Table I-1:
Exposure Situation and Hazard Summary Table - Mongmong Community and Agana Power Plant, Guam | Exposure Situation | Contaminant(s) | Source | Media | Point of Exposure | Route of Exposure | Exposed Populations | Time | Comments |
| 1. EATING FOODS FROM AGANA SWAMP AND RIVER - Completed Pathways< |
| Contaminants in fish, eels, and snails harvested in the Agana Swamp and River | PCBs Dioxins | Runoff from Agana Power Plant | Biota | Fish, eels,and snails | Ingestion | Completed exposure to people who eat fish, eels, and snails from the Agana Swamp and River: 270 adults; 140 children | 1950s to present | Levels of PCBs and other chemicals in fish, eels, and snails are very low and do not pose a public health hazard. There could be, however, hazards from bacteria, viruses, parasites, and other infectious agents. People should thoroughly cook all foods to kill any biologic contaminants and avoid touching raw fish with open cuts or wounds. The government of Guam should conduct a baseline survey of biologic contaminants as funding becomes available. |
Bacteria viruses, parasites, and other infectious agents | Septic tanks and sewage systems; snails |
| Contaminants in fruits and vegetables grown in Agana Swamp and in the soil runoff areas near APP | PCBs Dioxins* | Runoff from Agana Power Plant | Biota | Fruits and vegetables | Ingestion | Potential exposure to people who eat fruits and vegetables from the Agana Swamp and River: 270 adults; 140 children | 1950s to present | Levels of PCBs and other chemicals in fruits and vegetables are either not detectable or very low and do not pose a public health hazard. |
| 2. PLAYING IN DIRT OR RUNOFF DITCHES OR GARDENING - Completed Pathways |
| Playing in the Dirt, Runoff Ditches near the APP and Gardening in runoff areas near APP | PCBs | Runoff from Agana Power Plant | Surface soil | Ditches and runoff areas, including residential properties | Skin absorption, Ingestion | Completed exposure to people come in contact with soil Agana Swamp and River: 220 adults; 150 children | 1950s to present | The levels of PCBs in the soils from and around the runoff ditches and in residential areas do not pose a public health hazard. |
| 3. SWIMMING/WADING IN AGANA SWAMP and RIVER - Completed Pathways |
| Swimming or wading (contacting water) in the Agana Swamp | PCBs Bacteria, parasites, viruses, and other infectious agents | Runoff from Agana Power Plant, Septic tanks and sewage systems | Surface water | Agana Swamp and River | Skin absorption; Ingestion | Completed exposure to people who swim and wade in the Agana Swamp and River: 220 adults; 150 children | 1950s to present | Swimming and wading in the Agana Swamp poses no public health hazard from PCB contamination because the levels in the sediment are low. Also, PCBs do not dissolve easily in water, and would have diluted in the large volume of water. Still, the Swamp is possibly contaminated with bacteria, viruses, parasites, and other infectious agents and could pose a public health hazard. People with open cuts or wounds should not wade or swim and should avoid swallowing the water. |
The Agency for Toxic Substances and Disease Registry released the Agana Power Plant Mongmong,Guam Public Health Assessment (PHA) for public review and comment on September 10, 2002. Thepublic comment period, which ended on November 7, 2002, was announced in a press release onSeptember 27, 2002. The health assessment was made available for public comment at the followingrepositories on Guam: Nieves M. Flores Memorial Library, Robert F. Kennedy Memorial Library,and the Micronesia Area Research Center at the University of Guam. The PHA was also sent toGuame and federal agencies and interested members of the general public. For comments thatquestioned the validity of statements made in the PHA, ATSDR verified or corrected the statements.The following list of comments received during the public comment period does not include editorialcomments such as word spelling or sentence syntax. Comments were combined when possible.
Comment: One reviewer suggested mapping the sampling sites of the data used in the APP PHA.
Response: Navy documents with maps showing sampling locations are available at Nieves Flores Memorial Library, 254 Martyr Street, Hagatna, GU 96910.
ATSDR has obtained a number of maps of the area around the power plant—including soil,elevation (topographic), wetland, and geologic maps—from groups and agencies such as theUniversity of Guam, U.S. Fish and Wildlife Service and U.S. Geological Survey. Becauseeach of these maps uses different grid systems or projections, ATSDR has been unable to plotNavy sampling coordinates on these maps. ATSDR is continuing to request assistance fromother groups and agencies so that the sampling points may be accurately plotted on thedifferent map projections. If the issues relative to sampling coordinates, grid systems, andprojections are resolved, maps will be included in ATSDR's second PHA addressing air andgroundwater issues and public concerns.
Comment: One sample of tilapia was collected during the Navy's sampling. A reviewersuggested that more samples of tilapia should be collected to ensure that the tilapia will notexceed FDA's 2.0 mg/kg limit.
Response: ATSDR agrees that additional tilapia samples would have been preferred. However, ATSDR based its overall conclusions on a variety of information. When combined with other sampling data for fish, sediment and soil, ATSDR believes that PCB levels are below levels of health concern for non-subsistence fishing. In addition, the number of fish available in the Agana Swamp and River, including tilapia, appears to be lower than needed to support a subsistence fishing population. Also, ATSDR has not identified a population of subsistence fish eaters who exclusively consume tilapia. Therefore, for subsistence fish-eating individuals and families, exposure should be below the levels found in the tilapia sample. The Navy sampling plan was designed to find if PCB from Agana Power Plant had reached Agana Swamp and River. It is uncertain if the PCBs found in the sample of tilapia are from Agana Power Plant, or another location such as PCB-contaminated soil near Agana Springs, unregulated waste, or septic tank and sewage releases. ATSDR believes that low levels of PCBs are widespread in the Agana Swamp and other hot spots of PCB may be found in the future.
However, based on sampling from soils, sediment, and other fish—including eel andcatfish—ATSDR believes that the levels of PCBs in tilapia will be consistent with PCBlevels in fish already sampled.
Comment: Although the exposure doses calculated from fish, eels, and snails do not exceedthe World Health Organization (WHO) tolerable daily intake for dioxins, many of thesamples exceeded the EPA's risk-based concentration (RBC) for total dioxins.
Response: ATSDR used EPA's RBC as part of our screening process. The RBC is a very conservative concentration. It overestimates risk for individuals and families who do not regularly eat the amount of fish used by ATSDR to calculate the risk based screening numbers. ATSDR reviewed the literature for information about total dioxins in the food supply of the U.S. and other countries. Table 6 presents the levels of dioxin residues detected in common foods. The average levels of total dioxins in the majority of sampled Mongmong fish, eels, and snails are almost identical to or below many common foods eaten daily in the United States and other countries. In addition, ATSDR did not identify individuals whose only source of fish was from the Agana River and Swamp.
Comment: The one sample of a taro root exceeds the USEPA's RBC for dioxins in fish. Onereviewer commented that there is no comparison value in the document for this value. A reviewer also suggested that more taro, eel and tilapia samples should be collected andanalyzed for dioxin.
Response: ATSDR reviewed the literature for information about total dioxins in the food supply of the U.S. and other countries. Table 6 presents levels of dioxin residues detected in common foods. Known incidents of high dioxin levels in humans have resulted from accidental exposure, not dietary exposures. Despite a large body of research and data collection, there are numerous questions and uncertainties regarding scientific data on and analysis of dioxin risk. This fact is acknowledged by the EPA's Science Advisory Board, which nonetheless also acknowledged that these uncertainties are unlikely to be resolved in the near future.
Taro is rich in protein, carotene, fibre, potassium and phosphorus. Taro (root and leaf) iseaten cooked because it is poisonous (calcium oxalate crystals) when eaten raw—the skinalso contains an oil that is an irritant. If additional sampling occurs, it would be useful ifcooked and non-cooked taro were both sampled. Local recipes and cooking methods (skin onor off, broiled, steamed, fermented) should probably be considered during development ofsampling and analysis plans.
Dioxin levels in Agana Power Plant soil where PCBs leaked on the ground are extremelylow. One taro root sampled had dioxins but no PCBs at detection levels. It is unclear if thedioxins were in soil attached to the taro root, in surface cuts on the root, or in the skin of thetaro root. It appears that the dioxins may have come from manmade sources of incompletecombustion that might have also included trash burning, or septic tank and sewage releases,or natural processes, such as brush and swamp fires. The term "natural background" fordioxins refers to the dioxins that are in the environment because of these natural processes.We do not know what the natural background level of dioxins is. The term "currentbackground" refers to the level of dioxin in the environment today. Current background is primarily made up of dioxins from manmade (anthropogenic) sources.
If a regulatory agency or a potentially responsible party determines that additional sampling isneeded to determine natural, manmade (anthropogenic) or current background levels ofdioxin in and around Mongmong, Agana River and Agana Swamp, ATSDR will reconsider itevaluation if levels in the local food are higher than found in the common food supply.
Comment: This PHA discusses three activities related to APP and identifies five other issuesnot directly related to the APP that will be addressed in a future document. One reviewersuggests that the APP PHA implies the presence of unknown contamination everywhere andthat this raises doubts as to the safety of the five activities not associated with APP withoutproviding references regarding these issues or a rationale for the presence of the unknowncontamination. The reviewer believes that the report adds fear of the unknown without beingspecific about the contamination and how these five activities could be linked to the APPPHA.
Response: The issues are community concerns that are related to APP but are not limited to APP. The community concern about swamp fires is an example of this. The community concerns included the concern that PCB came from the power plant and washed into the swamp and would then be in the smoke from the swamp fires. ATSDR's response is to the overall community concern about smoke and all PCBs in the swamp fires and not just PCBs from Agana Power Plant in the swamp fires.
Comment: The table on page 12 lists sites on the northeast side of the Agana River aspossible sources of environmental pollution in the Agana Swamp and River. A reviewersuggests that references for these sources be provided. The reviewer also believes that thisinformation adds apprehension about the unknown since the report does not offer any detailson the type of contamination or the activities of each site that could have produced thecontamination.
Response: In the Agana Power Plant health consultation released in 2000, ATSDR provided a historical map showing the locations of areas used by military and non-military groups during 1945 and a map showing an unnamed military reservation. In that document and this PHA ATSDR stated that these were possible source areas and identified a few of the items such as chemical warfare materiel identification sets that have now been removed from local property.
ATSDR emphasizes that the goal of its PHA is to help put environmental data intomeaningful public health perspective for the community. That is, ATSDR tries to answer thequestion of whether environmental exposure occurred and whether any such exposure mightbe harmful. One of the challenges we face is to evaluate potential health hazards given thelack of historical records, environmental monitoring data from source areas, and points ofhuman exposure. Without additional data and information, ATSDR can only say that theseare possible sources of contamination based on the fact that similar sites have hadcontamination associated with them.
Comment: One reviewer suggests an appendix including information about health conditionsreported by Mongmong residents might add to apprehension of the unknown by indirectlyimplying that the conditions reported by Mongmong residents may be associated with PCBexposure. Instead, the reviewer suggests that ATSDR include information that concentrateson the health effects of PCB exposure, its toxicity, how it can enter the body, types of cancerfound in animal and human studies of PCBs, and other health conditions pertaining to PCBexposure.
Response: Villagers were concerned that family illnesses and deaths were associated with PCB exposure from APP. ATSDR does not believe that these health problems are related to PCBs. ATSDR has added an appendix with information on health effects of PCBs.
During conversations with ATSDR some family members asked what could be causing thehealth problems if PCBs were not responsible. To respond to the request for informationabout these health problems, ATSDR included information about the causes of the healthproblems to help families and individuals make informed health care choices. ATSDR hasalso suggested that individuals and families discuss their health concerns with their physicianor health care provider and have routine physicals.
Comment: A few reviewers suggested that information about dioxin be added to an appendix and wanted to know ATSDR recommendations for diet and breast feeding.
Response: Questions and Answers About Dioxins were prepared by the Interagency Working Group on Dioxin (January 2003). On the world wide web they may be found at http://www.epa.gov/ncea/dioxinqa.htm . The Interagency Working Group is made up of the following:
- Executive Office of the President
- U. S. Department of Health and Human Services
- U. S. Department of Agriculture
- U. S. Department of Veterans Affairs
- U. S. Environmental Protection Agency
- U. S. Department of Defense
- U. S. Department of State
The questions and answers are presented in four sections:
- General information about dioxins
- Overview of the EPA dioxin report
- Food safety questions and answers
- Risk assessment questions and answers