Davis South Campus Superfund Oversight Committee
Rt. 2 Box 2879
Davis, CA 95616
530-753-9446
fax 530-753-8220
e-mail [email protected]
http://members.aol.com/dscsoc/dscsoc.htm

March 25, 1999

Wayne Henry
Agency for Toxic Substance and Disease Registry
1600 Clifton Rd. NE MS-E-56
Atlanta, GA 30333

Dear Wayne,

DSCSOC is looking forward to working with you as ATSDR's new project manager for the UCD/DOE LEHR Superfund site, and I want to thank you for answering my questions regarding ATSDR's current site activities. As the US Environmental Protection Agency's Davis citizens oversight group for LEHR, DSCSOC has worked with ATSDR in the past to assist in the preparation of its Health Risk Assessment for LEHR. DSCSOC is concerned about the risks at the site and its impacts on the community's health, water resources, and the environment.

ATSDR completed its draft "Survey of Fish in Putah Creek (Phase II)" in September 1998. Based on the information gathered during the study, ATSDR recommends that women of child-bearing age, especially those who are pregnant or nursing, refrain from eating largemouth bass from Putah Creek. ATSDR proposed, as follow-up Public Health Actions, that ATSDR representatives work with local health officials to develop and implement a plan for providing survey information to persons who eat fish from Putah Creek and work with health department representatives to distribute information including a summary of the fish survey and health implications of mercury exposure to local health care providers who provide care to pregnant or lactating women. To my knowledge, ATSDR has not implemented its proposed follow-up Pubic Health Actions. Also, ATSDR has not finalized its draft Phase II report on the mercury issues in Putah Creek.

Dr. Lee, DSCSOC's technical advisor, has indicated that at this time, because of the inadequate stormwater runoff water quality monitoring studies that have been done by UCD and DOE at the LEHR site, it is not possible to rule out LEHR site stormwater runoff as a potential contributor to the excessive mercury that ATSDR has found in two different years of study. Recent work at the LEHR site is finding that the surface soils of this site contain elevated mercury compared to background soils in the region. This issue is being further investigated.

Another issue of public health concern with respect to the consumption of Putah Creek fish which still has not been adequately addressed in the ATSDR studies is the bioaccumulation of chlorinated hydrocarbon pesticides, dioxins and PCBs in these fish. A review of the previous ATSDR US EPA studies on Putah Creek fish shows that inadequate sensitivity was used in analyzing these fish for some chlorinated hydrocarbons that typically bioaccumulate to excessive levels in fish tissue.

It has been recently learned that the San Francisco Estuary Institute (SFEI) has been taking freshwater clams from Putah Creek as a source for their bioaccumulation monitoring. The data in the SFEI annual report show that freshwater clams taken from Putah Creek contain highly elevated concentrations of some chlorinated hydrocarbons. Based on these data, the higher trophic level fatty fish taken from Putah Creek should also have excessive concentrations of chlorinated hydrocarbons. This is another public health issue that needs to be addressed in order to protect the people who use Putah Creek fish as food.

As the executive director of DSCSOC, I submitted comments on the Phase II study which included the recommendation that posting Putah Creek is the most effective and efficient way of warning those at risk. Another spring is here and members of this community are fishing in Putah Creek in increasing numbers. Those at risk are once again being exposed to the health risks from eating largemouth bass and other fish without being warned. As the community representatives in the LEHR Superfund site investigation and remediation, DSCSOC has waited patiently for the agencies in charge and local health department officials to make a decision regarding the public health warning. Unfortunately, while the mercury risk has been known for years, no action has yet been taken to protect or warn those at risk. It is time for this situation to change.

I encourage and invite you to visit the Davis community, meet with the LEHR site representatives, Yolo and Solano County health departments and water quality/resources officials and request that ATSDR's Public Health Actions to be implemented. I have attached information regarding a meeting of the Technical Advisory Committee for the Putah and Cache Creek Ecotoxicity Project. This project is sponsored by Yolo County and managed by the Central Valley Regional Water Quality Control Board. The members include Yolo County Environmental Health, State Water Resources and State Water Quality Control Board officials, UC Davis representatives, members of public groups and private citizens. The first meeting is scheduled for the first week in April, although the date is not yet set. ATSDR's Public Health Actions regarding Putah Creek fish may be an issue which this committee can address. Please contact Dr. Val Connor, Regional Board Coordinator for the CVRWQCB at (916) 255-3111 for information regarding this committee's activities.

The next scheduled Remedial Project Managers meeting for the LEHR site is April 22nd at 10AM at the LEHR site. Kathy Setian, EPA's project manager (415) 744-2224, would be the person to contact regarding scheduling a meeting with LEHR site representatives.

I understand that it may be necessary for ATSDR to conduct a public meeting and include the local health and water agencies, LEHR site officials and other interested persons for the purpose of discussing and implementing ATSDR's follow-up Public Health Actions. If you wish, DSCSOC can assist ATSDR with this endeavor.

If you have any questions or need my assistance, please contact me.

Sincerely,

Julie Roth
Executive Director

cc: DSCSOC's Ex. Board
Dr. G. Fred Lee, DSCSOC's Technical Advisor
LEHR RPMs, (US EPA, CVRWQCB, DHS, Rad Branch and DTSC.)
LEHR PRPs, (UC Davis, Dept. of Energy.)
Jane Riggan , California Department of Health Services
Tom To, Yolo County Environmental Health
Richard Serrano, Solano County Environmental Health
Val Connor, CVRWQCB, Regional Board Coordinator
Greg Franz, State Water Board, Contract Manager