Community Concerns and Communications Work Group

Community Concerns and Communications Work Group

March 1, 2005 - Meeting Minutes

Attendance

ORRHES Members attending: George Gartseff (Chair), Jeff Hill, Karen Galloway (phone), David Johnson, and James Lewis

ATSDR Staff attending: Jack Hanley (phone), Marilyn (Palmer) Horton (phone), and Bill Taylor

DOE Staff attending: Tim Joseph

Public Members attending: Dick Gammage

TA Consulting, Inc. (contractor): Amy Adkins

ERG Contractor: Liz Bertelsen (phone)

Purpose

George Gartseff called the meeting to order at 5:35 p.m. He said that the purpose of the meeting was to review the executive summary of the Toxic Substances and Control Act (TSCA) Incinerator Public Health Assessment (PHA) so that the work group could provide the Agency for Toxic Substances and Disease Registry (ATSDR) with suggested revisions for the four-page summary document presented during the February 22, 2005, CCCWG meeting.

Discussion: TSCA PHA Executive Summary and Four-Page Summary Document

George Gartseff asked Jack Hanley to provide background information on the summary document. Mr. Hanley explained that he had presented a four-page summary document at the last CCCWG meeting and the work group had found it "ineffective" in its wording and "not effective in communicating." Jeff Hill had contacted Mr. Hanley to suggest that the CCCWG review the executive summary from the PHA, and that the group could possibly make suggestions based on seeing that information. Tonight, Mr. Hanley planned for the CCCWG to review the PHA summary and identify language that could be used in the four-page summary. If possible, Mr. Hanley hoped that they could have a draft four-page summary to present at the March 22, 2005, ORRHES meeting when the document is released for public comment.

James Lewis was unsure if Jack Hanley provided an "adequate summary" of the last meeting. He said that they were not given a product with enough time to review the information. He stated that the summary was "inadequate to convey even what little I know about the TSCA Incinerator." He had "assumed" that the product had already been "reviewed by ATSDR for accuracy, completeness, thoroughness, and usability with the public." He believed, however, that the document needed more specific details and that it was "weak." Mr. Lewis added that they needed items in advance so that they could be prepared to discuss the information and provide appropriate feedback at the meetings.

Jack Hanley explained that the summary had been modeled after the Y-12 four-page summary document. He agreed that the document needed more information and modifications. He noted that the process had changed since the Y-12 document when people had the PHA while they prepared the summary. Mr. Hanley stated that Jeff Hill had suggested beginning the process before the public comment period, but Mr. Hanley said that that it was unlikely that the summary would be printed before the document was final. Between the public comment and final release, however, Mr. Hanley said that they could start the process to prepare the summary.

Jeff Hill wanted to meet tonight and hopefully provide enough details for ATSDR to produce a draft summary document for the March 22 meeting. James Lewis appreciated Mr. Hill's efforts. He noted that he had seen a similar scenario with the Y-12 PHA. Mr. Lewis stated that they did not want "boiler-plate" information, and noted that this was a "non-issue." He added, "Lessons learned is supposed to kick in some place." Mr. Lewis would support their efforts, but he was "surprised" that "key comments about some weaknesses" in the past were not considered.

James Lewis believed that a copy of the PHA should be available in the ATSDR Oak Ridge Field Office and that the Tennessee Department of Environment and Conservation (TDEC) should have been provided a copy. He did not want these types of things "dumped on them at the last moment." George Gartseff agreed that they had not previously seen the executive summary from the PHA, but that it was not too long and could be read during the meeting.

George Gartseff asked Jack Hanley about the possible turn around time for the next ORRHES meeting. Mr. Hanley had initially anticipated only receiving minor suggestions since he was using the past process, however, the CCCWG thought that a lot of work was needed. He would try to have a draft by this date, but could promise that this would occur.

James Lewis said that Dick Gammage had made "excellent points" at the last meeting, which Mr. Lewis believed were "focused" and "on target" especially with regards to technical issues. Mr. Gammage explained that he was reading the four-page summary document as a "long-time Oak Ridge resident." He believed the "main problem was with the impressions given" when he looked carefully at what was said. He thought that a "suspicious reader" might believe that things were being hidden and noted, "Many sentences contradicted each other."

Dick Gammage believed that the first sentence on the last page of the four-page summary implied "that pollutant controls were not adequate." He said that this was not the impression that they wanted to give the public. He indicated that the "main problem" was that the document was "not logical in sequence," and as a result, the reader would not be given the impression that the incinerator was "perfectly safe." He was unsure if it would be appropriate, but he suggested something similar to the following statement regarding EPA limits with respect to automobiles and power plants: "If those power plants and automobiles were operated with the same rigor of pollution controls that exist at the incinerator, we wouldn't be out of compliance or at least it would be much reduced." He said that the document asks if there is a problem, and that the first sentence on the last page suggested that, "Yes, there is a problem." In his opinion, this "would cause more problems than do good."

George Gartseff was not necessarily in agreement that the summary led the reader to a particular conclusion. However, he agreed that they needed to provide the facts and explain the "critical analysis" that led to ATSDR's conclusions. Mr. Gartseff questioned what audience they were trying to reach and asked if they knew the audience's expectations. He did not want ATSDR to be "afraid" to provide details as necessary as he believed the summary "needed more substance."

The information contained in the executive summary was the type of information Jeff Hill had envisioned being presented in the four-page summary. He believed that it provided details in layman language, though he had problems with saying "all in limits." He stated that "line 20 down defined the who," which provided "credibility" because you could see the various agencies that have evaluated the incinerator. He suggested keeping the front cover of the four-page summary and using statements from the executive summary in the middle of the four-page summary. Mr. Hill believed that the main conclusions presented on page 2 were "excellent."

George Gartseff wanted the summary to detail "what came in and out of the incinerator." Dick Gammage added that the only figure provided was "16,000 tons." James Lewis believed that they needed to show the efficiency of the incinerator. Mr. Gammage asked if it was possible to provide a comparison, such as stack emissions to auto exhausts. He believed that the public would be able to relate to these types of facts. He said that the "16,000 tons" provides "nothing for the community to grasp." He knew that they might not be able to provide comparisons such as auto exhaust since metals, radionuclides, and other products were related to incinerators and not auto exhausts. However, he believed that putting information in this context would be helpful for the public. Jack Hanley said that the PHA makes comparisons to other area incinerators. Mr. Lewis said that they had recommended using similar types of comparisons in the Y-12 PHA. He recalled that John Wilhelmi had made comparisons in a presentation to the CCCWG.

James Lewis asked if the facility operated at only 10% of its capacity; Jeff Hill replied that line 31 in the executive summary said that it only operated at 5%. Mr. Lewis believed that this "linked" to the "efficiency and effectiveness" of the incinerator. He wanted this type of information in the summary because there are no "significant problems" with the incinerator.

James Lewis had read some of the questions in TDEC's list of 101 questions. Mr. Lewis believed that this list contained some "key concerns," some of which he believed were "outstanding." He suggested that ATSDR capture some of these concerns in this document to show that the agency has responded to the public. Mr. Lewis explained that they needed to "produce a product that allows people to draw a conclusion rather than lead them to a conclusion."

George Gartseff asked which questions James Lewis was referencing. Mr. Lewis explained that TDEC had produced a document that listed questions asked about the incinerator and TDEC's responses. Mr. Lewis thought that discussing these questions would give them a "general idea of what's been raised, answered, and the outstanding issues." Because the public had already seen this document, Mr. Lewis thought that their actions could build upon these efforts.

Jeff Hill suggested that they change the picture on the front cover of the four-page summary. The content on the cover, however, was fine with him. He recommended using a picture of the entire East Tennessee Technology Park (ETTP, formerly known as K-25) site; he did not think that they should show only a smoke stack. He wanted lines 20 to 28 of the executive summary included, which detailed the agencies that have been involved with evaluating the incinerator, presented on the front cover. Mr. Hill added that the statement under the main conclusions on the second page of the executive summary was a "good statement."

James Lewis said that a statement such as the "TSCA Incinerator released trace levels of contaminants into the environment" needed supportive information when used in the summary.

Jeff Hill suggested putting the main conclusion on page 4 of the four-page summary, but included text, such as from line 20 on pages 2 and 3. He read the following: "sophisticated controls automatically shut down the entire incineration process if operating conditions are not maintained within limits specified in health-protective environmental permits."

Jack Hanley asked if they should include lines such as "All wastes must be thoroughly characterized before they arrive at the TSCA Incinerator, and their contamination levels must meet strict criteria before they can be treated."

Jeff Hill referred to line 30, which stated that, "In recent years, the amount of waste treated at the TSCA Incinerator has been only 5% of the permitted limits." Dick Gammage questioned if the remaining 95% was too hazardous. Bill Taylor replied that the incinerator did not use its full capacity. Mr. Hill thought the statement meant that only 5% of its capacity was used. Karen Galloway referred to the following sentence: "In the isolated instances where higher emission rates were observed, ambient air monitoring data collected at the time show that air contamination at off-site locations was not affected." Ms. Galloway said that this leads her to think that if this could happen when the incinerator operates within only 5% of the permits, then what could happen if the incinerator increased its operations. Dr. Taylor said that this is the "reality"—releases have occurred. Jack Hanley added that they were trying to acknowledge that releases did occur, but that they were not at levels of health concern.

James Lewis thought that these issues had already been covered by other agencies, such as the U.S. Environmental Protection Agency (EPA) and TDEC. He stated that the summary should reflect that the equipment works because it is set up to shut down as the need arises. He wanted "kudos" to be given to EPA and TDEC since they had been monitoring the incinerator and had "not seen anything." Bill Taylor clarified that there were releases, but nothing was measured at monitoring stations. However, the equipment worked because the incinerator was shut down. Karen Galloway stated that the summary needed to mention that there were releases.

George Gartseff believed it was a "leap" to have "few isolated instances of excursions." He also noted that waste was mentioned first and design was mentioned second in the four-page summary, but that the design was mentioned first and waste was discussed second in the executive summary. He wondered if there had been "intent" with changing this sequence on the four-page summary. Jack Hanley said that the four-page summary was put into order and the executive summary detailed what the conclusions were based on. Mr. Gartseff believed that a sequence was implied because figure 1 in the executive summary followed the same order as the bulleted text. If it was important, Mr. Gartseff wanted the four-page summary to match the executive summary.

George Gartseff suggested that information in the executive summary figure be paraphrased and placed into the text boxes on the foldout graphic. He also thought that the four-page summary should include a write-up of the different elements of the design, lists of contaminants that went through the incinerator, modeling results, and other items. He thought that they could incorporate fewer words into the graphic, which would also alleviate repetition. He continued that they could open to the middle of the four-page summary and have the five text boxes, but these could include paraphrased wording from the content of the five pillars in figure 1 in the executive summary. Mr. Gartseff believed that consistency was needed between the summaries.

George Gartseff asked if the graphic was needed. Jack Hanley said that people suggested they use pictures with some text to communicate to the general reader. He said that this four-page summary was prepared for the "general audience," which includes people who would read the summary document, but not necessarily read the PHA. Jeff Hill asked about making the pictures smaller with text and adding arrows. He thought that they could use the artist's rendition of the facility instead of the mock-up, and use arrows and text to show the different stages of the incineration process.

James Lewis did not want to give the wrong impression by using this picture. George Gartseff said that they could use an aerial photograph on the inside graphic and the other photograph on page 1 as a replacement for the current picture.

Jack Hanley said that they could add another page and have more narrative in the summary document. George Gartseff replied that the "problem" with the summary was not related to the length. He explained that the "problem is that the short material provided needs to be meaningful."

Dick Gammage questioned mentioning "16,000 tons." He also referred the group to lines 25 to 31. He wondered if this meant that the design of the incinerator was such that they could have put over 300 tons of material into it. George Gartseff said that there might be some engineering factors that were not picked up in the facts and figures related to the incinerator. He thought it was important to note that they were talking about "5% of permitting limits," which was "not necessarily the same as operating limits." Mr. Gartseff thought that they needed to use caution when dealing with "permit limits versus design limits."

James Lewis believed that they had a "bigger issue," which was that the public assumed the facility was destroying wastes because it was burning them. He asked what the incinerator actually destroyed, and said that he wanted this conveyed in the summary. Jeff Hill replied that this was included. Jack Hanley read from the first paragraph of the executive summary, which states, "The TSCA Incinerator destroys organic chemicals in waste material and reduces the volume of waste materials that contain low-level radioactive contamination." Mr. Lewis said that this was an "important point" that the incinerator reduced the volume of materials and they were not necessarily being released up the stack. Mr. Hanley added that the summary should mention the following: "organics are destroyed," "volume is reduced," and "metals are captured."

Dick Gammage asked if the stack emissions contained essentially no radioactive materials. Bill Taylor "would not say none." Mr. Gammage knew that strontium was in such things as the slag and the refined particular matter. As a resident, he would like a description of materials that were not captured and go into the stack. George Gartseff suggested that this could be an opportunity to discuss recapturing and treatment of emissions on an inset graphic within the four-page summary. In addition, "he had trouble" using the word "smoke stack." He noted that this could "conjure up the image that James [Lewis] is worried about." Mr. Gartseff believed that the releases from the smoke stack were "more than minimal."

Jeff Hill suggested using a picture with arrows to show where solid waste was captured and removed. He added that as Dick Gammage said, "What happens to the residual material?" Mr. Gammage said that he would be "happier to know that" because the four-page summary only provided the "meaningless 16,000 tons" number. He preferred to know the particulate and metals that went out of the incinerator. He said that, "What exists in the stack is basically harmless water and carbon dioxide."

James Lewis thought that John Wilhelmi had presented a thematic diagram that simplified the process and reflected what came out of the stack. He added that it was "important to know what EPA and TDEC have done" because he heard "they have done an excellent job in overseeing" the incinerator.

George Gartseff referred to the statement in the four-page summary "ATSDR has recommended that DOE, EPA, and TDEC continue their air sampling." Mr. Gartseff said that this statement "struck him as backwards" because it implied that it had been ATSDR's idea for these agencies to conduct monitoring at the facility. He thought it should be re-worded or removed altogether.

Jack Hanley said that they could use a schematic of an actual incinerator to show what goes into and out of the incinerator, including identifying the rotary kiln, the type of material going into the incinerator, the scrubbers, and other aspects. He asked the CCCWG if this type of figure would be helpful because it was a picture, but also included wording.

George Gartseff explained that Jeff Hill suggested looking at an aerial view of the incinerator complex facility and using arrows to point out the different steps of the process. Mr. Gartseff said that they were looking at the schematic from the TSCA Incinerator Web site. He believed the schematic might be "too detailed." Jack Hanley stated that they could make the figure less detailed and remove most of the words. Mr. Gartseff thought that this was "too much for the public." He stated that they needed a figure to show the wastes going in, where they were burned, where the scrubbing occurred, and other main aspects. He suggested having a similar layout with an inset that showed the simplified process, whereas Mr. Hill was suggesting another approach to use relevant portions of the facility from the aerial photographs to show different stages of the process, including where burning, scrubbing, waste collection, and other processes took place. Bill Taylor was unsure that the aerial photograph was taken from the correct angle to be used for this purpose. Mr. Gartseff believed that they could use Mr. Hill's idea, and also show the five main steps assessed.

James Lewis asked about the primary materials put into the incinerator to be burned. Bill Taylor said that these were solid and liquid wastes.

James Lewis had TDEC's list of 101 questions. He read the following question because he had not liked TDEC's response: "In light of the current situation of sick individuals at and around the K-25 site, would the state even consider entertaining any alterations which would reduce the pollution control efficiency of the TSCA Incinerator?" TDEC responded, "The state expects the K-25 site to operate within the law, regulations and permits." Mr. Lewis explained that, "people are concerned that they are already sick" and that they needed to respond to the public, instead of saying that they have "met the permit." David Johnson said that this went back to the issue of "trust."

Jack Hanley asked which question number James Lewis had referenced; he said it was number 62. Bill Taylor thought the state was saying that it would make sure to follow the regulations, but it did not say that it would not reduce the regulations. He believed this was an "evasive answer." Jeff Hill interpreted the response as saying that the state "would allow more pollutants to be released if it increased efficiency, but still met guidelines." George Gartseff thought that this suggested a "design change." Dr. Taylor believed this could be interpreted differently. Mr. Gartseff stated that this response was the "reality" as "regulations won't change overnight and likely don't change to increase efficiency of the incinerator." He said that they should "not forget" that they had just been discussing that the "regulators did a good job." He also explained that this question was asked in 1997 and to remember that the context was probably a public meeting on permit renewal or a meeting of that sort.

Dick Gammage would "feel more comfortable" with using comparisons that the "general public can get their hands around," such as comparing the stack emissions to auto exhaust. Bill Taylor was concerned that this could mislead the public because incinerators and automobiles do not burn the same materials. Mr. Gammage agreed, but thought that they needed to compare the stack releases to something people would understand. George Gartseff did not disagree with this concept, but thought that they needed to use a relative balance because this was not a direct comparison. Mr. Gammage agreed, but thought that they should not use any numbers (e.g., 5%) if people were not comfortable with using these types of comparisons. Jeff Hill, however, wanted to include numbers in the summary. Mr. Gammage said that this would be fine as long as the reason for "only 5%" was explained. Amy Adkins, Mr. Gartseff, and Mr. Gammage all had different interpretations of the meaning behind the 5%.

George Gartseff wanted "to quantify more than not." He believed that the "existing summary was weak" in quantifying information. He noted that if they use "quantitative descriptors," then they needed "to be accurate." For instance, if they refer to "permit limits," then they need to say that instead of "operating capacity."

James Lewis wanted them to decide in ORRHES who the primary audience would be for the summary. Mr. Lewis believed it was "ATSDR's job" to see the efforts that need to be done to ensure that the documents are user-friendly for the target audience.

Jeff Hill provided his thoughts on the material from the executive summary that should be included in the four-page summary. After the first page in the four-page summary, he said that they should use lines 8, 9, and 10 from page 1; lines 20 to 29 from page 1; the first four lines from page 2; lines 20 to 22 that discuss "sophisticated controls;" and line 30 that defines the 5%. He noted that the main conclusion was necessary, but it should not be in the middle. George Gartseff disagreed with Mr. Hill "a little bit." He was "inclined to keep 95% of each of the five bullets as appropriate."

Dick Gammage thought that the sentence beginning with "in short" should follow the sentence ending with "each year" on line 30.

Jack Hanley read the following: "All wastes must be thoroughly characterized before they arrive at the TSCA Incinerator, and their contamination levels must meet strict criteria before they can be treated." Mr. Hanley said that this is an important issue as it has been a concern. He next read, "The TSCA Incinerator is designed to meet the strict requirements of multiple environmental regulations intended to protect human health and the environment." He asked if this language should be included.

James Lewis read the main topics from the current summary. He wanted to make sure that ATSDR focused on the questions presented as headings in the summary and ensure that each response was appropriate for the target audience.

George Gartseff disagreed with using "become involved" because it suggested that ATSDR was "part of the operation." He recommended using terms, such as "assessing" or "evaluating." He wanted the detail from the executive summary incorporated into the four-page summary.

Jeff Hill believed that the format of the first page was fine. He said that it made him "want to read it" and that it contained a "good basic introduction." George Gartseff had "no objection to the lay out."

Jack Hanley asked if the group thought it was appropriate to have the conclusions up front because many members of the public are likely to read the beginning text. George Gartseff had no problems with this, nor did Jeff Hill. Mr. Gartseff added that supportive details and facts must be presented for the conclusions. He recommended using about 90% of the executive summary (modifying language as appropriate) and accurately describing any quantitative details.

James Lewis read the head topic, "Are there any general air quality concerns for the Knoxville metropolitan area?" He then read the second paragraph under this heading in the summary. He believed that this used "boiler plate" language. He questioned the "value added of the paragraph." Bill Taylor asked if Mr. Lewis wanted this paragraph removed. David Johnson agreed with Mr. Lewis. Dick Gammage said that it could also be "put in better context." George Gartseff added that this wording was a "dangerous context by distracting from the particular source." Jeff Hill had "eliminated sub-headings from his mind and used the executive summary."

Dick Gammage explained that people in the valley had concerns about air quality, and that they should know that the incinerator is not a contributing factor. Jeff Hill said that the summary did not say that the incinerator was not contributing. He then read from the executive summary "emissions from the TSCA Incinerator appear to contribute little to these problems." He pointed out "little is still contributing." He believed that this wording was "factual and plain." Although, he said "little doesn't tell me much."

James Lewis explained that John Wilhelmi had compared the emissions from the incinerator to steam plants in the area. He said that this helped answer, "So is this insignificant compared to that?" He thought that this should be incorporated into the summary. George Gartseff replied that they were "not assessing air emissions;" they were "assessing the impact of the TSCA Incinerator." Mr. Lewis thought that this information was "usable" and that ATSDR should consider incorporating the information into the summary. Mr. Gartseff disagreed and said that they were not "assessing the air quality of the Tennessee Valley."

Jeff Hill liked the idea of using an analogy of exhaust in cars to emissions from the incinerator. George Gartseff said that this would have to be "generic" and something that people could understand. He noted that it would also have to be "as close to apples and apples as possible."

The group was looking at a potential figure for the summary and agreed that the summary needed to include what goes in and out of the incinerator. Jack Hanley said that questions, such as what is coming out of the incinerator (e.g., steam and water), were answered in the PHA.

George Gartseff had no objections to the questions and format of subheadings in the summary. He said that if these were kept, however, that he would re-shape the context. For example, "What is being done?" He stated that the summary should establish what is being done, continuing to be done, and what will be done in the future. He reiterated that the summary should not suggest that other agencies conducted activities at ATSDR's request, but instead possibly reflect ATSDR's analysis of these controls and make recommendations "as to the effectiveness" of the controls.

Jack Hanley said that ATSDR does make a specific technical recommendation to TDEC regarding its monitoring program in the PHA. He explained that this was a general way to explain the recommendation, but that this could be clarified. James Lewis asked if other recommendations were made. Mr. Hanley recalled making a recommendation to TDEC that the agency could publicize its findings in an annual summary made available to the public.

Dick Gammage believed that the first sentence on the last page of the four-page summary was the "worst sentence in the whole document" and recommended that it be changed. He thought it implied that either no safeguards or inadequate safeguards were in place when the incinerator began operating. He said that this sentence "ruins the whole document."

Jack Hanley said that the CCCWG had provided him with "excellent comments."

James Lewis wanted to see and read the product. Jack Hanley said that he would obtain their input before releasing the document to the public.

George Gartseff asked about the likelihood of having a draft document on March 22. Jack Hanley could not promise that a draft document would be ready because he had not anticipated these types of changes, but if possible he would have a draft at the next ORRHES meeting.

George Gartseff said that it had been speculated at the last meeting that approval of the summary would not be an issue since the executive summary was already approved during the PHA approval process. Jack Hanley said that this was correct. Mr. Gartseff said, "Anything that could be done to mock up the changes would be very welcome on the 22nd." Mr. Hanley noted that these comments would only improve the document.

Additional Items

Jeff Hill asked about the distribution list discussed during last week's meeting. He wondered what ATSDR would use to reach retirees. Jack Hanley said that one way was through unions, but he was not sure how involved retirees were with unions. Mr. Hill said that they were not involved. George Gartseff noted that there are some senior organizations in town and an operating senior center. He also indicated that the Oak Ridge Institute for Continued Learning (ORICL) was an active group. Mr. Hanley said that many retirees who were interested in environmental issues were involved in the Local Oversight Committee. Mr. Hill believed that these people needed to be approached.

George Gartseff adjourned the meeting at 7:30 pm.