text:
The Globemallow (Sphaeralcea coccinea and allied spp.) is a riotous splash across the mesa, all scarlet and orange and pink amongst the native grasses and blue flowered Sages. Unlike the common mallows, our spp. is so hairy as to sometimes be known as Sore Eye Poppy, and if you ever drive down a dry dirt road with Globemallow growing on either side and your windows down you'll soon be rubbing your eyes and understanding that particular common name in a very personal way. Children sometimes like to play with the pretty blooms and then accidentally rub the hairs into the eyes, causing quite the itchy, scratchy, owie kind of catastrophe.
However, outside of this strange anamoly, the Globemallow can be worked with in any way in which you would normally use a Malva spp. or good old Marshmallow. Like these other species, Globemallow makes a lovely gooey mess when pounded up. In fact, indigenous peoples once used the root goo as a kind of edible glaze on the inside of some of their earthenware. That same goo also makes a wonderful poultice for wounds, broken bones, sprains and swellings.
I do suggest that if you use any part of Globemallow medicinally besides the root, that you thoroughly strain whatever you're making to avoid any scratchy throat moments. It's also a traditional wash for irritated, red eyes and you definitely want to strain the wash, because the last thing you need is more itchiness in your eye. It works very well for that application though, and is especially effective when combined with Rose petals.
Essentially, much of the Mallow's medicine has its roots in the moistening and moderately cooling qualities of the plant overall. It's very useful here in the Southwest where everyone tends towards hot and dried out. It's really quite lovely come a sunbaked June day at the height of fire season when there's smoke in the air and one's lungs feel like they've been sun dried. Added to a nourishing infusion of Oatstraw and Rose, it provides a moist, sweet treat for the whole body, but especially the mucus membranes.
Globemallow makes a great oil despite the fact that it may seem like its mucilagenous nature would promote mold. So far I've had significantly less trouble with it than say, Plantain. It's a soothing and very healing addition to nearly any salve and is especially good at stimulating the local immune system. Poultices and washes also work nicely in a pinch.
Perhaps the most profound healing effect I've seen personally with the help of this plant is in cases of IBS and dyspepsia related to an irritated, imbalanced gut. Slow but sure, it can greatly restore the health of the GI in almost any situation where there's simple constitutional dryness accompanied by chronic inflammation. It's dependable, common and easy to use, just like all the best medicines. This is a great combo with Rose and Chamomile for many many cases of IBS.
That whimsical little painting over there on the left is by our very own lovely Loba, just this morning as a card for me. I drew her some Motherwort, Oats and Sage in return. 😀
For more on the amazing medicine of the Mallows, check out this previous post.
Medicinal Plants of the Mountain West by Michael Moore
Herbal Medicine of the American Southwest by Charles Kane
Native American Ethnobotany by Daniel E Moerman
2 Responses to "Globemallow In All Its Glory"
I just found this blog yesterday and have bookmarked it. I hope to return to it daily. This is something that is in my heart after being almost killed by the pharmaceutical industry with the help of my doctor.
I haven't had a chance to look very far, but I was wondering if you have, or are planning to show resources to learn how to make the different products. I know heal all and St. johns wort grow on my premises as well as clover and asters, the later I noticed you mentioned in another post.
I have a friend who is interested in this. I will add a link to this site from my blog.


text:
For 57 years, Ione was the devoted, wife of Gerald Callahan, loving father of Patty and Pam (Kevin), grandfather of Jamie and Garold Wood.
Ione was born on May 30, 1934, to James and Susan Westwood in Moab, Utah. Ione was the second youngest of 13 children.
Ione was a passionate nurse with a long and distinguished career in nursing with a degree from Westminster College. To fund her college education, she drove cattle and roped wild mustangs. She became one of the youngest supervisors at St. Marks Hospital, running the othopedics and psychiatric wards. She worked as director of nursing at the Duluth Clinic and South Davis Community Hospital and also as a hospice nurse. She loved her time as a school nurse in the Davis County school system.
She was an excellent golfer, all around athlete and a dedicated Jazz fan. She rarely missed a game and cheered loudly knowing all the players, their stats, strengths and weaknesses.
We wish to express our thanks to the many wonderful caregivers at The Legacy House, Lakeview Hospital and Orchard Cove that gave her loving quality care.
She loved with all her being; a fierce life force who touched all around her, demanding the best from everyone. She will be greatly missed by all.
A celebration of Ione's life was held, Saturday, Jan. 25 in North Salt Lake City.

subset: commoncrawl


text:
Lucy and Viv: Queens of Comedy
By: Legacy Staff
6 years ago
Lucille Ball and Vivian Vance – two of our very favorite funny women – made an unforgettable pair on I Love Lucy. We could watch them all day long.
And maybe that's just what we'll do today as we remember the anniversary of Vance's death and celebrate Ball's birthday (she would have been 101 this month). Want to watch with us? Here are a few favorite funny scenes.
Ball and Vance didn't immediately click as friends. In fact, Ball was reluctant to cast Vance on I Love Lucy – she was looking for an older, frumpier woman to play her neighbor. But Desi Arnaz had seen Vance's work on the stage and was convinced he had found the right actress for the job. As it turned out, the chemistry between the two women was brilliant.
Over time, Ball grew to respect Vance as an actress – and they became friends in real life as well as on TV.
After I Love Lucy ended, the fun went on with The Lucy Show. This time, Vance got to go by her real first name – she was more than ready for the world to stop calling her Ethel.
Though their regular collaboration ended when The Lucy Show went off the air, Vance continued to pop up from time to time when Ball would do a TV special or reunion show. And the friendship remained – as did the respect. Several years after her friend and costar's death, Ball remarked, "I find that now I usually spend my time looking at Viv. Viv was sensational. And back then, there were things I had to do—I was in the projection room for some reason, and I just couldn't concentrate on it. But now I can. And I enjoy every move that Viv made. She was something."
Written by Linnea Crowther


text:
TOKYO (AP) — Japan and North Korea began talks Thursday in Mongolia that Tokyo hopes will shed light on decades-old abductions.
The meetings in the Mongolian capital of Ulan Bator are scheduled to last through Friday. In August, lower-level negotiators from Japan and North Korea held the countries' first bilateral talks in four years, but made little progress.
Japan wants information on the abductions of Japanese citizens by North Korean agents in the 1970s and '80s. Japan believes at least one abductee may still be alive in the North, though North Korea denies this. Five abductees were returned to Japan in 2002.
Japan and North Korea do not have formal diplomatic relations. The abduction issue and concerns over North Korea's nuclear and missile programs have long strained ties.
Japanese officials indicated before the start of the talks that they expected them to be tough and not likely to lead to any immediate breakthroughs. North Korea's official media provided few details, reporting only that they were intended to deal with issues of mutual interest.
Japan has imposed strict sanctions against the North and cut off most economic and cultural exchanges in 2006 after a missile launch. Tensions heightened again earlier this year when the North launched a rocket that it said carried a satellite, but that Japan and other countries criticized as a thinly disguised test of long-range missile technology. The launch failed just after takeoff.
As the negotiators met in Mongolia, a group of university athletes from Japan's top sports university were holding a rare series of friendly competitions with students in North Korea's capital, Pyongyang. The 40 Japanese students squared off with their North Korean counterparts in judo, soccer and other events.


text:
George H. Miller, sales engineer, WWII veteran
Sept. 12, 1922 – March 26, 2013
Services for George Henry Miller of Elma, a former U.S. Marine who received a Purple Heart for his service in the Pacific during World War II, will be at 10 a.m. Saturday in Paul A. Kloc Blossom Chapels, 4680 Clinton St., West Seneca.
Mr. Miller died March 26 after a brief illness at his home in Gibsonia, Pa. He was 90.
A longtime resident of Elma, Mr. Miller and his wife of 64 years, the former Ruth L. Johnston, moved to Gibsonia in late 2012.
Mr. Miller served from March 21, 1942, to April 1, 1946, as a corporal in the U.S. Marine Corps. He was a member of the 5th and 14th Defense battalions and operated 40 mm anti-aircraft artillery, according to his daughter Susan A. Fortham of Gibsonia.
"He was one of the first reinforcements sent to Guadalcanal," said Fortham. "Dad earned his Purple Heart after he was injured by friendly fire on Tulagi, a small island in the Solomon Islands."
In 1982, Mr. Miller began attending reunions of World War II veterans held in cities throughout the country, recalled Fortham, who took her father to the last reunion in Quantico, Va., in 2009.
"It became increasingly difficult for my father and other vets from World War II to travel," Fortham said. "That year they decided it would be their last reunion. It was bittersweet."
Throughout the years, the United States flag held special significance for Mr. Miller, according to Fortham, who recalled her father teaching schoolchildren about the proper handling of the flag.
Mr. Miller was credited in May 2009 for his work on securing a flagpole for the Buffalo & Erie County Naval and Military Park Museum, where his uniform was once displayed.
An Elma resident for 60 years, he was active in the Elma Senior Citizens Center and Elma Post 5861, Veterans of Foreign Wars. He was a member of Immanuel Lutheran Church in East Aurora.
Born in Dover, Pa., Mr. Miller studied engineering at Penn State University. He moved to the Buffalo area in the early 1950s and worked as a sales engineer from 1952 to 1992 for Goergen-Mackwirth Co., a custom metal fabrication firm that opened here in 1916.
He was a member of the National Rifle Association and Niagara Frontier Detachment 239, Marine Corps League.
In addition to his wife and daughter, Mr. Miller is survived by a son, George "Art" Miller, and two sisters, Pauline Rhinehart and Ruth Lehr.


text:
Create an Account - Increase your productivity, customize your experience, and engage in information you care about.
The City of Aspen Utilities provide water and electric service to approximately 6,500 accounts. Environmental Initiatives has a goal of providing 100% of our electricity from renewable sources within the next five years. Currently 75% of our electricity comes from clean, renewable sources including hydroelectric and wind power. Water service to the city started in 1966. The majority of the electrical system was put underground in two major projects in 1976 and 1986.
To manage and maintain our water and electric resources from their resources to our customers in a manner that most efficiently meets, or exceeds, all related State and Federal standards, while driving the reduction of Aspen's greenhouse gas emissions and energy use through policy, outreach, energy efficiency and renewable energy programs.


text:
Governor Dayton Says He Paid $89K In Taxes In 2012
ST. PAUL (AP) — Minnesota Gov. Mark Dayton has released returns reflecting him paying about $89,000 in taxes for 2012.
Dayton released his tax returns on Tuesday, following his routine of doing so since he was a candidate in 2010.
Overall Dayton earned $343,000 last year. More of his money came from dividends and capital gains than from his gubernatorial salary of $120,000. His taxable income after deductions came to about $299,000.
His return showed him giving $1,000 to charity.
Minnesota law doesn't require the release tax information by officials, but some have done so voluntarily.
State Sen. Dave Thompson, who is among several GOP candidates for governor, also released his forms on Tuesday. They showed a family income of $198,322, a total tax bill of about $40,000 and $20,000 in charitable giving.


text:
Pinnacle Airlines is Leaving Memphis for Minnesota
MINNEAPOLIS (AP) — Pinnacle Airlines says it will move its headquarters to Minneapolis from Memphis, Tenn., by May.
The company employs about 500 people at its main office.
Pinnacle has been reorganizing under bankruptcy protection since last year. When it emerges, it will become part of Delta Air Lines Inc. Pinaccle plans to move into space that Delta has rented but isn't using at Minneapolis-St. Paul International Airport.
Pinnacle expects to fly 81 regional jets for Delta.
The regional airline business has been going through a major shakeout as rising fuel prices make some smaller jets unprofitable. And big airlines like Delta have been putting pressure on the regionals to cut costs.
Copyright 2013 The Associated Press.


text:
- Jan 23:
- Letting the Lot 4 question go before the voters is the right move
- Jan 22:
- Lot 4 petition validated by Estes Park clerk
- Jan 15:
- Lot 4 open space petition awaiting validation
- Lot 4 open space petition awaiting validation
- Jan 9:
- Estes still lacking open space guidelines
- Jan 8:
- Estes Park Medical Center CEO happy with trustee vote
- Jan 7:
- Estes Park trustees approve Lot 4 contract
- Jan 2:
- Lot 4 goes back before Estes trustees
- Dec 26:
- Lot 4 question moves forward as Estes Park groups turns in petition
Gov. John Hickenlooper has a vision for the future of Colorado.
He wants the state to become known not just as a healthy state with lots of great outdoor recreational opportunities, but as the healthiest state.
The governor kicked off that effort last May when he unveiled his working plan for health: "The State of Health: Colorado's Commitment to Become the Healthiest State."
A key part of that plan is promoting prevention and wellness. Some questioned at that time why was he so driven to make this a priority.
"What's wrong with wanting to make people healthy?" the governor asked with a chuckle during a telephone interview late last Friday.
The governor spoke with the Trail-Gazette to expound on his initiative and explain why the proposed partnership between the Stanley Hotel, Anschutz Medical Center, and Estes Park Medical Center for a world-class wellness center in Estes Park is important for the state and his health program.
Hickenlooper said the idea for Colorado to be the "healthiest state" came from conversations with top business officials.
"I talked to some CEOs and asked them why they had headquarters in Colorado," the governor said. "They said all the outdoor recreation and that Colorado had a very healthy quality of life. That was important to them. That was something that connected with them."
Hickenlooper said that's when he began to envision Colorado as the "healthiest" state.
"And, we already had a head-start," he added.
In late May or early June, the Colorado Office of Economic Development and International Trade arranged a meeting between Hickenlooper and Stanley Hotel owner John Cullen. The purpose of the meeting was for Cullen to reveal his plans to build world-class wellness centers in Estes Park, Colorado Springs and Telluride.
Hickenlooper liked what he heard.
"He explained that he wanted to build world-class centers to improve health and do that through the Anschutz Medical Center," Hickenlooper said. "Medical tourism; I thought it was a fascinating idea."
Hickenlooper thought the idea of world-class wellness centers in Colorado might someday be perceived in the same light as the Steadman Clinic in Vail or the Mayo Clinic in Minnesota.
"If people really want to change their lifestyle, why not do it in Estes Park, Colorado Springs or Telluride?" the governor said. "He's got great resources and he was willing to put his nickel in it so I encouraged him."
Hickenlooper, who spent Christmas with his family at the Stanley Hotel, said the hotel could be a great magnet for wellness tourists since it has a natural charm that many will find attractive.
"What a great thing (the wellness center) ... with such a beautiful lodge," he said.
Hickenlooper went on to talk about how prevention and wellness could bring other benefits to the state besides tourism. He pointed out it could help reduce the cost of healthcare.
"Over the past 10 years or so, we have seen an 8 to 12 percent increase in medical costs about every year," Hickenlooper said. "With wellness, I think we can slow that down to 6-8 percent."
So, how will the state market its health initiative?
Hickenlooper said the current state budget has about $15 million to market health and wellness. He hopes to get that bumped up to $17 million next year.


text:
Contact Us:
- Centers for Disease Control and Prevention
1600 Clifton Rd
Atlanta, GA 30333
24 Hours/Every Day
- email@example.com
Public Health Assessment
Air Pathway Evaluation,
Isla de Vieques Bombing Range,
Vieques, Puerto Rico
To print this report, please select the "Print Friendly View" option in left hand menu and use your browsers print function or the "Print Page" option on the right side of the page. You may also print individual sections of the report by navigating to a section using the left hand menu and following the same steps above.
August 26, 2003
Prepared by:
Federal Facilities Assessment Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry
Appendix E: ATSDR's Response to Public Comments
ATSDR made an earlier draft of this PHA available, both in Spanish and in English, for public review and comment, starting on November 22, 2002. We distributed the public comment release PHA to more than 200 persons or organizations, and made copies available at record repositories on the island of Vieques and in San Juan, Puerto Rico. An announcement that accompanied the public comment release PHA indicated that ATSDR would accept public comments through February 24, 2003. This 3-month public comment period is longer than the typical 1-month public comment period that ATSDR routinely uses for its PHAs. This appendix quotes every comment that ATSDR received, and presents our responses. All page numbers cited in this section refer to page numbers in the November 22, 2002, public comment release draft.
In addition to making changes to respond to the public comments, ATSDR made several additional revisions to the PHA. We updated our technical analyses based on our review of more recent ambient air monitoring data and meteorological monitoring data, and we incorporated several minor editorial revisions to clarify certain findings. Additionally, we made numerous changes throughout the PHA to reflect the fact that the Navy officially ceased all military training exercises at Vieques as of May 1, 2003.
This PHA now reflects our final conclusions and recommendations for this site, following our careful review and consideration of public comments.
Comment #1:
The following editorial suggestions and clarifications were made:
"Page v, Tables 8 and 9: Change 'Form' to 'From.'"
"Page 5, line 14: Change 'a' to 'at.'"
"Page 5, lines 18-20: Recommend delete last sentence" because military training exercises at Vieques are scheduled to cease in May 2003.
"Page 15, paragraph 3, line 2: Recommend change 'marine' to 'Naval.'"
"Page 18, line 19: Change April 19 to April 20. Exercises did occur on April 19, 1999."
"Page 24, line 11: Change 'D.' to 'G.'"
"Page 44, Section V, Line No. 23. '...no exposures would occur that present a public health hazard' should read '...no exposures would occur that present a public health hazard.'"
Response #1:
Several minor editorial revisions were made in the PHA to address this comment.
Comment #2:
"Recommend replace 'practice bombs' with 'non-explosive ordnance' and replace 'live bombs' with 'explosive ordnance.' Recommend universal change throughout document."
Response #2:
ATSDR recognizes that military personnel and civilians often use different terminology when describing military training exercises. While we try to be sensitive to differences in terminology, we also strive to prepare documents that communicate information in language that the public appreciates and understands. After working with community members on Vieques and reviewing local media accounts of the Navy's activities, ATSDR decided that the public–the intended audience of the PHA–is more familiar with the terms practice bombs and live bombs, rather than the terms non-explosive ordnance and explosive ordnance. Because of this, the terms practice bombs and live bombs are used consistently throughout the PHA. To highlight the different terms used to characterize the exercises, the PHA includes a text box titled "Terminology Used in this PHA to Characterize Military Training Exercises." Because we still believe that practice bombs and live bombs are the most appropriate terms to convey different military training exercises to the public, we have not made any changes in the PHA to respond to this comment.
Comment #3:
"Page 63, line 21: Incorrect statement regarding use of chaff. The use of chaff is prohibited over Vieques as well as the adjoining Warning and Restricted Areas (W-428 and R-1704)."
Response #3:
The comment addresses a sentence in the public comment release PHA in which ATSDR recommended actions to characterize potential exposures to chaff during future military training exercises. Since releasing the public comment draft, however, the Navy has ceased its military training exercises at Vieques altogether and there is no longer a need to characterize potential future exposures to chaff at the island. As a result, ATSDR has deleted the sentence of concern from the final version of the PHA.
Comment #4:
"This is a well written document that provides detailed information in regards to the evaluation of the air exposure pathway. The findings and recommendations from ATSDR are clearly stated and fully justified. Although all studies are not complete, the available environmental data is of sufficient quality for ATSDR to make a valid public health assessment for the air exposure pathway at this time."
Response #4:
No changes were made in the PHA to address this comment.
Comment #5:
"The section describing Demographics on page 12 would be more complete in regards to the census data shown in Table 1, if the increasing elderly population, decreasing number of children, and decreasing number of women of child-bearing age were mentioned."
Response #5:
ATSDR revised the section on Demographics (Section III.B) to indicate the population trends mentioned in the comment. We also added statements comparing demographic data for Vieques to that for the entire Commonwealth of Puerto Rico.
Comment #6:
"The information in Tables 4, 5, and 6 would be more descriptive if standard deviations or standard errors of the mean for the average concentrations as well as the number of samples were provided in each table, as appropriate."
Response #6:
ATSDR made several changes to the tables in question. First, we updated the tables based on the latest ambient air sampling data available from PREQB. The tables now reflect sampling data PREQB has reported to EPA through March 2003. Second, we included standard deviations in Table 6, which summarizes the particulate sampling that PREQB has conducted to date. We did not include standard deviations in Tables 4 and 5, as these tables present estimated exposure concentrations for a highly ideal scenario. Specifically, the scenario assumes that all airborne contaminants in the residential areas of Vieques originate from the bombing range. This scenario was used to illustrate the upper-bound impacts that the military training exercises using practice bombs might have had on air quality at the island. ATSDR does not believe that presenting standard deviations for upper-bound estimates adds any additional insights into this evaluation.
Comment #7:
"The data used in describing the air contaminants are the ones collected by PREQB since 2000. In relation with the other reviews of air sampling studies, ATSDR believes that the quality is questionable."
Response #7:
Appendix C presents ATSDR's review of air sampling studies that have been conducted to date at Vieques. The comment implies that we had questions about the quality of PREQB's particulate sampling data collected since 2000. To the contrary, Appendix C.1 states: "For several reasons, ATSDR believes the data collected by PREQB are of a known and high quality." To respond to this comment, we have added several statements to the main body of the report that echo this finding.
For reference, Appendix C reviews two additional sampling studies conducted by PREQB during the 1970s (see Sections C.4 and C.5). We concluded that the quality of these studies cannot be assessed, because original documentation for these sampling studies could not be located.
Comment #8:
"No data is available related to PM2.5. 'EPA proposed regulating ambient air concentrations of PM2.5 in 1997 based on evidence linking inhalation of fine particles to adverse health effects in children and other sensitive populations.'"
Response #8:
The comment correctly notes that EPA has recently placed a greater emphasis on measuring the levels of fine particulate matter (or PM2.5) in the air that people breathe, due to the findings of health studies linking exposure to these particles and adverse health effects. ATSDR does not necessarily view the lack of PM2.5 sampling data as a shortcoming in this evaluation, based on the results of our modeling analysis, which found that the military training exercises at Vieques using live bombs had only minimal air quality impacts in the residential areas of the island. Specifically, the modeling indicated that the exercises using live bombs caused annual average PM10 concentrations and maximum 24-hour average PM10 concentrations to increase by 0.04 µg/m3 and 10.2 µg/m3, respectively. Even if we make the worst-case assumption that all particulate matter emitted from the exercises was in the form of fine particulates, such incremental increases in PM2.5 are still considerably lower than EPA's current health-based standards (15 µg/m3 for annual average, and 65 µg/m3 for 24-hour average concentrations). Therefore, the modeling data indicate that air emissions of particulate matter, whether coarse or fine, from the military training exercises were not at levels of health concern for the residential areas of Vieques. We have added a few sentences to Section V.C of the PHA to explain why we think that ambient air concentrations of fine particulates were not of health concern.
Comment #9:
"The air sampling does not specify the time intervals of the readings (5 min., 10 min.,?)."
Response #9:
Appendix C of the public comment release of the PHA presents a detailed summary of the ambient air sampling studies previously conducted at Vieques. The appendix indicates that PREQB has been collecting 24-hour average air samples for particulate matter at Vieques in its most recent sampling efforts. This averaging time is entirely appropriate for characterizing air quality impacts for particulate matter and is routinely used at monitoring stations throughout the United States. Further, this averaging time is the basis of EPA's health-based standards for particulate matter. We have added text to the main body of the report noting the averaging times for PREQB's air sampling.
Comment #10:
"The model used by ATSDR to study the air quality does not specify the emissions punctually and the meteorological characteristics. This is due to lack of information and working with proxy. This makes the model weak due to lack of standards."
Response #10:
ATSDR considered many different approaches for how to model air emissions from the military training exercises. The comment correctly states that our modeling analysis did not account for the specific time of day and day of the year on which each detonation occurred at the bombing range. This fact does not make the modeling "weak," as the comment suggests. To the contrary, our modeling approach accounts for realistic worst case scenarios, as follows:
- We estimated maximum 24-hour average concentrations by reviewing range utilization statistics and meteorological data to identify the day with the most intense level of bombing activity and the day with the least favorable meteorological conditions (i.e., the conditions that would cause the highest levels of air pollution in the residential parts of the island). We assumed that the highest level of bombing activity occurred on the day with the least favorable meteorological conditions. Even when we added the air quality impacts from such an upper-bound scenario to the highest background concentrations recorded to date, the exposure levels predicted for the residential population were still considerably lower than levels of health concern. If we had modeled "the emissions punctually," as the comment suggests, we would have predicted lower air quality impacts than what is currently documented in the PHA.
- We estimated annual average concentrations by assuming that military training exercises, over the course of a year, did not preferentially occur during any specific meteorological conditions. This approach is sensible, given that the Navy scheduled the dates of its training exercises months in advance. A modeling approach that considered "emissions punctually" would likely generate only marginally different answers. However, marginal differences in the modeling predictions would not change our overall conclusions, given that the estimated annual average concentrations were orders of magnitude lower than levels of health concern.
Overall, we believe our modeling analysis was scientifically sound and provided reasonable upper-bound estimates of air quality impacts. We have not made any changes in the PHA in response to this comment.
Comment #11:
"ATSDR (page 47) points out the following observation: 'sources other than those related to Navy training exercises contribute to actual ambient air concentrations of metals during military training exercises.' If this is true, why hasn't ATSDR evaluated this situation?"
Response #11:
The PHA was prepared to address a specific community concern about potential air quality impacts from the Navy's military training exercises at Vieques. Accordingly, the PHA appropriately focuses on this emissions source. When evaluating air exposures, however, ATSDR recognizes that releases from numerous emissions sources contribute to exposure. Unfortunately, a detailed emission inventory is not available for Vieques. However, ATSDR implicitly evaluated the contributions from other sources in our review of PREQB's ambient air monitoring data for particulate matter. Those data reflect the contributions from all local sources and show that residents are not being exposed to particulate matter at levels of health concern.
Comment #12:
"Dr. Massol in the 'Ecological assessment of heavy metals in Vieques, Puerto Rico' found: 'excessive levels of Pb and Cd were found in plant species of agricultural production such as squash, chili pepper, pigeon peas, pineapple and yucca; only the plants of guamá and mango trees demonstrated acceptable levels for these toxics. The most affected species were those with shallow root systems, such as chili peppers, pigeon peas, squash and pasture grass. This is consistent with the thesis that heavy metals might have been deposited in the civilian area through air dispersion by windblown dust from the bombing zone' and 'based on ATSDR methodology, our studies found that five seeds of the pigeon pea will provide enough Cd to surpass the oral health guideline for children.' This data is not in accordance with ATSDR findings based en la Wind Rose from US Naval Station Roosevelt Roads."
Response #12:
The comment refers to a study that evaluated levels of contamination reported for plant tissues in the residential areas of Vieques. ATSDR reviewed the original report (Massol and Diaz 2001), which is a study conducted by researchers from Puerto Rico. The study, which has not been published in the peer-reviewed literature, reports elevated levels of several metals in the tissues of several plant species collected from the residential areas of Vieques.
ATSDR critically reviewed this study when preparing our PHAs. Given the implications of the study, we asked Dr. Rufus Cheney to review the study as well (Cheney 2002); Dr. Cheney is a premier research agronomist with the U.S. Department of Agriculture who has dedicated much of his professional career to examining plant uptake of environmental contaminants. Both ATSDR and Dr. Cheney have expressed serious concerns about the quality of the data reported in the plant tissue sampling study cited in the comment. At the heart of the concern is the fact that Dr. Massol's study presents no information on quality assurance (QA) and quality control (QC) procedures. Laboratories that routinely collect and analyze plant tissue samples typically report numerous QA/QC findings to convince the reader that the sampling results are valid and free from bias. Examples of such findings include results from duplicate samples and analyses of Standard Reference Materials. Without any such information documented in Massol's study, ATSDR can not be assured that the analytical methods have been applied correctly, and Dr. Cheney concluded that the study is "of suspect quality and all concerns based on these analyses must be rejected until proper analysis of appropriate samples are available."
In addition to our concerns about the lack of QA/QC information, ATSDR has serious questions about the underlying premise of the study–that air contaminants from the bombing range are reportedly being found in plant tissues more than 9 miles downwind from the source. The study does not clearly indicate the mechanisms by which the reported uptake is occurring (i.e., by root uptake or by deposition of particles onto plant surfaces). Researchers investigating these mechanisms would typically collect soil samples to investigate the matter further; yet Dr. Massol's study apparently did not include a soil sampling component, making the results (if one assumes they are correct) difficult to interpret. More importantly, ATSDR emphasizes that the available soil sampling data provide no evidence of contaminants from the bombing range accumulating in the soils at locations far from the source (ATSDR 2002). The fact that there is limited evidence of considerable environmental impacts in the residential area of Vieques raises further questions about the validity of the data in Massol's study.
Comment #13:
"The study shows significant limitations such as: time of sampling, data related to PM2.5, information about other sources of pollution."
Response #13:
The comment identifies three potential limitations in the PHA. Our responses to comments #8 and #11 address the topics of PM2.5 and other sources of pollution on Vieques. As those responses indicate, we view neither aspect as a significant limitation in the PHA.
Regarding the time of sampling, ATSDR based its conclusions on all of the information we gathered for this site, which included valid, representative sampling data from July 2000 through the present. Although we would have preferred to base conclusions for the time when the Navy used live bombs on ambient air sampling data, the fact remains that limited data are available for that time frame. The data we did obtain from the 1970s showed no evidence of unusually elevated levels of air pollution, but those data are of questionable quality, because original documentation for PREQB's sampling studies is not available. While the absence of sampling data is unfortunate, it does not preclude us from making scientifically defensible conclusions about this site. In fact, ATSDR's own guidance manual indicates that modeling results should be considered in cases where sampling data are incomplete (ATSDR 1992). Therefore, the approach we took–using modeling analyses to estimate exposures for times when samples were not collected–is not only scientifically defensible, but consistent with our internal guidance.
Comment #14:
"The isolated form of the presentation does not allow straightforward interpretation of the problem. It is important to present all the pathways integrated in the same health circle, to know better how is the integration of all information."
Response #14:
Early in the public health assessment process for this site, ATSDR decided that releasing a series of documents that address individual exposure pathways would provide the most timely release of information to the petitioner. We are currently compiling a summary document that integrates the findings from all of our previous PHAs (ATSDR 2001, 2003a, 2003b).
Comment #15:
"Risk factor evaluation and their implications is the methodology that should be used in the pathways and the study is limited in that way."
Response #15:
ATSDR evaluated the public health implications of exposure using well-established methodologies outlined in our Public Health Assessment Guidance Manual (ATSDR 1992). This approach was developed and reviewed by highly experienced environmental health professionals not only from ATSDR, but also from several other public health and environmental agencies. The approach includes several measures to ensure that health assessors make defensible conclusions that are protective of public health. We do not believe following the approaches described in our Public Health Assessment Guidance Manual is a limitation for this PHA.
While we acknowledge that other approaches are available to assess the health implications of potential exposures, it is important to remember that the estimated air quality impacts from the military training exercises at Vieques were so low that even highly sensitive air sampling devices likely would not have been able to measure them (e.g., see Tables 8 and 9). We doubt that any sensible health assessment approach would find legitimate public health concerns based on the minimal exposure levels that we predicted.
Comment #16:
"ATSDR states that the PHA was prepared pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 104(i)(6) and in accordance with their implementing regulations, found in 42 CFR Part 90. These regulations clearly specify that when information necessary to perform a health assessment is not readily available from other sources, ATSDR may arrange for sampling or additional data gathering. (See 42 CFR Part 90.8c.) ATSDR did not follow its own implementing regulations by not gathering any additional environmental data and relying solely on insufficient information and statistics. Public health implications cannot be determined if there is insufficient information on concentrations, frequency and duration of exposure."
Response #16:
ATSDR strongly disagrees with this comment. When preparing the Vieques PHAs, we made extensive efforts to gather all existing environmental and health data from multiple parties, including PREQB, PRDOH, EPA, several researchers from universities and private organizations in Puerto Rico, and the Navy and its contractors. Additionally, we conducted an extensive fish tissue sampling study, helped organize an expert panel committee among international experts in cardiology and epidemiology, performed a rigorous air dispersion modeling analysis, and initiated air sampling events. We believe that the existing information gathered and supplemental information we produced were sufficient to reach scientifically defensible public health conclusions. Additional information on the available data follows:
- For exposures from July 2000 to the present, we based our conclusions largely on the results of several hundred valid particulate air samples that PREQB collected in the residential areas of Vieques. These samples measured the air that residents actually breathed. To date, not a single sample has revealed particulate matter levels of health concern.
- For exposures prior to July 2000, the available sampling data are more limited. We did identify three studies that measured air pollution levels during the time when the Navy used live bombs during military training exercises. The air concentrations reported in these studies are clearly not at levels of health concern. However, the quality of the sampling data from these studies is not known.
The comment suggests that we should have conducted sampling to characterize exposures during this time frame. Practically speaking, this was impossible: the Navy had already stopped all live bombing exercises at Vieques before ATSDR was petitioned to evaluate this site. However, we remained committed to evaluate past exposures and conducted a rigorous dispersion modeling analysis. This was the most feasible and defensible approach to evaluate past exposures.
Overall, ATSDR strongly believes the PHA is based on the best available information on environmental contamination levels at Vieques. We gathered as much existing data as we could find and used defensible modeling techniques to fill data gaps, and none of the public comments identifies available data sets that were not considered.
Comment #17:
"Another major deficiency with the PHA is in the analysis of past levels of air contamination. Air samples that were collected on Vieques when Navy used live bombs are poorly documented; therefore, no reliable measurements of past levels of air contamination are available."
Response #17:
ATSDR used standard, defensible approaches to evaluate past levels of air contamination. For the Vieques site, we were asked to evaluate an emissions source that was no longer operating (i.e., military training exercises using live bombs). In cases such as this, we first try to gather existing sampling data and then use other approaches, as necessary, to fill data gaps. Although it is unfortunate that more sampling data were not collected at Vieques before ATSDR was involved with the site, we do not view the lack of extensive sampling data as a "major deficiency." Rather, our modeling results and the limited available sampling data both suggest that the Vieques residents were not exposed to air pollution at levels known to be associated with adverse health effects.
Comment #18:
"Also, the PHA distinguishes between times of activity (decades) for purposes of evaluating exposure. Archive research conducted by ATSDR could not produce an accurate date of the first air-to-ground military exercise in Vieques. On page 16 of the PHA, the Agency states that 'none of the reports ATSDR has obtained documents exactly when first air-to-ground exercises took place on Vieques.' Therefore, exposure evaluation based on this research is also inaccurate because ATSDR cannot conclusively determine whether harmful effects occur if a determination or assumption regarding contacts with hazardous substances is based on this information."
Response #18:
The comment correctly points out that we were unable to determine the first date on which air-to-ground military exercises occurred on Vieques, but the comment incorrectly infers that this is a critical limitation in the PHA. Our health conclusions for the time when the Navy used live bombs at Vieques are based on the outputs of our modeling analysis (i.e., the concentrations in Tables 8 and 9). These concentrations are our estimates of chronic exposure levels, based on range utilization statistics for the time frame when the Navy's live bombing exercises at Vieques were most intense. We believe these concentrations are reasonable estimates of exposures between the early 1970s and 1999, which is the time frame with the most extensive use of the bombing range (see Section III.D).
For years prior to the early 1970s, we cannot make precise estimates of exposure concentrations. However, multiple accounts we reviewed indicate that the frequency and intensity of military training exercises at Vieques was much lower prior to the early 1970s than during the time frame we considered for the modeling, primarily because the Navy previously conducted much of its training exercises on the island of Culebra. Because training exercises were far less frequent prior to the early 1970s, it is reasonable to conclude that air emissions and any associated exposures prior to the 1970s were notably lower than those that occurred for the time frame we evaluated. In other words, exposures that occurred prior to the early 1970s were likely much less than the exposures we predicted in our modeling (i.e., the concentrations in Tables 8 and 9), and therefore also were far lower than levels of health concern. Therefore, while we cannot pinpoint the exact date when potential exposures might have begun, we are confident that the magnitude of potential exposures was considerably lower than levels associated with adverse health effects.
Comment #19:
"If air-to-ground bombing accounts for the greatest proportion of high explosives used at Vieques, and none of the reports ATSDR has obtained documents exactly when the first air-to-ground exercises took place on Vieques, then ATSDR cannot present an accurate assessment of potential risks to human health pursuant to CERCLA 104(i)(6). On a similar note: complete statistics of range use are only available for exercises conducted between 1983 and 1999. Statistics for exercises conducted by foreign countries are also unavailable. If the type of ordnance used during military training exercises is one of the most important indicators of the amount of contaminants released into the air, and these statistics are not available for a considerable period of time, then exposure evaluation is in effect deficient."
Response #19:
The comment correctly indicates that statistics on the amount of ordnance used during military training exercises is a critical input to the air exposure pathway evaluation; however, ATSDR does not agree that the available information are insufficient for performing a public health assessment. Following is ATSDR's response to specific issues raised in the comment:
- Reliance on data from 1983 to 1999. The comment correctly states that the air modeling analysis in our public comment release PHA is based on a review of range utilization statistics from 1983 to 1999. ATSDR has since consulted reports that document range utilization statistics back to 1974 (TAMS 1979; Ecology and Environment 1986). The statistics ATSDR has obtained for earlier years are consistent with the statistics used in our modeling analysis in the public comment release PHA. For instance, the annual average range utilization statistics for 1974-1998 indicate that, on average, 441 tons of high explosives were used at Vieques per year. ATSDR's modeling analysis examines air quality impacts for a base year in which 458 tons of high explosives were used. Therefore, ATSDR's modeling analysis likely does not systematically understate annual average concentrations over the long term. Several statements in these reports (TAMS 1979; Ecology and Environment 1986) also confirm that the range utilization statistics we considered for evaluating short-term exposures are representative of activities that occurred at Vieques in the 1970s and 1980s.
- Date of the first exercise. This comment also suggests that our lack of knowledge of the exact date when air-to-ground bombing commenced is a critical data gap in the PHA. ATSDR again disagrees. As our response to the previous comment indicates, we are confident that the magnitude of potential exposures prior to the early 1970s was considerably lower than levels predicted by our models, even though we cannot pinpoint the exact data when air-to-ground exercises began. ATSDR is confident in this statement because our modeling analysis is based on the time frame when air-to-ground bombing activity was most intense. Finally, ATSDR notes that none of the reports we reviewed or public comments we received indicate, or even suggest, that emissions from the Navy's military training exercises at Vieques prior to the early 1970s were greater than the emissions considered in our modeling analysis. For these reasons, ATSDR considers the lack of information on the first day of bombing activity to have virtually no bearing on the conclusions of this PHA.
- Ordnance used by foreign countries. The comment suggests that our evaluation did not consider ordnance used by foreign countries at Vieques. The reports ATSDR recently accessed provide some perspective on this matter. These reports note, for example, that Germany, Great Britain, Canada, and Holland all have conducted ship-to-shore exercises at Vieques in the past. One report lists the specific ordnance types that these countries used, and several of these ordnance types are also accounted for in the range utilization statistics tabulated in the reports (e.g., TAMS 1979). Therefore, the past reports suggest, though do not clearly state, that the range utilization statistics do include some portion of the ordnance used by foreign countries. Furthermore, the reports state that foreign ships previously accounted for only 8% of the days with training exercises (TAMS 1979). Therefore, even if the statistics do not include every ordnance item used by foreign countries, this omission would account for a very small proportion of the range utilization statistics and would not have a strong influence on our overall predictions, especially considering that the estimated air quality impacts for most contaminants were orders of magnitude lower than levels of potential health concern.
In summary, ATSDR considered a large volume of range utilization statistics for the years 1983-1998 when preparing the public comment release PHA, and we have since acquired supplemental data that document ordnance usage from the early 1970s through the early 1980s. All data we have compiled to date indicate that the ordnance usage rates used in our modeling analysis are representative of actual conditions at Vieques during the years when military training exercises occurred most frequently. ATSDR believes that the available data are sufficient to make public health conclusions.
Comment #20:
"On page 26, the PHA says that contaminants will disperse greatly over the 7.9 miles that separate the LIA and residential areas. These contaminants including heavy metals will then accumulate in food items such as vegetables and fruits. In fact, recent studies indicate that high levels of metals are present in plant tissues examined from hills bordering Navy property (Camp Garcia) in Eastern Vieques. By addressing primarily on the issue of direct inhalation exposure to air contaminants, the PHA is limiting the exposure pathway analysis by not adequately considering indirect exposure (accumulation on other media or bio-accumulation) to air contaminants."
Response #20:
The comment raises the possibility of Vieques residents being indirectly exposed to air contaminants (i.e., the residents possibly being exposed to contaminants that settle from the air onto soils and plants). ATSDR considered this possibility in our other PHAs, which examined levels of contamination in groundwater, soil, fish, and shellfish (ATSDR 2001, 2003a, 2003b). We have yet to see any evidence of indirect exposure to air contaminants occurring in appreciable amounts. Moreover, as our response to Comment #12 discusses in far greater detail, we have not seen any reliable evidence of heavy metals accumulating in plant tissues in the residential areas of Vieques, as the comment suggests. To address the general concern regarding consideration of exposures to contaminants in multiple media, we are currently preparing a brief summary report that presents our final evaluation of contamination levels in all environmental media we have studied to date. We expect to release the summary report before the end of 2003.
Comment #21:
"A cumulative effect should be considered. The National Ambient Air Quality Standard (NAAQS) does not specify if the parameters are for one event or for years of exposure. Even though the data available does not exceed the NAAQS, it should be accounted the fact that the Vieques population has been exposed to these concentrations for many years."
Response #21:
The comment suggests that the PHA does not consider the possibility of effects resulting from many years of exposure. ATSDR disagrees. When evaluating the public health implications of exposure to air pollutants, we considered both chronic and acute exposure scenarios. None of the concentrations we estimated were at levels that would raise concern for exposure, whether over the short term or the long term. In fact, the estimated concentrations for the majority of pollutants were orders of magnitude lower than levels of health concern.
When mentioning the NAAQS, the comment specifically addresses our interpretation of particulate matter levels at Vieques. In response, ATSDR notes that all measured and modeled data compiled to date quite clearly indicate that ambient air concentrations of particulate matter at Vieques have been considerably lower than levels of health concern. Moreover, the concentrations are not unusually higher or lower than what we would expect to see for communities with similar population levels. We do not believe that prolonged exposure to the particulate matter concentrations typically observed at Vieques (and at locations throughout the United States) should be viewed as a public health hazard.
Comment #22:
"A comprehensive study that includes all types of airborne material that could affect the Vieques community should be analyzed. Taking into consideration, all together, PM10, TSP, PM2.5, metals, and explosives. The breathable airs received by the community members include a mix of all the contaminants present."
Response #22:
The comment suggests that a comprehensive study considering a wide range of contaminants should be conducted. We believe our PHA was such a study. For the last 3 years, we have evaluated the air quality impacts of nearly 100 contaminants that the military training exercises likely released to the air. The estimated air concentrations for most every contaminant was so low that even highly sensitive air sampling devices would likely not have been able to measure them. These evaluations have shown that the residents of Vieques were not exposed to contaminants from the military training exercises at levels that are associated with adverse health effects. We do not believe conducting a supplemental study is warranted.
Comment #23:
"A detailed accounting of all munitions and management activities at the Bombing Range (LIA), Eastern Maneuver Area (EMA) and Atlantic Fleet Weapons Training Facility (AFWTF) must be provided. This historical assessment should also include area of training activities that occurred at non-range locations. This information could reduce the travel distance for some contaminants. The assumption that the main concentration of contaminants has to travel more than 7.9 miles is based on actual operations not on the whole history of the facility."
Response #23:
When gathering information about past military training exercises at Vieques, the one concern repeatedly communicated to ATSDR was regarding inhalation exposures to air emissions from the air-to-ground bombing exercises. Accordingly, we focused on characterizing air emissions from the time frame with the Navy's most extensive use of the bombing range on Vieques. For this time frame, we estimated emissions and air quality impacts based on a large volume of the munitions and management activities at the bombing range: annual range utilization statistics from 1983 through 1999, daily summaries from a 6-year time frame, and a highly detailed inventory for 1998. We believe these statistics form an adequate basis for characterizing air quality impacts for the years when military training exercises were most frequent and intense.
In the PHA, we acknowledge that limited information is available on the exact quantities of munitions used between 1941 and the early 1970s. However, numerous site documents we reviewed report that the air-to-ground bombing activity prior to the early 1970s was far more intense on the island of Culebra than on the island of Vieques. Because the frequency and intensity of air-to-ground bombing on Vieques increased during the 1970s, it is reasonable to assume that the air quality impacts and any associated exposures prior to the early 1970s were lower than the concentrations we predicted in our models. In other words, the concentrations we predicted in the modeling (for years 1970s through 1999) are upper-bound estimates of air quality impacts for earlier years.
When preparing the PHA, we considered the fact that some training exercises have been conducted in areas outside the Live Impact Area. In recent years, for example, the Navy operated a small arms firing range in the Eastern Maneuver Area. However, the air emissions associated with such operations are truly minimal when compared to those that occur as a result of the air-to-ground bombing, and the shorter travel distance for the small arms firing range has limited effect on overall estimates of air quality impacts. Although other training activities have also occurred at locations outside of the Live Impact Area, these activities were limited in scope and duration and generally involved dramatically lower levels of high explosives. Consequently, the air quality impacts of such activities that occurred outside the Live Impact Area are believed to be limited.
Comment #24:
"A comprehensive chemical composition must be determined for each type of munitions. This is to include explosives, propellants, and pyrotechnics. The chemicals, firing by-product compounds, and breakdown product compounds cited in the report must then be compared to the health-based standards."
Response #24:
ATSDR's modeling analysis is based on a highly detailed inventory of the munitions the Navy used at the Live Impact Area during a representative year of activities. We considered statistics on the total amount of different types of ordnance used and composition data for both the ordnance casings and high-explosive content. The inventory included the entire range of ordnance used in air-to-ground, ship-to-ground, and land-based exercises. When estimating emissions, we considered nearly 100 different contaminants that could be released to the air, including chemicals in the high explosive charges, by-products of the explosions, and metals from the casings. We compared the estimated ambient air concentrations to health-based standards and health-based comparison values, just as the comment suggests.
Comment #25:
"Knowing that the US Navy has been using the LIA for more than 50 years, and having already established that wind speed and direction, munitions constituents and activities characteristics play an important role in the dispersion of chemical constituents in the waste, how is this represented in the average ambient air concentration number?"
Response #25:
The measured and modeled ambient air concentrations both reflect actual wind speeds and wind directions. Specifically, our modeling is based on meteorological data collected from US Naval Station Roosevelt Roads, which suggests that winds in the area blow from east to west approximately 75% of the time. The concentrations we estimated, however, also reflect the large distance that separates the Live Impact Area from the residential area of Vieques. Our modeling found, for instance, that chemicals emitted from the Navy's military training exercises dispersed to extremely low levels over the 7.9 miles that separate the emissions source from the nearest residential location. Therefore, even though the winds in the area primarily blew emissions from the Live Impact Area toward residents (a fact that we explicitly accounted for in our modeling), a more important determinant of the air quality impacts is the distance that separates the emissions source from the receptors.
Comment #26:
"Does ATSDR have evidence that the process by which multiplying the concentrations from soil samples by the 'average' of PM10 or TSP is a conservative or even real approach?"
Response #26:
In the PHA, ATSDR estimated the highest possible ambient air concentration of metals that would have resulted if the only source of pollution on Vieques was wind-blown dust from the Live Impact Area. In this highly ideal scenario, we estimated concentrations of metals by multiplying the measured particulate matter levels by the amounts of levels found in soils at the Live Impact Area. The results of this calculation were used only to demonstrate that it is not possible for the one emissions source considered (i.e., wind-blown dust from the Live Impact Area) to cause air pollution to reach levels of health concern. This is an entirely defensible approach to evaluate the potential contributions from this one source.
We used the estimated concentrations to evaluate this one emissions source. The calculation approach, as stated above, represents a highly ideal scenario and the concentrations we estimated may not represent actual air pollution levels. If the air contamination levels at Vieques are found to be higher than the levels we estimated, then we would investigate the issue further. The most logical explanation for why observed levels would be higher than what we estimates would be that other emissions sources at Vieques are contributing to air pollution. ATSDR will evaluate this issue further if we receive a detailed account of PREQB's air sampling results for metals (see our response to the following comment).
Comment #27:
"ATSDR should re-evaluate the conclusions regarding the concentrations and presence of metals once PREQB supplies the samples analysis."
Response #27:
PREQB has been collecting particulate samples at Vieques since July 2000 and analyzing many of these samples for concentrations of metals. ATSDR previously tried to obtain the metals sampling results from PREQB (see Appendix C.1 of the public comment release PHA); however, PREQB did not release the sampling results. ATSDR will review the health implications of the sampling data once PREQB makes the raw data and associated quality assurance information publicly available.
Comment #28:
"When will ATSDR have a complete health assessment including all the studies made in Vieques?"
Response #28:
ATSDR is currently preparing a document that summarizes our complete findings on exposures to contaminants in drinking water, soil, air, fish, and shellfish. That document should be available before the end of this calendar year.
Comment #29:
"As said by ATSDR, the cancer registry will be analyzed, but also the health history including asthma episodes and the heavy metals concentrations in the blood of Vieques residents should be researched and studied."
Response #29:
ATSDR remains committed to evaluating health and environmental information that is released relevant to Vieques. The cancer registry has not yet been officially published, nor are we aware of official publications on the prevalence of asthma episodes among island residents. Regarding concentrations of heavy metals in the blood of Vieques residents, ATSDR made efforts to conduct an exposure investigation to address this exact issue back in 2001. We allocated funding and conducted extensive planning to collect hair, blood, and urine samples from the residents of Vieques. Further, we solicited the support and assistance of several Vieques physicians. However, the physicians expressed reservation about whether the results will be reflective of actual exposures and were unwilling to proceed. While the offer to collect hair, blood, and urine samples is still available, the project has been indefinitely postponed until the physicians are willing to assist. We will be happy to review results of any relevant and thoroughly documented health studies that are published for the island.
Comment #30:
"Page 5, Section I: What is the particle size and specific composition of chaff? Under what category will it fall (TSP, PM10, metals, or PM2.5)?"
Response #30:
As the public comment release PHA indicates, chaff fibers are typically 25 microns (µm) thick and between 1 and 2 centimeters long. After being released from aircraft, the chaff fibers might break into smaller sizes before reaching the Earth's surface. In its health evaluation of chaff, ATSDR assumed that all airborne chaff fibers that fall to the ground are small enough to be completely respirable. This assumption caused us to overestimate potential exposures, because some portion of airborne chaff is likely too large to be respirable. Regarding chemical composition, chaff is aluminum-coated fiber glass fibers, and the primary components are aluminum and silicon oxides.
Comment #31:
"Page 9, Section III, Line 22. 'Vieques is several miles removed from sources of air pollution on any other island in the Caribbean Sea.' Even though there is a significant space separating the other islands this should not be a determining factor. Africa is considerably farther and the 'African dust storm' still affects Viequenses and Puerto Ricans."
Response #31:
Our primary goal when preparing the PHA was to respond to the concerns of the petitioner and community members. These concerns focused almost entirely on air emissions from the military training exercises. Accordingly, our PHA focused on this source of air emissions. However, we implicitly considered the results from other sources as well, by basing most of our conclusions on the results from ambient air monitoring data. The monitoring data reflect the contributions from all nearby sources, including those associated with the military training exercises and those found on other islands in the Caribbean Sea. PREQB's monitoring data quite clearly show that the combined effect of all emissions sources on and near Vieques does not cause concentrations of particulate matter to reach levels of health concern. Therefore, we do not believe that air emissions sources on other islands in the Caribbean have notable effects on air quality at Vieques.
Comment #32:
"Page 11, Section III, Line 24. 'The overwhelming majority of ordnance impacts the LIA, but some bombs and surface . . . have landed in the waters.' Taking into consideration that for many years some targets in the LIA were in the water, and the fact that the Eastern Tip of Vieques is very narrow, the word some should be replaced by the word several of for a more meaningful word."
Response #32:
The public comment release PHA states that "some bombs and surface fire projectiles have landed in the waters near the LIA." We believe this description is correct and appropriate, especially given that there are no detailed accounts of the exact percentage of ordnance that has landed in the waters, and no changes have been made in the PHA in response to this comment. Moreover, it is worth noting that the percentage of bombs landing in the water (rather than on land) has no bearing on the conclusions drawn in the air pathway PHA, because our air modeling evaluation assumes that every bomb hits the land and explodes upon impact. This modeling approach leads to higher emission rates than actually occurred, because the emissions resulting from bombs landing in the water are lower than those associated with bombs exploding on land.
Comment #33:
"Page 32, Section V, Line 3: '. . . measured in 43 soil samples . . .' When, who, where, and how were these samples taken? What were the QA/QC?"
Response #33:
The soil sampling in question was conducted by Navy contractors in June 2000 (CH2MHILL 2000). In this study, surface soils at the Live Impact Area were sampled from selected targets and from storm drainage areas and other low lying areas. The soils were collected following standard sampling procedures and were analyzed according to EPA Methods 6010, 8330, and E314. Extensive quality assurance and quality control information are available on the sampling data, including results from duplicate samples, matrix spikes, and matrix spike duplicates. Further, the sampling report fully documents critical aspects of the sampling program, including photographs of sampling locations, soil logs, chain-of-custody forms, and data validation narratives. ATSDR critically reviewed the entire soil sampling package and concluded that these soil sampling results are of a known and high quality and can be used to support our public health conclusions.
Comment #34:
"Page 34, Section V, Background Information on Particulate Matter. Following EPA evidence that links inhalation of PM2.5 to an adverse health effect, will ATSDR be conducting air monitoring for PM2.5?"
Response #34:
ATSDR recommends sampling when additional data are needed to make public health conclusions. Unfortunately, there is no sampling we can recommend now that would quantify past exposures. However, as our response to Comment #8 indicates, we do not believe that past exposures to PM2.5 were at levels of health concern. If PM2.5 sampling were to start now, it would characterize current and potential future exposures at Vieques. We do not believe it is necessary to initiate PM2.5 sampling now, primarily because such sampling would not reveal any insights on air contamination levels originating from Navy lands. The primary air emissions source from the Navy lands currently is wind-blown dust, which typically takes the form of TSP and PM10, not PM2.5.
Comment #35:
"Page 38, Section V, Line 9: '. . . metals in wind-blown dust on Vieques do not represent a public hazard.' This conclusion is incorrect since it is already proven that concentrations of arsenic (in an ideal scenario) exceed the health-based comparison numbers."
Response #35:
The comment addresses our conclusion regarding metals in wind-blown dust, particularly our finding regarding arsenic. The comment correctly indicates that the arsenic concentration we estimated in the public comment release PHA was higher than conservative health-based comparison values. However, the comment incorrectly infers that these arsenic levels are a potential health hazard. To the contrary, the PHA points out how one should interpret health-based comparison values: "Ambient air concentrations lower than their corresponding comparison values are generally considered to be safe and not expected to cause harmful health effects, but the opposite is not true: ambient air concentrations greater than comparison values are not necessarily levels of air pollution that could present a possible public health hazard. Rather, chemicals with concentrations higher than comparison values require further evaluation." Therefore, the fact that the estimated arsenic concentration was marginally higher than a health-based comparison value does not suggest that a hazard exists.
We have not changed our conclusion regarding arsenic and view the arsenic levels as not of health concern. Specifically, we concluded "that the estimated concentration is within the range of ambient air levels of arsenic reported for remote areas in the United States and is lower than the ranges reported for rural and urban settings." The comment also notes that our estimated arsenic concentrations represent an ideal scenario, as our response to Comment #26 also indicates. We would have preferred to base this conclusion on PREQB's metals sampling data, but these data were not provided to us. ATSDR will review the health implications of the sampling data once PREQB makes the raw data and associated quality assurance information publicly available.
Comment #36:
"Page 40, Section V, Line 21-23. Were the concentrations of particulate matter compared to the type, quantity, climate during the drop off, and if it was air-to-ground or surface-to-ground activity?"
Response #36:
The comment addresses our evaluation of particulate sampling data collected on days when the Navy conducted military training exercises using practice bombs. ATSDR compared the level of air-to-ground bombing activity on these days with the measured concentrations and found no relationship between the intensity of the bombing activity and the levels of air pollution. We did not conduct multi-variate statistical analyses to examine how other factors (e.g., climate) contribute to the data trends, or absence of trends. We have updated our statistical analyses of air sampling results based on data PREQB has reported up through the beginning of 2003, but these analyses still do not suggest any clear relationship between the intensity of practice bombing exercises and levels of air pollution.
ATSDR notes that we included the statistical analyses of the sampling data in the PHA to offer perspective on whether the practice bombing exercises contributed to the measured concentrations. The bigger picture among the sampling data, however, should not be lost: PREQB has collected more than 400 valid, representative air samples on Vieques since July 2000, and not one sample collected to date has indicated particulate matter levels of health concern. Our conclusions reflect this more important overall trend among the sampling data.
Comment #37:
"Page 50, Section V, Line 17. How can ATSDR use the word 'confident' if the only sampling and study done was to run an ideal model and it is based on 'several assumptions' and 'inherent uncertainties.'"
Response #37:
The comment addresses the terms we used to describe our modeling analysis. We used air dispersion modeling to characterize past exposures at Vieques. The modeling was performed because limited sampling data are available for the time when the Navy conducted military training exercises on Vieques using live bombs. We believe that our modeling analysis not only was rigorous and scientifically defensible, but also served a very useful purpose in filling a data gap.
The comment specifically questions our confidence in the modeling results, given the limitations and uncertainties associated with the analysis. When basing conclusions on modeling analyses, our internal guidance indicates that it is important to acknowledge uncertainties and limitations with fate and transport models, because these models can only estimate exposure conditions (ATSDR 1992). Consistent with this guidance, we have acknowledged that the estimated concentrations might not exactly equal past exposure levels. However, when one critically reviews the assumptions in the modeling analysis, it becomes clear that our modeling analysis offers a reasonable account of past exposures and that we truly can be confident that we have not failed to predict exposures at levels of health concern. Here are more specific reasons why we can have such confidence:
- When predicting emission rates for metals, we assumed that 100% of the metals in the bomb casings and explosive charge become airborne and available for downwind transport. We also assumed that 100% of the metals in the soils ejected during bombing events becomes airborne and available for downwind transport. These assumptions clearly overstate potential exposures, because we know that some fragments from the bomb casings (which contain metals) actually remain on the ground, and are not completely vaporized. Therefore, the emission rate we used for metals is clearly higher than the actual emission rate. Consequently, the air concentrations we predicted for metals also are higher than the actual incremental impacts from the bombing exercises.
- When predicting emission rates for explosives, we assumed that 10% of the explosive chemicals in the bombs becomes airborne and is not destroyed during the exercises, even though available data from the BangBox studies suggest that detonations typically consume more than 99% of the explosive charge. Our approach, therefore, likely overstates potential exposures to explosive chemicals. Moreover, as the PHA notes, even if we had assumed that 90% of the explosives in the bombs were emitted directly to the air (and not destroyed), the potential exposures would still be lower than levels of health concern. In other words, any reasonable estimate of destruction efficiency for the live bombs would not lead to exposure estimates that are at levels of health concern. It is for this reason that we can have confidence that our modeling analysis has not reached an erroneous conclusion.
- When modeling exposures to chemical by-products of explosions, we based emission rates using the OBODM model–the only relevant model published on EPA's Support Center for Regulatory Air Models clearinghouse site. Using the emission factors in the OBODM model, the concentrations we estimated for every chemical by-product of explosions were all at least 1,000 times lower than their corresponding health-based comparison values. Although it is likely that the exposure levels predicted by the model might be slightly higher or slightly lower than the concentrations that actually occurred, we seriously doubt that the model underestimates exposures by more than 3 orders of magnitude, which is why we reported having confidence in the conclusion.
- When modeling exposures to particulate matter, we found that the estimated exposures were lower than levels of health concern. Moreover, we were aware that PREQB conducted two particulate sampling studies on the island in the 1970s, and the Navy conducted its own study. All three studies did not find particulate matter concentrations at levels of health concern. The fact that three separate studies had findings consistent with our modeling gave greater confidence in the modeling results, though we acknowledge in the PHA that detailed documentation of the sampling events is lacking.
In short, for the reasons stated above, we continue to have confidence that our modeling analysis is an adequate basis for reaching public health conclusions, and we do not believe the modeling analysis failed to detect exposure levels of health concern.
Comment #38:
"Page 81, Section VI. Was the roof of some residents sampled? If not, why?"
Response #38:
ATSDR reviewed several information resources to respond to community concerns regarding potential exposures to contaminants that might have settled on rooftops used to collect rain water for drinking water purposes. The consensus reached by multiple environmental and health agencies on this matter is that rain water can be a safe and reliable source of drinking water, provided that good sanitation practices are followed in collecting and treating the water. Our PHA reaches the same conclusion, and we encourage residents who use such rooftop collection systems to follow the good sanitation practices mentioned in the PHA. Following such practices will eliminate, or greatly reduce, potential exposures to contaminants that settle on rooftops from a variety of sources.
Comment #39:
"Page 83, Section VI. Rainfall should be sampled in order to get a better understanding of the quality of the water that will be collected and therefore be able to give better recommendations to the people to use collection systems in Vieques."
Response #39:
ATSDR has no reason to believe that contaminants from the Navy's past military training exercises at Vieques would be found in rainfall at the island. The only mechanism by which contaminants can currently in the rainfall is through wind-blown dust from the Live Impact Area being deposited during rain storms. All sampling data collected to date suggest that the impacts of wind-blown dust from the Live Impact Area on air quality in the residential parts of the island are immeasurably small. As a result, ATSDR does not believe that rainfall sampling is an important public health action for this site.
ATSDR 1992. Public Health Assessment Guidance Manual. Agency for Toxic Substances and Disease Registry. March 1992.
ATSDR 2001. Petitioned Public Health Assessment: Drinking Water Supplies and Groundwater Pathway Evaluation. Isla de Vieques Bombing Range. Agency for Toxic Substances and Disease Registry. October 2001.
ATSDR 2003a. Petitioned Public Health Assessment: Soil Pathway Evaluation. Isla de Vieques Bombing Range. Agency for Toxic Substances and Disease Registry. February 2003.
ATSDR 2003b. Petitioned Public Health Assessment: Fish and Shellfish Evaluation. Isla de Vieques Bombing Range. Agency for Toxic Substances and Disease Registry. To be released in the summer of 2003.
CH2MHILL 2000. Live Impact Area Soil Sampling Report. U.S. Naval Facility. Vieques Island, Puerto Rico. Prepared for the Department of the Navy, Atlantic Division Naval Facilities Engineering Command. Prepared by CH2MHILL. October 2000.
RL Cheney. 2002. Review of Plant Uptake Studies from Vieques. March 5, 2002.
Ecology and Environment 1986. Environmental Assessment of Continued Use of the Atlantic Fleet Weapons Training Facility Inner Range. Vieques, Puerto Rico. Ecology and Environment, Inc. January 1986.
A Massol Deyá and E Díaz. 2001. Toxic metals in the vegetation of the civilian zone of Vieques, Puerto Rico. January 10, 2001.
TAMS 1979. Draft Environmental Impact Statement. Volume II. Continued Use of the Atlantic Fleet Weapons Training Facility Inner Range (Vieques). TAMS Consultants. December 1979.


text:
Play chess online against your friends and a global community of chess players
By signing up, you are indicating that you have
read and agree to the Terms of Service.
No boards to set up, no pieces to lose, just start a game and play chess. We record every move, and you can return to your game whenever it's convenient.
Playing chess online offers a fun alternative to traditional methods of play, such as over-the-board(OTB) play where players sit down together at a board, or 'snail mail' based correspondence chess(CC).
A great way to play chess when at home or at work. Enjoy your games without the pressure of a fast-ticking clock. Games can be started with a wide variaty of time controls to suit everyone, from those who can play multiple times a day to those who can only move at weekends.
If you would like to play more games, no problem, you can play 12 chess games all at once. Subscribers can play as many as they can handle. And you can also play blitz chess between moves.
When you are away from the site, we let you know it's your turn to move by sending an optional move notification email. All emails provide a link so you can jump right back to your waiting game.
If you preter to use our Android app, we can alert you that a game needs your attention right on your phone.
When you want to play chess, we have someone for you to play. At any time. A true global community guarantees games are being started and played 24 hours a day, 365 days a year. So when you want a game, either challenge an active opponent, or create an open invite games, and you will be playing soon after.
Play in chess tournaments, chess ladders and team play. And it's not all about playing games, Time For Chess also has active an chess forum, blogs, chess clubs and study tools.
Stay up-to-date with what is happening in the community and on the site
Of the many forums available, this is for chess and only chess
Browse the millions of games played on this service by move popularity.
Beginners tutorial on the moves of the chess pieces.
An extensive library of chess openings to study.
Searchable grandmaster games archive.
Solve thousands of chess puzzles, or submit your own to challenge the community.
Set a chess board from a board position in Forsyth-Edwards Notation.


text: Smaller devices may be improving in productivity, but desktops still take the cake in many areas. According to a March 2013 report by The NPD Group, a Port Washington, N.Y.-based market research company that provides sales-out data from leading technology distributors, here is a "Top 10" breakdown of the best-selling desktops for March. (The NPD Group's DistributorTrack sales database is comprised primarily of U.S. Global Technology Distribution Council members.)


text:
Game Leaders
Team Stats
Passing Yards
Rushing Yards
Time of Poss.
TACOMA, Wash. – A wild fourth quarter set up an exciting finish but the Puget Sound football team fell just short of a comeback in a 55-42 loss to Lewis & Clark. The Loggers (0-4, 0-1 NWC) were down 19 points with 6:39 left in the game but were able to cut the lead to just six before the Pios (4-0, 1-0 NWC) were able to put the game away.
A six-yard TD strike from Keith Welch to Connor Imel seemed to have the game well in hand for the Pios but the Loggers refused to go quietly. Braden Foley hit four different receivers on a seven play, 77 yard drive down the field that ended with a 19-yard TD pass to Adam Kniffin. It was Foley and Kniffin's third TD connection of the day.
The Loggers then tried an onside kickoff and the ball was pulled out of the pile by Tieler Souza to give the Loggers the ball back. Two minutes later, Ryan Rogers pulled down a tipped pass in the end zone for another Logger touchdown, which cut the lead to six points at 48-42.
Another onside kick was recovered by the Pios and the Logger defense stiffened up to force a 4th-and-9 situation. With the Loggers looking to get the ball back in a hurry to their offense. Welch found Jacob Costantino in a seam for a 32-yard touchdown. Evy VandenEkart intercepted Foley on the Loggers second play on the ensuing drive and the Pios went into victory formation.
A high-scoring fourth quarter provided half of the scoring in the game. The teams combined for 48 points and 400 yards of total offense. The Loggers had 290 yards in the fourth quarter alone with 261 yards coming through the air.
Adam Kniffin had his second 200-yard receiving game of the season. He hauled in 10 catches for 203 yards and three TDs. Foley ended up with 331 yards passing and four TDs while rushing for 35 yards and another touchdown. He also was intercepted twice.
Welch had 325 yards on 24-of-42 passing and also had four TDs. He also ran for 42 yards and three touchdowns. Curtis Shirey led the Pios with 212 rushing yards and found the end zone once on the ground.
The first half was more of a defensive struggle as a late Pio TD gave TD gave the visitors a 21-14 halftime lead. The Logger defense continued to force turnovers in the first half as Nasser Kyobe forced a fumble, which Connor Savage jumped on in the end zone for a touchback, and Joe Cerne brought down his first career interception.
However, Nico Ohland had 129 of his 140 receiving yards in the first half and scored the late TD for a Pio lead. Kniffin's first TD catch and a rushing TD for Kupono Park had given the Loggers a 14-7 lead earlier in the second quarter.
After Foley found Kniffin for a second time in the end zone and a successful two-point conversion from James Korn to Kyobe, the Loggers had a 22-21 lead just minutes into the second half. However, Welch ran for a couple touchdowns to regain the Pio lead, which they would hold the rest of the way. After falling behind 22-21, the Pios outscored the Loggers 27-7 to build the late 19-point lead.
The Loggers conclude their three-game homestand next week when the welcome Pacific into Peyton Field at Baker Stadium for a 1 p.m. kickoff.


text:
Start chatting to our centre now by clicking the button above
How can we help?VIEW OUR 18 PLATE BMWs
Find out more about BMW recalls and how to find out if your car needs to be recalled.
After 24 hours with a new BMW, you won't want to give it back.
BMW xDrive allows you to experience ultimate driving pleasure with over 140 of our BMW models, whatever the weather. Find out how you can benefit from BMW xDrive.
Featuring M xDrive for the first time, the new BMW M5 provides thrilling performance and power alongside superior handling. In the interior, ground breaking innovations offer versatile connections between the driver, car and the outside world.


text:
Morgan Park and South Shore each recorded a homicide in the last week, a RedEye analysis of preliminary police data found.
In Morgan Park, a 48-year-old man was stabbed to death Sunday in the 11400 block of South Rockwell Street, police said.
Morgan Park has logged one homicide so far this year. The Southwest Side community area recorded four homicides last year, according to RedEye data.
In South Shore, a 26-year-old man was fatally shot Saturday in the 7800 block of South Muskegon Avenue, officials said.
South Shore has logged four homicides so far this year. The South Side community area recorded 20 homicides last year, RedEye determined.
Twelve homicides have been logged so far this month. Fifty-two homicides were recorded in March 2012, RedEye data shows.


text:
DailyDirt: Robots For Farming
Robots are perfect for tedious and boring tasks, and they seem to be well-suited for the repetitive labor of farming. More and more robots are getting into the farming industry, with the potential to displace a lot of human labor. It might take some time before robots are growing a significant portion of our food supply, but farming technology could solve a lot of problems (and create a few more labor problems as well). Here are just a few more farming robots that might take over our farms.
- A "Lettuce Bot" made by Blue River Technology can recognize the difference between weeds and budding lettuce. This robot could improve yields for crops without using pesticides, but it would have to be re-trained for each new crop. [url]
- Hydroponic lettuce farms could be automated with indoor fields maintained by robots. Hortiplan is testing a hydroponic farm in Belgium, and hopefully, world hunger can be solved eating lettuce...? [url]
- Remote controlled helicopters can spray herbicides and pesticides more efficiently, and the RMAX helicopter has been used in Japanese rice fields for 20 years. The same mini-helicopter is being tested in a Napa vineyard, after obtaining FAA clearance to operate at a maximum altitude of 20 feet. [url]


text:
- About Us|
- Investor Relations|
- News Center|
- Corporate Governance|
- Working at Franklin Templeton|
- Commitment to Our People|
- College & University Connections|
- Meet Our People|
- Locations|
- Job Search|
- Submit Candidate Profile|
Clicking "Continue" below will take you to an independent site. Information and services provided on this independent site are not reviewed by, guaranteed by, or endorsed by Franklin Templeton or its affiliates. Please keep in mind that this independent site's terms and conditions, privacy and security policies, or other legal information may be different from those of Franklin Templeton's site. Franklin Templeton is not liable for any direct or indirect technical or system issues, consequences, or damages arising from your use of this independent website.