Comments on the ATSDR report "Loudon County Hazardous Air Pollutants."

July 4, 2005

From:
Jim Phelps
EM: magnu96196@aol.com

To:
Agency for Toxic Substances and Disease Registry
Attn: Division of Health Assessment and Consultation (E-60)
1600 Clifton Road, N.E., Atlanta, Georgia 30333

Greetings ATSDR,

Please accept the following opinions on the "Loudon County Hazardous Air Pollutants" May 17, 2005 Draft Report for Public Comment document.

First, allow me acknowledge that I am saddened to see another Tennessee County fall into the same high cancer risk for which Anderson County and Oak Ridge has been well known. It is a very sad thing when the State of Tennessee has nil emissions regulations and allows the citizens of Tennessee to become literal guinea pigs for ever-escalating emission levels that highly affect human health. It appears Tennessee only takes action after the fact on increased diseases and cancer, rather than implementing programs geared to protect human health and not let matters get this bad. This is reflected in the high numbers of people in Tennessee with not only cancers, but varied other immune linked illnesses.

Mr. J. B. Hill of Oak Ridge recently alerted me as to the existence of this Draft Report for Public Comment on Loudon County. I see a number of things that caused problems in Oak Ridge that can well be causing problems in Loudon Co. that I want to address. I live right next door to Loudon Co., in Knox Co., and what blows in the air there soon comes here. If not the air pollution itself, then the poor regulatory protection produced by the State of Tennessee will soon come to afflict Knox County too. In many ways, this has already happened.

Per the Draft Report, I see one glaring problem in that there is very little detail on the IMCO Company's emissions. What is the product the company gets from ALCOA to process? What specifically are the metals and the chemical forms present? What are the company's emissions? How much Aluminum dust is emitted? How much fluorine or fluoride dust is emitted? What kinds of stacks are involved in releases and what is the dispersion via stack height? There appears to be a black hole of little specific information the state attempts to slide past everyone by not providing for IMCO the same level of detail they provided on the other companies profiles listed in the Draft Report. Anything short of providing the specific information on IMCO might well be observed as the State of Tennessee persons attempting to hide important parameters, because aluminum dusts tie strongly into diseases and illness mechanisms.

Other emissions of concern are the 2,200,000 pounds of Carbon Disulfide (CS-2) emitted by Viskase Corp. and the 30,000 lbs. of Hydrofluoric Acid (HF) from A. E. Staley. It needs to be stated in the report how these are emitted, specifically from high stacks to enhance dispersion or from low-level points. The problem with HF is that it will combine with moisture in the air and linger at low levels, where it can be highly absorbed into lungs or via skin and fluoride is highly retained by those exposed. HF is a very high risk chemical and a systemic poison. Fluoride synergism with Aluminum emissions is a very high-risk problem because it forms compounds that damage the thyroid regulation of the body and exhausts an important enzyme called glutathione (GSH). This effect can result in high levels of the enzyme superoxide dimutase (SOD) that causes the loss of cellular cancer protection. This type emission is associated with not only cancer, but respiratory problems.

Likewise, the very high emissions of Carbon Disulfide are associated with loss of trace metals that are involved in the production of these essential cancer protection enzymes for the cells. The loss of these trace metals for enzyme repair processes for oxidative stress is connected to the mitochondria damage that results in the impairment of cancer protective enzymes. (See Ref. 1 below for citation.)

If either ATSDR or the State of Tennessee is going to attempt to determine the issues of cancer risk, it needs to explain the cancer risk processes of the cells in the body. Cancer risk cannot be done without a clear understanding by everyone of the process that leads to cancer activation within the human body. Oak Ridge studies found the prime model of cancer risk was one associated with total oxidative cell stress either from radiation or from mitochondria generated reactive oxygen species (ROS). The radiation model for cancer in cells is where the ionizing radiation produces high levels of ROS within the cells, which the mitochondria process attempts to neutralize using the mitochondria produced enzyme called Mn-SOD. At levels of around 100 R the external gamma dose to the cells causes the Mn-SOD activity to become so consumptive of manganese that the cancer viral protection enzymes fail. All the enzymes that cleave the cancer virus related RNA depends on the trace metal manganese to perform the task, even the ones that kill HIV.

The total oxidative stress model also includes problems that stem from loss of a metals clearance enzyme within the cells called GSH. GSH removes toxic metals from cells that cause excessive mitochondria malfunction and the production of excessive ROS. This causes the same oxidative stress problems to cells as does radiation. Se-GSH is a critical enzyme for human health and depends on the trace metal selenium. One of the chief antagonist processes to GSH levels needed in cells to keep down the ROS generation involves the formation of a thyroid hormone like G-protein from aluminum and fluorine within the body. The spontaneous formation of this aluminum and fluoride compound forms a protein that mimics the thyroid stimulating hormone (TSH) produced by the pituitary gland, which controls all thyroid hormones in the body. It is the up regulation of the thyroid hormones with no sleep cycle down times that depletes the GSH levels in cells that lead to accumulation of toxic metals within the cells and the production of excessive levels of ROS from the mitochondria. As this happens the mitochondria Mn-SOD production attempts to neutralize the ROS and robs all the manganese needed for viral and mycoplasma control within the cells. The high oxidative stress effect impairs manganese dependent cancer protection enzymes, like interferon and 2-5A RNase L.

It is with this rudimentary model for the cancer process that one must logically begin to consider how multiple emissions of these three principle plants may be causing health harm and higher cancer risks to persons of Loudon County, Tennessee. One deadly emission is that of aluminum, which will form AlFx type compounds in the body and begin to interfere with the thyroid hormone regulation process and deplete the GSH protective enzyme in every cell in the human body. Tiny amounts of this hormone like substance seriously affect the thyroid hormone regulation. Likewise, emissions of HF will find aluminum in the body from persons eating salt with aluminum silicate or baking powder with aluminum, and many sources including that from IMCO emissions to air. HF emissions enhance the formation of AlFx compounds that damage GSH levels in every cell of the human body.

Likewise, the Viskase emissions of CS-2 are associated with damaging the cell mitochondria in ways that lead to excessive ROS generation, as well as, damaging the levels of trace metals needed for protective enzyme functions in the human body.

In Oak Ridge, these problems have lead to serious health effects, many of which have been masked by the State of Tennessee in several studies on Oak Ridge's emissions. One of the worst studies on Oak Ridge was the Oak Ridge Health Advisory Steering Panel (ORHASP), that was overseen by Bonnie Bashor. This is the very same person that ATSDR chose to oversee and write this poor quality report on Loudon County's cancer risk problem. The State of Tennessee also oversaw another health investigation called the Governor's K-25 Blue Ribbon Panel to look into HF and toxic metals emissions from the K-25 plant and TSCA incinerator. The ORHASP studies took 9 years and 14 million dollars and overlooked the problems of HF emissions from K-25 affecting the health and GHS levels in all the workers and a large part of the community. The Governor's Panel overlooked factors like Dioxin, Hg, PCBs, and HF damaging the GSH protective enzyme's level in children that directly associated with asthma rates.

This State investigations happened when the TSCA incinerator's main function was to destroy DOE's PCBs, which had been burned in previous incinerators at K-25 producing Dioxin. Both Doixin and PCBs main mechanism associated with cancer causation is its damage to thyroid process and reduction of GSH in cells leading to higher cancer risks. The State of Tennessee persons had to intentionally look the other way for all these workers exposed to PCB and Dioxin complaining about illnesses. Then look the other way not to associate the HF releases causing the AlFx compounds to form that also wreck the thyroid hormone controls leading to even more loss of the critical GSH enzyme within cells of the body. These factors have been on the books for some 20 years, since the times of the TSCA legislation of 1982.

It was Bonnie Bashor who involved a number of Oak Ridge persons with conflicts of interest in the ORHASP process, plus the interests of the state of Tennessee in protecting jobs. All these poor studies came at the expense of citizen's health by not taking note of these extremely serious HF and Al problems that have long existed around the ALCOA plant and the Oak Ridge Plants. The state of Tennessee shows everyone via their actions here that they only care about jobs at whatever cost to human health in Tennessee. This even shows up by the state allowing huge emissions from TVA's coal plants of HF and Hg that directly tie into these thyroid type problems leading to GSH health affects causing everything from excessive heart diseases and kidney disease to higher rates of cancer. Coal gasification processes have long existed that would drastically cut TVA's toxic emissions and dramatically lower the kidney problems and dialysis clinics in Tennessee, as well as lower heart disease problems and cancer risk for a given age.

We see Bonnie Bashor misleading reporters and newspaper readers (Ref 2 below) with her either poor understanding of environmental pollution factors linked to the cancer causation mechanism or what is more likely her attempting to protect polluting industries and jobs in Tennessee at the expense of everyone's health. Air pollution factors from Loudon County emissions, as well as TVA's emissions of HF and Hg, all add into the cancer causation equation for thyroid hormone interference, GSH loss, mitochondria malfunction, excessive ROS in the cells, the loss of cancer protective enzymes, and higher cancer risk in Loudon Country. Yes, factors in food like aluminum content are involved in these health issues, and their synergistic effects with air pollution. There is no greater example of this effect than the AlFx compounds investigations. If the persons of Loudon County are not careful Bonnie Bashor will attempt to pull the wool over the citizen's eyes and again cover up serious health problems and provide Tennessee Jobs at the expense of high rates of local illnesses.

One can read in reference 3 that there are long established methods for how agencies and industries have pulled the wool over the citizens eyes when it comes to the liabilities of industries causing health problems in the surrounding populations. This sort of politicization of science to benefit the polluters has gone on in all the Oak Ridge investigations, with glaring omissions of the principle toxin causing the illnesses, the mechanisms for the illnesses, and conflicted panel administration.

ATSDR needs to be totally ashamed of itself for letting the contract on the Loudon Co. Cancer risk studies to the State of Tennessee and Bonnie Bashor, given their past track record for what appears to be totally corrupted studies that dodge the real problems. The People of the State of Tennessee sought an independent investigation of these problems, where the cards would be laid on the table for all the intelligently inspect and become totally informed. In place of independence, the People of Loudon Country are being run over by the politics for Tennessee Jobs Vs Human health protection.

No honest cancer risk study can ever be performed without the mechanism leading to cancer activation being well understood by everyone, especially the affected citizens. This means that any report of this nature needs to fully disclose the oxidative stress type models for cells and the GSH and SOD factors that shut down the manganese involved enzymes that cleave the cancer virus RNA within cells. Then and only then can the environmental pollutants be effectively compared and studied for either interference with these enzymes, hormone processes, and cell metabolic ROS effects.

Further reading on the Cancer Mechanism can be found at:
http://www.doewatch.com/cfs.html

Thanks for allowing me to share my opinions with ATSDR and the affected Citizens of Tennessee.

With Grace and Peace,
Jim Phelps

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Reference 1:

Citation on carbon disulfide:

"http://www.inchem.org/documents/pims/chemical/pim102.htm"

- acute CNS toxicity and peripheral neurotoxicity may be attributed to the formation of dithiocarbamates (CEC, 1988).

- non-enzymatic reaction of carbon disulphide with free amino groups indicates possible reaction with macromolecules such as enzymes, structural proteins, polypeptides and nucleic acids (CEC, 1988).

- the chelating effect of carbon disulphide metabolites (dithiocarbamates) on various essential metals, required for the functioning of enzymes (e.g. zinc and copper); the neurotoxic action of carbon disulphide could easily be explained by chelating effects on both metals (WHO, 1979).

- an effect of carbon disulphide on enzymatic systems: acute oral chronic exposures of animals to carbon disulphide result in changes of mitochondrial respiration and oxidative phosphorylation (WHO, 1979).

- disturbance of vitamin metabolism: carbon disulphide alters the metabolism of vitamin B6 and nicotinic acid (WHO, 1979).

- impairment of catecholamine metabolism: there is a decrease in the level of noradrenaline and increase in the level of dopamine. Brain dopamine B-hydroxylase is inhibited and unable to convert dopamine into noradrenaline. The inhibition of the enzyme occurs through the conversion of carbon disulphide to diethylthiocarbonate which chelates the cupricions essential for the enzyme function (CEC, 1988).

- disturbances in lipid metabolism, which lead to elevated total and esterified cholesterol levels in serum. Changes in the lipid metabolism may lead to development of atheromatous changes in the aorta (WHO, 1979).

- interaction with microsomal drug metabolism: an important feature of the liver toxicity caused by carbon disulphide seems to be the deactivation of cytochrome P450. This effect is due to the oxidative desulfuration of carbon disulphide by mixed-function oxidases (De Matteis & Seawright, 1973). The resulting highly reactive sulphur becomes covalently bound to the microsomal protein, mainly to the apoprotein of cytochrome P450. It is possible that the liberated sulphur is the real toxic agent in liver toxicity arising from carbon disulphide exposure (WHO, 1979).

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Reference 2:

Loudon County grapples with high cancer ranking
2005-06-12
by Barbara Pierce

Daily Times Correspondent

Now that data on disease in Loudon County is in -- and the numbers are frightening -- residents want to know why and what to do.

The Tennessee Department of Health recently notified county officials that Loudon residents top the state in rates of cancers, heart disease and breathing disorders.

The ranking is receiving close attention from air quality officials at federal, state and local levels.

The report issued May 17 by the state Department of Health followed community open houses and subsequent surveys in July 2004. The public health assessment of hazardous air pollutants in Loudon County was prepared by the health department under a cooperative agreement with the Agency for Toxic Substances and Disease Registry in Atlanta.

The findings came as no surprise to some.

Pat Hunter, president of Clean Air Friends-Clean Air Kids (CAF-CAK), said it was becoming known through friends and acquaintances that something was making people sick.

After hearing numerous accounts of friends and family members who were contracting respiratory illnesses (asthma, bronchitis) or various cancers (larynx, brain), the group submitted two petitions totaling more than 4,000 signatures to Gov. Phil Bredesen in 2004. The petitions requested independent health studies and improved technology in industry to reduce emissions.

``We just want to make this a better place to live,'' Hunter said. ``When I first moved here 20-some years ago, I thought the beauty of this place was awesome. The recreation, the green spaces, the lakes that's why people move here.

``We're all looking for a safe environment,'' said Hunter.

The Tennessee Department of Environment and Conservation (TDEC) designed a Hazardous Air Pollution (HAPs) study to look at emissions in the town of Loudon in Loudon County. The Tennessee Department of Health, Communicable Disease Services, Environmental Epidemiology (EEP) completed the assessment, which contains more than 170 pages of data on the exposure and health effects of about 41 chemicals.

The public is encouraged to comment on the information, which will be accepted through July 10.

`Waiting on the state'

Loudon County Mayor George Miller said the county set up an Air Quality Task Force in October 2003 because of public concerns.

``We're now waiting on the state Department of Health to provide some insight. We don't know the causes for why we are ranked so high,'' said Miller.

Asked if he thought the factories in Loudon County were a contributing factor, he said he wasn't qualified to make that judgment.

Loudon County Commissioner Bob Franke said the county's topographical location may be partly responsible for the problems. Franke said Loudon fits into almost a bowl shape against the side of the Smoky Mountains and pollutants get trapped and cannot escape.

Russ Ellis, chairman for the Loudon County Air Quality Task Force, said the task force has been charged with determining the air quality and the action needed to improve it.

Through meetings with the citizens and pulling data on the surrounding counties air, ozone and particulate matter, TDEC was requested to place air monitors adjacent to the industries, where, he said, the highest concentrations would be present.

According to the assessment, air toxics monitoring for Loudon began in November 2003. In the next couple of months, Ellis anticipates doing ``stack tests,'' where the emissions leaving the actual factory smokestack will be tested.

Don Miller, Loudon County commissioner for Tellico Village, explained that there are Environmental Protection Agency (EPA) classifications on toxic air emissions identified as E4, E5, and E6. E4 is unacceptable, E5 needs further analysis, and E6 is acceptable. Loudon County is falling between E5 and E6, which would require further analysis.

Air quality task force

The Loudon Air Quality Task Force is composed of 12 members including:

* Two Loudon County commissioners

* One representative from Loudon City Council and one from Lenoir City

* Three representatives from industry (one from Tate and Lyle, who own A.E. Staley Manufacturing, one from VisKase, and one from Kimberly Clark)

* One medical physician

* One TDEC representative

* And three citizens.

The task force is chartered by Lenoir City, Loudon City and the County of Loudon and reports to those entities.

When Miller was asked why there were members from the local plants on the task force, which are the areas being monitored for the toxic emissions, he said, ``We thought that maybe if we included people in industry, there may be more motivation for them to put in technology to reduce their emissions.''

Hunter of CAF-CAK is concerned that officials are looking at dollars and cents and not the big picture. Hunter's concern over raising children in an area already designated as a nonattainment area for ground level ozone by the EPA, and believes the serious health problems seemingly brought about or worsened by the air quality problems need to be resolved now.

``We have some serious health concerns and hope the Loudon officials look at us seriously,'' Hunter said. ``We will not let this go.''

Hunter also believes that the industry involvement as members of the Loudon Air Quality Task Force, is like putting the ``fox in charge of the hen house.''

``You cannot critique yourself; you need to be unbiased,'' said Hunter.

Study took over a year

Bonnie Bashor, TDEC director of Environmental Epidemiology, explained that it took over one year for this health assessment to be written by six individuals, two of whom have doctorates. (The roots of the report go back to March 2004, when the state Division of Air Pollution Control requested that data from monitoring devices in the industrial corridor be used to identify possible health risks.)

Bashor said the study was written mainly for the public's benefit, but that researchers could not connect the health data (number of illness) with environmental data (air emissions, etc.). ``The assessment wasn't designed to do that,'' said Bashor.

Bashor explained that according to a study done several years ago, by Sir Richard Doll (one of the scientists/researchers who proved the cigarette smoking, cancer relationship), 75-80 percent of cancers come from lifestyle and diet -- with major factors being smoking, obesity and genetics.

According to Bashor, air pollution is not generally a big cause of cancer. Bashor said that as far as respiratory illnesses go, that the Southeast is well known for allergens, especially in East Tennessee with its large number of plant species.

According to the health assessment, Loudon has a statistically significant increased rate of chronic bronchitis, which may have an association with the ozone levels in the county.

Bashor also said that TDEC would explore the pollution, if any, from the factories, cars and trucks, and would look into why the cancer rate is so high.

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Reference 3:

Source:
"http://www.uow.edu.au/arts/sts/bmartin/pubs/99rsppp.html"

Suppression of dissent in science
Published in Research in Social Problems and Public Policy, Volume 7, edited by William R. Freudenburg and Ted I. K. Youn (Stamford, CT: JAI Press, 1999), pp. 105-135. This version may have slight differences from the published version.

Brian Martin

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