April 15, 1998

via email

Julie,

Thank you for forwarding to me several of Dr. Lee's letters (April 14, 1998), including one that he titled, "Unreliable Information on the Hazards of Consuming Putah Creek Fish Due to Excessive Bioaccumulation of Mercury and Lead." I have several brief comments on this letter which I will list here. Please feel free to share these with any interested stakeholders.

1. I agree with Dr. Lee that the mercury and lead levels we detected in the fish in Putah Creek in 1996 were excessive, and posed a public health hazard. These data were not unreliable, though we did not have many data. I also agree that because the fish were composited, some of the fish likely had higher levels of mercury or lead than we measured-- not lower levels.

2. ATSDR does not yet have the metals data (including mercury and lead) for fish sampled in Putah Creek in 1997. I do not know what these data show. I spoke with the NAREL Project Manager, and he confirmed that he has not given out any information on the metals analyses in fish from the 1997 sampling to anyone. I expect to see the data soon, however.

3. It is true that there is disagreement between ATSDR and other agencies over what constitutes hazardous levels of mercury in fish. I will address this issue further in future correspondences.

4. It is also true, as Dr. Lee states, that we had problems with organic analyses in the 1996 fish samples. The EPA NAREL (Montgomery, Alabama) labs are not performing any organic analyses on the fish collected in 1997. Portions remaining from the 1997 fish samples will be sent from NAREL to EPA Region IX labs for analyses of organic chemicals.

5. The issue of repeated, seasonal monitoring of the fish for "three to five years after the site has been completely remediated," is an issue that will require further discussion among stakeholders. Remediation activities may not adversely affect the creek, and contaminants detected in the fish may not be site related.

6. I am interested in more information about plants that translocate wastes from their roots to leaves and flowers. What plants and what wastes does Dr. Lee refer to, and how might this process pose a public health problem at this site?

ATSDR expects to receive the final data packages from the 1997 fish study from NAREL this month. As soon as we get them, we will complete a health consultation and release it with the NAREL data. NAREL staff will send the fish samples to EPA Region IX for organic analyses after they have completed all quality assurance procedures with the samples. I am willing to discuss any of the issues raised by Dr. Lee with stakeholders at this site. If you have further questions, please do not hesitate to contact me at 1600 Clifton Road NE, Mailstop E-56, Atlanta, GA 30333, 404-639-6035, or [email protected].

Bill Taylor
ATSDR