.
Ms. Miller would like a report from the regulatory agencies concerning the key components of the ROD and what is envisioned for long-term monitoring.
Ms. Miller would like to know the outcome of the ATSDR health assessment. Mr. Stoll said when ATSDR releases its results, that information would be provided.
Ms. Miller requested that a status report on the ROD be given. Mr. Cora said the goal was signing by the end of September. The ROD is in the formal final review process. Ms. Miller reiterated that at the last two RAB meetings, the members felt signing the ROD was premature and community concerns have not been addressed. Ms. Miller requested that the RAB discuss or initiate a resolution stating for the record that signing of the ROD should be delayed. Mr. Cora said in order to slow down the process, there must be substantive deficiencies identified in the remedy. To date, nothing has been received to show that the remedies chosen will cause irreparable harm or are inadequate to protect human health and the environment. That is what EPA needs to change the remedies selected.
Mr. Mitchell would like a report on the adequacy of the assumptions that went into the risk assessment and the guidelines for institutional controls as they relate to fish consumption, particularly in light of Dr. Carpenter's comments. Mr. Mitchell requested that Suzanne Marcy be contacted and exchange information with Dr. Carpenter. Mr. Oates said the risk methodology used was peer reviewed by ADEC. The methodology, inputs and exposure assumptions for a subsistence scenario is almost identical to those published and adopted by the state. One difference was the daily consumption rate for Adak was 126 grams per day; the final ADEC rate was 129 grams. Mr. Oates will find out if Dr. Marcy did a review and report back.
- Meeting Adjourned.
The next meeting was scheduled for September 15, 1999 on Adak (6:00 p.m. Adak time; 7:00 p.m. Anchorage time), with a room reserved and teleconferencing available for Anchorage RAB members. The meeting was adjourned at approximately 10:27 p.m.
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