HEALTH CONSULTATION

From: Chief Medical Officer, Special Programs Activity, NCEH /CDC /HHS, and Deputy Director, Office of Federal Programs, ATSDR/HHS

To: Harvey I. Sloane, MD, Public Health Commissioner, District of Columbia Human Services Department

PURPOSES

1. Review Remedial Investigations and other environmental reports for the American University Experiment Station (AUES) Formerly Used Defense Site.
2. Identify public health hazards resulting from chemical warfare research activities conducted at the site during World War I.
3. Recommend initial public health activities to mitigate or prevent human exposure to hazardous substances released into the environment from the site.

AUTHORITY

This health consultation was prepared under authority of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, or Superfund), as amended, and Public Law 91-441.

CERCLA authorizes ATSDR to provide health consultations upon request on health issues related to exposure to hazardous or toxic substances to State and local officials, directs CDC and ATSDR to cooperate in conducting CERCLA public health activities, clarifies that ATSDR’s authorities apply to federal facilities, and assigns liability for the costs of ATSDR’s activities at federal facilities to federal principal parties.

PL 91-441 authorizes CDC to review issues involving disposal of lethal agents and make recommendations to the Secretary of Defense to protect public health and safety.

REFERENCES

Operation Safe Removal Remedial Investigation for Operable Unit 1, dated June 1, 1995

Spaulding and Capt. Rankin Operable Unit 2 Remedial Investigation, dated June 14, 1996

Final Report by Apex Corp. on arsenic at the residence of the President of American University dated August 1996

Administrative file correspondence between the District of Columbia (DC) government, the U.S. Environmental Protection Agency (EPA), the Department of the Army, and the Corps of Engineers (COE).

RECORD OF SIGNIFICANT EVENTS (from above references

1917-1920: Bureau of Mines & War Dept. operated chemical warfare research facility at American University, and conducted trench warfare training at adjacent Camp Leach.

1921: Newspaper reported burial of 8,000 ordnance items at AUES.

1920s-1990s: Area developed for residential housing.

1986: Army initiated archive research as a result of paper describing AU role in World War I.

May 2, 1992: “Rotten odor” detected in excavation by construction workers; soil sample revealed no hazardous substances; ok given to proceed.

May 27, 1992: Construction workers experienced eye irritation when loading dirt onto dump truck.

January 1993: Contractor digging utility trench in residential area hit ordnance; Operation Safe Removal initiated; 141 munitions removed; 43 suspected chemical munitions (mustard, fuming sulfuric acid). ATSDR and CDC provided public health support.

October 1993: 75 mm suspect chemical round found at surface by citizen.

May 1994: COE detected and removed Livens projectile partially filled with smoke agent.

July 1994: Contractor laying sod at soccer field found nose cone of incendiary bomb.

November 1994: Stokes mortar round without fuse left at site; possibly an “amnesty” round left by a citizen.

June 1995: Operable Unit 1 Remedial Investigation completed; Army & COE concluded that site poses no further hazard and no further remedial action recommended.

June 1996: Landscapers complain of eye and respiratory irritation while installing tree at President’s house; arsenic, VOCs, semi-VOCs, other priority pollutants, and acid with pH<1 detected in soil and glassware in hole. Indoor and outdoor air quality pose no hazards.

June 1996Operable Unit 2 completed; Army and COE concluded that bunkers pose no hazard; no further action recommended.

April 1997: DC Public Health Commissioner requested assistance from CDC and ATSDR; EPA and COE met with DC officials on 4/25/97 to discuss issues.

ASSESSMENT

Hazardous substances were released into the environment via detonation of high explosive, smoke, incendiary and chemical munitions; accidents involving releases of chemical munitions (mustard); open air dispersion testing of agents; and burial of surplus ordnance and laboratory wastes. Chemical warfare agents on the site during operations included mustard, Lewisite, Adamsite, phosgene, chloropicrin, cyanogen chloride, and fuming sulfuric acid. There is also some evidence in the record that chloroacetophenone, an irritant agent, and white phosphorus, a marking agent, may also have been used at the site during research operations.

Environmental impacts are currently limited to soil contaminated with arsenic, heavy metals, volatile and semi-volatile organic compounds, pesticides, herbicides, PCB isomers, and limited amounts of breakdown products from Lewisite and mustard. Monitoring data indicate that ground water and air are not currently impacted.

Exposure points are limited to areas where residents and construction workers may come into contact with residual contaminants in the soil (gardens, construction sites, etc.), although there may still be some “souvenir” rounds in nearby homes.

The primary exposure route is dermal contact with potential for incidental soil ingestion and inhalation.

Receptor populations are limited to residents and construction workers.

Public health implications are benign, according to Army and COE risk assessments. Time constraints have not yet permitted ATSDR and CDC to compare environmental monitoring data with ATSDR and CDC health guidelines in an independent assessment of monitoring results. Health outcome data were not addressed in remedial investigations, nor have ATSDR and CDC reviewed any local registries, health records, etc.

Community health concerns reviewed by ATSDR and CDC to date are limited to concerns expressed by the DC Public Health Commissioner in correspondence to the COE and EPA Region III. The District is concerned that large amounts of ordnance may still be buried at the site, that previous remedial investigations have not addressed the full range of hazardous substances at the site, and that contamination from the site may extend beyond the boundaries of previous remedial investigations.

CONCLUSIONS

Although previous remedial investigations have concluded that the AUES site poses no further public health hazards and that no additional actions are recommended, the subsequent unexpected encounter with hazardous substances by landscapers at the President’s residence and evidence of open air dispersion testing mentioned in the Operation Safe Removal RI indicate that the full range of potential hazards posed by releases of hazardous substances from the site may not yet have been identified and addressed.

EPA’s commitment on April 25th to review archives with COE and determine whether additional response actions are needed is a prudent approach to address potential hazards and the District’s concerns. However, that effort may need to be supplemented with a focused health education program to inform residents, construction workers, emergency responders and health care providers about potential hazards related to the site, and to prepare them to respond to unexpected encounters with residual ordnance and contaminants.

Health outcome data was not included in the references provided to CDC and ATSDR. This information is usually reviewed by CDC and ATSDR to determine whether biologically plausible adverse health impacts may be detectable in populations at risk. Therefore, formal causal relationship studies are not recommended at this time. ATSDR, CDC and District public health representatives should discuss the extent and types of health outcome data available, and determine an appropriate course of action.

RECOMMENDATIONS

1) Communication and Coordination:

• Establish an interagency team consisting of DC and federal representatives to further evaluate potential hazards and coordinate response actions.
• Prepare an activity-specific health consultation consisting of existing ATSDR fact sheets and information from other sources to address the District’s concern about all 52 hazardous substances at the site.
• Check with American University to determine whether some of the hazardous substances could have come from university lab wastes or other sources not related to chemical warfare research.
• Compare COE and EPA risk assessment results to ATSDR and CDC health guidelines, and discuss results with interagency team members to develop a consistent DC and federal government position on health risks.

2) Prevention:

• Map monitoring, population, and significant event data using a GIS database to provide spatial and visual information about potential hazards to the interagency team, construction and utility firms, residents, District building permit staff, emergency responders.
• Discuss the need for a limited, focused health education program through the DC Public Health Commissioner’s office to inform the local “Call Before You Dig” utility hotline, poison control center, HazMat Team, unions, construction and utility firms, etc., about potential hazards. Brief fact sheets have worked well in the past for these types of efforts
• Annotate POIs on deeds.
• Discuss previous efforts and the need for further efforts to inform residents of the hazards of souvenir ordnance and provide them with DOD contact numbers.

3) Surveillance

• Collate and distribute existing HHS and DOD medical management guidelines for hazardous substances, and information on sentinel signs and symptoms such as contact dermatitis related to arsenic exposure, to local health care providers, again through the District Public Health Commissioner’s office.

4) Response

• Provide HHS and DOD guidelines for patient decontamination and transport, and for emergency room chemical casualty management, to local emergency medical services and emergency rooms through the District Fire and Emergency Medical Services Department.

Please contact us at (770) 488-7091 or (404) 498-0001 if you have any questions about this consultation.

Signed,
CDR Paul Joe, DO, MPH
CDR Joe Hughart, MS, MPH