ATSDR-PHA-HC-Lawrence Livermore National Laboratory, Main Site, Livermore, Alameda County, CA

HEALTH CONSULTATION

Community Health Concerns

LAWRENCE LIVERMORE NATIONAL LABORATORY, MAIN SITE
LIVERMORE, ALAMEDA COUNTY, CALIFORNIA

BACKGROUND

The purpose of this health consultation is to summarize resident and community stakeholder concerns in Livermore, California, collected by the Environmental Health Investigations Branch (EHIB), within the California Department of Health Services (CDHS), from 1996 to 1998.

This is the third consultation written by CDHS that will be incorporated into the final public health assessment (PHA) document to be written by the Agency for Toxic Substances and Disease Registry (ATSDR). Because ATSDR and CDHS are currently engaged in the PHA process, many community concerns have yet to be evaluated and are not addressed in this document. A completed community health evaluation will be included in the final PHA by ATSDR.

In 1989, ATSDR completed a Preliminary Public Health Assessment recommending that environmental data be reviewed to assess the potential impact on human health from activities at the Lawrence Livermore National Laboratory (LLNL) Superfund site (1). The CDHS/EHIB is conducting a PHA of the LLNL Superfund site in conjunction with ATSDR's Federal Facilities Assessment Branch under cooperative agreement between the two agencies.

Site Description

LLNL is comprised of two sites, the main site and Site 300. The main site is located approximately 50 miles east of San Francisco. It occupies 826 acres and is situated in the southeast section of the Livermore Valley in Alameda County. Since 1951, LLNL has been an active multi-program research facility operated by the University of California for the Department of Energy (DOE). According to LLNL, it was established in 1952 to help ensure national security through the design, development and stewardship of nuclear weapons. A number of operations at LLNL handle or generate hazardous materials, mixed wastes, and radioactive wastes. Some of the activities at LLNL have resulted in off-site contamination and potential exposure to the community of Livermore (2). Upon LLNL's discovery of the off-site contamination LLNL provided owners of potentially impacted wells with bottled water and initiated a groundwater investigation. In 1987, the United States Environmental Protection Agency (USEPA) placed the Livermore site on the National Priorities List (NPL) of hazardous waste sites due to the presence of volatile organic chemicals (VOCs) in the groundwater. Heavy metals, tritium, and other contaminants are also present in the groundwater. Treatment of contaminated groundwater began in 1989 and is ongoing. These cleanup activities are performed under the regulatory oversight of the USEPA, California Department of Toxic Substances Control (DTSC), and the California Regional Water Quality Control Board(RWQCB). Site 300 encompasses approximately 11 square miles of hilly land between the cities of Livermore and Tracy. The site is surrounded by open space used mainly for recreation and ranching. Since 1955, Site 300 has been used for the processing and testing of explosive materials. In 1990, Site 300 was placed on the NPL list due to contamination of the groundwater (3). The main contaminants found in soil and groundwater includes VOCs, uranium 238, and tritium.

Demographics

According to the 1990 census, the total population of Livermore was 56,741(4). At that time, over 88% of the inhabitants were of European-American descent, 9.8% were of Hispanic/Latino origin, 1.5% of the population were African Americans, .07% were Native Americans, and 4.6% were Asian/Pacific Islanders. Although English is the most widely spoken language in Livermore, roughly 2,000 people are Spanish speakers with slightly less than 1,000 of those reporting low English proficiency. Roughly 1,000 people reported speaking an Asian or Pacific Island language with 500 of those households reporting low English proficiency.

Over 67% of the homes in Livermore at the time of the 1990 census were owner- occupied with an average of 2.7 persons per household. The median age of the population was 31.7, with 7.1% of the population being over age 65. In 1990, the median income in Livermore was $49,149. At that time, roughly 5% of the people reported living below the poverty level.

Early Community Concerns

After talking with the director of Tri-Valley CAREs (Communities Against A Radioactive Environment), an LLNL watchdog group based in Livermore, CDHS learned community health concerns regarding LLNL arose approximately 20 years ago. It was at this time that people concerned about how the activities of LLNL might affect the health and safety of the nearby community formed Tri-Valley CAREs. They received two USEPA technical assistance grants to monitor environmental cleanup at LLNL main site and at Site 300. In addition, a number of studies and reports regarding the extent of on-site and off-site contamination and community health status, conducted by CDHS, USEPA, LLNL, and DOE, began to prompt community concern. This section will briefly describe a few of these reports and will provide background on issues of community concern.

The Livermore community was first made aware of the issue of melanoma (a type of skin cancer) in the 1980s when a CDHS study showed that melanoma rates among LLNL employees were elevated (5). In 1984, LLNL began its workplace melanoma screening program.

Following up on previous findings, CDHS conducted a study that looked at cancer incidence among children and young adults in Livermore between 1960 to1991 (6). The study found that there were over twice the number of malignant melanoma cases in Livermore than expected. Children born in Livermore had six times as many cases than expected. The study also found that during the 1960s there were more childhood brain cancer cases in Livermore than would be expected for Alameda County. No follow up studies have been completed.

In response to community concerns, CDHS reviewed birth records in 1996 to determine if rates of birth defects in Livermore from 1983 to1987 were elevated. The review of records indicated that no unusual pattern of birth defects existed in Livermore during that time (7).

Also, in 1996, letters written by a Livermore resident to CDHS expressing concern over the high rates of various cancers in Livermore prompted a review of cancer cases by the California Cancer Registry (CCR). The CCR is a statewide, population-based cancer surveillance program that collects information about most cancers diagnosed in California residents after January 1, 1988. Their review found that adults living in census tract 4515, a residential area next to LLNL, showed higher levels of melanoma than other areas in Livermore although those levels were not statistically significant (8).

Big Trees Park is a community park located in a residential tract between Charlotte and Kathy Way in the City of Livermore. Although the park is not on the LLNL site, it is an area of concern to the community because higher than typical levels of plutonium were found in the soil. The Arroyo Seco Creek borders the northern boundary of the park, with the Arroyo Seco Elementary School bordering the west boundary. Residential homes border the south and east sides of the park. The park consists of a baseball field, a grass playing field, picnic areas, swings and other playground equipment, with numerous eucalyptus trees throughout.

Community members became aware of plutonium levels in soil in Big Trees Park in the mid 1990s. In 1991, LLNL collected and analyzed soil samples from LLNL property. From these data, USEPA determined that levels of plutonium in some areas approached the USEPA Preliminary Remediation Goal (PRG), a health protective screening level that is used to decide whether or not a site should receive further investigation. It represents a level of plutonium that could add a one-in-a million chance of developing cancer to already existing cancer risks.

These findings prompted USEPA to perform additional soil sampling on-site in September 1993. Samples were also collected from three community parks -- Big Trees Park, Sycamore Grove Park, and Sunflower Park -- in order to establish background levels for comparison. These areas were presumed to be unaffected by the operations at LLNL. In the limited sampling, plutonium levels were found to be above background levels at all three parks, with the highest concentrations found in Big Trees Park. USEPA concluded that additional soil sampling was needed at Big Trees Park.

In January 1995, LLNL, together with USEPA and the CDHS Radiologic Health Branch (RHB), collected surface soil samples in Big Trees Park. Again plutonium concentrations in a number of locations were found to be elevated above background levels (9). Although elevated, the levels were below the USEPA's proposed PRG of 2.5 picocuries per gram, the level that would trigger further investigation. Based on this evaluation, USEPA concluded that the amount of plutonium found in the Big Trees Park soil does not pose an unacceptable risk to human health or the environment and that remediation of the soil in Big Trees Park was not necessary (10).

In April 1995, at USEPA's request, ATSDR reviewed data collected from Big Trees Park and concluded that the maximum concentration of plutonium found in the soil is not at a level of health concern (11).

In 1996, community concern over melanoma rates and the presence of plutonium in Big Trees Park prompted CDHS to become involved in the PHA process. It is at this point that CDHS began to informally record community health concerns. In a joint effort, both CDHS and ATSDR were to be responsible for writing health consultations, while CDHS would take the lead on community participation and education. CDHS developed a 22 person site team made up of community members, stakeholders, LLNL environmental regulation staff, and representatives from the DOE, ATSDR, CDHS, Alameda County, and the City of Livermore. The site team was responsible for assisting in the prioritization of health consultation topics, for communicating site team information to and from their constituents, and for reviewing PHA related documents. Site team protocol and participation processes were established collectively. Regularly held site team meetings provided an important forum for the discussion and documentation of community concerns in Livermore. In 1998, ATSDR ceased funding CDHS community participation activities.

METHODOLOGY AND LISTING OF COMMUNITY CONCERNS

Between 1996 and 1998, CDHS employed five methods for documenting a broad range of community concerns: 1) scheduled interviews; 2) preliminary stakeholder meetings; 3) random door to door interviews; 4) recording community comments at site team meetings; 5) recording input from site team community representatives.

CDHS did not inquire as to whether an individual had already expressed a particular concern during an interview or at a previous meeting. Therefore, it is possible that a community member's concern was documented on more than one occasion and repeated in multiple sections of this document.

Scheduled Interviews

Community concerns were first solicited in October 1996. Eighteen interviews were conducted with resident's representatives of local businesses, and members of local organizations at their home, work place or over the phone. Interviews were conducted using open-ended questions regarding demographics, family health history, length of time in home, and health concerns related to the site.

Concerns about Melanoma and other Cancers

Several interviewees expressed concern about high cancer rates in Livermore, particularly regarding melanoma. One interviewee reported that a relative who worked close to the lab was diagnosed with melanoma.

Another interviewee, working close to LLNL, developed "suspicious" looking moles, that had to be removed.

An interviewee noted that he knew two LLNL employees who were diagnosed with melanoma.

A resident who lives close to the lab was diagnosed with a pre-cancerous lesion on his nose. The interviewee added that the lesion could be attributed to medication he was taking at the time, which required him to stay out of the sun.

A resident who was concerned about her child contracting melanoma, felt that high rates could be attributed to the large amount of sunlight in Livermore.

Another long-term resident reported cases of reproductive cancers among family and friends in Livermore.

Several interviewees had concerns about leukemia and brain cancer among elementary school-aged children, including children of LLNL employees.

Two interviewees did not attribute their cancers to LLNL.

Birth Defects

Two interviewees were concerned about an elementary school child that had a rare birth defect consisting of the inability to control his rectal sphincter. They remembered hearing that between five and eight other kids in Livermore had the same condition.

An interviewee reported that his son has a birth defect consisting of a smaller than normal esophagus.

Concerns about the Safety of Water, Soil and Air

Several interviewees expressed concern about the quality of drinking water. Some noted that although they may not be experiencing health problems currently, problems may occur in the future.

Two interviewees stated that in informal experiments goldfish were not able to survive in tap water. This led them to become suspicious about the quality of the water in Livermore.

A resident was concerned about children playing in the dirt and in the Arroyo Seco Creek. Since 1996, she has had chronic diarrhea, which she says could also be related to the medication she takes.

A resident complained of stomachaches, headaches, and fatigue. However, symptoms have decreased since the resident moved to another unit within the same complex. The resident stated that the dust in the house is abnormally sticky and thick.

Two Livermore residents felt that unsafe lab practices could have contaminated the land and drinking water, thereby indirectly causing the fibromyalgia, chronic fatigue, and diarrhea that both are experiencing.

Two long-term residents reported fatigue, body aches, headaches and irritable bowel syndrome, psoriasis and chronic rashes.

One interviewee is concerned about long term, low dose exposure to plutonium in soil in Big Trees Park because her kids often played there when they were young.

One resident is concerned about groundwater, air, soil safety and the plutonium in Big Trees Park. He and his family did not have any health problems but he felt that some exposures from LLNL are likely.

Another interviewee was concerned that the quality of air around the lab may have contributed to the fact that four of his children have asthma.

General Concerns

Concerns were expressed regarding adult and child exposure to radioactive substances such as tritium, plutonium and uranium via accidental or controlled releases, and the cumulative risk resulting from potential exposure to these chemicals. Questions were raised as to why LLNL does not measure organically bound tritium. It was suggested that the tritium concentration in organically bound material such as vegetation samples should be tested because concentrations of tritium could be 60% or higher than that shown in the free water.

Some interviewees believed that radioactive substances could impact both cancer and non-cancer endpoints. For instance, they had read that tritium damages red blood cell proteins and thus could impact health in several ways.

One interviewee was concerned about the effects of radiation on thyroid function.

Another interviewee felt comfortable with the Department of Energy's process of testing for tritium in grapes.

Concerns about Contaminated Sludge

An interviewee was confident that the results of LLNL water sampling were sound. The interviewee felt that in the future they would learn that the sludge that was distributed in the past was contaminated.

Preliminary Stakeholder Meetings

In meetings held with members of Tri-Valley CAREs and site team community members on September 11, 1996 and February 25, 1997, participants were mainly concerned that the accuracy of any PHA may be compromised if CDHS and ATSDR were to rely only upon data from LLNL. Attendees presented their concerns about the ability of the community to participate in the PHA process in a meaningful way. Clarification of their scope of influence in the PHA process and access to all raw data as well as to all materials and internal agency correspondence were requested. Attendees also expressed concern about how the affected area will be defined given that contamination from LLNL does not know boundaries.

Door to Door Discussions and Outreach

The following is a summary of the informal door-to-door outreach that was conducted on the afternoon of February 19, 1997, with residents living in census tract 4515. This tract was chosen because elevated levels of melanoma were observed there in CDHS's 1996 study (12). These were unscheduled discussions that were conducted without the use of a questionnaire. Residents were asked how long they had lived in Livermore, if they had any health concerns related to LLNL to report, and if they would like to attend public meetings or receive more information on the subject. Of the 15 homes that were approached, seven people were available. Of the seven people with whom we spoke, four did not have health concerns that were related to LLNL. Residents were provided with a fact sheet describing the PHA at the conclusion of each interview.

A Livermore resident was concerned about the "three mile cancer radius" around LLNL. She and her spouse often think about moving but are very settled in their home and have not "heard about any data to substantiate" their fears.

Another interviewee expressed concern about the plutonium in Big Trees Park and was eager to receive any information on the extent of the contamination there.

A resident did not have any health problems to report but stated that the family is generally concerned about health issues related to the lab. The interviewee remembers seeing steam generated near Big Trees Park years ago and wondered if remediation was taking place at that time.

Another interviewee had just moved into the area and had heard about the plutonium at Big Trees Park. She was concerned about exposure to her young child.

Site Team Community Representatives Comments

The community representatives who sit on the site team gave voice to community concerns on an on-going basis and acted as conduits between the community and CDHS and the other governmental agencies involved in the PHA process. These concerns were recorded in meeting notes at each site team meeting and in records of phone calls to CDHS staff. At the November 19, 1997, site team meeting, the site team members were asked to list the areas of concern for future health consultation topics. It was this first prioritization of health consultation topics that initially directed and shaped CDHS, USEPA, and ATSDR investigations in the PHA process. Those topics are listed hereafter in Appendix A.

Site team community representatives expressed concern that reliance on data generated by LLNL for the PHA would not produce a quality, unbiased report.

The site team member representing Alameda County stated that confirmation over the safety of drinking water was a priority. He reported that many calls are fielded to his office from Livermore residents concerned with their proximity to the lab and the safety of both groundwater and drinking water in Livermore. In addition, people considering a move to Livermore often request county verification of drinking water standards before they purchase their homes. Summarized water data would be useful to the county in addressing people's fears.

All site team community members had great interest in the extent and source of the contamination in Big Trees Park. Some questioned whether air emissions from an LLNL stack could have released plutonium into the park. Some were not satisfied with the depth of the samples taken during the 1995 sampling effort and were requesting additional sampling and further investigation.

Community members on the site team requested that CDHS review health studies conducted at Livermore in a health consultation. It was suggested that findings that LLNL employees had elevated rates of melanoma be more closely examined. They also suggested using LLNL employees as a sentinel for studying the health of non-LLNL employee residents. A community member suggested including the National Institute for Occupational Health (NIOSH) in any future investigations.

Community members on the site team expressed concern about past and present air emissions from LLNL. The members discussed that aerial deposition from a stack at the LLNL site could be a possible source of the plutonium found in Big Trees Park.

Several site team members stated that more accurate information on tritium is needed. They requested information on the effects of tritium on the lungs and the immune system.

Community members on the site team were concerned about the effects of exposure to a combination of chemicals. They suggested that exploring health impacts of cumulative exposures would be more useful than investigating one isolated chemical exposure at a time.

A representative from a community-based organization suggested that CDHS look into the feasibility of testing actinide levels in urine as a way of monitoring plutonium levels in the body.

Many felt that Sunflower Park and Sycamore Grove Park, the parks found to have plutonium above background levels during USEPA's 1995 round of sampling, should be included in a new sampling effort.

Community Comments at Site Team Meetings

Community members expressed their concerns at the quarterly, public site team meetings held on March 21, 1997, July 17, 1997, November 19, 1997, May 13, 1998, September 9, 1998, and February 25, 1999. Community members were asked to write their concerns on blue comment forms and/or to express them orally during public comment periods scheduled throughout the meeting. Comments that were not recorded on blue forms were captured in the meeting notes. Other comments reflected here were made in writing to CDHS through the mail. A total of 55 community comment forms were collected during four site team meetings. The following is a summary of concerns as expressed on the forms [Appendix B].

Plutonium in Big Trees Park

The largest number of concerns revolved around exposure to plutonium in Big Trees Park. Despite the fact that plutonium levels in the park were considered below levels of concern by USEPA, some community members continue to feel that exposure to any level of plutonium is unsafe. Community members expressed concern and anger about the potential risk of having their children play in the park and ingest soil or breathe soil dust. Those who owned homes around the park questioned whether it is safe to live in close proximity to a "contaminated area," where there may be exposures to soil dust that may blow onto their property.

Many community members questioned how the plutonium got into the Big Trees Park. Some community members felt that the 1995 sampling effort by USEPA should have involved deeper soil sampling. Many felt that the community should at least know about the levels so that they can decide whether or not to use the park. Some community members posted a sign in the park that read "Plutonium Found Here" and included additional information about the amount and nature of plutonium. Two community members reported that each time a sign was posted, someone would remove the sign from the park.

Sewage Sludge Concerns

Several comments from the public arose during the discussion of sludge as a possible mechanism for plutonium getting into Big Trees Park. The possible distribution of contaminated sewer sludge throughout the City of Livermore and the presence of plutonium in other parks and homes became a concern for the community. Two people stated that they remember receiving sludge from the reclamation plant in the 1970s. Other people inquired about costs and types of plutonium testing and requested recommendations for companies that conduct such tests. A few people asked what would be done if, in fact, plutonium were to be found in the soil on their residential properties in Livermore. They felt that a clean-up plan should be offered at no cost to the homeowner.

Community concerns regarding sludge increased as CDHS and ATSDR investigated the possibility of plutonium-contaminated sludge getting into the park. During completion of a health consultation on Big Trees Park, CDHS learned that in 1967, an accidental release of plutonium from LLNL to the city's sanitary sewer contaminated the sewage sludge at the Livermore Water Reclamation Plant (LWRP) (13). In the health consultation, CDHS reported that the sewage sludge was widely distributed to municipal agencies and the public for a number of years after the 1967 plutonium release (13). CDHS findings supported the possibility that sludge containing plutonium was distributed to the public and required further investigation.

Cancer Concerns

The third most pertinent area of concern expressed by community members at site team meetings was the cancer rate among Livermore residents. At one site team meeting, a resident summarized a letter she had sent to CDHS listing people who had died of various cancers in Livermore. At another meeting, a couple expressed anger over the rates of melanoma and brain cancer. Other community members cited leukemia, and pancreatic and liver cancer as being unusually high in Livermore.

Birth Defect Concerns

Concern was expressed that exposures to both residents who work at LLNL and to residents who are not employed at LLNL have caused a higher rate of birth defects in their children than in children in other cities. A LLNL employee whose child was born with a birth defect suggested that the children of LLNL employees be tested.

General Concerns

There was general concern about how little is known about health effects from low dose, long term exposures to radioactive materials. This is coupled with the concern that current levels of exposure considered safe by regulatory agencies are not sufficiently health protective.

Some people felt that government and LLNL studies were not credible and felt that more "neutral" or "unbiased" information was needed for people to feel safe.

Concerns Expressed at ATSDR's Public Availability Session

In September 1999, ATSDR conducted a public availability session in Livermore. Six people provided comments to ATSDR regarding their health concerns. A parent was concerned about her child's many absences due to illness while attending Arroyo Seco School. Since leaving the school, she does not have as many illnesses. This parent would like to know the absentee rate at Arroyo Seco School as compared with other schools.

A parent stated that her child had ridden his bicycle over an area near North Mines Road that had a radiation sign. She wanted to know if the lab had any activity in the area.

Another interviewee was concerned about a trichloroethene (TCE) groundwater plume in the northwest corner of LLNL.

One resident expressed concern about the adequacy of air modeling as well as the presence of tritium and plutonium in the area. This person was particularly concerned about the maintenance of filters at the lab that would prevent plutonium from entering the environment and stated that plutonium particle size should be considered during analysis.

Another resident was concerned about apparent burning at the lab after seeing a red glow on site.

Evaluation of Community Concerns

Although many community concerns have yet to be addressed, CDHS and ATSDR have undertaken a number of activities to respond to community concerns. First, to address concerns about inclusiveness and accountability in an open and fair assessment of public health, CDHS set up a public participation process. This process included the development of a site team as well as open, public, quarterly site team meetings during which community concerns could be addressed. CDHS also completed two health consultations that addressed concerns about the safety of Livermore water and the contamination in Big Trees Park. These efforts are discussed in more depth in the following paragraphs.

Addressing Water Concerns

As a step toward addressing community concerns regarding the safety of Livermore water, CDHS completed a health consultation that assessed the quality of the city's municipal water systems and identified private domestic wells potentially impacted by the contaminated groundwater plume (14). CDHS did not find that any site-related contaminants regulated under Title 22 of the State Drinking Water Act were detected above the maximum contaminant level (MCL) in public drinking water. However, three non-LLNL related contaminants -- tetrachloroethylene (PCE), di-(2-ethylhexyl)phtalate (DHEP), and ethylene dibromide (EDB) -- were detected above the MCL. CDHS identified approximately 70 private domestic wells in the vicinity of LLNL. Of those private wells, three that were a potential conduit for inter-aquifer cross contamination have been destroyed. Their owners destroyed 24 wells, nine wells are no longer in use, and 34 wells may still be in use.

ATSDR has completed an exposure evaluation of all of the private wells, which had detected contamination. The results of this evaluation, which indicated that completed exposures were below levels of health concern, were distributed to site team members at the September 1999 site team meeting and will be included in the public health assessment.

Addressing Concerns Pertaining to Plutonium in Big Trees Park

In response to community concerns regarding the presence of plutonium in Big Trees Park, CDHS completed a health consultation on February 9, 1998, to evaluate the potential source or route of the plutonium in Big Trees Park (15). ATSDR staff performed a radiological analysis to determine the health impact from exposure to plutonium found in surface soil of Big Trees Park. The analysis evaluated two exposure routes, ingestion of contaminated soil and inhalation of particles, and took into account a young child playing in the park where the maximum plutonium concentration was found. ATSDR concluded that plutonium found in surface soil at Big Trees Park is below a level of health concern.

In the health consultation, CDHS staff investigated three potential sources for the plutonium found in Big Trees Park: sewage sludge; aerial deposition; and sediment distributions from Arroyo Seco. The health consultation concluded that the plutonium might be the result of both aerial deposition and sediment distribution from the Arroyo Seco channel.

To protect the public from potential exposure to plutonium that may exist at greater depths, CDHS recommended additional soil sampling to define the vertical extent of plutonium contamination in the Arroyo Seco channel and in Big Trees Park. Based on these recommendations, LLNL, with oversight from USEPA and CDHS-Radiological Health Branch, conducted additional soil sampling in Big Trees Park in 1998 to determine if plutonium was present at levels of health concern at deeper soil concentrations and to learn more about how the plutonium could have reached the park. ATSDR reviewed the additional data and completed a health consultation that was released on January 10, 2000. In this health consultation, ATSDR stated that the most likely pathway by which plutonium reached the park was through the application of plutonium contaminated sludge as a soil amendment (15). ATSDR also restated that although there are elevated concentrations of plutonium in the park, those levels are below levels of health concern set by USEPA and are below levels that the National Council on Radiation Protection (NCRP) has set for requiring additional activities.

Addressing Concerns Related to Tritium Monitoring and Potential Exposure

ATSDR responded to the community's request for sampling of organically bound tritium by writing two health consultations, one related to tritium monitoring and another that related to exposure assessment of tritium exposure from two accidental tritium releases. In October 2000, ATSDR convened an expert panel to review tritium monitoring and dose assessment procedures. Members of the LLNL site team were asked to review and comment on the areas of expertise and tasks of the proposed panel and a representative of the site team attended the panel meeting. Community members of the site team were not in favor of this panel and reiterated that ATSDR should conduct environmental sampling of organically bound tritium instead.

The panel completed a report of their review of tritium monitoring and community exposure (at LLNL and the Savannah River Site) in July 2001. ATSDR's summary of this report was distributed as a public comment health consultation in July 2001 (16). This health consultation concludes that current tritium dose assessment procedures may underestimate tritium doses due to contributions from organically bound tritium, but that those contributions may be estimated from existing inorganic tritium measurements. The panel developed recommended dose parameters that account for contributions from organically bound tritium. This health consultation further concludes that tritium exposures to the LLNL community are not at levels of public health concern.

In response to the panel conclusion about short-term accidental exposures, ATSDR completed another health consultation specifically addressing two known accidental tritium releases. ATSDR applied the dose parameters recommended by the expert panel and tritium concentrations estimated from air dispersion modeling to evaluate off-site doses. The estimated doses were below levels of health concern. The analysis was corroborated by human urine analyses, which were collected and analyzed immediately after one of the releases .

At the November 8, 2001, Site Team meeting, the community members on the site team expressed great concern over the methodology and findings of the tritium health consultation, particularly the validity of the results of the human urine analysis. ATSDR subsequently withdrew the draft health consultation on the health effects that may have resulted from two accidental releases that occurred in 1965 and 1970. ATSDR modified the evaluation and released a public health assessment addressing exposures to the 1965 and 1970 releases (17).

Public comments were received on this health consultation and were responded to by CDHS [Appendix C].

CHILDHOOD HEALTH CONSIDERATIONS

This health consultation includes community concerns about exposures and health impacts to children. CDHS and ATSDR recognize that children can be more sensitive to health effects caused by environmental contaminants and believe that it is important to search for additional information that will increase our understanding and ensure that children's health is protected. While this document does not evaluate exposures to adults or children, other documents produced by CDHS have evaluated children's exposures in accordance with health guidance set by ATSDR and USEPA.

CONCLUSIONS

In this health consultation, CDHS has summarized community concerns collected during scheduled interviews, preliminary stakeholder meetings, site team meetings, and door-to-door interviews. Overall, people were concerned about exposures to potentially contaminated water, air, and soil. Residents questioned the safety of the City of Livermore's water supply and wondered whether contaminated water may have migrated off-site from the lab. Citing a smoke stack located at the main site, some residents were concerned that plutonium and tritium may have been released into the air and may have been deposited onto vegetation. Plutonium, present in off-site soil in three parks, was also of concern given the proximity of one park to an elementary school. Other interviewees, including some who live directly across from the lab, were not concerned about exposures to chemicals from LLNL.

The prevalence of various cancers dominated the community health concerns, which were recorded in the two-year period during which CDHS met with community members and community stakeholders. Although melanoma was of great concern, people also worried about brain cancers, childhood leukemia, and cervical and breast cancers among others. Several people seemed to be experiencing fatigue and muscle aches related to fibromyalgia and or chronic fatigue syndrome. The perceived prevalence of birth defects was also expressed with a specific concern voiced by two community members about health effects in children of LLNL employees. Others reported that they did not have any health concerns related to LLNL.

PUBLIC HEALTH ACTION PLAN

The public health action plan for the LLNL site contains a description of actions that have been taken or will be taken by ATSDR and CDHS. These actions address recommendations based on the findings presented in this health consultation.

Actions Completed

CDHS completed a health consultation which evaluates potential routes for the plutonium contamination in Big Trees Park (May 1999).

ATSDR completed a health consultation which evaluates the 1998 sampling in Big Trees Park (January 2000).

ATSDR released a public comment draft health consultation which evaluates potential exposures from tritium releases in 1965 and 1970 (August 2001).

ATSDR released a public comment draft health consultation which describes the conclusions of an expert panel's review of tritium analyses used by LLNL (August 2001).

CDHS released a public comment draft health consultation which describes community health concerns relative to the LLNL Site (May 2002).

ATSDR released a public comment draft health assessment which evaluates potential exposures from tritium releases in 1965 and 1970 (July 2002).

CDHS released a public comment draft health consultation which summarizes health studies conducted of the Livermore community and LLNL workforce (February 2003).

Ongoing Actions

CDHS convened a workgroup to generate possible strategies for investigation of the distribution of sewer sludge. In November 2002, CDHS released a report proposing a process to address the distribution of sludge.
ATSDR is continuing work on the public health assessment (PHA). This assessment will integrate the results of the completed health consultations and address potential community exposures from air releases, soil and sediment contamination, and potential releases to surface water.
ATSDR is currently leading all site team activities. ATSDR will continue to be responsible for recording community concerns until the completion of the PHA process.

PREPARERS OF REPORT

Gina Margillo, M.A.
Community Education and Participation Coordinator
Impact Assessment, Inc., Contractor to
Environmental Health Investigations Branch
California Department of Health Services

Sumi Hoshiko, M.P.H.
Epidemiologist
Site Assessment Section
Environmental Health Investigations Branch
California Department of Health Services

Marilyn C. Underwood, Ph.D.
Staff Toxicologist
Site Assessment Section
Environmental Health Investigations Branch
California Department of Health Services

Tracy Barreau
Environmental Scientist
Environmental Health Investigations Branch
California Department of Health Services

ATSDR Regional Representatives

William Nelson
Gwendolyn Eng
Libby Levy
Regional Representatives, Region IX
Agency for Toxic Substances and Disease registry

ATSDR Technical Project Officer

Tammie McRae, M.S.
Environmental Health Scientist
Division of Health Assessment and Consultation
Superfund Site Assessment Branch, State Program Section
Agency for Toxic Substances and Disease Registry

REFERENCES

Agency for Toxic Substance and Disease Registry (1989). Lawrence Livermore National Laboratory Preliminary Public Health Assessment, U.S. Department of Health and Human Services.

National Air and Radiation Environmental Laboratory (1994). Confirmatory Sampling of Plutonium in Soil from the Southeast Quadrant of the Lawrence Livermore National Laboratory. United States Environmental Protection Agency.

Lawrence Livermore National Laboratory (1992). Final Impact Statement and Environmental Report for the Continued Operations of Lawrence Livermore National Laboratory and Sandia National Laboratory; SCH90030847.

Bureau of the Census. 1990 Census Population: Washington: US Department of Commerce.

Austin, D., Reynolds, P, Snyder, M, Biggs, M. (1981). Malignant Melanoma Among Employees of Lawrence Livermore National Laboratory. The Lancet October 3:712-716.

California Department of Health Services, Environmental Health Investigations Branch, (1995). Cancer Incidence Among Children and Young Adults in Livermore, California, 1960-1991.

California Birth Defects Monitoring Branch, California Department of Health Services, (1996). Birth Defects Around Livermore, 1983-1989.

Cancer Surveillance Section, California Department of Health Services, (1986). Review of Cancer Cases 1988-1993.

MacQueen, Don (1995). Livermore Big Trees Park, 1995 Soil Survey Results. University of California, Lawrence Livermore National Laboratory. UCRL-ID-121045.

United States Environmental Protection Agency, (1998). Split Sampling Plan, Livermore Big Trees Park, Lawrence Livermore National Laboratory, EPA Region IX. August 1998. Document Control Number 4900-06-23-AAAB.

United States Environmental Protection Agency. Lawrence Livermore Laboratory Plutonium Fact Sheet; 1995 September.

Cancer Surveillance Section, California Department of Health Services, (1996). Cancer Incidence in Livermore, 1988-1993.

California Department of Health Services, Environmental Health Investigations Branch (1999). Health Consultation concerning Lawrence Livermore National Laboratory: Plutonium Contamination in Big Trees Park, Livermore, Alameda County, California.

California Department of Health Services, Environmental Health Investigations Branch (1998). Health Consultation concerning Lawrence Livermore National laboratory: Water Quality of the City of Livermore's Municipal Water Systems and the Identification of Private Wells in the Vicinity of the Lawrence Livermore National Laboratory.

Agency for Toxic Substances and Disease Registry (2000). Health Consultation concerning Lawrence Livermore National Laboratory: Big Trees Park Sampling. Atlanta: US Department of Health and Human Services.

Agency for Toxic Substances and Disease Registry (2001). Health Consultation concerning Lawrence Livermore National Laboratory: Tritium releases and potential offsite exposures. Atlanta: US Department of Health and Human Services.

Agency for Toxic Substances and Disease Registry (2001). Health Consultation concerning Lawrence Livermore National Laboratory: Exposure Assessment of 1965 and 1970 Accidental Tritium releases at the Lawrence Livermore National Laboratory. Atlanta: US Department of Health and Human Services.

CERTIFICATION

This Public Health Consultation, Community Health Concerns, Livermore, California, was prepared by the California Department of Health Services under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the public health consultation was begun.

Tammie McRae, MS
Technical Project Officer, SPS, SSAB, DHAC

The Division of Health Assessment and Consultation, ATSDR, has reviewed this public health consultation and concurs with the findings.

Roberta Erlwein
Chief, State Program Section, DHAC, ATSDR

APPENDIX A: SITE TEAM PRIORITY CONCERNS

More complete sampling effort in Big Trees Park that would include Sycamore and Sunflower parks

A closer examination of melanoma rates in Livermore

Health impacts of cumulative exposures

Past and present air emissions from LLNL

More accurate information on tritium levels and tritium testing

Confirmation of the safety of Livermore's drinking water

A closer examination of LLNL employee melanoma rates

Need for a review of health studies

Biomonitoring for plutonium

APPENDIX B: LIST OF COMMUNITY AND STAKEHOLDER CONCERNS

Exposure Concerns

Children's exposure to plutonium in Big Trees Park-inhalation of soil dust
Exposure to LLNL contaminants in drinking water
Cumulative risk of multiple exposures
Long term low dose exposures to LLNL contaminants
Residential distribution of plutonium contaminated sewer sludge from the LWRP
Exposures to tritium and uranium

Health Concerns

Melanoma
Birth defects
Leukemia
Ovarian Cancer
Lymphoma
Brain cancer
Headaches
Fatigue
Stomachache
Diarrhea
fibromyalgia
Irritable bowl
Psoriasis
Rashes

Procedural Concerns

Meaningful community participation
Public access to raw data
Clear definition of affected area
The need for deeper sampling
Accurate tritium information needed
Notification of plutonium in Big Trees Park
Credibility of LLNL studies
Financing of plutonium testing in yards that received sewer sludge from LWRP

APPENDIX C: RESPONSE TO PUBLIC COMMENTS

In April 2002, copies of the Health Consultation Lawrence Livermore National Laboratory, Community Health Concerns, were distributed to the Lawrence Livermore Public Health Assessment (PHA) Site Team for review. Copies of the document were placed in the Livermore Public Library for all interested parties to review. Also, additional copies were sent to individuals who requested this document. Furthermore, staff presented the major points of the consultation from the Environmental Health Investigations Branch (EHIB), of the California Department of Health Services (CDHS), at the PHA Site Team Public meeting held on February 25, 1998.

This appendix contains the comments received from community members, governmental regulators, community-based organizations, and Lawrence Livermore National Laboratory (LLNL), as well as responses to the comments prepared by CDHS-EHIB. Occasionally, there were questions/comments that were unanswerable in the context of this health consultation. Furthermore, it was not the purpose of this health consultation to respond to community concerns; this is primarily a summary of community concerns. Several sections of the health consultation have been updated to include information provided to us during the public comment period.

I. Comments

CDHS's stated purpose in the April 30, 2001, health consultation on Community Health Concerns is to review resident and community stakeholder concerns in Livermore, California, collected by CDHS from 1996 to 1998. We applaud and appreciate CDHS's efforts to methodically collect and describe community health concerns during approximately the first two years of the PHA. However, as noted above, CDHS's responsibilities around community involvement in the PHA ended in early 1999, when ATSDR ended CDHS funding for these activities. But ATSDR's PHA process continued, and is still on going. As a result, CDHS's Community Concerns Health Consultation records community concerns for approximately a two year period (1996-98), but CDHS's evaluation of these health concerns covers an additional four year period (1998-2002). The disjuncture in time frames between the listing community concerns period and the evaluation of community concerns period introduces a serious source of error into CDHS's health consultation and should be addressed.

The unfortunate result of de-funding CDHS's critical activities regarding public participation is that there is no community voice recorded in CDHS's health consultation during the period that CDHS was not responsible for compiling this information. In contrast, under the section Evaluation of Community Concerns (page 12), CDHS's health consultation presents a progress report of PHA activities conducted by ATSDR during these later years. This progress report appears to present an objective accounting of how several community concerns were addressed by CDHS and ATSDR. It does not. We recognize that CDHS states on page 12 that "because ATSDR and CDHS are currently engaged in the PHA process, many community concerns have yet to be evaluated." However, despite the implications of this important acknowledgment, the health consultation goes on to evaluate community concerns up to the present time. This problem begins in the middle of the "Addressing Concerns Pertaining to Plutonium in Big Trees Park", and continues through all of the section "Addressing Concerns Related to Tritium Monitoring and Potential Exposure".

For example, page 14, first paragraph, under the section "Addressing Concerns Pertaining to Plutonium in Big Trees Park", CDHS states: "ATSDR reviewed the additional data and completed a health consultation that was released on January 10, 2001. ATSDR stated that the most likely pathway by which plutonium reached the park was through the application of plutonium contaminated sludge as a soil amendment [and] that although there are elevated concentrations of plutonium in the park, those levels are below levels of health concern set by USEPA". We documented many concerns with ATSDR's 2000 report in our written comments, including our disagreement with ATSDR's narrow, regulatory-based interpretation of the public health significance of elevated levels of plutonium in three public parks. However, because community concerns during this time period are not covered in this health consultation, the findings of the health consultation could be misconstrued as ATSDR addressed this community health concern.

Similarly, page 14, second paragraph, under "Addressing Concerns Related to Tritium Monitoring and Potential Exposure", CDHS states: "Members of the LLNL site team were asked to review and comment on the areas of expertise and tasks of the proposed panel and a representative of the site team attended the panel meeting. The consultation further concludes that tritium exposures to the LLNL community are not at levels of public health concern. ATSDR completed another health consultation specifically addressing two known accidental tritium releases the estimated doses were below levels of health concern. The [ATSDR's] analysis was corroborated by human urine analyses which were collected and analyzed immediately after one of the releases." Because the activities described in this section occurred during the time period that CDHS was not responsible for collating community members concerns, such concerns are absent or inaccurately reflected in this section too. The fact is, we strongly urged ATSDR not to convene the "expert panel", but suggested that instead of an expert panel, ATSDR should conduct environmental sampling for organically bound tritium. At the November 8, 2001 Site Team meeting, we expressed great concern over the methodology and findings of the tritium health consultation, presented an independent assessment by the renowned health physicist John Goffman that these releases may have caused 60 or more fatalities, and questioned the validity of the results of the human urine analyses. We note that ATSDR subsequently withdrew the draft health consultation on the health effects of those two accidents.

In summary, we believe that CDHS's evaluation of activities undertaken in response to community concerns must evaluate the degree to which these activities actually addressed community concerns. If this is not possible (because CDHS responsibilities in this regard were ended several years ago by ATSDR), we suggest that the Evaluation of Community Concerns section of the Health Consultation be limited to the period of time that CDHS was in a position to conduct such an evaluation. This would constrain the findings of this Health Consultation to the top of page 14, first paragraph up to "learn more about how plutonium could have reached the park". The section beginning with the next sentence "ATSDR reviewed" up to (but not inclusive of) the "Conclusions" section should be deleted, unless community concerns for this more recent time period are also included in your evaluation.

CDHS Response. The text has been changed to reflect the comments.

Page 1. CDHS states "Since 1951, LLNL has been an active multi-program research facility operated by the University of California for the Department of Energy". It is imprecise and potentially misleading to describe LLNL's mission in this way because: (1) the primary mission of LLNL is to conduct nuclear weapons research, development and testing. According to LLNL, [it was] "Established in 1952 to help ensure national security through the design, development, and stewardship of nuclear weapons." Today, our primary mission is to ensure that the nation's nuclear weapons remain safe, secure, and reliable..." (See http://www.llnl.gov/director/profile.html Accessed May 25, 2002; (2) all of the community health concerns in your report are related to environmental contamination resulting from LLNL's nuclear weapons activities; and (3) community concerns (or lack of concerns) are influenced by this context. For all of these reasons, we believe it is important to state clearly the true mission of LLNL in this report.

CDHS response. Your comments are noted and changes to the text have been made.

Page 3, second paragraph. Following up on previous findings 1960 to 1991 (6). Should this be reference 7, not 6? In addition, the last sentence of this paragraph reads, "Since that time the number of childhood brain cancers has not been higher than expected." It would be more accurate to state the precise post-1960s time period that the 1995 CDHS study looked (i.e., brain cancer rates in the 1970s and 1980s). Using the phrase "since that time" could lead the reader into thinking it is up to date information. To our knowledge the study cited does not support that interpretation.

CDHS response. The text has been changed to reflect the comments.

Page 4, last paragraph. CDHS states, "In 1996, community concern over melanoma rates and the presence of plutonium in Big Trees Park prompted ATSDR and CDHS to move forward with the PHA process." As written, this sentence implies that the PHA was undertaken by ATSDR (and CDHS as its contractor) in response to community concerns. We strongly disagree with this interpretation. Our recollection of the impetus for the PHA is that ATSDR was [is] required by law to conduct the PHA because LLNL is on the National Priorities List of the most contaminated sites in the US. The reason that ATSDR undertook the PHA was because LLNL was a Superfund site, not because ATSDR was being responsive to community concerns. It is an important distinction, because ATSDR's conduct of the PHA was, and remains, a major community health concern.

CDHS response. The text has been changed to reflect the fact that CDHS decided to move forward with ATSDR on the PHA process because of earlier health studies had shown increased levels of melanoma and cancer in the community.

Pages 8-9. Under "Site Team Community Members Comments": we recall that in addition, a major concern of the community members on the Site Team was the reliance on LLNL data in the PHA process. This may be succinctly expressed as the concern about "garbage in, garbage out" of a PHA.

CDHS response. The text has been changed to reflect the comment.

Page 11. Last paragraph under "General Concerns". Our understanding of the concern expressed about how little is known about health effects from low dose, long-term exposures to radioactive materials is that it was coupled with the concern that current levels of exposure considered "safe" by regulatory agencies are not sufficiently health protective.

CDHS response. The text has been changed to reflect the comment.

Page 12. Under "Evaluation of Community Concerns", CDHS states: CDHS and ATSDR have undertaken a number of activities to address community concerns. These actions are listed in Appendix B". However, Appendix B lists "Site Team Priority Concerns". It does not list the activities described. The activities described seem to be listed under "Public Health Action Plan" (pages 15-16). It would be useful to specify on the list on page 16 the title and status of all completed and planned health consultations, including the date completed, estimated date of completion, whether a draft exists, etc.

CDHS response. The text has been changed to reflect the comments.

Page 12. The methodology should also include summarizing the concerns made in writing to ATSDR and CDHS. Due to time constraints at meetings, and a host of other barriers, written comments are a key mechanism by which community concerns are expressed.

CDHS response. As described, we did include written information and comments.

Page 15, under "Childhood Health Initiative". It is unclear what CDHS is trying to express in this section, for example by the statement, "It is important to search for additional information that will increase our understanding and ensure that children's health is protected."

CDHS response. Additions to the text have been made for clarification.

Page 14. We believe reference 18 is really 17.

CDHS response. This error has been corrected.

II. Comments

Comment 1. I cannot tell from reading the first sentence of the first paragraph in this section whether the ATSDR's two health consultations related only to routine tritium monitoring or to two accidental tritium releases or to both.

CDHS response. The health consultations referred to the accidental releases. We made no further changes to the text.

Comment 2. The last sentence of the second paragraph of this sections I do not understand the meaning of "such results" versus chronic tritium releases. Does "such results" mean the results of accidental releases, or does it refer to organically bound tritium levels? Does chronic tritium releases refer to ongoing tritium releases to the air from stacks at LLNL?

CDHS response. CDHS has added language to better clarify the text. "Such results" refer to accidental releases. Chronic tritium releases refers to ongoing releases from the stacks at LLNL.

Comment 3. I am also confused by the first sentence of paragraph 3, section 3 on page 14. I am not sure which panel conclusions about short-term accidental exposures ATSDR was responding to when it completed another health consultation specifically addressing two known accidental tritium releases.

CDHS response. CDHS agrees that there has been confusion relating to ATSDR's evaluation of tritium exposure. The ATSDR authors are best able to clarify these concerns.

III. Comments

Comment 1. The document does not specify its methodology, statistically represent results, nor use specificity and other techniques of science. Additionally, it provides little or no context for those few concerns that were cited. We strongly suggest that there be descriptions as to how individuals were chosen for interviews, as there appears to be subjectivity in the study.

Also, it should prove helpful to provide representative tables of the actual incidence of the diseases and cancers in the Bay Area and in the nation.

This draft document does little to discuss or include the wealth of information that has been publicly available for years. We believe the draft document brings up issues that have been already addressed by these earlier studies, some conducted by CDHS, and the recent work completed by the Agency for Toxic Substances and Disease Registry (ATSDR), U.S. Environmental Protection Agency (EPA), and Lawrence Livermore National Laboratory (LLNL).

CDHS Response. CDHS has changed the text to reflect that the collection of community concerns was never intended to be a study or to contribute to a study in any way.

Comment 2. Page 1. CDHS-EHIB comments that in 1989 ATSDR completed a Preliminary PHA. We suggest citation of the other ATSDR and EHIB documents regarding LLNL that were produced in the intervening 13 years so the readers will understand that other work has been performed.

CDHS response. Your comment has been noted. No changes were made to the text because the purpose of this document is primarily to summarize community concerns collected between 1996-1998, not to summarize "other work" conducted over a 13 year period. It would be most appropriate for ATSDR to evaluate whether community concerns have been addressed once they have completed a thorough evaluation (public health assessment process) of the potential health implications posed by all site related contaminants (chemicals and radionuclides). At this time it is unclear if such an evaluation will occur.

Comment 3. Site Description: Insert "U.S. Department of Energy" before "LLNL." After the third sentence, please insert the following two sentences, "The property was developed and used as a Naval air training and airplane engine maintenance facility during World War II. Navy handling and disposal activities resulted in VOC (i.e., solvent) contamination of ground water and soil."

CDHS response. The text has been changed to reflect the comment.

Comment 4. Please correct the last sentence. The EPA placed the site on the NPL in 1987 for VOCs in groundwater (not for heavy metals, tritium or any other materials) that could impact drinking water wells. More specifically, EPA's score for LLNL on EPA's hazard ranking system met the NPL threshold because of the VOCs above drinking water standards in ground water within three miles of municipal drinking water wells.

CDHS response. The text has been changed to reflect the comment.

Comment 5. Also, you ought to mention that upon LLNL's discovery of offsite contamination, LLNL provided owners of potentially impacted wells with bottled water, initiated the groundwater investigation, and took other actions to ensure that people were not exposed to VOCs in ground water from LLNL.

CDHS response. The text has been changed to reflect the comment.

Comment 6. Treatment of contaminated ground water began in 1989 and is ongoing. These cleanup activities are performed under the regulatory oversight of the EPA, California Department of Toxic Substances Control (DTSC), and the California Regional Water Quality Control Board (RWQCB) in addition to the DOE. This too should be stated.

CDHS response. The text has been changed to reflect the comment.

Comment 7. Page 2. Please note that Vasco Road is on the west side of LLNL, not the east; Greenville Road is to the east, not the west. The main site is "bordered by homes to the west of Vasco Road", not "surrounded by large homes, each sitting on roughly one to two acres of land."

CDHS response. The text has been changed to reflect the comment.

Comment 8. We suggest that you add "Road" to "Patterson Pass" to clarify that you meant the road which runs roughly west to east along the buffer property north of LLNL and not the pass located in the hills east of LLNL.

CDHS response. The text has been changed to reflect the comment.

Also, please add the actual distance from the California Aqueduct to the LLNL Main Site, as the aqueduct passes northeast, east, and south of LLNL (not just east) and is not on the border of the Lab. Also specify the direction and distance from LLNL to those "several wineries and small ranches with farm animals".

CDHS response. These descriptors have been removed from the text.

Comment 9. We suggest you also describe what is south and east of the LNLL Main Site as well as north and west.

CDHS response. The text has been changed and provides the location and a general description of the LLNL Main site.

Comment 10. Early Community Concerns: Please note that LLNL publications and public outreach addressed community concerns prior to the formation of the cited watchdog group and have continued to do so.

CDHS response. Comment noted. No changes were made to the text because we have no way to verify the claim that the community's concerns were addressed by these activities.

Comment 11. The Livermore community was made aware of melanoma via LLNL publications and publicity which predate the 1980 CDHS on melanoma.

CDHS response. Comment noted.

Comment 12. Page 3. The study reviewing the CCR data does not show "higher levels of melanoma than other areas of Livermore": there are no statistical differences.

CDHS response. The text has been changed to reflect the comment.

Comment 13. In the paragraph beginning "Big Trees Park is", Arroyo Seco does not require modification by adding the word Creek. Also, Arroyo Seco Elementary School is on the west side of the park, not to east side.

CDHS response. Comment noted. The text has been changed to reflect the comment.

Comment 14. Community members became aware of plutonium levels in soil in Big Trees Park through LLNL outreach. The EPA report prepared by NAREL was published in August 1994,which is more accurately described as the mid 1990s rather than the "early 1990s."

CDHS response. The text has been changed to reflect "mid" 1990s, rather than "early" 1990s.

Comment 15. Of the almost 200 samples collected by LLNL in 1991 in an onsite area known and documented in the public record to have plutonium in soil from past waste management activities, only a handful of samples approached the residential PRG. The soil from the one location that slightly exceeded the reduced industrial PRG was exhumed by LLNL for disposal.

CDHS response. Comment noted. The text is correct as stated; no changes have been made.

Comment 16. Page 4. The paragraph that begins "These findings prompted..." and ends "needed at Big Trees Park." is written in a way that may mislead the reader into believing the EPA found plutonium levels above background at all three parks. Nowhere does the 1994 EPA sampling report state that the other two parks had plutonium levels above background, nor do they. This is an unfounded claim that appears to be based on (1) a selected subset of the data, and (2) lack of awareness of the data quality objectives by which the EPA values (from 1993) were obtained and those by which the reference "background" values were obtained.

Comment 17. Of the eight measurements at the other two parks (four at each park) only three are above any reference values for fallout background that EHIB has cited. The other five were non-detections. Thus, the unqualified description of these two parks as being above background deprives the reader of the opportunity to assess all of the information available, and overstates the strength of the evidence. In particular, the relationships between the values are not consistent with above-background levels.

Comment 18. The reference "background" samples were collected and analyzed with data quality objectives designed to give accurate and representative results at low (background) levels. The EPA 1993 samples were not. Instead, the EPA samples were collected and then analyzed with data quality objectives designed for comparison with the higher values found in LLNL's 1991 onsite study. The 1993 EPA data quality objectives are known to give unreliable results at fallout background levels. Thus, these data sets cannot be compared.

CDHS response to comments 16-18. This Health Consultation summarizes information present in a final ATSDR Health Consultation, which was reviewed by DOE and USEPA. No changes have been made.

Comment 19. The four highest values in 1995 in Big Trees Park ranged roughly from 0.2 to 1 pCi/g. Referring to these collectively as "about half of the EPA's proposed PRG of 2.5 picocuries per gram" is inaccurate because 0.2 is less than 1/10 of 2.5. Even the highest value from the 1995 sampling is 40%, not 50%, of the PRG.

CDHS response The text has been changed to reflect the comment.

Comment 20. Also please note that on the previous page you call the PRG a "health protective screening level that is used to decide whether or not a site should receive further investigation" and here it is described as the level at which EPA "would consider removing the contaminant from residential areas." We suggest using language approved by the EPA. Please also note that we cannot find where EPA has ever undertaken a removal on an EPA-performed Superfund cleanup upon receiving an analytical result at the PRG level.

CDHS response. The text has been changed to reflect the comment.

Comment 21. The topic sentence of the last paragraph under this section is not accurate as the PHA process was mandated by Congressional funding language.

CDHS response. The Congressional mandate had already been met by the 1989 Preliminary Public Health Assessment. The information is correct as stated.

Comment 22. Page 5. Methodology and Listing of Community Concerns:
It would be helpful to present a table listing activities and the results. Also helpful would be attachments indicating how interview respondents were selected, the questions used and the forms shown that enabled data collection.

CDHS response. The collection of concerns for a public health assessment is not intended to be a study. Concerns are collected informally to get a general over view of community issues

Comment 23. There seemed to be no differentiation of the immediate LLNL area from that of some general and more distant area.

Comment 24. Without information on how the interviewees were selected and approximately where they live, and how many were from each of the described categories (residents, local businesses, local organizations) it is impossible to evaluate the significance, if any, of their anecdotal comments. We also suggest adding a table listing the incidence of the diseases found in some geopolitical area, e.g. the Bay Area and, for comparison, those found in the U.S.

CDHS response to comments 23 and 24. As described earlier, the collection of concerns for a public health assessment is not intended to be a study. Concerns are collected informally to get a general over view of community issues.

Comment 25. Page 6. It is fairly common knowledge that goldfish seldom live in tap water due to its chlorine content and, more recently, the addition of chloramines. Chlorine is used as the primary disinfectant, and chloramines are added to maintain disinfection after the treated water enters the drinking water distribution system.

CDHS response. Comment noted.

Comment 26. Page 7. General Concerns: EHIB may wish to refer the interviewees concerned with the tritium methodology to the recent ATSDR study and the DOE specifications ("Environmental Regulatory Guide for Radiological Effluent Monitoring and Environmental Surveillance," January 1971, DOE/EH-0173T) for how tritium monitoring and analyses are performed by LLNL.

CDHS response. Comment noted

Comment 27. Preliminary Stakeholder Meetings: you neglected to mention the following concern that was expressed at early stakeholder meetings. Several attendees expressed concern that EHIB misunderstood the plutonium results from the 1995 soil sampling in Big Trees Park.

CDHS response. CDHS does not recall concerns raised by stakeholders relating to a misunderstanding by EHIB of the 1995 soil sampling results.

Comment 28. Page 8. Door to Door Discussions and Outreach: the 1996 CDHS study cited does not find melanoma in census tract 4515 "excessive"; indeed, they find it falls within statistical parameters. We do not find a report calling melanoma in census tract 4515 "excessive", so please cite any such source; this would be appropriate in all cases where judgments are made on the basis of existing reports.

CDHS response. This tract was chosen because a cancer review by CDHS in 1996 found melanoma there to be elevated, although the increase was not statistically significant. We have changed the wording from excessive to elevated.

Comment 29. Other than the EHIB selection of the census tract for an invalid reason, we cannot find any methodology for selection of the homes approached nor the forms for collecting data nor the "fact sheet" described as being presented. Including the methodology, copies of the data collection forms and the "fact sheet" as attachments or in appendices would be helpful. Again, a tabular presentation of resultant data may be more helpful to public understanding.

CDHS response. Comment noted. Please refer to CDHS response to comment 1.

Comment 30. Page 9. Site Team Community Representatives' Comments: Please clarify whether the Alameda County comments were related to LLNL or not. It is common for people to ask a County Health Department about drinking water quality since that is often the responsible health agency. If the comments were in fact related to LLNL, it seems only prudent that you also state that summaries of LLNL impacts on ground water and ground water samples are public record and that summarized drinking water data is published at least annually by the drinking water suppliers.

CDHS response Changes were made in the text related to this comment.

Comment 31. Also, raising of the airborne plutonium issue after ATSDR has evaluated it and found it neither credible nor possible is worth the ATSDR reference and closure rather than raising it and leaving it appearing to be unresolved.

CDHS response. Your comment will be addressed in the larger public health assessment document that will be written by ATSDR, which should include an evaluation of potential air releases.

Comment 32. The subject of analyzing actinide levels in urine was discussed at some length in one of the site team meetings and we believe closure was reached. The testing shows at the very most very, very minute levels in workers known to have been exposed to plutonium via accidental cuts or inhalation. Routine testing of the urine of other plutonium workers shows no biological uptake or detectable levels of plutonium in their bodies, so monitoring of members of the offsite public would show nothing.

CDHS response. Your comment has been noted.

Comment 33. Page 10. The results of EPA's 1993 (reference 2) soil samples from Sunflower Park and Sycamore Grove Park were discussed earlier in these comments. The EPA did not find the parks to have above-background levels of plutonium; EHIB improperly makes that claim as explained earlier in these comments. ATSDR's final report also deals with this (reference 16).

CDHS response. Please refer to CDHS response to comments 16-18.

Comment 34. Community Comments at Site Team Meetings:
Again, we suggest that the use of a table to present the concerns might be helpful for reducing the repetition in the text and could serve to clarify the numbers of particular comments. For example: did one person say the same thing(s) repeatedly in different settings and get the comment(s) counted as independent comments each time; did someone or several people continue to make the same comments after the question or issue raised was already, in fact, fully addressed?

CDHS response. Your comments have been noted and additional information has been added to the text for clarification. A table is presented in the appendix.

Comment 35. Sewage Sludge Concerns: we strongly disagree with the use of the adjective "possible" relative to "distribution of contaminated sewage sludge" in Livermore. It has been public knowledge for the past 35 years, especially to CDHS and the City, as well to the general public, that "contaminated sewage sludge" was available at the City's sewage treatment facility and taken by the public and the City for use as a soil amendment. The contamination included biological and inorganic (such as, heavy metals) as well as radiological components. It was, after all, sludge from sewage. Nonetheless, it was deemed appropriate for distribution by the City and the California Department of Public Health (later renamed the California Department of Health Services). In the more recent evaluation of pathways for plutonium above fallout background to get to Big Trees Park, ATSDR found use of sewage sludge as a soil amendment to be the most credible and only viable pathway of the above fallout background levels of plutonium being found in some soil samples from Big Trees Park. ATSDR also found that these values were representative of that to be found in Livermore Water Reclamation Plant (LWRP) sludge used elsewhere and that no health threat was presented by these values.

CDHS response. The word possibly has been removed from the text. It is not scientifically defensible to conclude that the plutonium levels found in Big Trees Park in 1995 and in 1998 are representative of sludge that was distributed to the public and/or municipal agencies for eighteen years (1958-1976).

Comment 36. It may be helpful to include by reference and as an attachment, the U.S. EPA Fact Sheet on The 1995 sampling. This draft EHIB consultation would also be helped and made more complete by listing and briefly discussing the other LLNL, ATSDR and/or EPA studies which were produced in the 1994 to 2002 time frame.

CDHS response. Your comments have been noted. This health consultation is a summary of community concerns. It is not intended to provide a summary of LLNL, ATSDR and/or EPA studies.

Comment 37. General Concerns: actually, there is a lot known about "low dose, long term exposures to radioactive materials." In general, there is broad consensus in the scientific community that if the dose is low, the risk is also low.

CDHS response. CDHS acknowledges that the risk to low dose long-term exposures to radiation may be low, but that the risks are still present. Much community concern pertained having to accept any additional risk to radiation as a result of LLNL activities.

Comment 38. Page 12. Evaluation of community concerns: the first sentence in this section that "many community concerns have yet to be evaluated" seems odd as many concerns repeated in the body of this draft consultation have already been addressed and documented in public reports by the EPA, ATSDR, and LLNL. Furthermore, the actual sampling of the public is so small as to render the word "many" inaccurate. Finally, some of the "health concerns" are such that it would be difficult to seriously consider them related to LLNL (e.g., headaches are very common worldwide; irritable bowel syndrome is widespread enough for radio ads; chronic diarrhea thought to be related to "medication she takes").

CDHS response. Comment noted.

Comment 39. Page 13. Addressing Water Concerns: we suggest you recount the number of domestic wells and their condition as the numbers in this draft consultation do not correlate with information available elsewhere. You may want to reference and include the ATSDR document showing no exposures to LLNL related contaminants and that exposures to non-LLNL related contaminants were below levels of health concern. Again, you ought to mention that LLNL has a mature groundwater and soil cleanup and monitoring program that is performed under the regulatory oversight of the EPA, DTSC, and the RWQCB in addition to the DOE.

CDHS response. The purpose of this health consultation is to summarize community concerns, not to summarize environmental assessments or LLNL monitoring programs.

Comment 40. Addressing Concerns Pertaining to Plutonium in Big Trees Park: we suggest you add the words "even for a pica child" to the last sentence in the first paragraph of this section to emphasize that ATSDR and CDHS did carefully consider the sensitivity of children and the protection of their health when ATSDR did its worst-case exposure assessment.

CDHS response. Your comments are reflected in changes to the text.

Comment 41. In the paragraph which begins, "In the health consultation, CDHS staff...", we suggest that you close the paragraph with a sentence stating that the ATSDR found that the CDHS health consultation conclusions about air and arroyo sediment/water pathways were incorrect, and that the use of sewage sludge as a soil amendment was the only credible pathway to put the detected levels of plutonium in the park.

CDHS response. ATSDR concluded that the "most" credible pathway for the plutonium detected in the park was from the use of sewage sludge as a soil amendment. However, this does not address why the highest level of plutonium measured is in an area where there are no trees. The negative results from the limited number of samples (two) collected downstream in the Arroyo Seco do not provide evidence to discount the sediment pathway given the amount of erosion and scouring that has occurred over the years. The text has not been changed.

Comment 42. Page 14. Addressing Concerns Related to Tritium Monitoring and Potential Exposure: The second paragraph in this section ends with the phrase, "but that such results do not include the contribution from chronic tritium releases." That statement is incorrect. The tritium panel evaluation did include the contribution from chronic releases.

CDHS response. CDHS expects this to be addressed in the larger public health assessment document that will be completed by ATSDR.

Comment 43. Page 15. Childhood health initiative: we suggest that you document that ATSDR/CDHS assiduously worked the "pica child" issue in early analysis of Big Trees Park but did not find anything. The way this section is written, it gives the impression that concerns were found but no actions were taken over these past six years of health consultations to evaluate any impacts on children.

CDHS response. Your comment has been noted.

Comment 44. Conclusions: we suggest that you clearly state the non-scientific nature of the EHIB sampling, polling and opinion-collecting done in this health consultation.

CDHS response. The text clearly states the methods used to gather community concerns.

Comment 45. It seems inaccurate to refer to any of these various cancers (melanoma, brain cancer, etc.) as prevalent due to prior CDHS studies finding otherwise.

CDHS response. Your comment has been noted.

Comment 46. Page 16. Public heath action plan: we suggest that your "Ongoing Action A" be omitted since it has already been determined by the ATSDR that there are no health consequences.

CDHS response. The text has not been changed. The CDHS report referred to in Ongoing Action A, proposes a community based process to address uncertainties in the available information and community concerns related to the 18 year distribution of plutonium-contaminated sewage sludge, which remains appropriate.

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Public Health Assessments & Health Consultations