Document 5LDGV23Rkk1rX4MxQqQNyrVqJ

* * "Applied Chemistry, Creative Solutions September 11, 2000 Solutia Inc. 575 Maryville Centre Drive St. Louis, Missouri 63141 RO. Sox 66760 St. Louis, Missouri 63166-6760 Tel 314-674-1000 Mr. Clement J. Welsh, PhD.'/MPH Environmental Health Scientist Agency for Toxic Substances and Disease Registry 1600 Clifton Road, NE Atlanta, Georgia 30333 Re: Supplemental Information Regarding April 26.2000. Comments on the Health Consultation for Monsanto Company. CERCLIS No. ALDQQ4019048 Dear Dr. Welsh: Pursuant to your request, this letter provides additional information in support of the comments of Solutia Inc. on Table 5 and the conclusions based upon Table 5 of the draft Health Consultation for Monsanto Company (Monsanto), dated February 14, 2000. Pertinent parts of Solutia's original comments are presented in italics followed by a discussion of'the facts supporting each comment. I. Subject 1 Subject 1 was reported to be 2 years old at the time ofsampling and the blood level was reported to be 11.1 ppb. Based upon the information provided in the last paragraph on Page 9 and additional information in litigation discovery materials, it appears that this subject was in fact bom in 1949, not 1994; in other words, the last two digits of the birth year appear to have been reversed.. .. Based upon all of the information provided to us in the on-going litigation and the description and other information contained in the Health Consultation, Solutia Inc. believes that "Subject 1" is "Martin Luther Meadows." A copy of the laboratory sheet reporting a level of 11.1 ppb of PCBs for Mr. Meadows is attached as Exhibit 1-A. Mr. Meadows' responses to discovery are DEFENDANT'S EXHIBIT 789 DSW 159451 WATER PCB-SD0000067374 Mr. Clement J. Welsh, Ph.D,, MPH Page 2 September II, 2000 attached as Exhibit 1-B. Both documents report a date of birth of October 25,1949. Mr. Meadows' address is reported as 2411 W. Jefferson Street as shown in Exhibit 1-B. Teresa Diane Meadows, Mr. Meadows' spouse, also lives at this address. Ms. Meadows' date of birth is June 6,1951, and she reports a PCB level of 19.2 ppb. (Exhibit 1-C) Finally, Scott Allan Meadows (DOB -11/21/72) also lived at this address. The laboratory report for Scott Allan Meadows reported no detectable concentration of PCB s. (Exhibit 1-D) II. Subject 2 Subject 2 is the 'same child to whom reference is made in Footnote d on Page 8 and who was discussed above. There is no quality assurance or quality control information to help determine whether the reported blood levelfor this child of17.2 ppb is correct or not. However, the fact that the blood levels of her mother and her three siblings, ifwe have correctly identified the child, are all below the detection limit ofthe analytical method would seem to argue that there may be an error in the analytical resultfor the child. 'Based upon all of the information provided to us in the on-going litigation and the description and other information contained in the Health Consultation, Solutia Inc. believes that "Subject 2" is "Tiffany McFarlane" (DOB 5/7/1994). A copy of the laboratory sheet reporting a level of 17.2 ppb of PCBs for Miss McFarlane is attached as Exhibit 2-A. Laboratory sheets and discovery responses for Miss McFarlane's mother, Karen (DOB 7/3/1968) and siblings, Nathan (DOB 8/1/1992), Christopher (DOB 11/24/1988), and Belinda (DOB 2/23/1985), are attached as Exhibit 2-B and report that blood levels of her mother and her three siblings are all below the detection limit of the analytical method. HI. Subject 3 Subject 3 appears to be a child who lives in San Bemadino, California. Based on information provided by the plaintiffs' attorney in discovery in the on-going litigation, this child and an older sibling have resided in California since birth. Further, PCBs were not detected in the blood of the older sibling. Based upon all of the information provided to us in the on-going litigation and the description and other information contained in the Health Consultation, Solutia Inc. believes that "Subject 3" is "Charles Cannon, Jr." (DOB 4/6/1989). A copy of the laboratory sheet reporting a level of 11.8 ppb of PCBs for Charles Cannon is attached as Exhibit 3-A. Discovery responses indicating Charles Cannon has resided in California since birth are attached as Exhibit 3-B. A copy of the DSW 159452 WATER PCB-SD0000067375 Mr. Clement J. Welsh, Ph.D., MPH Page 3 September 11,2000 laboratory report for Charles Cannon's older sibling is attached as Exhibit 3-C and shows that no PCBs were detected in the sample from this individual. IV. Subject 4 Subject 4 appears to be an adult whose birth year is actually 1956, not 1986. However, there also seems to have been some error in the transcription ofhis reported blood level. Based on the information available in the discovery materials provided by the plaintiffs' attorneys, a male subject who was bom in 1956 had a blood PCB level reported to be 36.3 ppb, not 26.3 ppb as reported in Table 5. Based on the coincidence ofthe last two digits ofthe discrepant blood levels, the apparent error in birth year, and our inability to locate other potential matchesfor Subject 4 in the information available to us, we believe this subject is an adult, not a child. Based upon all of the information provided to us in the on-going litigation and the description and other information contained in the Health Consultation, Solutia Inc. believes that "Subject 4" is "Douglas Anderson" (DOB 8/30/1956). A copy of the laboratory sheet reporting a level of 36.3 ppb of PCBs for Mr. Anderson is attached as Exhibit 4-A. A copy of the first page of a table prepared by Mr. Anderson's lawyer, Donald Stewart, is attached as Exhibit 4-B. The entry in this table for Mr. Anderson (entry 20) reports a date of birth of August 30,1986, and a date of testing of September 14,1998. However, Mr. Anderson's responses to discovery (Exhibit 4C) clearly state that his birth year is 1956, not 1986. Please contact me if you require any additional information to correct the information in the Health Consultation. Sincerely, Robert G. Kaley, II Director, Environmental Affairs cc: Cheryl Browder ADPH Donald Williamson ADPH Gerald Hardy ADEM Russ McLean EPA Elmer Akin EPA DSW 159453 WATER PCB-SD0000067376 EXHIBIT 1-A DSW 159454 WATER PCB-SD0000067377 kMM ` hr! PWMIWTL4S wnma 'tS6-llS-BOA5^a s MB FIHAL PG 1 S3 B1 LabCorp 09/66/96 GflsEfi DCS: MMMB. MWIB, n| jittM I MEADOWS MARTIN 046/07 DR. RONALD STEWART 012B562E \\ ll j" i I'UU LHbuKinriHv piKnliil L&^'LC) STEWART, CODV t SMITH RTTT 901 LEIGHTON AVE STE R0 ANNISTON , AL 36E01- *769 PBff-33fi-*437 ____fiLE______________ LIMITS __ 00 00 TfPHil>flAJfnFit ;! -PCBr-Broelor IRBA^SR****** i .1 ,'. Hone Dt*e'tto' TM, 5 [ ", 1 ----- BN *' T>tctlon Licit S.B. Bcg/L PCB-Argelor 1E66 P _- t ~ ici/l, . e.e_ -.i?T9 : bn i 1 DIRECTOR I JAMES. A 0AVIS XXX MD IF'*VOU HAVE fiHT'MXaEflTIOMS' CONTACT -*^13^1^gB^S43-99B-LAB; I` '` LAST PAGE OF REPORT 'I5 ar-M^ragiSMEare^ i ?! . 000-7W-4W ' ' ........ ?! "MJ U\ DSW 159455 700386001-0001 WATER PCB-SD0000067378 EXHIBIT 1-B DSW 159456 WATER PCB-SD0000067379 IN THE CIRCUIT COURT FOR CALHOUN COUNTY, ALABAMA MARS HILL MISSIONARY BAPTIST CHURCH,, et al. , Plaintiffs, v. MONSANTO COMPANY, et al.. Defendants. ) ) ) ) ) ) Civil Action No, 96-243 ) ) > ) '. PLAINTIFF MARTIN MEADOWS' RESPONSE TO DEFENDANTS * FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION Comes now the plaintiff, MARTIN MEADOWS, and files this his response to defendants' First Set of Interrogatories and Requests for Production, and says as follows: _ ANSWERS TO INTERROGATORIES 1. Please provide the following information: a. Your full name and, if applicable, your maiden name; ANSWER: Martin Luther Meadows b. Your date of birth; ANSWER: October 25, 1949 ANSWER: c. Your current and each previous residence address; 1. 2411 W. Jefferson St., Anniston, AL 2. 2412 W. Jefferson St., Anniston, AL 3. 2304 Calhoun St., Anniston, AL 4. Arnold Dr., Anniston, AL 5. 1st Ave., Anniston, AL 6. Huntington, West VA ' DSW 159457 WATER PCB-SD0000067380 d.Your social security number; ANSWER 235-84-2245 e. " .Your currant and previous occupations and employers and the dates of such employment; ANSWER: 1. National Gyspum Corp., Coldwater, AL - Truck Driver - 1985 - present 2. Dalton Wastepaper, Dalton, GA - Truck Driver - 1981 - 1985 : 3. Bama Warehouse, Oxford, AL - Warehouse - 1978 - 1981 . 4. Alabama Institutional Foods, Birmingham, AL - January 1977 - August 1977 . 5. IGA Chastine Roberts Supervalue, Oxford^ AL - Truck Driver/Warehouse - 1972 - 1977 6. Anniston star Newspaper, Anniston, AL - Proof Runner/ Classifieds/ Circulation Department - 1969 - 1972 7. Sears Roebuck & Co., Atlanta, GA - Salesman - two months in 1969 8. Peachtree Parking Garage, Atlanta, GA - Parking Cars - for six months in 1968 - 1969 f. The address of your current employer and each of your previous employers; ANSWER: See Answer Number 1(e). ANSWER: g. If applicable, the full name(s) of your spouse (s); Theresa Diane Shears Meadows h. if applicable, the full names of your children, or stepchildren; DSW 159458 WATER PCB-SD0000067381 ANSWER: __'Scott' Allen Meadows i. The full names of your parents; ANSWER: - ._ Jonathan .Luther Meadows and Louellen Hanks Meadows (deceased) 2. For each residence identified in your response to Interrogatory No. l(c), please provide the following information: ANSWER: a. . The dates during which you resided in the residence; 1. 1987 - present ' 2. 1982 - 1987 3. 1975 - 1982 4. 1970 - 1975 5. 1969 - 1970 6. Late 1968 - 1969 ' ~~ 7. 1949 - 1968 b. The identity of each person who lives or lived with you in the residence; ANSWER: 1. Wife and Doris Shears (mother-in-law) ' 2 . Wife and son 3. Wife and son 4. Wife 5. Wife 6. No one 7. Father - c. State whether you are or were the owner or lessee of the residence and, if not, identify the owner(s) or lessee(s) of the residence during the time you resided in the residence. answer: 1. Arthur Gene Shears (brother-in-law) owns 2. Rented from Mr. Barnett DSW 159459 WATER PCB-SD0000067382 .1. pother-in-law owned . 4. Rented, owner unknown 5* Rented,* owner unknown 6. Rented, owner unknown <i 7. Father owned 3. state whether you are or were a member of Mars Hill Missionary Baptist Church or Bethel Baptist Church and, if so, the dates during which you have been or were a member of each such Church. ANSWER: Neither ': 4. Describe each occurrence or incident and/or method or manner of exposure or potential exposure that you contend caused you to be exposed to polychlorinated biphenyls ("PCBs"), or to have the potential for exposure to PCBs, including the date(s) and location(s) at which you contend such exposure or potential for exposure occurred. . ,' ANSWER: I was exposed by living on 1st Ave., W. Jefferson St. and Calhoun St.; playing in Monsanto field, eating produce from the garden, breathing the air and dust; and eating the chickens and eggs I raised. I drove a dump truck for Anniston Concrete and hauled 'Montar" out of Monsanto. We dumped it on Coldwater Mountain and it was used to make the dams higher. 5. If soil from the property on which you currently reside or on property on which you have ever resided has been sampled and/or tested far the presence of PCBs, please state the following: a. The location s)/address (es) of such sampling and/or testing; ANSWER: Testing has not been done to my knowledge. . b. The date(s) of such sampling and/or testing; ANSWER: See Answer Number 5(a). DSW 159460 WATER PCB-SD0000067383 c. . . ..Identify the person or entity that conducted such sampling and/or testing; ANSWER: See Answer Number 5(a). d. The results of such sampling and/or testing. ANSWER: See Answer Number 5(a). 6. If dust in the residence in which you are currently residing or is a residence in which you have ever resided has been sampled and/or tested for the presence of PCBS/ please state the following: a. The location(s) /address (es) of such sampling and/or testing; ANSWER: Testing has not been done to my knowledge. b. The date(s) of such sampling and/or testing. ANSWER: See Answer Number 6(a). c. Identify the person or entity, that conducted such sampling and/or testing; '' ANSWER: . See Answer Number 6(a). . d. The results of such sampling and/or testing. ANSWER: See Answer Number 6(a) . 7. If your blood has been tested and/or sampled for the presence of PCBs, please state the following: ANSWER: a. The date(s) of such sampling and/or testing; . June 14, 1996 b. identify the person or entity that conducted such sampling and/or testing; ANSWER: LabCorp c. The results of such sampling and/or testing. ANSWER: .' DSW 159461 WATER PCB-SD0000067384 11.1 mcg/L . 8. Do yon allege: a. Any injury, illness, incapacity, ailment or disease from exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Honsanto from the manufacturing plant operated by Honsanto at Anniston, Alabama (the "Facility"); ANSWER: Yes, my skin blisters, then flakes and peels. I have bad sinuses and sinus headaches. I have also had a kidney infection. b. Any emotional or mental distress, mental anguish, or emotional or psychological injury from exposure or the potential for exposure to PCBs or "other chemicals" or "pollutants'* you allege were "released" by Honsanto from the Facility or from the presence of such PCBs or "other chemicals" or "pollutants" on, at or near the property identified in your response to Interrogatory Ho. 1(c)? -. ANSWER: " Yes. I worry about what the PCBs may have done to me. I worry about the possibility of other health problems in the future. 9. If your answer to subparagraph (a) or (b) of interrogatory No. 8 is in the affirmative, please answer the following; a. Identify every medical doctor, psychiatrist, psychologist or other health care practitioner or provider by whom you have consulted at any time, including the date(s) on which each such examination, treatment or consultation occurred; ANSWER: Dr. Mccrimmon, Anniston, AL - 1977 b. Identify each instance when you have been admitted to a hospital, clinic, health care facility or received treatment at an emergency room of a hospital, clinic, health care facility or emergency room and the date(s) of each such visit or admission; ANSWER: 1. Regional Medical Center, Anniston, AL - 1977; 1996 2. Sylacauga hospital, Sylacauga, AL - 1977 c. Identify each insurance agent, insurance company, employer or other entity to whom you or anyone acting ` on your D5W 159462 WATER PCB-SD0000067385 behalf has. submitted an application for life, health or disability insurance fTSi 'you or which has provided or does provide life, health or~disability insurance for you; ANSWER: Liberty National and Provident Health Source d. If applicable, identify each "other chemical" or "pollutant" relating to your affirmative answer to either subparagraph (a) or (b) of Interrogatory No. 8. ANSWER: . This cannot be answered at this time because Monsanto has refused to identify all the chemicals and pollutants emitted from the plant into the community. RESPONSE TO REQUESTS FOR PRODUCTION OF DOCUMENTS 1. Produce all photographs, film or videotape that you have taken or have in your possession, custody or control of . the property identified in your response to Interrogatory_No. 1(c) , the Facility, or any creeks, ditches or waterways near the Facility. RESPONSE: I do not have any such documents. 2. Produce all documents reflecting or describing meetings or other communications between you and any representative, employee or contractor of Monsanto. RESPONSE: See Response Number 1. __ 3. Produce all documents which reflect or describe what you contend is a representation or misrepresentation from Monsanto to you regarding or relating to polychlorinated biphenyls (PCBs). RESPONSE: ' See Response Number 1. .4 Produce all documents in your possession, custody or control that originated from or purport to originate from Monsanto, the Alabama Department of Public Health, the Alabama Department of Environmental Management, the Agency for. Toxic Substances and Disease Registry or the united States Environmental Protection Agency regarding or relating to PCBs and/or the claims alleged in the Complaint. RESPONSE: See Response Number 1. - DSW 159463 WATER PCB-SD0000067386 5. Produce all documents in your possession, custody or control reporting or reflecting tests or sampling or results of tests or-sampling of dust, soil, blood, tissue, sediment, or other media for the presence of polychlorinated biphenyls {PCBs) . RESPONSE: - .. 'See Exhibit "A" Attached. . 6. Produce all documents which record, reflect or evidence any. medical, psychiatric or psychological examination, care or treatment received by you from any medical doctor, psychiatrist, psychologist or other health care practitioner or provider. . RESPONSE: See Response Number 1. 7. Produce all documents which record, reflect or evidence any application for life, health or disability insurance made by you or on your behalf. RESPONSE: See Response Number 1. - 8. Produce all documents which record, reflect or evidence each instance in which you have been admitted to a hospital, clinic or other health care facility or received treatment at an emergency room of a hospital, clinic or other health care facility. RESPONSE: See Response Number 1. 9. Produce an executed original of the "Medical Authorization" attached hereto. RESPONSE: See Exhibit "B*1 Attached. DSW 159464 WATER PCB-SD0000067387 tscJdLj&G> ;TIN L. MEADOWS sworn to and subscribed Usef ore me this theC?A^"dav of 19 2. ''Notary- Public C? My Commission Expires on / w r 7 y OF COUNSEL: STEWART, CODY 4 SMITH, P.O. Box 2274 Anniston, AL 36202 (205) 237-9311 P.C. DONALD W. STEWART Attorney for Plaintiffs DSW 159465 WATER PCB-SD0000067388 CERTIFICATE OF SERVICE ' This~is to certify that I have this date served counsel for all parties to this action with a copy of the within and foregoing document by depositing same in the United States mail in a properly addressed envelope with adequate postage affixed thereon and addressed as follows: William S. Cox III, Esq. LIGHTFOOT, FRANKLIN & WHITE, 300 Financial Center 505 North 20th Street Birmingham, A1 35203 L.L.C. " This the , 1997. DONALD W. STEWART Attorney for Plaintiffs DSW 159466 WATER PCB-SD0000067389 [116.6-112-9045-0 1 s` j MB [plMftL j PO 1 03 01 A&crnowMVfwuTnN DG3 : 10/25/49 uimurp 09/96 s MTCHUMM MEADOWS . . E rtAOO. , MARTIN . .. sex 1 MfprMOl) M 046/07 /cooutr DR. RONALD STEWART STEWART, CODY & SMITH ATT 3 *. .. ___ QATE0FSHQMSN_ - - CHTtfiMTOCO 0*TtPCflTED 86/1 4/fJh 86/t4/*6 < POLYCHLORINATED BIPnENYLS-PCB 4SUR RESULT 901 LEIGHTON ANNISTON 05-236-4437 AUE STE , AL ALG 02 36,2 D PCB-Aroclor 1254 ' None Detected ` --0v'S ; Detection Limit = PCB-Aroclor 1260 11..1 _ ' X~ mcg/L 0.6 Detection Limit- " DIRECTOR: JAMES A DAVIS III MD IF YOU HAVE ANY QUESTIONS CONTACT - BRANCH* 205-543-2990 LAB:--S LAST PAGE uF REPORT f" 1i i si ^ ; fold i DSW 159467 ' * UboratQtY Co" RESULTS ARE FLAGGED IN ACCORDANCE WITH AGE DEPENDENT REFERENCE RANGES WATER PCB-SD0000067390 MEDICAL ADTH0K3ZAJI0N He:' j Mar? FTP Migionarr Bantfat Omreh v. Monsanto Company Thomas G. Longer. v. Momanto Company Absmatar, ct al.v, Morning .Compaai To Whom It May Cancan: , You arc hereby authorized and requeued to furnish to Adam K. Psdc, Lightrbot, FranHfn i White Si J 300 Financial Center, Birmingham, Alabama' 35203, any and all records or other documents pertaining to______ _ -- ... C^316 birth Soda! Security Number: _________________ ____________________ _________ ), including without Iiinitarioii all % charts, prognoses, histories, photographs, x-rays (rnrhtrfmg reports and films), Tirnimarii-c, analytical data, qualitative laboratory results, quanriative laboratory results^ records or interviews, records cf treatments, emergency room records.and reports, memoranda, progress notes, qpnrirma, psychiatric tftagnnses and notes, conrinrions, nfffr- r^rm-r handwritten notes, bills, invoices, pharmaceutical records, prescriptions, and any other writings of any nature prepared at any time winch relate in any way to____ _____________________________________ , including, without lintttaaon, all such records and documents until the response is made to this request. SIGNATURE: NAME: 'S'Lg? D$W 159468 WATER PCB-SD0000067391 EXHIBIT 1-C DSW 159469 WATER PCB-SD0000067392 nhk ^ Tfft WXMWflM MKWTlWm "Itsa-ue-aieeLa. s MB FINAL PG 1 . s REAPOWS -J' DIANE DOE: 66/ it/ti to <atrnu>ot4 F 045/80 mtfttaai rauiantMD Hr,/H/96 MA/ii/Aftt 09/86/56 4058 63 81 BMumwvi LabCorp 05/06/96 86;26 uxatn DR. RONALD STEWART 0i056E(j STEWART, CODY S SMITH ATTY 08 SB1 LEIGHTON AVE STE H02 00 ANNISTON , AL 36201-4769 AAS-F3A-4437___ALN_____`_______________ : POLYCriuONihA'itw BIPhENYlS-PCB x I 1 PCB^Arriclor lBSS^e4s^'\ i None DetecSeH'.vil.i^- BN ' g *:-..- Detection Limit * 5.0.jacg/L i | ^PCB-Aroc^gr_^|^ 1. ^ Y ' ; .-"DIRECTOR;. JAMES A DAVIS III MD . J. `.I IF YOU HAVE ANY QUESTIONS CONTACT ^TSTEfiNCTtr .285r343-5?9BH-ftB*- 6|0f7&2=4^jJl-w ' " LAST PAGE OF REPORT II '6 ftVTJAJ*: H* YX 4f.i `V a " .YJ,r l . Oil ui-'6r-*r! * DSW 159470 WATER PCB-SD0000067393 EXHIBIT 1-D DSW 159471' WATER PCB-SD0000067394 DOB: li/3/7H MornwHi MEADOWS ,. , SCOTT . &x n AscrmjMau 023/06 ACCOUNT Dft. RONALD STEWART " ____ .J otfiOFS^nN a*noma onMKffrtD STEWART, CODY 4 SMITH A 301 LEIGHTON AVE STE E0; ANNISTON , AL 3i 06/14/96 06/i4/96 1 09/06/96 -4039 RESULT 205-S36-4437 ALG Luu t'LhLGRIMATED BIPHENYLS-*PCEf PCBtAtocIot 1E5-4. * None Detecteffigy?```"T***'*?*; ~ q- _ Detection Limit *= PCB-H-roclor 12&U None Detected _ 0, ItrX` VI.1;'. X^Datecti on.--Liwi.t^~r=- MU IFJ.TQO __ DIRECTOR: JAMES A DAVIS_III MD HAVE . ANY-.-QUES-TIORS j CONTACT-fit'?ANCH^gf543^'3a~'6Sg~3 ' ......... _ LAST PAGE OF REPORT ~ ` . ' ' KVZ Z** i A1"'! ", ! ! r SSsL Mvoee . ,, / a*ww^tk 1 i>:*M'>xI pt, . . '."ace r"! S- " _- 'y -t.t'.r... y-r-; '-rrr.^cg; -=n TTfSKV 11 - i"Tr`;- r,r"'a fOUJ ,. DSW 159472 -.vj Laboratory Cot RESULTS ARE FUGGED IN ACCORDANCE WITH aGc DEPENDENT REFERENCE RANGES WATER PCB-SD0000067395 EXHIBIT 2-A DSW 159473 WATER PCB-SD0000067396 '.L i, li-JUJ-i' ^OOinONM. 4MKMMAHON l* UUU i 135/ 4 7/ T-H t^JUK'.Li JrfnOMUlf&l U1UUUI |4 aT/tjc,-?o 'jo-.^d ngKTM>* nCFARLANE rr*oo. , TIFFANY MX 1 4GE{nLAK&l F [ 002/08 *ceouHr _ DR. RONALD STEWART STEWART, CODY & SillTif Al'TY '" 01EQ5- 00 DM* Of $^ECIueH *6\>s 14/ 1 OAT1 chtimd 0*TEKWTO 0ti/1. 4/Ge. 1 1 .4$j3 901 LEIGHTON AVti STE 292 ANNISTON , hL 3&231--h79 305--53p--4437 hLG 00 t-UL.1 uHLuKjlnh l c.V ifAhfc.ru La-AUB RESULT limits PCo--AtocIot- 12S4- Norte Detected'1 .... ... ;. - 0. S -- 19.*9*777; Detection Limit - 5.0 rocg/L I !`,C3-h-('oc1ot 12G0 17.2 mcg/L 0.0 - 19.9 . .... Detection Limit = 5.0-mcg/tTM 3QL0 DIRECTOR: JAMES A DAVIS III I'lD ". IF YOU HAVE ANY QUESTIONS CONTACT -`BRANCH: .0.57543-990- LAB: 3.06--7S2--i4,3Jrjt- . LAyT RACE OF ALT-clA < JLD DSW 159474 ' Laborarnry Corporation af America'1* Mole RESULTS ARE FLAGGED IN ACCORDANCE WITH AGE DEPENDENT REFERENCE RANGES REPO RT WATER PCB-SD0000067397 EXHIBIT 2-B DSW 159475 WATER PCB-SD0000067398 IN THE CIRCUIT COURT FOR CALHOUN COUNTY, ALABAMA MARS HILL MISSIONARY BAPTIST CHURCH, et al., Plaintiffs, v. MONSANTO COMPANY, et al. , Defendants. ) ) ) ) ) ) Civil Action No. 96-243 ) ) ) ) PLAINTIFF KAREN MCFARLANE'S RESPONSE TO DEPENDANTS' FIRST , INTERROGATOR!ES AND REQUESTS FOR PRODUCTION * Comes now the plaintiff, Karen McFarlane, and files this her response to defendants1 First Set of Interrogatories and Requests for Production, and says as follows: ANSWERS TO INTERROGATORIES l. Please provide the following information: ANSWER: a. Your full name and, if applicable, your maiden name; . Karen Belinda Moore McFarlane b. Your date of birth; ANSWER: ANSWER: July 3, 1968 c. Your current and each previous residence address; 1. 807 Bancroft, Anniston, AL 2. 809 Bancroft, Anniston, AL 3. 2106 W. 10th St., Anniston, AL ANSWER: d. Your social security number; 420-96-3999 . .... DSW 159476 WATER PCB-SD0000067399 e. Your current and previous occupations and employers and the dates of such employment; ANSWER: . 1, Waffle House - Waitress - Anniston, AL - 1997 and 1987. 2. Sentinel consumer Products - Packer/Machine t- Operator - Anniston, AL - 1992 - 1996. . 3. Western Sizzler - Cook - `Anniston, AL - 1992. 4. Quincy's - Waitress - Oxford, AL - 1990. 5. Tyson's - KLC Cutter - Heflin, AL - 1989'. 6. Shoney's - Waitress - Anniston, AL - 1988. v 7. Holiday Inn - Food Preparer - Oxford, AL - 1987. 8. JTPA - Cook - Anniston, AL - 1986; Construction- Maintenance - 1997. f. The address of your current employer and each of your previous employers; . ANSWER: See Answer Number 1(e). g. If applicable, the full name(s) of your spouse(s); ANSWER: Jeffrey Ryan McFarlane, h. If applicable, the full names of your children or stepchildren; .. ANSWER: Belinda Danielle McFarlane, Christopher Ryan McFarlane, Nathan Daniel McFarlane, and Tiffany Lashay McFarlane. ANSWER: i. The full names of your parents; Hubert Dean Moore, Sr. and Eva Lois Turley Moore. 2. For each residence identified in your response to Interrogatory No. 1(c), please provide the following information: DSW 159477 WATER PCB-SD0000067400 a. The dates during which you resided in the residence; ANSWER: 1. 1990 - present. - 2. 1985 - 1990. 3. 1968 - 1985. b. The identity of each person who lives or lived with you in the residence; ANSWER: 1. Husband and children. ` ' - 2. Husband and children. .. 3. Parents, Hubert D. Moore, Jr. (brother) and * the the , c. residence residence Debbie Ann Moore Gravette (sister). k . State whether you are or were the owner or lessee and, if not, identify the owner(s) orlessee(s) during the time you resided in the residence. of i .i \ of< ANSWER: 1. Owner. , 2. Husband's grandparents owned. 3. Parents owned. 3. State whether you are or were a member of Mars Hill Missionary Baptist Church or Bethel Baptist Church and, if so, the dates during which you have been or were a member of each such church. ANSWER: Neither. 4. Describe each occurrence or incident and/or method or manner of exposure or potential exposure that you contend caused you to be exposed to polychlorinated biphenyls ("PCBs"), or to have the potential for exposure to PCBs, including the date(s) and location(s) at which you contend such exposure or potential for exposure occurred. ANSWER: From breathing the air and dust, eating the vegetables . from the garden and playing in the ditches. 5. if soil from the property on which you currently reside or on property on which you have ever resided has been sampled and/or tested for the presence of PCBs, please state the following: DSW 159478 WATER PCB-SD0000067401 a. The location(s)/address(es) of 3uch sampling and/or tasting; _ ANSWER: . 807 Bancroft ,, b. The date(s) of such sampling and/or testing; ANSWER: April or May, 1996. f. c. Identify the person or entity-that conducted such sampling and/or testing; . ANSWER: Monsanto people. .i d. The results of such sampling and/or testing. *' , ANSWER: The front yard had 17% and the back yard next to the ditch had 33%. '' 6. If dust in the residence in which you are currently1 residing or in a residence in which you have ever resided has been sampled and/or tested for the presence of PCBs, please state the following: a. The location(s)/address(es) of such sampling and/or testing; .. ANSWER: Testing has, not been done to my knowledge. b. The date(s) of such sampling and/or testing. ANSWER: See Answer Number 6(a). c. Identify the person or entity that conducted, such sampling and/or testing; ANSWER: See Answer Number 6(a). ANSWER: d. The results of such sampling and/or testing. See Answer Number 6(a). _ 7. If your blood has been tested and/or sampled for the presence of PCBs, please state the following; a. The date(s) of such sampling and/or testing; DSW 159479 WATER PCB-SD0000067402 ANSWER: ' "June 14, 1996 . b. Identify the person or entity that conducted 3uch sampling and/or testing; ANSWER: LabCorp. " c. The results of such sampling and/or testing. ANSWER: None detected. - . 8. Do you allege: .- aN * a. Any injury, illness, incapacity, ailment or disease from exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Konsanto from the manufacturing plant operated by Monsanto at Anniston, Alabama (the "Facility"); ANSWER: ' . Yes, I have asthma, bronchitis, nerve problems, ,, " headaches, allergies and stomach problems. As a - child, I always went barefoot around this area and now I have severe itching all over my feet. I played in the creeks. I have blackheads and pimples at the top of my leg, in the crease, that have been there since I was a child. I also have short-term memory. I've had this problem since I was a child. I've been to the hospital numerous times for my breathing problems; they had to put me on a breathing machine. b. Any emotional or mental distress, mental anguish, or emotional or psychological injury from exposure or the potential for exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Monsanto from the Facility or from the presence of such PCBs or "other chemicals" or "pollutants" on, at or near the property identified in your response to Interrogatory No. 1(c)? . ANSWER: Yes. I worry about what the PCBs may have done to my family and me, especially my daughter. I have DSW 159480 WATER PCB-SD0000067403 bad nerves and my property is worthless now. 9. If your answer to subparagraph (a) or (b) of interrogatory Ho. 8 is in the affirmative, please answer the following: . a. Identify every medical doctor, psychiatrist, psychologist or other health care practitioner or provider by whom you have consulted at any time, including the date(s) on which each such examination, treatment or consultation occurred; l* ANSWER: 1. Dr. Ferguson - Anniston, AL - 1993 and 1994. 2. Dr. Daniels - Anniston, AL - 1992. I've seen other" doctors but I cannot remember their names nor the dates. V ' b. Identify each instance when you have been admitted to a hospital, clinic, health care facility or received treatment at an emergency room of a hospital, clinic, health care facility or emergency room and the date(s) of each such visit or admission; - ANSWER: 1. Anniston Medical Clinic - Anniston, AL - 1985, 1988, 1992 and 1994. 2. Regional Medical Center - Anniston, -AL - ' 1993, 1994 and 1997. c. Identify each insurance agent, insurance company, employer or other entity to whom you or anyone acting on your behalf has submitted an application for life, health or disability insurance from you or which has provided or does provide life, health or disability insurance for you; ANSWER: Liberty National. d. If applicable, identify each "other chemical" or "pollutant" relating to your affirmative answer to either subparagraph (a) or (b) of Interrogatory Ho. 8. ANSWER: This cannot be answered at this time because Monsanto has refused to identify all the chemicals and pollutants emitted from the plant into the community. ' DSW 159481 WATER PCB-SD0000067404 RESPONSE TO REQUESTS FOR PRODUCTION OF DOCUMENTS 1. Produce all photographs, film or videotape that you have taken or have in your possession, custody or control of the property identified in your response to Interrogatory No. 1(c), the Facility, or any creeks, ditches or waterways near the Facility. RESPONSE: I do not have any such documents. i 2. Produce all documents reflecting or describing meetings or other communications between you and any representative, employee or contractor of Monsanto. ' RESPONSE: See Response Number 1. . 3. Produce all documents which reflect or describe what you contend is a representation or misrepresentation from Monsanto to you regarding or relating to polychlorinated biphenyls (PCBs) . RESPONSE: See Response Number 1. '' 4. Produce all documents in your possession, custody or control that originated from or purport to originate from Monsanto, .the Alabama Department of Public Eealth, the Alabama Department of Environmental Management, the Agency for Toxic Substances and Disease Registry or the United States Environmental Protection Agency regarding or relating to PCBs and/or the claims alleged in the Complaint. RESPONSE: See Response Number 1. 5. Produce all documents in your possession, custody or control reporting or reflecting tests or sampling or results of tests or sampling of dust, soil, blood, tissue, sediment, or other media for the presence of polychlorinated biphenyls (PCBs). RESPONSE: See Exhibit "A" Attached. 6. Produce all documents which record, reflect or evidence any medical, psychiatric or psychological examination, care or treatment received by you from any medical doctor, psychiatrist, psychologist or other health care practitioner or provider. RESPONSE: See Exhibit "B" Attached. . 7. Produce all documents which record, reflect or evidence any application for life., health or disability insurance made by you or on your behalf. DSW 159482 WATER PCB-SD0000067405 RESPONSE: . . _ See Response Number 1. 8. Produce all documents which record, reflect or evidence each instance in which you have been admitted to a hospital, clinic or other health care facility or received treatment at an emergency room of a hospital, clinic or other health care facility. RESPONSE: See Exhibit "Cu Attached. 9. produce an executed original of the "Medical Authorization" attached hereto. ' RESPONSE: .. See Exhibit "D" Attached. .. . . DSW 159483 WATER PCB-SD0000067406 Auj- (boOi/iia. Mc&Jhu*. KAREN BELINDA MCFARLANE Sworn to and subscribed before me this the day of v .&zLu tf.Xh^zX Notary Public SMa/sX My commission Expires on 19.52 OF COUNSEL: STEWART, CODY P.O. Box 2274 Anniston, AL (205)237-9311 & SMITH, 36202 P.C. Cu)^ *J) u lts$ DONALD W. STEWART Attorney for Plaintiffs DSW 159484 WATER PCB-SD0000067407 CERTIFICATE OF SERVICE This is to certify that I have this date served counsel for all parties to this action with a copy of the within and foregoing document by depositing same in the United States mail in a properly addressed envelope with adequate postage' affixed thereon and addressed as follows: William S. Cox-III, Esq. LIGHTFOOT, FRANKLIN & WHITE, 300 Financial Center 505 North 20th Street Birmingham, AL 35203 . L.L.C. . - .. ". `' This the _ of 1997. DONALD W. STEWART Attorney for Plaintiffs DSIV '59485 WATER PCB-SD0000067408 nn MHNWM wrmiui "|lS6-U2n-fcfcfi6jtei: s HB FINAL PG l 03 01 --DOB: 07/03/66 LabCorpT 09/06/96 06:a *1 II DR. RONALD STEWART ' : *' -01605. STEWART,- CODY, & SMITH ATTV ' 00 961,* LEIGHTON AWE STE 292 * ''"r , J 00 31 ]' "Bfif/iV/96' I- 09/06/96 I *Q2?~ -ANNISTON-- 06/14796 psi.-!s!lfiJ4437 RESULT POLYCHLORINATED- B1PHENYLS-PCS r AL 36291-476S"?'-'? AfS 1 % , 4 ** , > <J 52^S sc .. - Detection' Limit " 5.9`-aeg/L.Z C - PCB-AtocIot 1260 S.*J3$S3 .. Hon* Detected e.o 19.9..; ami.Mnnrv*tta i ` > *u. *ea0'*y>w6!lRECTOR: . JAMES A DAVIS* III MD ^F^in^ffoiagwarosswaEaggKi: ? rw rreKSmeifft 3r-?; ! LAST PASEhOF.REPORT 9 \ l syaktMMyaMHaMBB^^ 9 . 1 .`.'ii j : : 's . j--.v ; m .. . - -st iHT&i'ftlAi iwik ^trsr ' V* ^sBMgsaaaaawa^ Is - **-/*' . %* . t* *v Mgggmrotg 4 Yl 3 \5 r-*?5Z?jz . - * " -, .** " ' * -- * .--^ .----- - ---------- . -------- T ' : WE-nIC.; Laboutorf Cwporamn sf Amena4' Hal- RESULTS ARE RUGGED IN ACCORDANCE WITH AGE DEPENDENT REFERENCE RANGES REPORT DSW 159486 WATER PCB-SD0000067409 IN THE CIRCUIT COURT FOR CALHOUN COUNTY, ALABAMA MARS HILL MISSIONARY BAPTIST CHURCH, et al.. Plaintiffs, v. MONSANTO COMPANY, et al. , Defendants. ) ) ) ) ) ) Civil ^ction No. 96-243 ) ) )' ) PLAINTIFF NATHAN DANIEL MCFARLANE1S RESPONSE TO DEFENDANTS * FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION Comes now the plaintiff, Nathan Daniel McFarlane, and files this his response to defendants7 First Set of Interrogatories and Requests for Production, and says as follows: ANSWERS TO INTERROGATORIES 1. Please provide the following information: a. ' Your full name and, if applicable, your maiden name; ANSWER: Nathan Daniel McFarlane ' b. Your date of birth; ANSWER: August 1, 1992 c. Your current and each previous residence address; ANSWER: 807 Bancroft Ave., Anniston, AL d. Your social security number; answer: 421-39-9530 . e. Your current and previous occupations and employers and the dates of such employment; ANSWER: ' DSW 159487 i il WATER PCB-SD0000067410 Not applicable. - f. The address of your current employer and each of your previous employers; ANSWER: Not applicable. ' g. If applicable, the full name(s) of your spouse (s); ANSWER: Not applicable. '. h. If applicable, the full names of your children or stepchildren; ANSWER: " Not applicable. ... ` i. The full names of your parents; ` ANSWER: Jeffery Ryan McFarlane and Karen Belinda McFarlane 2. For each residence identified in your response to Interrogatory No. 1(c), please provide the following information: a. The dates during which you resided in the residence; ANSWER: 1990 - present. b. The identity of each person who lives or lived with you in the residence; ANSWER: Parents and siblings. c. State whether you are or were the owner or lessee of the residence and, if not, identify the owner(s) or lessee(s) of the residence during the time you resided in the residence. ANSWER: Parents own. 3. state whether you axe or were a member of Kars Hill Missionary Baptist Church or Bethel Baptist Church and, if so, the dates during which you have been or were a member of each such Church. ANSWER: Neither. - 4. Describe each occurrence or incident and/or method or manner of exposure or potential exposure that you contend caused you to be DSW 159488 WATER PCB-SD0000067411 exposed to polychlorinated biphenyls ("PCBs"), or to have potential for exposure to PCBs, including the date (a) location (s) at vhich you contend such exposure or potential exposure occurred. the and for ANSWER: He has breathed the air in the Monsanto area all his life. He ate the eggs and meat from the chickens that im we raise. He ate vegetables from the garden and there is an open ditch on'the north side of Monsanto - near the rail road. 5. If soil from the property on which you currently reside or .on property on which you have ever resided has been sampled and/or tested for the presence of PCBs, please state the following: . testing; . answer: a. The location(s)/address(es) of such sampling and/or J ' " * 807 Bancroft b. The date(s) of such sampling and/or testing; ANSWER: April or May, 1996. * c. Identify the person or entity that conducted such sampling and/or testing; ANSWER: Monsanto people. d. The results of such sampling and/or testing. ANSWER: The front yard had 17% and the back yard next to the ditch had 33%. 6. If dust in the residence in which you are currently residing or in a residence in which you have ever resided has been sampled and/or tested for the presence of PCBs, please state the following: a. The location(s)/address(es) of such sampling and/or testing; ' ANSWER: Testing has not been done to my knowledge. DSW 159489 WATER PCB- t>. The date(3) of such sampling and/or testing. ANSWER: See Answer Number 6(a). c. Identify the person or entity that conducted such sampling and/or testing; answer: See Answer Number 6(a). d. The results of such sampling and/or testing. ANSWER: See Answer Number 6(a). . 7. If your blood has been tested and/or sampled for the presence of FCBs, please state the following:' * a. The date(s) of such sampling and/or testing; ANSWER: . . June 14, 1996 1 r ** b. Identify the person or entity that conducted such sampling and/or testing; ANSWER: LabCorp . c. The results of such sampling and/or testing. ANSWER: None detected ' 8. Do you allege: a. Any injury, illness, incapacity, ailment or disease from exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Monsanto from the manufacturing plant operated by Monsanto at Anniston, Alabama (the "Facility"); , ANSWER: Yes. Nathan has a skin disorder called spreading warts. Nathan was quarantined at the hospital. He is cripple, he has mild Cerebral Palsy, asthma and cirrhosis. His spine is bigger than it is supposed to be. At age two, he lacked brain ' matter. DSW 159490 WATER PCB-SD0000067413 b. Any emotional or mental distress/ mental anguish, or emotional or psychological injury from exposure or the potential for - exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Monsanto from the Facility or from the presence of such RCBs or "other chemicals" or "pollutants" on/ at or near the property identified in your response to Interrogatory No. 1(c)? ANSWER: Yes. 1. 9* If your answer to subparagraph (a) or (b) of Interrogatory No. 8 is in the affirmative, please answer the following: . a. Identify every medical doctor, psychiatrist, psychologist or other health care practitioner or provider by whom you have consulted at any time, including the date(s) on which each such examination, treatment or consultation occurred; ' ANSWER: 1. Dr. Woodruff - Anniston, AL - 1992 - present. 4 2. Dr. Matheson - Birmingham, AL - 1995-present. 3. Dr. Smith - Anniston, AL - 1993 - 1994, He has seen other doctors whose names his parents cannot remember. b. Identify each instance when you have been admitted to a hospital, clinic, health care facility or received treatment at an emergency room of a hospital, clinic, health care facility or emergency room and the date(s) of each such'visit or admission; ANSWER: Regional Medical Center - Anniston, AL - 1995. c. Identify each insurance agent, insurance company, employer or other entity to whom you or anyone acting on your behalf has submitted an application for life, health or disability insurance from you or which has provided or does provide life, health or disability insurance for you; ANSWER: Medicaid. d. If applicable, identify each "other chemical" or "pollutant" relating to your, affirmative answer to either subparagraph (a) or (b) of Interrogatory No. 8. ANSWER: This cannot be answered at this time because DSW 159491 WATER PCB-SD0000067414 Monsanto has refused to identify all the chemicals and pollutants emitted from the plant into the community. . RESPONSE TO REQUESTS FOR PRODUCTION OF DOCUMENTS 1. Produce all photographs, film or videotape that you have taken or have in your possession, custody or . control of the property identified in your response to interrogatory No. 1(c), the Facility, or any creeks, ditches or vatervays near the Facility. RESPONSE: I do,not have any such documents. 2. Produce all documents reflecting or describing meetings 'or other communications between you and any representative, employee or contractor of Monsanto. RESPONSE: See Response Number 1. -, `,, 3. Produce all documents which reflect or describe what you contend is a representation or misrepresentation from Monsanto to you regarding or relating to polychlorinated biphenyls (PCBs) . RESPONSE: See Response Number 1. . 4. Produce all documents in your possession, custody or control that originated from or purport to originate from Monsanto, the Alabama Department of Public Health, 'the Alabama Department Of Environmental Management, the Agency for Toxic Substances and Disease Registry or the United states Environmental Protection Agency regarding or relating to pcbs and/or the claims alleged in the Complaint. response: See Response Number 1. 5. Produce all documents in your possession, custody or control reporting or reflecting tests or sampling or results of tests or samplingof dust, soil, blood, tissue, sediment, or other media for the presence of polychlorinated biphenyls (PCBs). RESPONSE: See Exhibit "A" Attached. 6. Produce all documents which record, reflect or evidence any medical, psychiatric or psychological examination, care or treatment received by you from any medical doctor, psychiatrist, psychologist or other health care practitioner or provider. DSW 159492 WATER PCB-SD0000067415 RESPONSE: See Exhibit "B" Attached, 7. Produce all documents vhich record, reflect or evidence any application for life, health or disability insurance made by you or on your behalf, response: See Response Number 1. ' 8. Produce all documents vhich record, reflect or evidence each instance in vhich you have been admitted to a hospital, clinic or other health care facility or received treatment at an emergency room of a hospital, clinic or other health care facility. RESPONSE: . See Exhibit "C" Attached. - . V 9. Produce an executed original of the "Medical Authorization" attached hereto. . RESPONSE: . See Exhibit "D" Attached. '* - DSW 159493 WATER PCB-SD0000067416 NATHAN DANIEL MCFARLANE Sworn to and subscribed before me this the 7) day of . < -/ Notary Public My Commission Expires on is22. OF COUNSEL: STEWART, CODY & SMITH, P.O. BOX 2274 Anniston, AL 36202 f205)237-9311 P.C. DONALD W. STEWART Attorney for Plaintiffs DSW 159494 WATER PCB-SD0000067417 CERTIFICATE OF SERVICE ,This isjto certify that I have this date served counsel for all parties to this action with a copy of the within and foregoing document by depositing same in the United States mail in a properly addressed envelope with adequate postage affixed thereon and addressed as follows: ' William S. Cox III, Esq. LIGHTFOOT, FRANKLIN & WHITE, 300 Financial Center 505 North 20th Street Birmingham, AL" 35203 L.L.C. . .. , ' This the DONALD W. STEWART Attorney for Plaintiffs DSW 159495 WATER PCB-SD0000067418 IN THE CIRCUIT COURT FOR CALHOUN COUNTY, ALABAMA MARS HILL MISSIONARY BAPTIST CHURCH, et al., ` Plaintiffs, v. MONSANTO COMPANY, et al. , Defendants. ) ) ) ) ) ) Civil Action No. 96-243 ). ) ) ) ' ' PLAINTIFF BELINDA DANIELLE MCFARLANE*S RESPONSE TO DEFENDANTS'. . ' FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION f. Comes now the plaintiff, Belinda Danielle McFarlane, and files this her response to defendants' First Set of Interrogatories and Requests for Production, and says as follows: "- ANSWERS TO INTERROGATORIES 1. Please provide the following information: ANSWER: a. ' Your full name and, if applicable, your maiden name; Belinda Danielle McFarlane b. Your date of birth; ANSWER: February 23, 198S . . ANSWER: c. Your current and each previous residence address; 1. 807 Bancroft Ave., Anniston, AL 2. 809 Bancroft Ave., Anniston, AL d. Your social security number; ANSWER: 417-21-7756 e. Your current and previous occupations and employers .' DSW 159497 WATER PCB-SD0000067419 and the dates of such employment; ANSWER: Not applicable. f. The address of your current employer and each of your previous employers; ANSWER: Not applicable. g- If applicable, the full name(s) of your spouse (s); ANSWER: Not applicable. h. If applicable, the full names of your children of stepchildren; r ANSWER: Not applicable. . i. The full names of your parents; .,, ANSWER: Jeffery Ryan McFarlane and Karen Belinda McFarlane 2. For each residence identified in your response to Interrogatory No. 1(c), please provide the following information: a. The dates during which you resided in the residence; ANSWER: 1. 1990 - present. 2. 1985 - 1990. b. The identity of each person who lives or lived with you in the residence; ANSWER: 1. Parents and siblings. 2. Parents. c. State whether you are or were the owner or lessee of the residence and, if not, identify the owner(s) or lessee(s) of the residence during the time you resided in the residence. ANSWER: 1. Parents own. 2. Great-grandparents owned. DSW 159498 WATER PCB-SD0000067420 3. State whether you are or were a member of Mars Hill Missionary Baptist Church or Bethel Baptist Church and/ if so, the dates during which you have been or were a member of each such Church. ANSWER: Neither. 4. Describe each occurrence or incident and/or method or manner of exposure or potential exposure that you contend caused you to be exposed to polychlorinated biphenyls ("PCBs"), or to have the potential for exposure to PCBs, including the date(s) and location(s} at which you contend such exposure or potential for exposure occurred. . ANSWER: She has breathed the air in the Monsanto area all her life. She ate the eggs and meat from the chickens tb^t we raise. She ate the vegetables from the garden; and there is an open ditch on the north side of Monsanto - '' '/ near the rail road. -- 5. if soil from the property on which you currently reside or on property an which you have ever resided has been sampled and/or .tested for the presence of PCBs, please state the following: a. The location(s)/address(es) of such sampling and/or testing;. ANSWER: ' 807 Bancroft b. The data(s) of such sampling and/or testing; ANSWER: April or May, 1996. c. Identify the person or entity that conducted such sampling and/or testing; ANSWER: Monsanto people. d. The results of such sampling and/or testing. ANSWER: The front yard had 17% and the back yard next.to the ditch had 33%. 6. if dust in the residence in which you are currently residing or DSW 159499 i WATER PCB-SD0000067421 in a residence in which you have ever resided has been sampled and/or tested for the presence of PCBs, please state the following! a. The location(s)/address (es) of such sampling and/or testing; . ANSWER: Testing has not been done to my knowledge. b. The date(s) of such sampling and/or testing. ANSWER: See Answer Number 6(a). . . c. Identify the person or entity that conducted such sampling and/or testing; ANSWER: See Answer Number 6(a). < d. The results of such sampling and/or testing.. ANSWER.: .. See Answer Number 6(a). . . " 7. If your blood has been tested and/or sampled for the presence of PCBs, please state the following: a. The date(s) of such sampling and/or testing; ANSWER: June 14, 1996 '. ' b. Identify the person or entity that conducted such sampling and/or testing; ANSWER: LabCorp c. The results of such sampling and/or testing. ANSWER: None detected 8. Do you allege: a. Any injury, illness, incapacity, ailment or disease from exposure to PCBs or Mother chemicals" or "pollutants" you allege were "released" by Konsanto from the manufacturing plant operated by Monsanto at Anniston, Alabama (the "Facility"); ANSWER: Yes, she has headaches and a skin disorder - spreading SVV 159500 WATER PCB-SD0000067422 warts, and some type of rash. ^ b. Any emotional or mental distress, mental anguish, or emotional or psychological injury from exposure or the potential for exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Monsanto from the Facility or from the presence of such PCBs or "other chemicals" or "pollutants" on, at or near the property identified in your response to Interrogatory No. 1(c)? ANSWER: '' Yes, the rash itches and the warts bother her. I worry about the what the PCBs may have done to her. 9. If your answer to subparagraph (a) or (b) of Interrogatory No. 8 is in the affirmative, please answer the following: V a. Identify every medical doctor, psychiatrist, psychologist or other health care practitioner or provider by whom you have consulted at any time, including the date(3) on which each such examination, treatment or consultation occurred; ANSWER: Dr. Woodruff - Anniston, AL - 1985 - present. - b. Identify each instance when you have been admitted to .a hospital, clinic, health care facility or received treatment at an emergency room of a hospital, clinic, health care facility or emergency room and the date(s) of each such visit or admission; ANSWER: I have not been admitted to a hospital. 1 c. Identify each insurance agent, insurance company, employer or other entity to whom you or anyone acting on your behalf has submitted an application for life, health or disability insurance from you or which has provided or does provide life, health or disability insurance for you; ANSWER: . Medicaid. d. If applicable, identify each "other chemical" or "pollutant" relating to your affirmative answer to either subparagraph (a) or (b) of interrogatory No. 8. ANSWER: This cannot be answered at this time because Monsanto has refused to identify all the chemicals and pollutants emitted from the plant into the t. DSW 159501 WATER PCB-SD0000067423 community, RESPONSE TO REQUESTS FOR PRODUCTION OF DOCUMENTS 1. Produce all photographs, film or videotape that you have taken or have in your possession, custody or control of the property identified in your response to Interrogatory No. 1(c), the Facility, or any creates, ditches or waterways near the Facility. RESPONSE: ' I do not have any such documents. 2. Produce all documents reflecting or describing meetings or other communications between you and any representative, employee or contractor of Monsanto. RESPONSE: . See Response Number 1. ' 3. Produce all documents which reflect or describe what you contend is a representation or misrepresentation from Monsanto to you regarding or relating to polychlorinated biphenyls (PCSs). ; __ RESPONSE: See Response Number 1. . .4 Produce all documents in your possession, custody or control that originated from or purport to originate from Monsanto, the Alabama Department of Public Health, the Alabama Department of Environmental Management, the Agency for Toxic Substances and Disease Registry or the United States Environmental Protection Agency regarding or relating' to PCBs and/or the claims alleged in the Complaint. RESPONSE: See Response Number 1. 5. Produce all documents in your possession, custody or control reporting or reflecting tests or sampling or results of tests or sampling of dust, soil, blood, tissue, sediment, or other madia for the presence of polychlorinated biphenyls (PCBs). RESPONSE: See Exhibit "A" Attached. 6. Produce all documents which record, reflect or evidence any medical, psychiatric or psychological examination, care or treatment received by you from any medical doctor, psychiatrist, psychologist or other health care practitioner or provider. RESPONSE: See Exhibit "B" Attached. DSW 159502 WATER PCB-SD0000067424 7. produce all documents which record, reflect or evidence any application for life, health or disability insurance made by you or on your behalf. RESPONSE: See Response Number 1. 8. Produce all documents which record, reflect or evidence each instance in which you have been admitted to a hospital, clinic or other health care facility or received treatment at an emergency room of a hospital, clinic or other health care facility. RESPONSE: ' See Response Number l. . 9. Produce an executed original of the "Medical Authorisation*' attached hereto. _ V RESPONSE: See Exhibit "C" Attached. ,} DSW 159503 WATER PCB-SD0000067425 parents and next friend of , BELINDA DANIELLE MCFARLANE Sworn to and subscribed before me this the O day of s. Notary Public My Commission Expires on % jL2X 1912.'. OF COUNSEL: STEWART, CODY P.0. Box 2274 Anniston, AL (205)237-9311 & SMITH, 36202 P.C. DONALD W. STEWART Attorney for Plaintiffs OSW 159504 WATER PCB-SD0000067426 CERTIFICATE OF SERVICE - This is to certify that I have this date served counsel for all parties to this action with a copy of the within and foregoing document by depositing same in the United States mail in a properly addressed envelope with adequate postage affixed thereon and addressed as follows: William S. Cox III, Esq. LIGHTFOOT, FRANKLIN & WHITE, 300 Financial Center 505 North 20th -Street Birmingham, AL 35203 L.L.C. This the of , 1997. DONALD W. STEWART Attorney for Plaintiffs DSW 159505 WATER PCB-SD0000067427 r WflBlt n*t ^iiwteu^ MpOMTnuvn I "|166-112:t0-LB5*0i s MB FINAL PG 1 03 01 i ' DOB: 02/23/as LabCorp 09/06/96- 06:36 'll**-'* MMOI. 3 911/33 DR.1 RONALD STEWART eVaaS, STEWARTi~.fcQDV-4 SMITH ATTT -- -'-- 00 .901 CEIGHTON AVE STE 203 ,u"* r'- *i'.rr L.... 06/14796 I' B6/r4/SST89/06/96j .4023 i TEST ANNISTO.K--:','. , AL 36201-4767-1;.. ; g05iB3-c^7 " ALB - PUL Y UHLOKiNmI ED BIPHENT-LS-PCB rfa.gt^aAlUJi.tlL.iiLLit*- V-rJ. l aTd <; SEESESSSb e5wUeMeeMew^wMeiiBWBB*M.--tW.-fDirTe1tfer*c*t*iToniri-L~irm^-.itn i' 5tt.--.iB--irB.Jc.g/C_.'JJt . PCB-A-roclor 1260 :- . . None Detected ", ___ V e.a --.t 'is.s ..a.: 'i 1 ***-' 3-S j J* " 7-jJ ` . *' .'i' * .'1 <"** rt*-' :i=wDI R ECTOR: - s m^00jBQEgWWW3B^ l.-Wm\ril JAMES .A DAOl'syiTI .MD S3 y*w> > "> . l*. .> I i W nr=K-**T3 rfit ?asni i LAST PAGE;.-OF*REPORT * ----------- ---- V **r*. i*W5' ?> wt^. J 'j roaM^aaBBBBBa&aHM^M^ V I - --.* I j-i.:--. 1 u.". i -1 h-i -II (or!. >. . .*. -. - ; g ** i 1 * *#. '$;WS3^SA WBgaWBBWM^^ ........ -. ... . -* .. . ai^-SSRaaBiiSiSCT h^.Mgafa^6^saaa^^ i ^yraagHWHagga^^ .c- icizzig f i.* . v a ^-^-.^^'-..'.mII...1 air, a m1.;'.^CliLiSS gEESgE5EE5iaHi^.3Kd^^^ SEMgtEaBBBnEtggnaasgfliffli^ vsfwawaaeteaafcw^^ sy*iY v m^aBffiSEbaffiEESSES^SZEES E&ssasi^TajaigaiES^^ oc eIlj*: .,,..-vr rtg','.''-Wa r,.^J.Xf.. LLL e*^LI ~ :&7,jzzzs -^*;t--F-e5,:'i-- ' M^rf-^**w*i**l.**-^ rT^*Ntw: ^ --v ;.*** - * > * - >* Ti,'T CUtiootVY Corporation of America*- Ho RESULTS ARE FLAGGED IN ACCORDANCE WITH ACE DEPENDENT REFERENCE RANGES R PO RT DSW 159506 WATER PCB-SD0000067428 IN THE CIRCUIT COURT FOR CALHOUN COUNTY, ALABAMA MARS HILL MISSIONARY BAPTIST CHURCH, et al., Plaintiffs, v. MONSANTO COMPANY, et al Defendants. ) ) ) ) ) ) Civil Action No. 96-243 )' ) -' ) ) PLAINTIFF CHRISTOPHER RYAN MCFARLANE'B RESPONSE TO DEFENDANTS' FIRST INTERROGATORIES AMD REQUESTS FOR PRODUCTION Comes now the plaintiff, Christopher Ryan McFariane, and files this his response to defendants' First Set of Interrogatories epd Reguests for Production, and says as follows: ' ANSWERS TO INTERROGATORIES . 1. Please provide the following information: ANSWER a. Your full name and, if applicable, your maiden name; ` Christopher Ryan McFariane b. Your date of birth; ANSWER: November 24, 1988 c. Your current and each previous residence address; ANSWER: . 1. 807 Bancroft Ave., Anniston, AL : 2, 809 Bancroft Ave., Anniston, AL . d. Your social security number; ANSWER: . 419-31-2499 '' e. Your current and previous occupations and employers DSW 159507 WATER PCB-SD0000067429 and the dates of such employment; ANSWER: Not applicable. ' f. The address of your current employer and each of your previous employers; ANSWER: Not applicable. > . g. If applicable, the full name(s) of your spouse(s); ANSWER: Not applicable. ' '' h. If applicable, the full names of your children ,or stepchildren; ANSWER: Not applicable. i. The full names of your parents; ' - ANSWER: Jeffery Ryan McFarlane and Karen Belinda McFarlane 2. For each residence identified in your response to interrogatory No. l{c), please provide the following information: a. The dates during which you resided in the residence; ANSWER: 1. 1990 - present. 2. 1988 - 1990. b. The identity of each person who lives or lived with you in the residence; ANSWER: . 1. Parents and siblings. 2. Parents and sister. _ c. State whether you are or were the owner or lessee of the residence and, if not, identify the owner (s) or lessee (s) of the residence during the time you resided in the residence. ANSWER: 1. Parents own. 2. Great-grandparents owned. SW 159508 WATER PCB-SD0000067430 3. State whether you are or vere a member of Mara Hill Missionary Baptist church or Bethel Baptist Church and, if so, the dates during vhich you have been or vere a member of each such Church. ANSWER: Neither. 4. Describe each occurrence or incident and/or method or manner of exposure or potential exposure that you contend caused you to be exposed to polychlorinated biphenyls ("FCBs"), or to have the potential for exposure to FCBs, including the date(s) and location(s) at vhich you contend such exposure or potential for exposure occurred. . ANSWER: He has breathed the air in the Monsanto area all his life. He ate the eggs and meat from the chickens that we raise. He ate the vegetables from the garden; and there is an open ditch on the north side of Monsanto - near the rail road. ' 5. If soil from the property on vhich you currently reside or on property on which you have ever resided has been sampled and/or tested for the presence of FCBs, please state the following: a. The location(s)/address(es) of such sampling and/or testing; ANSWER: ` 807 Bancroft b. The date(s) of such sampling and/or testing; ANSWER: April or May, 1996. . c. Identify the person or entity that conducted such sampling and/or testing; ANSWER: Monsanto people. ANSWER: d. The results of such sampling and/or testing. The front yard had 17% and the back yard next to the ditch had 33%. 6. If dust in the residence in vhich you are currently residing or DSW 159509 WATER PCB-SD0000067431 in residence in which you have ever resided has been sampled and/or tested for the presence of PCBs, please state the following: ' a. The location(s) / addressees) of such sampling and/or testing; . ANSWER; Testing has not been done to my knowledge, b. The date(s) of such sampling and/or testing. ANSWER: See Answer Number 6(a). - c. Identify the person or entity that conducted such sampling and/or testing; ANSWER: See Answer Number 6(a). i d. The results of such sampling and/or testing. ANSWER: See Answer Number 6(a). ' ' .. .. f" 7. If your blood has been tested and/or sampled for the presence of PCBs, please state the following: a. The date(s) of such sampling and/or testing; ANSWER? June 14, 1996 . b. Identify the person or entity that conducted such sampling and/or testing; ANSWER: LabCorp c. The results of such sampling and/or testing. ANSWER: None detected 8. Do you allege: a. Any injury, illness, incapacity, ailment or disease from exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Monsanto from the manufacturing plant operated by Monsanto at Anniston, Alabama (the "Eacility"); ANSWER: Yes, he has a skin rash and spreading warts. DSW 159510 WATER PCB-SD0000067432 He a-lso has difficulty learning; and he has asthma. b. Any emotional or mental distress/ mental anguish, or emotional or psychological injury from exposure or the potential for exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Monsanto from the Facility or from the presence of such PCBs or "other chemicals" or "pollutants" on, at or near the property identified in your response to Interrogatory No. 1(c)? . ANSWER: ' Yes, we worry about what the PCBs may have done to him. 9.If your answer to subparagraph (a) or (b) of Interrogatory'No. 8 is in the affirmative, please answer the fallowing: a. Identify every medical doctor, psychiatrist, psychologist or other health care practitioner or provider by whom you have consulted at any time, including the date(s) on which each such examination, treatment or consultation occurred; ANSWER: Dr. Woodruff - Anniston, AL - 1988 - present. * * * _ .. ** b. Identify each instance when you have been admitted to a hospital, clinic, health care facility or received treatment at an emergency room of a hospital, clinic, health care facility or . emergency room and the date(s) of each such visit or admission; ANSWER: He has not been admitted to a hospital. c. Identify each insurance agent, insurance company, employer or other entity to whom you or anyone acting on your behalf has submitted an application for life, health or disability, insurance from you or which has provided or does provide life, health or disability insurance for you; ANSWER: Medicaid. . d. If applicable, identify each "other chemical" or "pollutant" relating to your affirmative answer to either subparagraph (a) or (b) of Interrogatory No. 8. ANSWER: This cannot be answered at this time because Monsanto has refused to identify all the chemicals and pollutants emitted from the plant into the community. DSW 159511 WATER PCB-SD0000067433 RESPONSE TO REQUESTS FOR PRODUCTION OF DOCUMENTS 1. Produce all photographs, film or videotape that you' have taken or have in your possession, custody or control of the property identified in your response to Interrogatory No. 1(c), the Facility, or any creeks, ditches or waterways near the Facility. RESPONSE: I do not have any such documents. ' 2. Produce all documents reflecting or describing meetings or other communications between you and any representative, employee or contractor of Monsanto. ' RESPONSE: See Response Number 1. .. 3. Produce all documents which reflect or describe what you contend is a representation or misrepresentation from Monsanto to you regarding or relating to polychlorinated biphenyls (PCBs) . RESPONSE: ' See Response Number 1. . .- 4. Produce all documents in your possession, custody or control that originated from or purport to originate from Monsanto, the Alabama Department of Public Health, the Alabama Department of .Environmental Management, the Agency for Toxic Substances and Disease Registry or the United States Environmental Protection Agency regarding or relating to PCBs and/or the claims alleged in the Complaint. `. RESPONSE: See Response Number 1. 5. Produce all documents in your possession, custody or control reporting or reflecting tests or sampling or results of tests or sampling of dust, soil, blood, tissue, sediment, or other media for the presence of polychlorinated biphenyls (PCBs) . RESPONSE: See Exhibit "A" Attached. 6. Produce all documents which record, reflect or evidence any medical, psychiatric or psychological examination, care or treatment received by you from any medical doctor, psychiatrist, psychologist or other health care practitioner or provider. RESPONSE: See Exhibit "B" Attached. 7. Produce all documents which record, reflect or evidence any application for life, health or disability insurance made by you or on your behalf. - DSW 159512 WATER PCB-SD0000067434 RESPONSE: See Response Number 1. 8. Produce ell documents which record, reflect or evidence each instance in which you have been admitted to a hospital, clinic or other health care facility or received treatment at an emergency room of a hospital, clinic or other health care facility. RESPONSE: See Exhibit "C" Attached. 9. Produce an executed original of the "Medical Authorization" attached hereto. '* . RESPONSE: See Exhibit "D" Attached. ' DSW 159513 WATER PCB-SD0000067435 and CHRISTOPHER RYAN MCFARLANE Sworn to and subscribed before me this the day of Notary public My Commission Expires on 19?7. OF COUNSEL: STEWART, CODY P.0. BOX 2274 Anniston, AL (205)237-9311 & SMITH, 36202 P.C. Q~J) DONALD W. STEWART Attorney for Plaintiffs DSW 159514 WATER PCB-SD0000067436 CERTIFICATE OF SERVICE This 'is to certify that I have this date served counsel for all parties to this action with a copy of the within and foregoing document by depositing same in the United States mail in a properly addressed envelope with adequate postage affixed thereon and addressed as follows: William S. Cox III, Esq. LIGHTFOOT, FRANKLIN & WHITE, 3 00 Financial Center 505 .North. 20th- Street Birmingham, AL 35203 L.L.C. - . ' This the 1997 DONALD W. STEWART Attorney for Plaintiffs DSW 159515 WATER PCB-SD0000067437  -- R*frSlCWH0. WfKL | MniNTNAM^ SEJ( ^K%|YR#iJOU ACCOUNf PlCFARLANE , CHRISTOPH PT AO0. 11 007/06 DR. RONALD STEWART j . ..vji in i , U-j. - s. t. 0120566 'JL ArCO^MClMeM DATlfHrtWO 1 DATE WWttO | .l.u.l 1 J>i !'<;. J>u -- t-L- cJtJ rli Uu J !"tl- juilO 1 T*k 'A J V>G/L*/26 06/14/96 39/06/96 1 .432.1 TEST RESULT 205-236-4437 ' HLu uwrrs PULYCHL.Ufti.NH TED tUPHENTLS-PUB | PCB-Aroclor 1S54 C u None Detected , 0.0 - 19.9 . . Bt> Detection Limit = 5.0 mcg/L < l i-`:-i i'OC j. w'i' AiXiifc! DeTjecteo 0.0- - L'J. 9 Jil' Detection Limit = 5.0 mcg/L i/Xisiiw i orv i I Jt 111 O it Lt t \ V VI J. -I * Iki/ IF YOU HAvE ANY QUESTIONS CONTACT - BRANCH: 05-543-2990 LAB: 600-762-4344 i_HST PAGE OF REPORT ID DSW 159516 . SLsoara: Corooraw cr America1''1 Holdi RESULTS ARE ^LAGGED in ACCORDANCE WITH AGE DEPENDENT REFERENCE RANGE; RSPGr.T WATER PCB-SD0000067438 EXHIBIT 3-A DSW 159517 WATER PCB-SD0000067439 r irr` 1 lBi-ns-ooso-o s KB FINAL PG 1 05 01 rAMMM (MUM - DOB i 04/06/89 * r OMMM TiiwlO M STEWfiRT LabCorp' 07/04/98 11>21 ' <wta l _________! 1__________ CANNON tmutnu _ Mann 06/30/9.8 , CHARLES k [ OOT/oa MlnM MMM t 06/30/96 07/04/96 ! 5016 DR. RONALD STEHART 1STEWART, CODY 1 SMITH ATTY 01205620 00 901 LEIGHTON AVE STE EOS 00 1ANNISTON SOS-236--** *37 PL 36201-4769 ALB 2 r ItSTS HnuufLUnb RESULT PL FLAG <jsn$ firrCREfiCE ll/TEnifAL LAft ] PCB-Aroelttr 1E54 " " Non* Dattctad 0.0-19.9 BN Srttctitn Li a it - 5.0 acfi/L PCB--ArDelor I860 it.a cb/I-------- . p.,0 19.9. _ BN Dctactlon Llalt . ,5.0,efl/L_ ~) LAEi BN LABCORP HOLDINGS DIRECTOR! >! _ 1*47-YORK COURT BURLINGTON, NC 2721S-22S0 FRANK HANCOCK HD DIR 1 _____ I DIRECTOR! CONTACT LABORATORY I IF YOU HAVE ANY QUESTIONS CONTACT - BRANCH! 05-5*3-2990 LAB: 600-621-6037 LAST PAGE OF REPORT !| i i 1 A 4 l ~f - sirZ' "T" ~ ` , J .. PtPWTT Oli98uteito>YfapoKM0ftd#iiwiiiJ^lbtdiiigi im^mtatnad *Sf8WtAWfc^95^;caCi^*i3Sj!*5rjJW^fcia<*S9>3^'^ DSW 159518 700323001-0001 WATER PCB-SD0000067440 EXHIBIT 3-B DSW 159519 WATER PCB-SD0000067441 m THE CIRCUIT COURT FOR CALHOUN COUNTY, ALABAMA MARS HILL MISSIONARY BAPTIST CHURCH, et al.; Plaintiffs, v. MONSANTO COMPANY, et al.; Defendants. ) ) ) '' ) ). ) Civil Action No.: CV-96-243 ) ) ) ) PLAINTIFF CHARLES CANNON, JR.'S RESPONSES TO DEFENDANT. MONSANTO'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION TO PLAINTIFFS Plaintiff Charles Cannon, Jr. responds as follows to the interrogatories propounded by defendant Monsanto Company: INTERROGATORY NO. 1: Please provide the following information: a. Your lull name and, if applicable, your maiden name:" RESPONSE; Charles Cannon, Jr. b. Your date of birth: . . RESPONSE: April 6, 1989. c. Your current and each previous residence address: RESPONSE: 675 South Dallas Ave., San Bernardino, CA 92410 - Current d. Your social security number: RESPONSE: 616-58-8710. * DSW 159520 WATER PCB-SD0000067442 e. Your current and previous occupations and employers and the dates of each such employment: RESPONSE: Not applicable. f. The address of your current employer and each of your previous employers: RESPONSE: Not applicable. g. If applicable, the full name(s) of your spouse(s): RESPONSE: Not applicable. h. If applicable, the full names of your children or stepchildren: RESPONSE: Not applicable. i. The full names of your.parents: < ", ' RESPONSE: Mamie Trammell, mother. INTERROGATORY NO. 2: For each residence identified in your response to Interrogatory No. 1(c), please provide the following information: a. The dates during which you resided in each residence: RESPONSE: DATE RESIDENCE . 1989-1996 675 South Dallas Ave., San Bernardino, CA 92410 b. The identity of each person who lives or lived with you in the residence: RESPONSE: 675 S. Dallas Ave.: Mamie Trammell, Porscha T. Cannon- c. State whether you are or were the owner or lessee of the residence and, if not, identify the owner(s) or lessee(s) of the residence during the time you resided in the residence. * DSW 159521 WATER PCB-SD0000067443 RESPONSE: 675 S. Dallas Aye. - Mamie Trammell (mother), owner INTERROGATORY NO 3.: State whether you are or were a member of Mars Hill Missionary Baptist Church or Bethel Baptist Church and, if so, the dates during which you have been or were a member of each such Church. RESPONSE: I have never been a member of either church. INTERROGATORY NO. 4: Describe each occurrence or incident and/or method or maimer of exposure or potential exposure that you contend caused you to be exposed to polychlorinated biphenyls ("PCBs") or to have the potential for exposure to PCBs, including"the date(s) and locations) at which you contend such exposure or potential for exposure occurred. RESPONSE: I have vacationed at 712 Montrose Avenue, 714 Montrose Avenue, 800 Montrose Avenue, and 806 Ferron Avenue, Anniston, Alabama for approximately two to four weeks every year. I have also played in the ` yards and residences above. INTERROGATORY NO. 5: If soil from the property on which you currently reside or on property on which you have ever resided has been sampled and/or tested for the presence of PCBs, please state the following: a. The locadon(s)/address(es) of such sampling and/or testing: RESPONSE: 714 Montrose Avenue, Anniston, Alabama. 800 Montrose Avenue, Anniston, Alabama. DSW 159S22 WATER PCB-SD0000067444 Lots # 4 and #5 Montrose Springs Cobb Town, Anniston, Alabama. 712 Montrose Avenue, Anniston, Alabama. b. The date(s) of such sampling and/or testing: RESPONSE: Unknown. c. Identify the person or entity that conducted such sampling and/or testing; and RESPONSE: Unknown. ' d. The results of such sampling and/or testing. RESPONSE: Unknown. INTERROGATORY NO. 6: t If dust in the residence in which you are currently residing or in a residence in which you have ever resided has been sampled and/or tested for the presence of PCBs, please state the following: a. The location(s)/address(es) of such sampling and/or testing: RESPONSE: 712 Montrose Avenue, Anniston, Alabama. 714 Montrose Avenue, Anniston, Alabama. 800 Montrose Avenue, Anniston, Alabama.> Lots # 4 and #5 Montrose Springs Cobb Town, Anniston, Alabama. b. The date(s) of such sampling and/or testing; RESPONSE; Unknown. c. Identify the person or entity that conducted such sampling and/or testing; and RESPONSE: Unknown. d. The results of such sampling and/or testing. DSW 159523 WATER PCB-SD0000067445 RESPONSE: Unknown. INTERROGATORY NO. 7: If your blood has been tested and/or sampled for the presence of PCBs, please state the following: a. The date(s) of such sampling and/or testing: RESPONSE: Not applicable. b. Identify the person or entity that conducted such sampling and/or testing: and RESPONSE: Not applicable. c. The results of such sampling and/or testing. RESPONSE: Not applicable. ' ~ i I \ ' INTERROGATORY NO. 8: Do you allege: a. Any injury, illness, incapacity, ailment or disease from exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Monsanto from the manufacturing plant operated by Monsanto at Anniston, Alabama (the "Facility1^; or RESPONSE: Yes. b. Any emotional or mental distress, mental anguish, or emotional or psychological injury from exposure or the potential for exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Monsanto from the Facility or from the presence of such PCBs or "other chemicals" or "pollutants" on, at or near the property identified in your response to Interrogatory No. 1(c)? ^ DSW 159524 WATER PCB-SD0000067446 RESPONSE: No. INTERROGATORY NO. 9: If your answer to subparagraph (a) or (b) of Interrogatory No. 8 is in the affirmative, please answer the following; a. Identify every medical doctor, psychiatrist, psychologist or other health care practitioner or provider by whom you have ever been examined or treated or with whom you have consulted at any time, including the date(s) on which each such examination, treatment or consultation occurred: RESPONSE: Medical - Kaiser Pennanente, Fontana, CA. 'i b. Identify- each instance when you have been admitted to a hospital, clinic of other health care facility or received treatment at an emergency room of a hospital, clinic or other health care facility including the identity of the hospital, clinic, health care facility or emergency room and the date(s) of each such visit or admission: RESPONSE: Kaiser Pennanente, Fontana, CA. c. Identify each insurance agent, insurance company, employer or other entity to whom you or anyone acting on your behalf has submitted an application for life, health or disability insurance from you or which has provided or does provide life, health or disability insurance for you; and. RESPONSE: Kaiser Pennanente. d. If applicable, identify each "other chemical" or "pollutant" relating to your affirmative answer to either subparagraph (a) or (b) of Interrogatory No. 8. DSW 159525 WATER PCB-SD0000067447 RESPONSE: Any chemical released by Monsanto at its Anniston Facility. DSW 159526 WATER PCB-SD0000067448 REQUESTS FOR PRODUCTION OF DOCUMENTS REQUEST FOR PRODUCTION NO. 1; All photographs, film or videotape that you have taken or have in your possession, custody or control of the property identified in your response to Interrogatory No. 1(c), the Facility, or any creeks, ditches or waterways near the Facility. RESPONSE: I have none. i* REQUEST FOR PRODUCTION NO. 2: All documents reflecting or describing meetings or other communications between you and any representative, employee or contractor of Monsanto. RESPONSE: I do not have any such documents. REQUEST FOR PRODUCTION NO. 3: All documents which reflect or describe what you contend is a representation or misrepresentation from Monsanto to you regarding or relating to polychlorinated biphenyls (PCBs). RESPONSE: I do not have any such documents in my possession. REQUEST FOR PRODUCTION NO. 4: All documents in your possession, custody or control that originated from or purport to originate from Monsanto, the Alabama Department of Public Health, the Alabama Department of Environmental Management, the Agency for Toxic Substances and Disease Registry or the United States Environmental Protection Agency regarding or relating to PCBs and/or the claims alleged in the Complaint. RESPONSE: I do not have any such documents. DSW 159527 WATER PCB-SD0000067449 REQUEST FOR PRODUCTION NO. 5: All documents in your possession, custody or control reporting or reflecting tests or sampling or results of tests or sampling of dust, soil, blood, tissue, sediment, or other media for the presence of polychlorinated biphenyls (PCBs). RESPONSE: None. .. THE FOLLOWING REQUESTS FOR PRODUCTION ARE PROPOUNDED ONLY IF YOU ANSWERED AFFIRMATIVELY ANY SUBPART OF INTERROGATORY NO. 8. REQUEST FOR PRODUCTION NO, 6: All documents which record, reflect or evidence any medical, psychiatric or psychological examination, care or treatment received by you from any medical doctor, psychiatrist, psychologist or other health care practitioner or provider. RESPONSE: I do not have any such documents. REQUEST FOR PRODUCTION NO. 7: All documents which record, reflect or evidence any application for life, health or disability insurance made by you or on your behalf. RESPONSE: I do not have any such documents. REQUEST FOR PRODUCTION NO. 8: All documents which record, reflect or evidence each instance in which you have been admitted to a hospital, clinic or other health care facility or received treatment at an emergency room of a hospital, clinic or other health care facility. RESPONSE: I do not have any such documents. DSW 159528 WATER PCB-SD0000067450 REQUEST FOR PRODUCTION NO. 9: An executed original of the "Medical Authorization" attached hereto. RESPONSE: I object to signing this document. The defendant has available to it procedures under the rules of discovery for securing my medical records. i i t DSW 159529 WATER PCB-SD0000067451 TRAMMELL, as mother and next friend of CHARLES CANNON, JR,, a minor STATE OF CALIFORNIA San BernardinCQUNTY ) ) Before me, the undersigned authority, a Notary Public in and for said State and County, personally appeared MAMIE TRAMMELL, as mother and next friend of CHARLES CANNON, JR., a minor, who is known to me and who, being first duly sworn, deposes and says that, being informed ofthe contents of such instrument, she executed the same voluntarily on the date set forth below. Given under my hand and seal of 16th day of October 1996. GRS1 GEtINY HORNSBY _ Comm. No. 1021116 " NOTARY PUBLIC4 CAUfOMIA W UN RERtUJOIllO MUJ1TY M My Comm. E*p. April 3.1998 *"* Notary Publi/ 9 My Commission Expires: 4/^/qr Donald W. Stewart, Atty. and/or Gary P. Cody, Atty, for the Plaintiffs STEWART, CODY & SMITH, P.C. 650 Park Place Tower 2001 Park Place Birmingham, AL 35203 (205) 458-3050 DSW 159530 WATER PCB-SD0000067452 CERTIFICATE OF SERVICE I hereby certify I have this day served a true and correct copy of the foregoing discovery to the following: Adam K. Peck, Atty. LIGHTFOOT, FRANKLIN & WHITE, L.L.C. 300 Financial Center 505 North 20* Street Birmingham, AL 35203 (205) 581-0700 * ' i* by placing a copy of same in the United States mail, first class postage prepaid, on this the 24th day of December, 1996. . . .. Gary P. Cody ' Attorney for the Plaintiffs DSW 159531 WATER PCB-SD0000067453 EXHIBIT 3-C DSW 159532 WATER PCB-SD0000067454 If r Ijmiwii* typf Pif4a| LIS rwpBrtiuwt 181-112-0051-0 s MB FINAL PG DOB: 05/ 1 7/8 MNM CANNON PamtWW 1 WiMM ( 06/30/98 , PORSHA 1 Sh F 4ffHYnUn| 0I&/01 1 DwIimv 06/30/98 07/04/98 5017 j 03 01 CWkwauMA STEWART LabCorp' 07/04/98 11s21 toMO ' DR. RONALD STEWART 01058e<) STEWART, CODY t, SMITH ATTY 00 901 LEIGHTON AVE STE 02 00 ANNISTON , AL 3601~4769 L05--36--4437 ALB REFERENCE interval PCB-Aroclor 1254* ' None Detected 0.0- 19. 9 BN Detection Limit ** 5.0 mcg/L PCB-Arbclor I860 ------ ------------- ... None Det ected 0.0 - 19. 9 Detection Limit = 5. 0 mcg/L ........ - ...... - .. t -1 .4 BN LAB: BN LABCORP HOLDINGS DIRECTOR: .. JL447 Y.9?K COURT BURLINGTON, NC 715-230,,, FRANK HANCOCK MD DIR DIRECTOR: CONTACT LABORATORY IF YOU HAVE ANY QUESTIONS CONTACT - BRANCH: 05-543-2990 LAB: 800-621-8037 LAST PAGE OF REPORT R EPORT DSW 159533 199B labafawiy Corpotaiion of Amaiica' Holding? All Rights Reserved WATER PCB-SD0000067455 EXHIBIT 4-A DSW 159534 WATER PCB-SD0000067456 57-11--0049--0 I too fflNAL.1 Hr i . . . 03 Ol Slw . '** 1 *MW<rvl ' 1 ' 09/17/96 *V:5- ' DOB* OS/SO/Ef. nien^S &mrtD V !l| S" fWlM . ANDERSON, IBiIiWM DOUGLAS #*frw STEWART M 042/00 DR. RONALD STEWART STEWART, CODY t, SMITH ATTY 0120S 00 tm tmmt. 1 | 09/14/92| r 9 DwcL--i* f 03/H/VB TESTS ftpIBtWH | OS/37/*el S07B RESULT 90J LEIGHTON ftVD. s^E 202 ANNISTON , AL 360i-47fc9 ig56-c36-4t37__ ALG ___ ____ "" n ErEREHm interwu_ 00 22 PCB, AROCHLORS 1254/1260, PL __ ____ o: PCS--Aroclor 1254""" * *None Detected . lU*'^ |Tr. . . _____p.0 -^9.9 Detection Liait 5.0 *cb/L 5 PCB-Aroclor 1260 36.3 H acg/L 0.0 - 19.9. t Detection Liai.t_. 5,.0,.ea^L,, g. , . _,BN.,LflBCORR,^URLINSTgfrL^.^DIRECTQR^.-^-JRflfc^HNCIlCK^jr^DTF pwe,, -VQ^QORTZBUgUNGI^CNC------------------- ill ...*1I-.-. I i ig-n 0:! ':s"si m " bIRECT0Rl~0KTACf LABORATORY IF YOU HAVE ANY~iCiESTIONS 'CONTACT'-'BRANCH* 56-543-2990 LAB*'BOO-621 -8037 ............. .. pflGE F *:l ::: :'j; w. . ' `!VWV.* ' Vjji*'*'. *\ .if#-.. j A.'wliajjigi.VtiArfVA,MS<M ilHri * *T ZS^-JliSGSS&l&ffiEaSgi DSW 159535 700147001-0001 WATER PCB-SD0000067457 EXHIBIT 4-B DSW 159536 WATER PCB-SD0000067458 POSITIVE TEST: POLYCHLORINATED BIPHENYLS-PCB LIMITS: PCB-AROCLOR1254 0.0 - 19.9 DETECTION LIMIT * 5.0 mcg/L PCB-AROCLOR 1260 0.0 - 19.9 DETECTION LIMIT = 5.0 mcg/L CLIENTS RESULT DATE OF BIRTH DATE TESTED 1 Gerald Abbott .2 Anna B. Abernathy . 3 James Abernathy 4 Ralph Abernathy 5 Sabrina Abernathy 6 Tommy Abernathy 7 Mary Sue Adams 8 Sadie Adams 9 Buford Adamson 10 Helen Adamson 11 Martha Akles 12 Trent Akles 13 Charles Alexander 14 Dorothy Allen 15 Linda Alien - 6 Harold Almond 17 Danny Alston 18 Richard Ammerson 19 Ruth Ammerson 20 Douglas Anderson 21 Bobby Andrews 22 Carol Angle 23 Kathy Angle 24 Minnie Angle 25 Travis Angle 26 Carol Armstrong 27 Stephen Armstrong 28 Vetayna Armstrong 29 Edna Arnold 30 Joyce Arnold 22.6 18.3 31.3 11.8 11.3 18.0 17.1 14.9 24.7 *35/55.0 25.7 10.5 8.8 7.8 111.1 30.0 12.5 11.2 8.7 36.3 7.5 8.0 7.9 15.0 14.5 33.3 <3.0 3.4 23.8 15.5 . 8/22/33 8/31/34 11/26/42 2/22/70 6/9/57 4/3/34 4/3/32 03/23/23 8/3/41 5/11/42 5/22/71 6/7/44 11/30/37 10/25/48 3/23/34 . 02/26/46 05/25/20 10/18/22 08/30/86 06/25/59 07/12/47 12/1/51 01/22/27 2/18/49 7/21/40 3/13/97 09/14/98 09/17/98 05/21/98 6/7/96 11/19/98 12/18/96 11/30/98 05/26/98 10/22/96 11/19/98 11/19/98 11/16/98 12/14/98 11/19/97 3/3/97 03/10/98 11/11/97 11/11/97 09/14/98 05/20/98 09/21/98 6/7/96 ' 11/21/97 6/7/96 6/1/49 2/14/59 6/10/96 12/3/98 DSW 159537 PLAINTIFFS EXHIBIT 'SePf- WATER PCB-SD0000067459 EXHIBIT 4-C DSW 159538 WATER PCB-SD0000067460 IN THE CIRCUIT COURT FOR CALHOUN COUNTY, ALABAMA SABRINA ABERNATHY, ET AL. , Plaintiffs, v. MONSANTO COMPANY, et al.# Defendants. ) )) ) ) Civil Action No. 96-269 ) ) ) ) PLAINTIFF DOUGLAS L. ANDERSON'S RESPONSE TO DEFENDANTS FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION Comes now the plaintiff, DOUGLAS L. ANDERSON, and files this his response to defendants' First Set of Interrogatories and Requests for Production, and says as follows: ANSWERS TO INTERROGATORIES _ 1. Please provide the following information:. a. Your full name and, if applicable, your maiden name; ANSWER: Douglas Lorenzo Anderson ANSWER: b. Your date of birth; August 30, 1956 ~ c. Your current and each previous residence address; ANSWER: 1. 3819 Brookcrest, Decatur, GA 2. 2231 McCoy Avenue, Anniston, AL 3. 1516 Stephens Avenue, Anniston, AL 4. 1411 Pine Avenue, Anniston, AL DSW 159539 WATER PCB-SD0000067461 5. 1302 Brown Avenue, Anniston, AL 311 H~Street, Anniston, AL 7. Amnion Street, Anniston, AL 8. 8 04 Sparks Street, Anniston, AL d. Your social security number; answer: 422-82-0607 e. Your current and previous occupations and'employers and the dates of such employment; ANSWER: ,, 1. Construction, Sunbelt Glass & Aluminum, Decatur, GA, 1998 - Present 2. Janitor, Central Casting, Anniston, AL, 1997 - 1998 3. Forklift Operator, Boozer Lumber Co. Anniston, AL, 1995 - 1997 4. Forklift Operator, Draper Scrap, Anniston, AL, 1996 - 1997 (client worked jobs # 3&4 at same time) 5. City of Anniston Fire Dept., Anniston, AL, 1982 - 1985 Client worked odd jobs in between years. f. The address of your current employer and each of your previous employers; _ ANSWER: See Answer Number 1(e) g. If applicable, the full name(s) of your spouse(s); ANSWER: Hazel Ervin Anderson, (separated) h. if applicable, the full names of your children or stepchildren; ANSWER: Nicholas Chiliabe Ervin DSW 159540 WATER PCB-SD0000067462 i. The full names of your parents; ANSWER: >. Elma Gertrude Anderson Vincent and Billy Lewis Tippins 2. For each residence identified in your response to Interrogatory No. l(c)/ please provide the following information: a.. The dates during which you resided in the residence; ANSWER: 1. 1998 - Present . 2 . 1997 - 1998 3. 1991 - 1997 4. 1973 - 1991 5. 1972 - 1973 6. 1965 - 1972 7. 1962 - 1965 8.. 1956 - 1962 b. The identity of each person who lives or lived with you in the residence; ANSWER: 1. Brother; Webster Anderson, sister-in-law; Daffney Anderson, nephews; Ryan and Webster Anderson Jr. . 2. Self 3 . Father, mother, niece & nephew; Jasmine Nicole Vincent and Charles Rashad Woods. 4 . Father, mother, and siblings; Douglas Lorenzo and Webster Jerome Anderson, Christopher, Donte Pierre and Charles Edward Vincent Jr. 5. Father, mother and siblings 6- Mother, aunt, Mary Anderson Tippins, uncle, James Tippins, cousins; James Howard, William, Anthony, Randy, Mary, Janice, Linda, and Judy Tippins, and DSW 159541 WATER PCB-SD0000067463 siblings 7-Mother, aunt, uncle cousins and siblings 8. Mother, grandmother, grandfather, aunts, Cora and Mary Anderson, uncles, Ben Ernest and Jesse Anderson c. State whether you are or were theowner r lessee of the residence and/ if not/ identify the owner(s) or lessee(s) of the residence during the time you resided in the residence. ANSWER: 1. Brother owns 2. Leased, owner unknown 3. Parents Lease, owner, Mr. Trammell 4. Parents leased, owner, Mr. Kidd 5. Parents leased, owner unknown 6. Aunt owned 7. Aunt leased, owner unknown 8. Parents leased, owner unknown 3. State whether you are or were a member of Mars Hill Missionary Baptist Church or Bethel Baptist Church and/ if so, the dates during which you have been or were a member of each such Church. ANSWER: Neither ^ 4. Describe each occurrence or incident and/or method or manner of exposure or potential exposure that you contend caused you to be exposed to polychlorinated biphenyls ("PCBs"), or to have the potential for exposure to PCBs, including the date(s) and location(s) at which you contend such exposure or potential for exposure occurred. ANSWER: I feel that I was exposed by breathing the air and drinking the water. I lived in back of Monsanto for a number of years. Our family grew our own vegetables and raised hogs. We consumed most of what we raised in the DSW 159542 WATER PCB-SD0000067464 soil. The fumes were so strong at times it was very hard tar-hreathe. There was an all around bad odor. 5. If soil from the property on which you currently reside or on property on which you have ever resided has been sampled and/or tested for the presence of PCBs, please state the following: a. The location (s)/address {es} of such sampling and/or testing; - ANSWER: . Testing has not been done to my knowledge. b. The date(s) of such sampling and/or testing; ANSWER: _ See Answer Number 5(a) . c. Identify the person or entity that conducted such sampling and/or testing; ANSWER: See' Answer Number 5(a). d. The results of such sampling and/or testing. ANSWER: See Answer Number 5(a). 6. If dust in the residence in which you .are currently residing or in a residence in which you have ever resided has been sampled and/or tested for the presence of PCBs, please state the following: a. The location (s)/address (es) of such sampling and/or testing; ANSWER: Testing has not been done to my knowledge. b. The date(s) of such sampling and/or testing. ANSWER: See Answer Number 6(a). c. Identify the person or entity that conducted such sampling and/or testing; ANSWER: See Answer.Number 6(a). d. The results of such sampling and/or testing. DSW 159543 WATER PCB-SD0000067465 ANSWER: See Answer Number 6(a). 7. if your blood has been tested and/or sampled for the presence of pcbs, please state the following: a. The date(s) of such sampling and/or testing; ANSWER: September 14, 1998 - b. Identify the person or entity that conducted such sampling and/or testing; . ANSWER: ANSWER: LabCorp c. The results of such sampling and/or testing. 36.3 H ncg/L 8. Do you allege: a. Any injury, illness, incapacity, ailment or disease from exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Monsanto from the manufacturing plant operated by Monsanto at Anniston, Alabama (the "Facility"); ANSWER: I have bleeding from my bowels, shoulder pain, general hand cramps, high blood pressure, headaches, and bronchitis b. Any emotional or mental distress, mental anguish, or emotional or psychological injury from exposure or the potential for exposure to PCBs or "other chemicals" or "pollutants" you allege were "released" by Monsanto from the Facility or from the presence of such PCBs or "other chemicals" or "pollutants" on, at or near the property identified in your response to Interrogatory No. o.(c}? ANSWER: Yes, I worry about what the PCB's may have done to me. 9. If your answer to subparagraph (a) or (b) of Interrogatory No. 8 is in the affirmative, please answer the following: a. Identify every medical doctor, psychiatrist, psychologist or other health care practitioner or provider by whom you have consulted at any time, including the date{s) on which each such examination, treatment or consultation occurred; . DSW 159544 WATER PCB-SD0000067466 ANSWER: 1. Dr. Smith, Anniston, AL, 1999 Client says that he always uses the ER when sick. h. Identify each instance when you have been admitted to a hospital/ clinic, health care facility or received treatment at an emergency rooh of a hospital, clinic, health care facility or emergency room- and the date(s) of each such visit or admission; ANSWER: - 1. Anniston Family Practice, Anniston., AL, dates vary 2. Regional Medical Center ER, Anniston, AL, dates vary 3. Stringfellow Memorial Hospital, ER, Anniston, AL, 1999 c. Identify each insurance agent, insurance company, employer or other entity to whom you or anyone acting on your behalf has submitted an application for life, health or disability insurance from you or which has provided or does provide life, health ox disability insurance for you; ANSWER: Glazers Union Medical Health d. If applicable, identify each "other chemical" or "pollutant" relating to your affirmative answer to either subparagraph (a) or (b) of Interrogatory No. 8. ANSWER: This cannot be answered at this time because Monsanto has refused to identify all the chemicals and pollutants emitted from the plant into the community. RESPONSE TO REQUESTS FOR PRODUCTION OF DOCUMENTS 1. Produce all photographs, film or videotape that you have taken or have in your possession, custody or control of the property identified in your response to Interrogatory No. 1(c) , the Facility, or any creeks, ditches or waterways near the Facility. RESPONSE: I do not have any such documents. 2. Produce all documents reflecting or describing meetings or other communications between you and any representative, employee DSW 159545 WATER PCB-SD0000067467 or contractor of Monsanto. RESPONSE: s See Response Number 1. 3. Produce all documents which reflect or describe what you contend is a representation or misrepresentation from Monsanto to you regarding of 'relating to polychlorinated biphenyls {PCBs) . RESPONSE: See Response Number 1. - 4. Produce all documents in your possession, custody or control that originated from or purport to originate from Monsanto, the Alabama Department of Public Health, the Alabama Department of Environmental Management, the Agency for Toxic Substances and Disease Registry _or the United states Environmental Protection Agency regarding or relating to PCBs and/or the claims alleged in the complaint. . RESPONSE: See Response Number 1. 5. Produce all documents in your possession, custody or control reporting or reflecting tests or sampling or results of tests or sampling of dust, soil, blood, tissue, sediment, or other media for the presence of polychlorinated biphenyls (PCBs) . RESPONSE: See Exhibit "A" Attached. 6. Produce all documents which record, reflect or evidence any medical, psychiatric or psychological examination, care or treatment received by you from any medical doctor, psychiatrist, psychologist of other health care practitioner or provider. RESPONSE: I do not have any such documents. 7. Produce all documents which record, reflect or evidence any application for life, health or disability insurance made by you or on your behalf. RESPONSE: See Exhibit HB" Attached. 8. Produce all documents which record, reflect or evidence each instance in which you have been admitted to a hospital, clinic or other health care facility or received treatment at an emergency room of a hospital, clinic or other health care facility, RESPONSE: See Response Number 6. DSW 159546 WATER PCB-SD0000067468 9. produce an executed original of the "Medical Authorization',1 attached hereto. RESPONSE: See Exhibit MC" Attached. i DSW 159547 WATER PCB-SD0000067469 Mfctdfo /yr: Douglras L. 'Andersof)'' Sworn to and subscribed before me this the f*fa~ Notary Public; _ if j My Commission Expires on //f '0'S , 1999, OF COUNSEL: STEWART & SMITH, P.C. P.O. Bax 2274 Anniston, AL 36202 (256) 237-9311 DONALD W. STEWART Attorney for Plaintiffs DSW 159548 WATER PCB-SD0000067470 CERTIFICATE OF SERVICE This is to certify that I have this date served counsel for all parties to this action with a copy of the within and .foregoing document by depositing same in the United States mail in a properly addressed envelope with adequate postage affixed thereon and addressed as follows: William S. Cox III, Esq. LIGHTFOOT, FRANKLIN & WHITE, L.L.C. ' 300 Financial Center 505 North 20th Street Birmingham, AL 35203 . orSThis the ' of 1999. DONALD W. STEWART. Attorney for Plaintiffs DSW 159549 WATER PCB-SD0000067471 f In***! J tr . ,ll'J1 \ 57- 112-0049-0 ! -fi-'-i.-.-TiS. ? 'INAL PG 1 vow jir LabGorp' '.i<- Jj 7 /'Vi) 09 : St DOE v *. ANDERSON, DOUGLAS -'' *- t 4f M ! 042/00 STEWART ;DR. RONALD STEWART 01205820 STEWART, CODY t SMITH ATTY 00 ! :901 LEIGHTON AVE STE 02 -00 } 'ANNISTON , AL 36201-47-69 | 109/14/93j 09/14/33j 09/17/9fli 3078 J 'v36-36-4437 ALG . REFERENCE INTERVAL J LAB PUB, AHUCHLORS 1254/1260, PL PCB--Aroclor 1254 None Detected 0. 0 - 19, 9 BN Detection Lieit >= 5,0 ecg/L PCS--Aroclor 1260 36.3 H bcq/L 0.0 - 19.9 BN Detection Lieit 5. 0, ecg/L.., LAB: BN LASCORP BURLINGTON DIRECTOR: 1447 YORK COURT BURLINGTON, NC 7722115-2230 FRANK HANCOCK MD DIR .. DIRECTOR: CONTACT LABORATORY f > ' IF YOU HAVE ANY QUESTIONS CONTACT - BRANCH: 56-543-2990 LAB:'BOO-62!-6037 . LAST PAGE OF REPORT Iun i ^ ..-'v .-v .. . - . ... ^ : REPORT CT997 Laraaicry CsiDMiian oi Annua4 HC'rfUngs Aii Fiipjs tasrvifi DSW 159550 WATER PCB-SD0000067472 GLAZIERS LOCAL 1930 HEALTH ACD WELFARE PLAN GROUP HEALTH PLAN IDEflTIFICATIDfJ CARD To Verify Benefits Calor Write: GLAZIERS LOCAL . LOCAL IMS HEALTH MO WELFARE PUN 2167 NorttiaJce Partway. Suite 106, Bldg. /9 Tuder (Atlanta), Georgia 30081 800-959-3853 (770) 931-3953 THIS PLAN ADMINISTERED BY: ADMINISTRATIVE SERVICES, INCORPORATED r DSW 159551 WATER PCB-SD0000067473 . SPECIAL AUTHORIZATION FOR RELEASE OF MEDICAL INFORMATION l da hereby authorize any hospital. physician or physician's office, substance abuse treatment facilitv program, including any federally assisted substance abuse treatment facility or program, or any other health care from which t have sought care, including, but not limited to, Northeast Alabama Regional Medical Center (collcc-" vHv "Health Care Providers") to release, upon presencation of this authorization, to Donald W, Stewart. Esquire, Steward Cody & Smith, L ID l Layton Avenue. Post Office Box 2274, Anniston, Alabama, 36202, and Monsanto ConTpanv and its counsel, Lightfooc, Franklin Sc. White, LL.P., 300 Financial Center, 505 North' 20* Street, Birmingham, Alabama 35203-2706, the following information: All medical records, physician's's records, surgeon's records, radiology reports, pathology mm slides, [issues, physicals and histories, laboratory reports, discharge summaries, progress notes, consultations, -prescriptions, nurses' cates, physical therapy notes, correspondence, psychiatric^ records, psychological records, insurance records, consent for treatment, records regarding HIV testing and/or status as an HIV or AIDS patient, records regarding drag and/or alcohol use and/or treatment, consent for treatment or any other papers cooeenuBg any treaaneat examination, periods or stays ofhospitalizatioc, confinement, diagnosis or other information pertaining andconcerningany physical or mental condition. I do understand the purpose of this disclosure is to facilitate discovery regarding certain legal claims I havasserted against Monsanto Company, which are pending b the Circuit Court ofCalhoun County, Alabama. I understand that my medical records may contain confidential remarks furnished by me, my family, my physician, or other health care professional l may net have knowledge ofwhat my Emily said, my family may not have knowledge ofwhat I said. I nor my family, may have knowledge ofwhat a doctor or other health care professional my have said and is reflected b my medical records, [ALSO UNDERSTAND THATTHE HEALTH CARE P ROVTD ERS ARE HEREBY AUTHORIZED TO RELEASE INFORMATION CONCERNING DRUG AND/OR.ALCOHOL USE OR TREATMENT, PSYCHIATRIC CONDITION, HTV TESTING, AND/OR STATUS AS AN HTV OR AIDS PATIENT. . ' , l hold the Health Car: Providers, bcludbg, but not limited to, Northeast Alabama Regional Medical Center, harmless form any and all damages which might result to myself, my relatives or heirs, from the use of this bformation being disclosed to the persons and for the purposes specified above. This Authorization also bcludes the authority to copy and inspect any and all such records. This Authorization is conttnubg b nature and is to be given full force and effect to release any and all of the foregobg bformation teamed or determbed after the date hereof. A copy of this Authorization may be used b place of and with the same force and effect as the original This Authorization is subject to revocation by me at any time, except to the extent that action has been taken.in reliance thereon. a-/7-?? Date This Authorization expires December 31, 1999. T)ouc,Us Patient't Snow (Print w type sleatly) L- i:t*n i 5 if --l ^ ^ o ^ 7 5T- 3 0- S6 Patient^ Dice ofatnix . DSW 159552 WATER PCB-SD0000067474 Document Break Code39 WATER PCB-SD0000067475 DEPARTA&NT OF HEALTH & HUMAN SERVICES locr 30 2001 yj Public Health Service Agency for Toxic Substances and Disease Registry Atlanta GA 30333 October 25, 2001 Mr. Craig Branchfield Solutia, Incorporated 702 Clydesdale Avenue Anniston, AL 36201-5328 Dear Mr. Branchfield: Enclosed please find a copy of the health consultation for Solutia, Inc. [Aliases: Anniston PCB Site (Monsanto Company) and Monsanto Company], Anniston, Calhoun County, Alabama, dated October 22, 2001. The purpose of this exposure investigation was to assess the level of exposure to polychlorinated biphenyls for children and their families living near the facility who would most likely have been affected. Please address correspondence to the Chief, Program Evaluation, Records, and Information Services Branch, Division of Health Assessment and Consultation, Agency for Toxic Substances and Disease Registry, ATTN: Solutia, Inc., 1600 Clifton Road, NE (E56), Atlanta, Georgia 30333. If there are any questions, please direct them to Kenneth Orloff, the health assessor, at (404) 498-0506. Sincerely yours, Enclosure IL-Max M. Howie, Jr. I Chief, Program Evaluation, Records, ' and Information Services Branch Division of Health Assessment and Consultation You May Contact ATSDR TOLL FREE at 1-888-42ATSDR or Visit our Home Page at: http://www.atsdr.cdc.gov DEFENDANT'S EXHIBIT 1080 WATER PCB-SD0000067476 Health Consultation EXPOSURE INVESTIGATION SOLUTIA, INC. [Aliases: ANNISTON PCB SITE (MONSANTO COMPANY) AND MONSANTO COMPANY] ANNISTON, CALHOUN COUNTY, ALABAMA EPA FACILITY ID: ALD004019048 OCTOBER 22, 2001 U S. DEPARTMENT OF HEALTH AND HUMAN SERVICES Public Health Service Agency for Toxic Substances and Disease Registry Division of Health Assessment and Consultation Atlanta, Georgia 30333 WATER PCB-SD0000067477 Health Consultation: A Note of Explanation An ATSDR health consultation is a verbal or written response from ATSDR to a specific request for information about health risks related to a specific site, a chemical release, or the presence of hazardous material. In order to prevent or mitigate exposures, a consultation may lead to specific actions, such as restricting use of or replacing water supplies; intensifying environmental sampling; restricting site access; or removing the contaminated material. In addition, consultations may recommend additional public health actions, such as conducting health surveillance activities to evaluate exposure or trends in adverse health outcomes; conducting biological indicators of exposure studies to assess exposure; and providing health education for health care providers and community members. This document has previously been released for a 30 day public comment period. Subsequent to the public comment period, ATSDR addressed all public comments and revised or appended the document as appropriate. The health consultation has now been reissued. This concludes the health consultation process for this site, unless additional information is obtained by ATSDR which, in the Agency's opinion, indicates a need to revise or append the conclusions previously issued. You May Contact ATSDR TOLL FREE at 1-888-42ATSDR or Visit our Home Page at: http://www.atsdr.cdc.gov WATER PCB-SD0000067478 HEALTH CONSULTATION EXPOSURE INVESTIGATION SOLUTIA, INC. [Aliases: ANNISTON PCB SITE (MONSANTO COMPANY) AND MONSANTO COMPANY] ANNISTON, CALHOUN COUNTY, ALABAMA EPA FACILITY ID: ALD004019048 Prepared by: Exposure Investigation and Consultation Division of Health Assessment and Consultation Agency for Toxic Substances and Disease Registry WATER PCB-SD0000067479 Preface This document describes the exposure investigation (El) conducted by the Agency for Toxic Substances and Disease Registry (ATSDR) in Anniston, Alabama. This El is not meant to represent the community at large. The conclusions for tins report are based on biological and environmental samples collected from 18 families living near the Solutia Inc. facility who volunteered to participate. The purpose of the El was to assess the level of exposure to polychlorinated biphenyls (PCBs) for children and their families living near the facility who would most likely have been affected. The El is one of the series of public health activities underway in the Anniston area. Additional public health activities are planned to provide a clearer picture of exposure to PCBs within the greater Anniston community. WATER PCB-SD0000067480 Background The Monsanto Company produced polychlorinated biphenyls (PCBs) at a plant in Anniston, Alabama, from 1935 to 1971, Hazardous wastes, including PCB still bottoms, were disposed in two unlined landfill areas located adjacent to the production facility. Investigations conducted by Monsanto (now Solutia Inc.) under a Consent Order with the Alabama Department of Environmental Management (1996) documented the presence of PCB contamination in sediment samples from off-site drainage ditches and in soil samples from private residences east and north of the facility. These findings led to the remediation of off-site contaminated areas and property buyouts for some homeowners. Recent investigations have detected elevated blood levels of PCBs in some residents ofthe community surrounding the Solutia facility and other neighborhoods in Anniston [1], The source and exposure pathways by which residents have been exposed to PCBs have not been defined. Furthermore, it is uncertain whether significant exposures are still occurring. To address these issues, the Agency for Toxic Substances and Disease Registry (ATSDR) conducted this Exposure Investigation (El). This investigation was done to determine if a community health problem existed and to develop plans for its control. The results ofthis investigation are applicable only to the participants of this investigation and are not generalizable to other individuals or populations. Methods Target Population Prior to conducting this investigation, staff from ATSDR and the Alabama Department of Public Health (ADPH) met with community representatives to explain the El and solicit their input. In March 2000, ATSDR met with families who lived within a radius ofapproximately 14-mile of the site and invited them to participate in the El. In order to be eligible for the study, at least one family member had to be a child between 1 and 7 years old. ATSDR staff and representatives of Community Against Pollution (CAP) went door-to-door in the designated neighborhoods to invite eligible families to participate. A total of 18 families fully participated in the El. Environmental samples were collected from these 18 homes, and biological samples were collected from 78 residents of these homes. In addition, environmental samples, only, were obtained from one home; and biological samples, only, were obtained from two people who lived in the target area. The map in Figure 1 depicts the approximate locations of the homes that were tested; the locations of the homes on the map were slightly moved to protect the anonymity of the participants. 1 WATER PCB-SD0000067481 Biological Sampling ATSDR staff made appointments with the residents to come to the Calhoun County Health Department (CCHD) where blood samples were collected. A few of the participants were unable to come to the CCHD. ATSDR staff traveled to the homes of these individuals to collect the blood samples. A licensed phlebotomist collected a 7-ml blood sample from each participant using a Vacutainer tube with no anticoagulant. After collection, the blood samples were allowed to clot for 2 hours at room temperature. The tubes were then placed on ice until they were delivered to the laboratory for analysis. Blood collection supplies and laboratory analyses were provided by the National Center for Environmental Health laboratory at the Centers for Disease Control in Atlanta, Georgia. Blood serum samples were analyzed for 37 PCB congeners using gas chromatography/mass spectroscopy (GC/MS). Results were reported as concentrations of individual PCB congeners per unit volume ofblood serum, and also as lipid-based concentrations. Individual congeners were added together to yield total PCB concentrations. Environmental Samples ATSDR staff used a metal trowel to collect a composite surface soil sample (0-3 inches in depth) from an area in the yard that the parent or child identified as a frequent play area. In addition, ATSDR staff used a Nilfisk HEPA vacuum cleaner to collect an indoor house dust sample from a room frequented by family members; this was typically the living room of the house. The environmental samples were shipped by overnight mail to the Midwest Research Institute in Kansas City, Missouri, for analyses of PCB congeners and total PCBs, The house dust samples were strained through a wire mesh screen to remove food particles, fibers, and other debris prior to analyses. Soil and house dust samples were analyzed for PCB congeners using gas chromatography/mass spectroscopy (GC/MS). Consent/Assent Form Prior to testing, each adult and a parent or legal guardian of each minor participant was required to sign an informed consent/assent form. A separate informed consent form for environmental testing was also obtained for each house prior to testing. Statistical Analyses Descriptive statistics were used to characterize the blood serum and environmental media PCB data. To assess correlations between biological and environmental data, Spearman rank correlation coefficients were calculated. The correlation analyses were conducted using the lipidbased concentrations of blood serum PCBs. 2 WATER PCB-SD0000067482 Results Biological Samples The concentration ofPCBs was determined in blood serum samples from 37 children (16 years old or less) and 43 adults. In adults, the blood PCB concentrations ranged from non-detected to 210 parts per billion (ppb). The mean concentration in adults was 14.2 ppb, and the median concentration was 2.2 ppb. In children, the blood PCB levels ranged from non-detected to 4.6 ppb. The mean concentration in children was 0.37 ppb, and the median concentration was non-detected. Among the adults, five people had a blood PCB concentration in excess of 20 ppb; the PCB levels in these five people were: 22, 54, 93,97, and 210 ppb. These five high values skewed the arithmetic mean of the adult population. If the five individuals with elevated PCB levels are not included in the mean, the average PCB concentration in the rest of the population of 38 adults was 3.5 ppb. In Figure 2, blood PCB levels are plotted as a function of age. The ages of the participants ranged from 1 to 89 years old. In general, there was a tendency for blood PCB levels to increase with age, as has been reported for other populations (2,3], In Table 1, the mean blood concentrations of individual PCB congeners are listed. The results are reported as pg/L and as ng/g serum lipid. Previous studies have shown that blood concentrations of PCBs can increase after the ingestion of large quantities ofdietary fat [4], To correct for this transient hyperlipidemia, blood serum concentrations ofPCBs can be normalized by calculating them as a blood lipid concentration. As indicated, for the population of 80 people, the mean concentration of total PCB congeners was 7.80 ug/L or 1,397 ng/g lipid. Environmental Samples The concentration of PCBs detected in composite surface soil samples from 19 homes ranged from non-detected to 11.7 parts per million (ppm). The mean concentration ofPCBs in soil was 1.4 ppm, and the median concentration was 0.60 ppm. The EPA has established a Recommended Soil Action Level - Analytical Starting Point of 1 ppm for PCBs in residential soil [5], Soil samples from four homes contained PCB concentrations in excess of 1 ppm (11.7, 5.14, 1.31, and 1.20 ppm). The concentration of PCBs detected in house dust samples from 18 homes ranged from nondetected to 10.3 ppm. The mean concentration of PCBs in house dust samples was 0.81 ppm, and the median concentration was 0.11 ppm. House dust samples from two homes contained PCB concentrations in excess of 1 ppm (10.3 and 1.71 ppm). Indoor surface loading concentrations of PCBs in house dust ranged from non-detected to 31.9 ,ug/m7r, The mean surface loading concentration was 2.07 //g/m2 of floor surface area, and the median concentration was 0.071 //g/m2. 3 WATER PCB-SD0000067483 Discussion Biological Samples In the United States, no study of blood PCB levels in a statistically-based sample ofthe population has been conducted. Therefore, there is no national reference range that can be used as a comparison population for this El. However, several studies have measured PCB levels in populations that had no known exposures to PCBs other than typical background levels. The results from these studies are listed in Tables 2 and 3. As indicated in Table 2, mean background blood PCB levels in adults range from 3.7 to 6.8 ppb. The geometric mean and median PCB values calculated from these studies are somewhat lower, since these statistical measures of central tendency reduce the influence of individuals with unusually high PCB levels in the test population. In comparing the results of these studies, several caveats must be considered. First, different analytical methodologies were used, which could account for some of the variability between studies. Earlier studies used packed column gas chromatography with electron capture detectors; more recent studies have used glass capillary columns with mass spectroscopy to detect individual PCB congeners. In addition, different populations were studied, and background PCB exposures of these populations could vary. In the United States, dietary intake of PCBs is thought to be the major source of exposure [6], Therefore, regional variations in food consumption patterns could explain some of the variability in the studies. The age of the participants in these studies also varied. Since blood PCB levels increase with age, some of the variability between studies might be accounted for by the different age distributions of the study populations. Finally, these studies were conducted over the time period, 1982-1995. Since production of PCBs in the United States was halted in 1977, PCB releases to the environment have decreased. This could cause PCB blood concentrations to decrease over time, although this speculation has not been adequately documented. In spite of these limitations and differences between studies, the results are fairly consistent. These studies suggest that mean PCB levels in blood serum from adults without unusual PCB exposures are 3 to 7 ppb, with lower levels being reported in more recent studies. The upper end distribution ofPCB levels in the general population has not been well characterized. In a review paper, Kreiss estimated that the 95th percentile PCB blood concentration in adults is 20 ppb [7], Since this estimate was based on studies conducted in the late 1970s and early 1980s, it is likely that the 95<h percentile level would be lower today. However , in the absence of a more recent estimate, ATSDR will assume that a blood PCB level in excess of 20 ppb is significantly elevated. In this investigation, five adults had a blood PCB level (22, 54, 93, 97, and 210 ppb) that exceeded 20 ppb. It was noted that the blood serum sample from the individual with 22 ppb PCBs was hyperlipidemic (total lipid = 1,417 mg/dl; normal = 400-800 mg/dl). Following a heavy fat meal, blood PCB levels can be temporarily elevated by the transient lipidemia [4], Therefore, the elevated blood PCB level in this individual may have been spuriously elevated by the presence of hyperlipidemia. 4 WATER PCB-SD0000067484 None of the other participants had a blood PCB level in excess of 20 ppb. If the five individuals with elevated PCB levels are excluded, the mean PCB level in the rest of the adult population is 3.5 ppb, which is within the normal background range. Therefore, these results indicate that blood PCB concentrations for most of the adult population were within the normal background range. Relatively few studies have measured PCB levels in children. However, based on two published studies (Table 3), PCB levels in blood serum from children are about 2 to 4 ppb, which is less than for adults. In the El population , the average blood PCB level in children was 0.37 ppb, and the median value was non detected. These levels are less than the values cited in the comparison studies. Only 10 of 37 children tested in the El had a detectable PCB level in their blood serum. The highest blood level detected in a child was 4.6 ppb, which was detected in an older child (a 13year old girl). Reference ranges for PCB concentrations in teenagers are not available, but they would likely be between those for young children and adults. Nevertheless, all of the PCB concentrations detected in children from the El were within the ranges detected in the comparison studies for children (Table 3). ATSDR concludes that none of the children tested in the El had a significantly elevated blood PCB level. Because PCBs are resistant to metabolism in the body, they bioaccumulate as a person ages. Therefore, blood PCB concentrations tend to increase with age. As indicated in Figure 2, all of the people with elevated blood PCB levels (> 20 ppb) were aged 45 years or older. Although blood PCB levels typically increase with age, PCB levels in excess of 20 ppb are unusual in unexposed populations, even among older adults. In a recent study, PCB levels were measured in a group of older adults (aged 50 to > 70 years old) [8, 9]. The mean blood PCB level in this population was 4.55 ppb, and the maximum level detected was 25.9 ppb. There are 209 possible congeners of PCBs, which differ in the number and position of the chlorine atoms on the biphenyl ring structure. In this investigation, 37 PCB congeners were measured in the blood samples. As shown by the data in Table 1, the congeners that contributed most to the total blood concentration of PCBs in the participants were PCB congeners 153, 138/158, 180, 118, and 187 (IUPAC designation). These congeners contain from five to seven chlorine atoms and are components of commercial PCB mixtures. Because these congeners contain chlorine atoms on the meta and/or para position of the biphenyl ring, they are resistant to metabolic degradation and bioaccumulate in humans [10, 11]. Asa collective group, commercial mixtures of PCBs have an estimated half-life of 2 to 6 years [12], However, the half-life of individual congeners may be even longer. For example, the half-life of PCB congener 153 was estimated to be 12.4 years [13], In Lhe adults with elevated blood PCB concentrations (>20 ppb), PCB congeners 153, 138/158, 180, 118, and 187 accounted for 59% of the total PCB concentrations. In the other adults, they accounted for 60% of the total PCBs. This indicates that the same PCB congeners composed the bulk of the PCBs in adults with either norma! or elevated PCB levels. Therefore, variations in PCB exposure in adults appeared to be more quantitative than qualitative. 5 WATER PCB-SD0000067485 In children, the same six PCB congeners accounted for 67% ofthe total blood PCB concentrations. The total PCB concentrations in children were generally lower than for adults. As a result, the children often lacked detectable quantities of the minor PCB congeners that were detected at low concentrations in adults. The absence of detectable quantities of these minor PCB congeners in children increased the relative proportion of the major congeners. Correlation Analysis To assess the relationships between blood PCB concentrations and age and length of residency at current address, Spearman rank coefficients were calculated. Age was strongly correlated with the blood PCB level (r, = 0,729, p < 0.001). Length of residency was also correlated with the blood PCB level (r, = 0.645, p < 0.001). By calculating the Spearman partial correlation coefficient, it was determined that if age were controlled for, there was still a significant correlation between the blood PCB level and length of residency (r, = 0.310, p = 0.0054). In these calculations, a participant's length of residency was equated to how long he had lived at his current address. However, many of the participants indicated that they had lived at more than one house in the area over the course of their lives. Therefore, the length of residency value may have underestimated how long some people actually lived in the vicinity of the facility. If this information had been incorporated into the calculations, the correlation coefficient between blood PCB concentrations and length of residency may have been even higher. Nevertheless, these statistical analyses suggest that people were exposed to PCBs while living near the facility, although it is not known when the exposures occurred or what the source of PCB exposure was. Environmental Samples Environmental sampling at the homes indicated the presence of PCB contamination in soil and house dust samples from many ofthe houses. This contamination poses a potential source of exposure, since children may intentionally (pica behavior) or inadvertently ingest soil and house dust [14, 15], Soil and house dust ingestion by adults has not been well studied but is likely less than for children [16]. To examine the correlations between the concentrations of PCBs in blood and environmental samples, Spearman rank correlation coefficients were calculated. This statistical analysis demonstrated that there was a significant correlation between the concentrations of PCBs in soil and house dust samples from individual homes (r, = 0.628, p < 0.0052). This correlation is expected since soil typically constitutes about 50 percent of the mass of house dust [17], Further statistical analyses failed to demonstrate a significant correlation between blood PCB levels and the concentration of PCBs in either soil (r, = -0,128, p ~ 0.26); house dust (r, = 0.078, p - 0.51); or house dust loading (jug/m2) (rs = 0.046, p = 0.70). Additional analyses in which the test population was divided into adults and children also failed to demonstrate any significant correlations between blood and environmental PCB levels. The absence of a correlation between blood PCB concentrations and soil or house dust PCB concentrations suggests that other sources of PCBs, besides those in soil and house dust, have contributed to the body burdens of PCBs 6 WATER PCB-SD0000067486 Health Implications The blood levels of PCBs that cause adverse health effects have not been well characterized. In occupational studies, exposures to PCBs have been associated with chloracne and subtle evidence of liver damage, although it is possible that polychlorinated dibenzofuran impurities in the PCBs might have contributed to the toxicity [18, 19], Slight elevations in serum enzymes of hepatic origin, such as y-glutamyl transferase, have been reported in workers with blood serum PCB levels of several hundreds of parts per billion [18]. However, in occupational studies, it is difficult to unequivocally attribute the observed health effects to PCBs because of the possible confounding effect of concurrent exposure to other chemicals. Nevertheless, based on one such study, a blood PCB level of 200 ppb was suggested as a no effect level [18]. Based on this criterion, only one ofthe El participants had a blood PCB level that exceeded this level of concern. However, it should be recognized that occupational studies have examined only a limited number of health endpoints and have limited statistical power to detect an effect. Therefore, no firm conclusions can be drawn regarding a safe blood level for PCBs in adults. Several studies have reported that low level PCB exposure during fetal or neonatal development can effect the infant's neurobehavioral development [6, 20, 21]. Although several limitations of these studies have been noted [22, 23], they provide evidence that the developing fetus or infants may be the most sensitive human population for PCB toxicity. However, the reported health effects occurred in populations with background exposures to PCBs, so a threshold effect level has not been defined. Therefore, it is not possible to predict the health impact of the PCB exposures in the El participants. Nevertheless, to minimize any potential health risks, it is prudent public health policy to reduce exposure to environmental PCB contamination. Characterization of PCB Exposures In the general population, the major background source of PCB exposure is from food [6], Among foodstuffs, the major contributors to the body burden ofPCBs are fish, meat, and poultry. It is likely that trace levels of PCBs in comercially-available foods have contributed to the body burden of PCBs in the El participants. However, for those El participants with elevated PCB levels, additional sources of PCB exposure are likely. The El participants with elevated blood PCB levels share several characteristics: (1) They are older adults, aged 45 and above. (2) They reported no known occupational exposure to PCBs. (3) They grew up in neighborhoods near the facility and have lived there most of their lives. (4) They ate locally-grown fruits and vegetables and locally-raised chickens and eggs. In addition, three ofthe five individuals with elevated blood PCB levels reported that in the past they ate clay from the neighborhood. Geophagia, including clay eating, has been reported to be a cultural or social tradition in some Southern societies [24], Once PCBs get inside the body, they are stored in adipose tissue and are resistant to metabolic degradation. The major PCB congeners detected in the participants of this investigation were the ones with long biological half-lives. Therefore, exposures to PCBs that occurred years ago could 7 WATER PCB-SD0000067487 have contributed to the high body burdens of PCBs seen in some long-term residents ofthe area. This hypothesis is supported by the absence of elevated blood PCB levels in younger residents of the community (Figure2), as well as by the strong correlations between blood PCB levels and age and length of residency in the area. Furthermore, analyses of environmental data (soil and house dust) failed to show a correlation between current environmental levels of PCB contamination and blood PCB levels. In recent years, Solutia Inc. has purchased, remediated, and restricted access to some off-site, PCB-contaminated properties. However, it is likely that prior to remediation, long-term residents of the area had exposure to environmental contamination by direct contact with contaminated soil, sediment, surface water, and air, and by indirect contact from eating locally-raised animal and plant foodstuffs. Therefore, past exposure to environmental PCBs may have exceeded current ones, and could be responsible for the elevated blood PCB levels seen in some older, long-term residents of the community. Nevertheless, this study and others conducted by the EPA have documented that elevated levels ofPCBs remain in off-site soils and sediments. Since the future use of these areas cannot be predicted, they should be remediated to prevent further human exposure to environmental contamination. Conclusions (1) Five of 43 adults had an elevated blood PCB level (> 20 ppb). (2) Blood PCB levels in 37 children were not elevated. (3) Blood PCB levels were correlated with age and length of residency near the Solutia facility. (4) Blood PCB levels were not correlated with soil or house dust PCB levels. (5) Available evidence suggests that PCB exposures in the past may have exceeded more recent exposures. Recommendations (1) Homes with PCB contamination in soil in excess of EPA action levels should be evaluated for possible remediation. (2) Residents should minimize further exposure to areas of known PCB contamination. 8 WATER PCB-SD0000067488 Report Prepared by: Kenneth G. Orloff, Ph.D., DABT Senior Toxicologist Exposure Investigations and Consultations Branch Division of Health Assessment and Consultation 9 WATER PCB-SD0000067489 References (1) R. Canady, Agency for Toxic Substances and Disease Registry, Draft Health Consultation; Evaluation of Soil, Blood, and Air Data from Anniston, Alabama; February 14, 2000. (2) SL Gerstenberger et al; Concentrations of blood and hair mercury and serum PCBs in an Ojibwa population that consumes Great Lakes region fish; Clinical Toxicol. 35 377-386 (1997). (3) DT Miller et al; Human exposure to polychlorinated biphenyls in greater New Bedford, Massachusetts: A prevalence study; Arch. Environ. Contain. Toxicol. 20 410-416 (1991). (4) DL Phillips et al; Chlorinated hydrocarbon levels in human serum: effects offasting and feeding; Arch. Environ. Contam. Toxicol. 18 495-500 (1989). (5) U.S. Environmental Protection Agency, Solid Waste and Emergency Response; A Guide on Remedial Actions at Superfund Sites With PCB Contamination; Directive 9355,4-01 FS; August 1990. v*. (6) Agency for Toxic Substances and Disease Registry; Toxicological Profile for Polychlorinated Biphenyls (update); November 2000. (7) Kathleen Kreiss; Studies on populations exposed to polychlorinated biphenyls; Environ. Health Perspec. 60 193-199 (1985). (8) H. Humphrey et al.; PCB congener profile in the serum of humans consuming Great Lakes fish; Environ. Health Perspect. 108(2) 167-172 (2000), (9) S. Schantz et al.; Impairments of memory and learning in older adults exposed to poychlorinated biphenyls via consumption of Great Lakes fish; Environ. Health Perspect. 109(6) 605-611 (2001). (10) Larry G. Hansen; Stepping backward to improve assessment of PCB congener toxicities; Env. Health Perspec. J06 171-189 (1998) (11) JF Brown; Determination of PCB metabolic, excretion, and accumulation rates for use as indicators of biological response and relative risk; Environ. Sci. Technol. 28 2295-2305 (1994). (12) JH Shirai and JC Kissel; Uncertainty in estimated half-lives of PCBs in humans: impact on exposure assessment; Science of the Total Environment 187 199-210 (1996). (13) JF Brown et al.; PCB metabolism, persistence, and health effects after occupational exposure: Implications for risk assessment; Chemosphere 29 2287-2294 (1994). (14) EJ Calabrese et al; How much soil do young children ingest: An epidemiologic study, Regulatory Toxicology and Pharmacology; .10 123-137 (1989). 10 WATER PCB-SD0000067490 (15) EJ Stanek and EJ Calabrese; Daily estimates of soil ingestion in children; Environ. Health Perspect. 103(3) 276-285 (1995). (16) EJ Calabrese et al; Preliminary adult soil ingestion estimates: Results of a pilot study, Regulatory Toxicology and Pharmacology 12 88-95 (1990). (17) DJ Paustenbach, BL Finley, and TF Long; The critical role of house dust in understanding the hazards posed by contaminated soils; Int J Toxicol; 16 339-362 (1997). (18) H Ouw et al; Use and health effects of Aroclor 1242, a polychlorinated biphenyl, in an electrical industry; Archives Environ. Health 31 189-194 (1976). (19) A. Fischbein et al; Dermatological findings in capacitor manufacturing workers exposed to dielectric fluids containing polychlorinated biphenyls (PCBs); 37 69-74 (1982). (20) JL Jacobson et al; Effects of in utero exposure to polychlorinated biphenyls and related contaminants on cognitive function in young children; J. Pediatrics 116 38-45 (1990). (21) WJ Rogan, BC Gladen, ID McKinney et al.; Neonatal effects of transplacental exposure to PCBs and DDE; J Pediatrics J09 335-341 (1986). (22) SL Schantz; Developmental neurotoxicity of PCBs in humans: What do we know and where do we go from here? Neurotox, Teratology Jj} 217-227 (1996). (23) RF Segal; Epidemiological and laboratory evidence of PCB-induced neurotoxicity; 26 709-737 (1996), (24) MD Feldman; Pica: Current perspectives; Psychomatics 27(7) 519-523 (1986). (25) JD Sahl et al; Polychlorinated biphenyls in the blood of personnel from an electric utility; J Occup Med 27 639-643 (1985). (26) MS Wolf et al; Blood levels of organochlorine residues and risk of breast cancer; J Nat Cancer Inst 85 648-652 (1993). (27) ME Hovinga et al, Historical changes in serum PCB and DDT levels in an environmentally -exposed cohort; Arch Environ Contain Toxicol 22 362-366 (1992). (28) DJ Hunter et al; Plasma organochlorine levels and the risk of breast cancer; New Eng J Med; 337 1253-1258 (1997V (29) HEB Humphrey et al; PCB congener profile in the serum of humans consuming great lakes fish; Environ Health Perspec J08 167-172 (2000). (30) LP Hanrahan et al; Serum PCB and DDE levels of frequent Great Lakes sport fish consumers - A first look; Environ Research Section A 80 S26-S37 (1999). li WATER PCB-SD0000067491 (31) JL Jacobson et al; Effects of exposure to PCBs and related compounds on growth and activity in children; Neurotoxicology and Teratology 12 319-326 (1990). (32) A Schecter et al; Polychlorinated biphenyl levels in the tissues of exposed and nonexposed humans; Environ Health Perspect 102 Suppl 1: 149-158 (1994). 12 WATER PCB-SD0000067492 Table 2: Blood Serum PCB concentrations (ppb) in adults Mean Median Number tested Date of testing Location Notes Reference 5 4 738 1982-1984 California pre-employment Sahl et al [25] screening 5.8 3.9 840 i985-19S6 Massachusetts random sample - Miller et al [3] New Bedford, MA 6.7 - 171 1985-1991 New York City breast cancer controls Wolff et al [26] 6.8 - 90 1989 Michigan - controls for fish eaters Hovinga et al [27] 5.16 4.68 230 1989-1990 US women - median age Hunter et al [28] of 59 4.56 - 78 1993-1995 Michigan > 50 years old Humphrey et al [29] 1.5 57 -- (geometric mean -males) 0.9 42 -- (geometric mean - females) 1994-1995 Great Lakes infrequent fish eaters Hanrahan et al [30] 3.7 - 66 1997 Great Lakes Ojibwa Indians Gerstenberger et al [ WATER PCB-SD0000067493 Table 1: Average blood serum PCB congener concentrations in Anniston residents (n = 80) Congener number 28 52 49 44 74 66 101 99 87 110 118 105 151 149 146 153 138/158 128 167 156 157 178 387 183 177 172 180 170 189 201 196/203 195 194 206 209 foial average concentration (mb/D average concentration (ng/g lipid) 0.0111 0.00971 0.00564 0.00799 0.170 0.0409 0.0315 0.358 0.0281 0.0138 0.621 0.144 0.0288 0.0126 0.261 1.58 1.15 0.0408 0.0654 0.144 0.0393 0.104 0.441 0.125 0.127 0.0721 0.829 0.327 0,0118 0.268 0.219 0.039 0.253 0.141 0.0830 " 1.90 1.60 0.914 1.32 30.3 7.60 5.76 65.8 5.25 2.57 112 26.3 5.20 2.63 46.4 283 205 8.08 11.5 24.8 6.82 18.7 79.7 22.9 22.2 12.4 148 57.5 2.05 47.8 39.1 7.14 44.7 25.3 14.9 7.80 1397 WATER_PCB-SD0000067494 Mean (arithmetic) 2.1 4.3 Table 3: Blood Serum PCB concentrations (ppb) in children Range 0-23.3 Number tested 285 11 Age (years) 4-5 _ Date of testing 1984-1985 1984 Location Reference Michigan US Jacobson et al [31] Schecter et al [32] WATER PCB-SD0000067495 Figure 2: Blood serum concentrations (ppb) in El participants vs. age (years) 10 20 30 40 50 60 70 80 90 100 Age WATER PCB-SD0000067496 Figure 1 Location of El Participant Homes /\/ Roads Ei Participants* ' Y 1 Solutia Property I 1/2 Mile Buffer * the locations of Ei homes have been slightly moved in random directions to protect the anonymity of participants WATER PCB-SD0000067497 Appendix A Responses to Comments Received During the Public Comment Period WATER PCB-SD0000067498 Commentor 1 (The comments provided are reproduced ver batim). (1) Comment: 1, Background Not explicit enough Response: Additional background information for the site is presented in numerous reports previously prepared by ATSDR and the Alabama Department ofPublic Health. Please refer to ATSDR's Public Comment Release Health Consultation (February 14,2000) and the Alabama Department ofPublic Health's Public Comment Release Health Assessment (December 3, 1999). (2) Comment: Target Population A The Vi mile radius is questionable due to denial of access by number of residents upon advice oftheir attorneys. B. Would like to see a map of household locations, as displayed in other health consultation reports. Response: A map indicating the approximate location of the houses tested in the El is included in the final report. (3) Comment: C. Number of children tested between the ages of 1-7 and the results chart not clear. Response: ATSDR tested 31 children between the ages of 1 and 7 years old. (4) Comment: D. What % would 18 households be oftotal number of households in targeted area? E. Document number of universal households and number of children within radii from center of solutia plant. Response: This cannot be estimated until the Year 2000 census data become avialable. (5) Comment: 3. Biological Sampling A, How many participants did the health department test? B, How many were tested by ATSDR C, What were the protocols for both agencies El testing? Please submit and indicate as reference. Response: ATSDR conducted all of the blood tests. The Calhoun County Health Department provided the facility where residents came to have blood samples drawn. The protocol for this El is described in the Methods section of the report. A total of 80 people were tested in the El. (6) Comment: D. When did the samples arrive at CDC for testing and were holding times complied with? 1 WATER PCB-SD0000067499 Response: Sample handling procedures are described in the Methods section of the report. The samples were delivered to the laboratory within 24-48 hours of collection. (7) Comment: E. May we have a copy of CDC'S actual analyzing procedure? Please submit raw data. Response: The National Center for Environmental Health provided the following description of their analytical methodology. Polychlorinated dibenzo-p-dioxins (PCDDs), dibenzofurans (PCDFs), non-ortho substituted or coplanar polychorinated biphenyls (cPCBs), other polychlorinated biphenyls (PCBs), persistent chlorinated pesticides and selected pesticide metabolites are measured in serum by highresolution gas chromatography/ isotope-dilution high-resolution mass spectrometry (HRGS/IDHRMS). Serum samples are spiked with I3Ci2-labeled internal standards and the analytes of interest are isolated using a Clg solid phase extraction (SPE) procedure followed by a multi column automated cleanup and enrichment procedure. The analytes are separated by HRCG using a DB-5 ms capillary column and quantified by ID-HRMS using selected ion monitoring (SIM) at 10,000 resolving power. The concentration of each analyte is calculated from an individual standard linear calibration. Each analytical run is conducted blinded and consists of three unknown serum samples, a method blank, and a quality control sample. After all data are reviewed using comprehensive quality assurance and quality control (QA/QC) procedures, the analytical results are reported on both a whole-weight and lipid-adjusted basis. Serum total lipids are calculated using an enzymatic `summation5 method. International toxicity equivalents (ITEQs) are also reported for PCDDs, PCDFs, cPCBs and other `dioxin-like' PCBs, based on the WHO-TEQ system. Detection limits, on a whole-weight and lipid-adjusted basis, are reported for each sample, corrected for sample weight and analyte recovery. The references for these analytical techniques and QA/QC procedures are listed below. ATSDR does not release individual test results as stated in the Informed Consent Agreement with the participants. (8) Comment: 3. Environmental Samples: A. This appears to be a general assessment no specifics. B. Please submit a copy ofMidwest Research Institute procedure for testing soil and dust samples? C. Indicate what EPA Protocol was adhered to. D. Is Midwest Research Institute an approved EPA lab? Response: The Midwest Research Institute provided the following information: The procedure for analyzing PCB congeners in soils is not a standard procedure but a combination of standard procedures. The analysis follows Method 680. Basically, this is a low resolution mass spectrometry method that performs quantitation using internal standard analysis. For preparation, the extraction procedure is soxhlet extration SW-846 Method 3540, the acid partitioning is a procedure within SW846 Method 8290 and 1613B, the Florisil procedure is SW846 Method 3620. WATER PCB-SD0000067500 EPA does not officially certify laboratories for PCB analysis. MRI has served as a subcontractor to the USEPA Office of Pollution Prevention and Toxics (OPPT) for PCB method development and analysis for the last 25 years. (9) Comment: 4. Consent/Assent Form A. No problem Response: no response needed (10) Comment: Statistical Analyses: A, Please explain in laymen's Response: The PCA statistical analysis was deleted. Instead, a descriptive analysis of the major PCB congeners detected in the blood samples was presented. (11) Comment: Results. 1. Biological Samples: A. Addressed concerns in target population with numbers and results. B. If more samples were taken would have been reflective of the total community the mean and median concentrations would have been different. Response: ATSDR offered testing to all families who lived near the Solutia Inc. facility and had a child aged 7 years old or less. The people who volunteered to participate in the El were selfselected residents who lived within 0.6 miles ofthe facility, ATSDR has no way of estimating what the blood PCB levels might be in those individuals who chose not to participate in the El, (12) Comment: C. Why use blood lipid concentrations if there are few/no studies to compare with? Response: Reporting the blood PCB concentration as a function of the blood lipid concentration reduces the variability caused by fluctuations in blood lipid levels. ATSDR believes that in future studies, more emphasis will be placed on reporting blood PCB levels as a function ofblood lipid concentrations, (13) Comment: D. Insert table of results within text. Response: The final report includes a table of PCB congener concentrations in blood samples from the El participants. (14) Comment: E. Were results compared to results from community data used with ATSDR PCB Health Consultation (Feb. 2000)? Response: This report evaluated only the data generated by ATSDR in its exposure investigation. The previous draft health consultation included an evaluation of data that was provided by an attorney who is representing residents of the area. Information provided to ATSDR during the public comment period for this health consultation suggests that some of the 3 WATER PCB-SD0000067501 information in the attorney's data base is incorrect. The final health consultation will be revised in accordance with the new information received. (15) Comment: 2. Environmental Samples: A. Were results considered a health risk/hazard or not? Response: The purpose of this exposure investigation was to characterize PCB exposure in the community. For an assessment of the risk posed by environmental contamination, the reader is referred to ATSDR's Public Comment Release Health Consultation (February 14, 2000). (16) Comment: B. Please define/explain indoor surface loading concentrations Response: Indoor house dust samples were collected using a HEPA vacuum cleaner. The concentration of PCBs in the house dust sample was expressed as a mass concentration (milligrams of PCBs per kilogram of dust), and indoor surface loading contamination was expressed as nanograms of PCBs per square meter of floor surface area. Indoor dust samples were tested to determine ifthere was a correlation between the concentration ofPCBs in house dust and concentration of PCBs in blood samples, No correlation was detected, in this investigation. (17) Comment: Discussion 1. Biological Samples A. Are there really populations that have not been exposed to PCBs? Response: Low level exposures to PCBs are ubiquitous throughout the world. (18) Comment: B. Is this the total universe of studies and how were they selected? Response: ATSDR assumes that the commentor is referring to the studies in Table 1. These studies were selected using the following criteria: (1) published in a peer-reviewed scientific journal within the past 15 years, (2) procedures and analytical methodology were adequately described, (3) test subjects were residents of the United States, (4) test population had no unusual PCB exposures, (5) study provided the mean, median, or other statistical measure of central tendency in the reported blood PCB concentrations. (19) Comment; C. The major source of exposure in Anniston AL. has not been identified Response: Possible sources of PCB exposure in the Anniston community are discussed in the Characterization of PCB Exposures section. (20) Comment: D. PCB level increase with age? Is this with ongoing exposure? Response: PCBs ingested in food and from other sources bioaccumuiate in the body and cause the PCB level in the blood to increase with age. 4 WATER PCB-SD0000067502 (21) Comment: E. ATSDR is going to assume that blood PCB level in excess of 20 ppb is significantly elevated based on a REVIEW PAPER F. In the previous sentence you stated that today levels would be lower. Response: As discussed in the report, this reference provides the best available documented estimate of the upper end distribution of PCBs in the general population. In an upcoming National Health and Nutritional Examination Survey (NHANES), the CDC will characterize the distribution of PCBs in the general population. However, these data are not currently available. (22) Comment: G. Were the adults with elevated levels samples taken after a fatty meal intake? Response: As stated in the report, the person with a blood PCB level of 22 ppb had an elevated blood lipid level. (23) Comment: H. Please submit supporting data. I. How can a report be accurate if certain data is omitted from report? Response: The final report has been expanded to include a map indicating the approximate locations of the houses sampled during the investigation and a table that lists the blood congener concentrations of El participants. (24) Comment: J. Third paragraph page 6, last sentence, would this indicate that further studies and evaluations are needed. Response: ATSDR is working with the U S. Environmental Protection Agency, the Alabama Department of Environmental Protection, and the Alabama Department of Public Health to identify and characterize sources of environmental contamination. (25) Comment; PCB Congener Analyses A. Congener Analyses indicates ongoing exposure. Response: There is widespread exposure to PCBs through low level contamination of foodstuffs with PCBs. (26) Comment: B. As you referenced breast milk studies, fatty tissue studies, from other human studies should El not be expanded to include these types of studies along with umbilical and placental studies also here. Response: Measuring PCB concentrations in blood samples from a population is the most practical way of characterizing exposure in a population. It was beyond the scope of this investigation to measure PCB levels in breast milk, fatty tissue, umbilical cord, or placental tissue. Moreover, the availability of these types of tissue samples is much more limited than blood samples. 5 WATER PCB-SD0000067503 (27) Comment: Health Implications A. None of participants had any occupational exposure. Response: No response needed (28) Comment: B. Who is responsible for reducing exposure to environmental PCB contamination? Response: ATSDR is working with the U.S. Environmental Protection Agency, the Alabama Department of Environmental Protection, and the Alabama Department of Public Health to identify environmental health hazards and implement actions to remediate them. (29) Comment: C. ATSDR just where do you suppose that these participants were/got exposed to/from PCBs if not from AIR, DUST, and SOIL? Response: Possible sources of PCB exposure are discussed in the Characterization of PCB Exposures section. (30) Comment: D. Please explain studies used in health implications and their significance. Response: ATSDR has provided fact sheets to the public on the health effects of PCBs. The El report provides references for readers who want additional information on the studies cited. (31) Comment: E. How and who is responsible for reducing exposure to environmental PCB contamination? Response: See response to comment 28. (32) Comment: Environmental Samples A. Please explain statistical analyses exposure in layman's terms. Response: See response to comment 10. (33) Comment: Characterization of PCB exposure A. The exposure here is site specific and not just from food. Response: This issue was discussed in the Characterization of PCB Exposures section. (34) Comment: B. PCB's were banned in 1977 by the U.S. government WONDER WHY? C. There are no more locally grown fruits and vegetables and folks don't raise chickens anymore, Response: No response needed 6 WATER PCB-SD0000067504 (35) Comment: D. Did you find any fresh eggs? Response: None of the HI participants reported that they were currently eating eggs from home* raised chickens, although some reported that they had done so in the past. (36) Comment: E. If the half-life of PCB's is 2-6 yrs, explain why the adults continue to have elevated levels if there is no ongoing exposure. FDA has established safe levels for food etc. Response: As an illustrative example of a biological half-life, assume that a person has a blood level of a chemical of 100 ppb with a half-life of 10 years. Assuming that this person has no further exposure to the chemical, the blood level of the chemical will decrease as indicated in the following table: 0 years - 100 ppb 10 years - 50 ppb 20 years - 25 ppb 30 years - 12.5 ppb Therefore, even in the absence of any further exposures to the chemical, a person would still have a detectable level ofthe chemical in their blood, even though several half-lives have transpired. All residents of the United States have continuing, low-level exposure to PCBs in food. The major sources of PCBs in the diet are fish, meat, and poultry. These dietary exposures will contribute to the body burden of PCBs derived from other sources. The biological half-life of commercial PCB mixtures was estimated to be 2-6 years. However, this is an average half-life for the mixture of congeners. Some individual congeners have a half life of only a few months; others have estimated half-lives of 10 years or more. The predominant PCB congeners found in human blood samples are those with long half-lives. (37) Comment: F. Why is there no reference to EPA's current release of exposure into air, soil sediment, and water? Response: These issues were not the subject of this El. Environmental contamination data collected by the EPA was discussed in ATSDR's Public Comment Release Health Consultation (February 14, 2000), and additional health consultations will evaluate new data as they become available. (38) Comment: G. No reference to EPA's current 2yr investigation with RICA and Superfund program. Response: See response to comment 37. (39) Comment: Conclusions Your conclusions were once again, based on outdated, inadequate, not sufficient, not site specific, and irrelevant references that produced a lot of suggestive and assumptive conclusions that are not going to benefit anyone especially this community. 7 WATER PCB-SD0000067505 Response; The data and information presented in the report support the conclusions. (40) Comment: Recommendations ARE YOU SEROUS? You would have been better off to have suggested that you do nothing. With your recommendations there is no specifics as to WHO, WHAT, WHEN, and HOW anything is going to be or get done. Response: ATSDR provided the EPA with the data gathered during the El and requested that they consider implementing remedial actions at those properties that had environmental contamination that exceeded their clean-up criteria. ATSDR is working with the U.S. Environmental Protection Agency, the Alabama Department of Environmental Protection, and the Alabama Department of Public Health to identify environmental health hazards and implement actions to remediate them. Commentor 2 (The comments provided are reproduced ver baiim): (41) Comment: Thanks for the information you sent concerning testing being done in Anniston, Alabama. Monsanto Chemical plant recently changed name to Solutia facility. You stated in your report that testing has been done on residents blood, urine, soil, water, and air. I would like to know what other tests can be done? Response: Biomonitoring for PCBs is usually done by analyzing a blood sample. In the past, when analytical methods were not as sensitive, PCBs were sometimes measured in a fat sample, which contains a higher PCB level than that found in blood. However, there is no need to analyze fat samples, since modern analytical techniques can detect PCBs in blood at a concentration of less than I part per billion, which is below normal background levels. (42) Comment. We the victims of this horrendous disastrous afflictions caused by PCBs and other toxins that are a by-product of these chemicals? I have suffered with painful joint diseases for as long as I can remember, with something new being discovered each time I see the doctor. These chemicals stay in your adipose tissue and come out from time to time thereby entering our blood stream where it works havoc for a time then stores itself back in our adipose tissue. It (PCBs) will never leave our bodies. We will die with them, live with them, and suffer with them. Sirs, I ask you, who do we blame for all our suffering, pain, and heartache? I'm trying to learn all I can about PCBs in order to help my children and grand children (which 1 only have one grand child) so far. How come all of the testing done on people and some animals for long term effects of PCBs are found to be inconclusive? Why was testing stopped in most cases? I would love to get answers to these and more questions. Can PCBs be destroyed? If so how? P S. Please take blood samples when persons have an out-break of skin eruptions. The PCB level will be much higher. I guarantee it. Response: In laboratory studies, PCBs can be administered to animals in precisely measured doses and over a wide range of doses. This allows scientists to determine the relationship between exposure to a toxic chemical and an adverse health effect in the animal. In humans, it is seldom possible to determine how much PCB a person has been exposed to. Furthermore, in 8 WATER PCB-SD0000067506 occupational studies, a person is often exposed to more than one chemical, so it is not certain which chemical, if any, is responsible for an adverse health effect. In addition, many adverse health outcomes, such as cancer, can be caused by or influenced by factors other than chemical exposures. Therefore, it is much more difficult to prove a causal association between exposure to PCBs and disease in humans. PCBs can be safely destroyed by burning them in a hazardous waste incinerator. Other techniques, such as chemical dechlorination and bioremediation, show promise but are still in the experimental stage. PCBs can also be safely disposed of in a hazardous waste landfill. Commentor 3 (The comments provided are reproduced ver batim); (43) Comment: TITLE The use of the idiomatic "a/k/a" is inappropriate in a document of this type. In addition, the description of the site in the title is inaccurate and misidentifies the area to which the consultation is addressed. The name and current owner of the former PCB-manufacturing in Anniston is Solutia Inc. (The company name does not include a comma between the two words of the company name.) However, the area addressed by the Health Consultation is not the facility but rather is off-site areas in the greater Anniston area. Solutia suggests that the title of the document be changed to the following: Health Consultation Exposure Investigation Report Near-site and Off-site Areas Solutia Inc. (formerly the chemical businesses of Monsanto Company) Anniston, Calhoun County, Alabama CERLIS No.ALD004G19048 Response: ATSDR recognizes your concern. However, ATSDR is required to identify the site by its name in EPA's CERCLIS database, which is the Monsanto Company. Solutia Inc. has been listed as an alias. (44) Comment: The current document appears to be an exact duplicate of a document dated August 18, 2000, and apparently released by ATSDR on or about that date. That version was titled as an Exposure Investigation Report, but it is not designated as a "Public Comment Release". Solutia believes the existence of two essentially identical documents with different release dates, the earlier of which was not designated for comment, may lead to substantial confusion among persons with an interest in this site. ATSDR should acknowledge the earlier document in the final version of this Health Consultation and provide some explanation for existence of the earlier document. Response: The report was released a second time in response to community's request for a public comment period so that they could comment on the report. 9 WATER PCB-SD0000067507 (45) Comment: Preface In the third sentence, "residence" should read "residences" and the comma between "Solutia" and "Inc." should be deleted, as should the comma following "Inc." Response: The preface was revised accordingly. (46) Comment: Background Page 1, first sentence. "Company" should be capitalized; the manufacturing of PCBs ceased in 1971, which is more precise that the generic "1970s". Third sentence: The comma should be removed from the company name in the parentheses. The Consent Order under which Monsanto undertook sampling of residential properties in areas east and north of the facility was signed in 1996, not 1985 as denoted in the parentheses. Response: The text was revised accordingly. (47) Comment: Results, Biological Samples: Page 3, third paragraph of this section: ATSDR correctly notes that blood concentrations of PCBs can be influenced by the intake of dietary fat. It is for this reason that most protocols for taking blood samples for PCB analyses specify that the subject should be in a fasting state, i.e., the subject should not have eaten on the day of the sampling prior to the blood being drawn. Were the blood samples in this exposure investigation taken from subjects in the fasting state? Response: In investigations of this type, it is not practical to obtain fasting blood samples from the participants, who include young children. However, variations in blood PCB levels due to blood lipid levels would be expected to be comparable to those reported in other studies. It should be noted that the comparison studies cited in Table I and 2 were not conducted with blood samples from fasting individuals. (48) Comment: Discussion , Biological Samples: Page 4, second paragraph ofthis section and Table 1: Table 1 provides useful information about some ofthe many studies which have measured PCB levels in the blood of nominally unexposed populations. The table would be much more useful as a reference if ranges of PCBs levels in the subjects were included as a column in the table. Such information on the distribution of PCB levels in populations would provide additional context in which to consider the results presented in the Health Consultation. Page 5, last full paragraph and Table 2: It is noted that Table 2 does include a column for the range of blood levels reported in the two studies noted. Such a column would be a useful addition to Table 1, as noted above. Response: The amount of information presented in the Tables was limited by available space. The information referred to can be obtained from the original references. 10 WATER PCB-SD0000067508 (49) Comment: PCB Congener Analysis Page 6, last paragraph and Page 7, top: Although the discussion implies that the two clusters identified in the cluster analysis of the PCB congener specific analytical data are largely, if not exclusively, a function ofPCB concentration, ATSDR should make this point more clearly. Cluster A appears to be primarily the low-concentration samples, whether for adults or children, in which the lower concentration congeners were at concentrations less than the detection limits for those congeners. In Cluster B, the total concentrations of PCBs were high enough that those relatively less-concentrated congeners were present at levels above their respective detection limits. Response: The PCA statistical analysis was deleted. Instead, a descriptive analysis and discussion of the major PCB congeners detected in the blood samples from adults and children was presented. (50) Comment: Characterization of PCB Exposures Page 9, second paragraph, first sentence: The phrase "the potentially responsible party" implies that Solutia is the only PRP associated with this site. While Solutia has undertaken extensive sampling and remedial activities in the near-site and off-site areas, there has been no determinaten that other PRPs may not have contributed to PCB levels in soils and sediments. Solutia suggests replacement of the phrase with "Solutia Inc " Response: The text was revised accordingly. ll WATER PCB-SD0000067509