ATSDR - PHA - Del Monte Corporation, Kunia, Honolulu County, Hawaii

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PUBLIC HEALTH ASSESSMENT

DEL MONTE CORPORATION
(OAHU PLANTATION)
KUNIA, HONOLULU COUNTY, HAWAII

APPENDICES

Appendix 1
Figures 1 and 2

Figure 1

Figure 2

Appendix 2
Health Comparison Values

Health comparison values for ATSDR public health assessments are contaminant concentrations that are found in specific media (e.g., air, soil, and water) and that are used to select contaminants for further evaluation. The health comparison values were developed by using the most conservative assumptions (i.e., worse case). For example, soil health comparison values are developed for children who exhibit pica behavior. Soil ingestion in pica children greatly exceeds the soil ingestion rate for the normal population. Health comparison values used in the Environmental Contamination and Other Hazards section of this public health assessment are described below.

Cancer Risk Evaluation Guides (CREGs) are contaminant concentrations estimated to cause no more than one excess cancer in a million (10E-6) persons exposed over a lifetime. CREGs are calculated from U.S. Environmental Protection Agency's (EPA's) cancer slope factors.

The Lifetime Health Advisory for drinking water (LTHA) is developed by the EPA. The LTHA is a lifetime exposure level specific for drinking water (assuming 20% of an individual's exposure comes from drinking water) at which adverse, noncarcinogenic health effects would not be expected to occur. When health comparison values are not available for other environmental media (i.e., soil and air), the LTHA is used to calculate a comparison value by factoring in the different ingestion or inhalation rates.

A Minimal Risk Level (MRL) is an estimate of daily human exposure to a chemical (in milligrams per kilogram per day) that is unlikely to cause an appreciable risk of deleterious effects (noncarcinogenic) over a specified duration of exposure. MRLs are based on human and animal studies and are reported in the ATSDR Toxicological Profiles for acute (< 14 days), intermediate (15 to 365 days), and chronic (> 365 days) exposures.

EPA's Reference Dose (RfD) is an estimate of the daily exposure to a contaminant that is unlikely to cause adverse health effects. However, RfDs do not consider carcinogenic effects.

Environmental Media Evaluation Guides (EMEGs) are based on ATSDR's MRLs and factor in body weight and ingestion or inhalation rates. Reference Dose Media Evaluation Guides (RMEGs) are the same as EMEGs except that they are based on EPA RfDs.

Maximum Contaminant Level (MCL) is an EPA regulatory standard that is developed from health and technological criteria (e.g., whether the compound can be detected).

Appendix 3
Response to Comments Received During the Public Comment Period

The Del Monte Corporation Oahu Plantation Public Health Assessment was available for public review and comment from November 21, 1994 through January 23, 1995. The Public Comment Period was announced in the Honolulu Star-Bulletin. Copies of the public health assessment were made available for review at the Wahiawa Library and the Pearl City Library. The public health was also sent to six persons and organizations. In addition, staff from the Agency for Toxic Substances and Disease Registry (ATSDR) held two public Availability Sessions on December 11 and 12, 1994. The Availability Sessions permitted individuals to discuss the public health assessment with ATSDR in private. ATSDR also conducted a Public Meeting on December 12, 1994. The meeting permitted the public to discuss the public health assessment in an open forum. Comments were received from one individual and the U.S. Environmental Protection Agency, Region IX.

Comments and responses are summarized below. The comment letter can be requested from ATSDR through the Freedom of Information Act.

Comment: It is not understood why your Dec. 12 meeting is confidential. The residents were also divided in your Jan. 25 meeting.
Response: The Agency for Toxic Substances and Disease Registry (ATSDR) frequency holds Public Availability Sessions at which people can, if they wish, speak to ATSDR scientists in private. This is a service ATSDR provides to the community. ATSDR has found that frequently people prefer to talk to ATSDR scientists in private. It is not intended to divide the community. Nor would ATSDR discourage anyone from speaking out about their concerns.
In addition to the two Public Availability Sessions held on December 11 and 12, 1994, ATSDR did hold a Public Meeting on December 12. The Public Meeting was arranged by ATSDR so that the community could, if they wish, present their concerns to ATSDR in a open forum. ATSDR does not direct or indicate to anyone which forum (Public Availability Sessions or Public Meeting) they should attend. It is a decision made by each individual.
Comment: Can a health judgement be made without independent drinking water tests? The city does not test Kunia Camp.
Response: As indicated in the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment (Page 12, Quality Assurance and Quality Control section), several samples from the Kunia well and the three monitoring wells were sent to different laboratories (i.e., Del Monte, Hawaii Department of Health, and University of Hawaii). The analytical result for these split samples were comparable. This comparability would tend to indicate that data submitted to ATSDR is truly reflective of the conditions at the Del Monte Corporation Oahu Plantation National Priorities List (NPL) site.
ATSDR was not able to obtain quality assurance and quality control (QA/QC) information for the data presented in the public health assessment. Therefore, ATSDR has and will continue to recommend that appropriate QA/QC procedures be conducted for any future environmental sampling conducted at this NPL site.
The Hawaii Department of Health does test the drinking water supply currently being provided to the Kunia village. The results of these tests are included in the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment (Page 10, Off-Site Contamination section and Table 2).
Comment: Your superfund study asks for (very weak) "EPA sampling and analysis protocols."
Response: ATSDR believes that the analysis protocols recommended by the U.S. Environmental Protection Agency (EPA) are appropriate and are not weak. The detection limits and other methodology required by the EPA protocols are rigorous enough for ATSDR to determine whether there may be any possible health concerns at the Del Monte Corporation Oahu Plantation NPL site.
Comment: Kunia Camp is surrounded by contaminated wells. Your report does not use USGS numbers.
Response: The USGS numbers for the drinking water wells discussed in the Del Monte Corporation Oahu Plantation Public Health Assessment have been added.
Comment: The new "clean" camp water contains ethylene dibromide (EDB), 1,2-dibromo-3-chloropropane (DBCP), tetrachloroethylene, trichloroethylene, trichloropropane (TCP), carbon tetrachloride and dichloroethylene.
Response: On pages 10 through 12 of the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment, ATSDR discusses the contaminants found in the two wells that presently provide drinking water to Kunia. No contaminants were detected in the wells above ATSDR health comparison values. Therefore, it is unlikely that any adverse health effects will occur to people ingesting the water from these wells. Table 2, page 11, summarizes the analytical results and comparisons values of the samples taken from the two wells.
In February, 1989, a packed tower aeration facility was installed at the Kunia village. This tower reduces the concentration of volatile organic compounds even further below health comparison values, most below the analytical detection limits. By reducing the concentrations of these contaminants in the drinking water supply for Kunia, it is even more unlikely that any adverse health effects will occur to people ingesting the water from these wells. This information is also found in Table 2, page 11 of the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment.
Comment: The Kunia/Poamoho health study may be flawed. DBCP, dichloropropane (DCP), and TCP were found in that Poamoho square mile. Poamoho is only four miles from Kunia.
Response: As discussed on page 22 through 24 (Health Outcome Data Evaluation section) of the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment, ATSDR found several problems with several of the Kunia/Poamoho health studies. That is why ATSDR did not use most of the Kunia/Poamoho studies to develop our conclusions and recommendations concerning this NPL site.
However, the information contained in the Kunia/Poamoho studies indicate that the Poamoho drinking water well did not contain DBCP, DCP, or TCP above detection limits at the time of the study. This is not to say that no DBCP, DCP, or TCP were detected within a square mile of Poamoho village. Even if DBCP, DCP, or TCP were present in the Poamoho well just below detection limits, the differing amounts (concentrations) of these compounds in the drinking water for Kunia and Poamoho would be large enough (over 1,000 times) to allow a valid scientific comparison to be made.
Comment: Is the Kunia filter install date actually in our records?
Response: The installation and start up of the Kunia pack tower aeration facility is a matter of public record. The Hawaii Department of Health has inspected the Kunia pack tower aeration facility and will continue to inspect and take water samples from the facility.
Comment: Your "EPA target compound list" does not name the health effects for all of our 37 toxins.
Response: The EPA Target Compound List is apart of the contract EPA has with various laboratories through out the United States. The Target Compound List specifics what compounds the laboratory should test for in each environmental sample. The EPA Target Compound List does not provide any information on the health effects of the compounds.
In the public health assessment, ATSDR recommended that any future environmental samples taken at the Del Monte Corporation Oahu Plantation NPL site be analyzed for all of the substances on the EPA Target Compound List. ATSDR made this recommendation because none of the environmental samples taken at this NPL site have been analyzed for any contaminants besides EDB, DBCP, and metals. In addition, ATSDR has recommended that any future environmental samples taken at the NPL site also be analyzed for all of the pesticides used at the Del Monte Oahu Plantation. Therefore, any future environmental samples taken at the Del Monte Corporation Oahu Plantation NPL site should be analyzed for the 37 compounds you discuss and more.
Comment: Does any reference name the health effects of mixtures, or the possible synergistic or generational effects on a fetus? Is mothers food, air, and water considered?
Response: The two ATSDR toxicological profiles referenced in the Del Monte Corporation Oahu Plantation Public Health Assessment discuss the possible effects of EDB and DBCP on the fetus and mothers. The profiles also state that both of these compounds do not accumulate in the body. Therefore, it is unlikely that there would be any generational effects caused by these two compounds.
The studies conducted by Wong et al. evaluated California populations exposed to DBCP-contaminated drinking water. No adverse health effects were found by these studies.
During the evaluation of this site, ATSDR did consider whether EDB and DBCP could cause any health effect through the additive combination of these two compounds. It is ATSDR's conclusion that it is unlikely that the combine exposures that occurred at Kunia could result in any adverse health effects.
Comment: Do no harm. A comprehensive health effect and birth defects search should be done on the present and former Kunia children.
Response: ATSDR has determined that no health effects are expected in children because of the past exposures to EDB and DBCP in the Kunia drinking water. No Kunia children were born with birth defects during the period of highest drinking water contamination (1977 through 1979). Because EDB and DBCP do not bioaccumulate, it is not likely that any children presently living in Kunia would have any birth defects or other health affects related to the past drinking water exposures to EDB and DBCP. Therefore, ATSDR is not considering conducting any follow-up health activities at this NPL site at this time. However, if data suggesting that human exposure to hazardous substances at levels of public health concern is currently occurring become available, ATSDR will reevaluate this site for any indicated follow-up.
Comment: The pumping of the Kunia well no longer occurs. During our investigation of the Del Monte site, EPA noted that untreated water from the Kunia well was being spread on the site as a dust suppressant. Since EDB and DBCP are both listed wastes, EPA believes this activity may violate the Resource, Conservation & Recovery Act ("RCRA") which expresses prohibition on use of material which has been mixed with any hazardous waste for dust suppression purposes. It may also violate RCRA's general prohibition on disposal of contaminants to land. Del Monte has agreed to cease spreading the water in response to EPA concerns.
Response: The Del Monte Corporation Oahu Plantation Public Health Assessment has been modified to indicate this change.
Comment: During ATSDR's site visit, no standing water was seen in the 60-foot deep pit. EPA has observed standing water in this area during a site visit last year.
Response: The Del Monte Corporation Oahu Plantation Public Health Assessment has been modified to reflect this observation.
Comment: Recommendations on page 27 of the Public Comment Release are consistent with EPA's RI/FS objectives.
Response: ATSDR appreciates EPA's support in this effort.
Comment: EPA will assure that any downgradient wells are monitored annually for site-related contaminants to the extent possible. Also, EPA will assure that future samples will be collected in accordance with EPA sampling and analysis protocols.
Response: ATSDR appreciates EPA's support in this effort.

Table of Contents

Agency for Toxic Substances and Disease Registry, 1825 Century Blvd, Atlanta, GA 30345
Contact CDC: 800-232-4636 / TTY: 888-232-6348

Department of Health and Human Services

Comment:	It is not understood why your Dec. 12 meeting is confidential. The residents were also divided in your Jan. 25 meeting.
Response:	The Agency for Toxic Substances and Disease Registry (ATSDR) frequency holds Public Availability Sessions at which people can, if they wish, speak to ATSDR scientists in private. This is a service ATSDR provides to the community. ATSDR has found that frequently people prefer to talk to ATSDR scientists in private. It is not intended to divide the community. Nor would ATSDR discourage anyone from speaking out about their concerns. In addition to the two Public Availability Sessions held on December 11 and 12, 1994, ATSDR did hold a Public Meeting on December 12. The Public Meeting was arranged by ATSDR so that the community could, if they wish, present their concerns to ATSDR in a open forum. ATSDR does not direct or indicate to anyone which forum (Public Availability Sessions or Public Meeting) they should attend. It is a decision made by each individual.
Comment:	Can a health judgement be made without independent drinking water tests? The city does not test Kunia Camp.
Response:	As indicated in the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment (Page 12, Quality Assurance and Quality Control section), several samples from the Kunia well and the three monitoring wells were sent to different laboratories (i.e., Del Monte, Hawaii Department of Health, and University of Hawaii). The analytical result for these split samples were comparable. This comparability would tend to indicate that data submitted to ATSDR is truly reflective of the conditions at the Del Monte Corporation Oahu Plantation National Priorities List (NPL) site. ATSDR was not able to obtain quality assurance and quality control (QA/QC) information for the data presented in the public health assessment. Therefore, ATSDR has and will continue to recommend that appropriate QA/QC procedures be conducted for any future environmental sampling conducted at this NPL site. The Hawaii Department of Health does test the drinking water supply currently being provided to the Kunia village. The results of these tests are included in the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment (Page 10, Off-Site Contamination section and Table 2).
Comment:	Your superfund study asks for (very weak) "EPA sampling and analysis protocols."
Response:	ATSDR believes that the analysis protocols recommended by the U.S. Environmental Protection Agency (EPA) are appropriate and are not weak. The detection limits and other methodology required by the EPA protocols are rigorous enough for ATSDR to determine whether there may be any possible health concerns at the Del Monte Corporation Oahu Plantation NPL site.
Comment:	Kunia Camp is surrounded by contaminated wells. Your report does not use USGS numbers.
Response:	The USGS numbers for the drinking water wells discussed in the Del Monte Corporation Oahu Plantation Public Health Assessment have been added.
Comment:	The new "clean" camp water contains ethylene dibromide (EDB), 1,2-dibromo-3-chloropropane (DBCP), tetrachloroethylene, trichloroethylene, trichloropropane (TCP), carbon tetrachloride and dichloroethylene.
Response:	On pages 10 through 12 of the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment, ATSDR discusses the contaminants found in the two wells that presently provide drinking water to Kunia. No contaminants were detected in the wells above ATSDR health comparison values. Therefore, it is unlikely that any adverse health effects will occur to people ingesting the water from these wells. Table 2, page 11, summarizes the analytical results and comparisons values of the samples taken from the two wells. In February, 1989, a packed tower aeration facility was installed at the Kunia village. This tower reduces the concentration of volatile organic compounds even further below health comparison values, most below the analytical detection limits. By reducing the concentrations of these contaminants in the drinking water supply for Kunia, it is even more unlikely that any adverse health effects will occur to people ingesting the water from these wells. This information is also found in Table 2, page 11 of the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment.
Comment:	The Kunia/Poamoho health study may be flawed. DBCP, dichloropropane (DCP), and TCP were found in that Poamoho square mile. Poamoho is only four miles from Kunia.
Response:	As discussed on page 22 through 24 (Health Outcome Data Evaluation section) of the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment, ATSDR found several problems with several of the Kunia/Poamoho health studies. That is why ATSDR did not use most of the Kunia/Poamoho studies to develop our conclusions and recommendations concerning this NPL site. However, the information contained in the Kunia/Poamoho studies indicate that the Poamoho drinking water well did not contain DBCP, DCP, or TCP above detection limits at the time of the study. This is not to say that no DBCP, DCP, or TCP were detected within a square mile of Poamoho village. Even if DBCP, DCP, or TCP were present in the Poamoho well just below detection limits, the differing amounts (concentrations) of these compounds in the drinking water for Kunia and Poamoho would be large enough (over 1,000 times) to allow a valid scientific comparison to be made.
Comment:	Is the Kunia filter install date actually in our records?
Response:	The installation and start up of the Kunia pack tower aeration facility is a matter of public record. The Hawaii Department of Health has inspected the Kunia pack tower aeration facility and will continue to inspect and take water samples from the facility.
Comment:	Your "EPA target compound list" does not name the health effects for all of our 37 toxins.
Response:	The EPA Target Compound List is apart of the contract EPA has with various laboratories through out the United States. The Target Compound List specifics what compounds the laboratory should test for in each environmental sample. The EPA Target Compound List does not provide any information on the health effects of the compounds. In the public health assessment, ATSDR recommended that any future environmental samples taken at the Del Monte Corporation Oahu Plantation NPL site be analyzed for all of the substances on the EPA Target Compound List. ATSDR made this recommendation because none of the environmental samples taken at this NPL site have been analyzed for any contaminants besides EDB, DBCP, and metals. In addition, ATSDR has recommended that any future environmental samples taken at the NPL site also be analyzed for all of the pesticides used at the Del Monte Oahu Plantation. Therefore, any future environmental samples taken at the Del Monte Corporation Oahu Plantation NPL site should be analyzed for the 37 compounds you discuss and more.
Comment:	Does any reference name the health effects of mixtures, or the possible synergistic or generational effects on a fetus? Is mothers food, air, and water considered?
Response:	The two ATSDR toxicological profiles referenced in the Del Monte Corporation Oahu Plantation Public Health Assessment discuss the possible effects of EDB and DBCP on the fetus and mothers. The profiles also state that both of these compounds do not accumulate in the body. Therefore, it is unlikely that there would be any generational effects caused by these two compounds. The studies conducted by Wong et al. evaluated California populations exposed to DBCP-contaminated drinking water. No adverse health effects were found by these studies. During the evaluation of this site, ATSDR did consider whether EDB and DBCP could cause any health effect through the additive combination of these two compounds. It is ATSDR's conclusion that it is unlikely that the combine exposures that occurred at Kunia could result in any adverse health effects.
Comment:	Do no harm. A comprehensive health effect and birth defects search should be done on the present and former Kunia children.
Response:	ATSDR has determined that no health effects are expected in children because of the past exposures to EDB and DBCP in the Kunia drinking water. No Kunia children were born with birth defects during the period of highest drinking water contamination (1977 through 1979). Because EDB and DBCP do not bioaccumulate, it is not likely that any children presently living in Kunia would have any birth defects or other health affects related to the past drinking water exposures to EDB and DBCP. Therefore, ATSDR is not considering conducting any follow-up health activities at this NPL site at this time. However, if data suggesting that human exposure to hazardous substances at levels of public health concern is currently occurring become available, ATSDR will reevaluate this site for any indicated follow-up.
Comment:	The pumping of the Kunia well no longer occurs. During our investigation of the Del Monte site, EPA noted that untreated water from the Kunia well was being spread on the site as a dust suppressant. Since EDB and DBCP are both listed wastes, EPA believes this activity may violate the Resource, Conservation & Recovery Act ("RCRA") which expresses prohibition on use of material which has been mixed with any hazardous waste for dust suppression purposes. It may also violate RCRA's general prohibition on disposal of contaminants to land. Del Monte has agreed to cease spreading the water in response to EPA concerns.
Response:	The Del Monte Corporation Oahu Plantation Public Health Assessment has been modified to indicate this change.
Comment:	During ATSDR's site visit, no standing water was seen in the 60-foot deep pit. EPA has observed standing water in this area during a site visit last year.
Response:	The Del Monte Corporation Oahu Plantation Public Health Assessment has been modified to reflect this observation.
Comment:	Recommendations on page 27 of the Public Comment Release are consistent with EPA's RI/FS objectives.
Response:	ATSDR appreciates EPA's support in this effort.
Comment:	EPA will assure that any downgradient wells are monitored annually for site-related contaminants to the extent possible. Also, EPA will assure that future samples will be collected in accordance with EPA sampling and analysis protocols.
Response:	ATSDR appreciates EPA's support in this effort.