Davis South Campus Superfund Oversight Committee
Rt. 2 Box 2879
Davis, CA 95616
fax 916-753-8220
e-mail [email protected]

May 11, 1999

Chief, Program Evaluation, Records, and Information Services Branch
Agency for Toxic Substance and Disease Registry
1600 Clifton Road (E-56)
Atlanta, GA 30333

Re: Comments on "Draft Agenda for Public Health Activities for Fiscal Years 1999 and 2000 at Department of Energy Sites" for the UCD/DOE LEHR Superfund site.

Dear Chief,

The Davis South Campus Superfund Oversight Committee (DSCSOC) wishes to thank ATSDR for its studies and assessment at the Laboratory for Energy-Related Health Research (LEHR) Superfund site and thank you for providing DSCSOC an opportunity to comment on ATSDR's Draft Agenda. As a US/EPA Technical Advisor Group (TAG), DSCSOC has represented the Davis community and the affected citizens in the LEHR site's investigation/remediation since 1995.

DSCSOC has asked that the site's impact on the community's health, water resources and environment be given priority in the Responsible Parties, University of California, Davis (UCD) and Department of Energy (DOE) investigation/remediation at the site. This has not happened. The full extent of surface and groundwater pollution at the site and off-site is still not known, even though the site has been under investigation now for over nine years. DSCSOC wishes to provide comments on data gaps for the Draft Agenda and recommendations for Public Health Actions.

There are data gaps in the site's impact on Putah Creek water quality and health implications on the citizens who use the Putah Creek fish as a food source and the creek for recreation. ATSDR's limited fish studies are the only studies conducted at the site which begin to look at the LEHR site's impacts on Putah Creek fish, and ATSDR's recommendation that there are public health implications of mercury exposure based on its fish survey only begins to address the mercury issues in Putah Creek. Dr. G. Fred Lee, DSCSOC's technical advisor, has indicated that at this time, because of the inadequate stormwater runoff water quality monitoring studies that have been conducted by UCD and DOE at the LEHR site, it is not possible to rule out the 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. Stormwater runoff from these soils could be carrying mercury to the creek that is contributing to the excessive mercury found in Putah Creek fish.

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. There is substantial contamination of soils at the site associated with the use of chlordane for flea control on the test dogs that were used in the studies conducted at the site. A review of the previous ATSDR 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 health issue needs to be addressed in order to protect the people who use Putah Creek fish as food.

Yolo County is currently sponsoring a Putah and Cache Creek Ecotoxicity Project which is being conducted by the Central Valley Regional Water Quality Control Board under the direction of Dr. Val Connor. ATSDR may wish to join this project as a follow-up Public Health Action to address the mercury, chlorinated hydrocarbon pesticide, dioxin and PCB issues not adequately addressed in the previous ATSDR fish studies. ATSDR may have an opportunity to enhance this project rather than repeat work currently being undertaken.

ATSDR's Phase II fish study recommends that as a follow-up Public Health Action, 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 the proposed follow-up Public Health Actions. As DSCSOC's executive director, I have provided comments on ATSDR's Phase II study that this proposed program needs to include posting Putah Creek. Posting the creek is the most effective and efficient method of notifying the public of the health implications from eating the fish. UCD changed the name of the LEHR site to ITEH and has refused DSCSOC's request to post the site as the LEHR Superfund site. Many citizens of this community do not know where on the UCD campus the Superfund site is located, and most who are fishing in the creek near the site have no knowledge of the site's potential impacts on Putah Creek fish. Any reference to the LEHR Superfund site in ATSDR's proposed information would be of little value as the site is not posted or listed in UCD information. ATSDR needs to include posting the creek as a Public Health Action as it would be the most protective method of informing the public of the health implications from eating Putah Creek fish.

DSCSOC has offered to assist ATSDR with any of its activities at the site where its services would be beneficial.


Julie Roth
Executive Director

cc: DSCSOC's Ex. Board
Dr. G. Fred Lee
Dr. Val Connor, CVRWQCB
Wayne Henry, ATSDR
Jane Riggan, CDHs

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