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PUBLIC HEALTH ASSESSMENT

U.S. NAVY PORT HADLOCK DETACHMENT (INDIAN ISLAND DEPOT)
PORT HADLOCK, JEFFERSON COUNTY, WASHINGTON


Table 1. Exposure Pathways

Pathway Name Potential Source of Contamination Environmental Medium Point of Exposure Route of Exposure Exposed
Population		 Comments
Consumption of Contaminated Shellfish Located Adjacent to Site 10 and Along Boggy Spit Site 10
North End Landfill 		Shellfish Shellfish beds adjacent to Site 10 and along Boggy Spit Ingestion Past: Prior to 1988, Naval employees and some community members harvested shellfish from this area
Current: No one is being exposed to the shellfish. (A ban prohibiting shellfishing in these beds has been in place since 1988. No trespassers have been caught violating the ban.)
Future: The beds could be reopened in the future. 		Past: Based on information about consumption patterns and available data, ATSDR concluded that exposure to contaminated shellfish were unlikely to pose health hazards.
Current: The current ban reduces public health hazards by preventing consumption of potentially contaminated shellfish. Although it is impossible to conclusively state that no one is trespassing and violating the ban, the Navy's security has never reported any occurrences of trespassing. Signs are posted to inform people of the bans in these areas. Available data are not adequate to firmly conclude whether contaminant levels could pose health hazards if the ban were not in place. ATSDR recommends that people adhere to the shellfish harvesting ban as a precautionary measure while Navy continues to monitor the area.
Future: Measures taken by the Navy will prevent future health hazards by (1) minimizing further contamination of the marine environment, and (2) ensuring that the beaches remain closed until the contaminant concentrations are at levels that do not pose a health hazard.
Consumption of Contaminated Shellfish Along the North-
Northwestern Shores of Marrowstone Island		 Unknown Shellfish Shellfish beds along the northern and northwestern shores of Marrowstone Island Ingestion Past, Current and Future: The shellfish beds were (past scenario) and are (current scenario) used for shellfishing. There are currently no restrictions planned for the future. Past, Current and Future: Because so few samples were collected in the past, ATSDR was unable to conclusively state whether past exposures to shellfish consumed along the north-northwestern shores of Marrowstone Island posed a health hazard. Current and future consumption of these shellfish is not expected to pose health hazards, however.
Exposure to Groundwater Potentially Impacted by Site 21

Site 21
Central Island disposal site		 Groundwater Water from backup water supply wells Nos. 1 and 2 Ingestion
Inhalation
Dermal		 Past: People on base may have used backup water supply wells Nos. 1 and 2 between 1941 and 1945.
Current: No one is being exposed to groundwater in the vicinity of Site 21 (Backup water supply wells Nos. 1 and 2 are closed).
Future: Backup water supply wells Nos. 1 and 2 could be reopened in the future. Additionally, a new well could be installed in the future. 		Past: Past exposures to groundwater cannot be evaluated. (Water supply wells Nos. 1 and 2 may have been used from 1941 to 1945, however, data are not available to address possible exposures to groundwater contamination during this 4-year period.)
Current: No production wells are being used in the vicinity of Site 21. Because there is no potential for exposures, Site 21 does not pose a health hazard.
Future: It is highly unlikely that future consumption of groundwater in the vicinity of Site 21 will pose a public health hazard. The Washington Department of Ecology, EPA, and the Navy are analyzing groundwater reports. If these agencies decide that contaminant concentrations pose a public health hazard, backup water supply wells Nos. 1 and 2 will be abandoned and deed restrictions will be implemented to prevent the installation of future wells.


Table 2

The following table was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333


Table 3
Littleneck Clam Tissue Dataa
Samples Collected Adjacent to Site 10 and Along Boggy Spit in May 1998

Contaminantb Concentration range (ppm)c EPA Region III Risk-Based
Concentration (ppm)

Semivolatile Organic Compounds

Anthracene ND-0.0026 410
Benzo(a)pyrene ND (detection limit of 0.0016) 0.00043
Benzo(g,h,i)perylene ND-0.0053 27d
Benzoic Acid ND-0.729 5,400
Dibenzo(a,h)anthracene ND (detection limit of 0.0008) 0.00043
Diethylphthalate 0.0018-0.0026 1,100
Naphthalene ND-0.0016 27
N-nitrosodi-n-propylamine ND (detection limit of 0.002) 0.00045
Pentachlorophenol ND (detection limit of 0.049) 0.026

Pesticides

alpha-hexachlorocyclohexane ND-0.000081 0.0005
beta-hexachlorocyclohexane ND-0.00011 0.0018
Heptachlor epoxide ND-0.00010 0.00035
4,4-DDE ND-0.00013 0.0093
4,4-DDT ND-0.000081 0.0093

Ordnance Chemicals

Cyclotrimethylenetrinitramine
(RDX)		 ND (detection limit of 1) 0.029
Nitrobenzene ND (detection limit of 1) 0.68
2,4,6-trinitrotoluene ND (detection limit of 3) 0.11
4-Amino-2,6-dinitrotoluene ND (detection limit of 1) 0.081e
2-Amino-4,6-dinitrotoluene ND (detection limit of 1) 0.081e

Metals

Aluminum 10-82 1,400
Arsenic 2.2-3.7f 0.0021f
Barium 0.38-0.63 95
Cadmium 0.28-0.36 1.4
Calcium 487-793 NA
Chromium 0.29-0.55 4.1
Cobalt 0.08-0.15 81
Copper 0.81-1.1 54
Iron 23-88 410
Lead 0.016-0.06 NL
Magnesium 785-1,059 NA
Manganese 1.0-2.2 190
Mercury 0.005-0.008 0.14g
Nickel 0.19-0.44 27
Potassium 2,008-2,218 NA
Selenium 0.16-0.49 6.8
Silver 0.015-0.17 6.8
Sodium 5,603-7,821 NA
Thallium ND-0.0015 0.095
Vanadium 0.21-0.44 9.5
Zinc 11-19 410
Note: Contaminants highlighted in bold were detected above Region III RBCs. Contaminants listed in italics were not detected, but were included in this table because their detection limits exceed their EPA Region III RBCs. It is uncertain, therefore, whether these chemicals are present at levels of potential health concern.
a Data provided by Foster Wheeler 1999. Data represent wet weight concentrations.
b Contaminants listed are those that were either (1) detected above detection limits at least once or (2) listed as having detection limits that exceeded Region III RBCs.
c Concentrations listed represent the range detected at Beaches 1, 2, and 19 (See Figure 7).
d No RBC is available for benzo(g,h,i)perylene. Like naphthalene, benzo(g,h,i)perylene is a PAH that exerts noncarcinogenic effect. Therefore, ATSDR used naphthalene's RBC (27 ppm) as a screening value.

e

Comparison value is for aminodinitrotoluenes.

f

This value represents total arsenic (inorganic concentration plus organic concentration).

g

Comparison value is for methylmercury.

NA

Not applicable. Calcium, magnesium, potassium, and sodium are considered essential nutrients and do not exert toxic effects at low levels.

ND

Not detected

NL

Not listed
ppm parts per million
RBC Risk-based concentration


Table 4

The following table was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333

 


Table 5

The following table was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333

 

Table 6
Shellfish Data From The North/Northwestern Shores of Marrowstone Island
Collected By ATSDR in April 1998
Marrowstone Island, Washington

Contaminant Maximum
Concentration
(ppm)a		 Shellfish
Species 		EPA Region III Risk-Based
Concentration (ppm)

Sample Location #1b

Arsenic 0.115c
0.012c		 HC
NLN		 0.0021d
Benzo(e)pyrene 0.0038 NLN 0.00043e
Benzo(g,h,i)perylene 0.00278 NLN 27f
Dibenzo(a,h)anthracene 0.0025 NLN 0.00043
Indeno (1,2,3-cd)pyrene 0.00349 NLN 0.0043
Perylene 0.00278 NLN 0.00043e

Sample Location #2b

Arsenic 0.0162c
0.0226c		 NLN
cockles		 0.0021d
Benzo(a)pyrene 0.0029 NLN 0.00043

Sample Location #3b

Arsenic 0.0171c
0.0162c		 NLN
cockles		 0.0021d
PCB 28
PCB 52
PCB 52		 0.00044
0.00085
0.00149		 NLN
cockles
NLN 		0.0016

Sample Location #4b

Arsenic 0.0154c
0.0193c		 NLN
cockles		 0.0021d
PCB 52 0.00083 NLN 0.0016

Sample Location #5b

Arsenic 0.020c
0.004		 NLN
HC		 0.0021d
Benzo(a)pyrene 0.0030 NLN 0.00043

Sample Location #6b

Arsenic 0.019c cockles 0.0021d
PCB 28 0.00047 cockles 0.0016

Sample Location #7b

Arsenic 0.035c NLN 0.0021d
Perylene 0.0035 NLN 0.00043e

Sample Location #8b

Arsenic 0.016c
0.012c		 NLN
oyster		 0.0021d
Fluoranthene 0.011 oyster 54
Benzo(a)anthracene 0.0023 oyster 0.0043
Chrysene 0.0047 oyster 0.43
Pentachlorophenol 0.0019 oyster 0.026
PCB 118
PCB 153
PCB 138		 0.00037
0.00102
0.00417		 oyster
oyster
oyster		 0.0016

Sample Location #9b

Arsenic 0.0252c
0.0321c		 NLN
cockles		 0.0021d

Sample Location #10b

Arsenic 0.122c
0.0152c		 HC
cockles		 0.0021d
Note: Contaminants highlighted in bold were detected above Region III RBCs.
a Data provided by ATSDR 1998b. Data represent wet weight concentrations.
b Sample locations are depicted on Figure 9.
c This value represents measured inorganic arsenic concentrations. In nature, arsenic exists in organic and inorganic forms. While organic forms are relatively non-toxic, inorganic forms can produce a variety of adverse health effects. Therefore, health assessors consider the inorganic component when evaluating the potential for health hazards.
d

This RBC is for total arsenic (organic concentration + inorganic concentration).

e

Because no RBCs are available for the PAHs benzo(e)perylene and perylene and these PAHs have not been classified for carcinogenicity, ATSDR used the benzo(a)pyrene RBC as a conservative (protective) screening value.

f No RBC is available for benzo(g,h,i)perylene. Like naphthalene, benzo(g,h,i)perylene is a PAH that exerts noncarcinogenic effect. Therefore, ATSDR used naphthalene's RBC (27 ppm) as a screening value.
   
ppm parts per million
RBC

Risk-based concentration

HC Horse clams
NLN Native little neck clams


Table 7

The following table was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333


Figure 1. Area Map


Figure 2. Site Map


Figure 3. Locations of Beaches in the Vicinity of Site 10


Figure 4. ATSDR's Exposure Evaluation Process


Figure 5. Site 10


Figure 6. 1987 and 1988 Shellfish and Sampling Locations


Figure 7. May 1998 Shellfish Sampling Locations


Figure 8. RI/FS Shellfish Sampling Locations


Figure 9. Shellfish Sampling Locations


Figure 10. Site 21


Figure 11. Long Spit


Figure 12. Sediment Location #12


Appendix A. Evaluation of Potential Public Health Hazards Associated With the 17 Port Hadlock Sites

Port Hadlock Site Site Description/Waste Disposal History Investigational Results/ Environmental Monitoring Results Corrective Activities and Current Status ATSDR's Evaluation of Public Health Hazards
Site 10
(North End Landfill)		 The landfill was used from 1945 to the mid-1970s. Materials reportedly disposed include zinc sludges, waste paints and thinners, solvents, strippers, waste petroleum oil and lubricants, sandblasting paint residues, waste oil, batteries, unidentified liquid waste, bomb ordnance and incinerator ash, asbestos, submarine nets, polyurethane resins, and residential trash.

Contaminants from Site 10 have been introduced to the marine environment via direct erosion, surface water runoff, and groundwater discharge.

Soil: Metals, PCBs, and SVOCs detected.
Groundwater: Metals, pesticides, and SVOCs detected.
Sediments adjacent to Site 10: Results suggest a link to Site 10 contaminants.
Shellfish adjacent to Site 10, along Boggy Spit, and along the north/northwestern shore of Marrowstone Island: Metals, ordnance compounds, pesticides, and SVOCs detected. 		Corrective Activities:
•A shellfish ban was issued in 1988.
•A landfill cap and erosion protection measures were constructed in 1997.
•A groundwater, sediment, and shellfish monitoring program is ongoing. (The Navy's contractor collected the first round of shellfish sampling and completed a human health risk assessment.)
•Institutional controls (e.g., land use restrictions for residential and farming use, deed restrictions in the event of property transfer) will be installed.
•A maintenance/inspection plan will be implemented.
Current Status:
• Remedial activities are completed.
• Monitoring activities are ongoing.
• Areas adjacent to Site 10 and along Boggy Spit are closed to shellfishing. 		Soil: Access to Site 10 was highly restricted and past exposures to the general public, therefore, are unlikely. Exposures to workers did not pose a public health hazard because exposures were infrequent and/or conducted with PPE if necessary. Current and future exposures are prevented by the landfill cap.
Groundwater: No drinking water wells are located in this area. Past and current exposures to groundwater, therefore, have not occurred. Wells will not be installed in the future because groundwater under Site 10 is not potable.
Sediments: Exposures do not pose a public health hazard because (1) sediment concentrations are low, and (2) the exposures would be infrequent.
Shellfish located adjacent to Site 10 and along Boggy Spit: Past exposures were unlikely to pose health hazard. A shellfish ban prevents current exposures. The ban will remain in place until future sampling indicates that the contaminants are at concentrations that do not pose a hazard.
PCB = Polychlorinated biphenyls
SVOC = Semivolatile Organic Compound
PPE = Personal Protective Equipment

Site 11
(Walan Point)

Site 11 was used for ordnance disposal in the late 1940s. Soil: 2,4,6-Trinitrotoluene detected.
Groundwater collected prior to corrective activities: Cadmium, trichloroethylene, and tetrachloroethylene detected.
Groundwater collected after corrective activities: Some metals detected at concentrations that are slightly above health guidelines. 		Corrective Activities:
• Soil excavated in 1994 and 1995. (Approximately 4,600 tons of metal slag, ordnance debris, bomblets, and soils were screened and 1,500 tons were properly disposed offsite.)
Current Status:
• No further action required. 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary. Excavation activities further reduced the hazards associated with potential current and future exposures.
Groundwater: No drinking water wells are located in this area. Past and current exposures to groundwater, therefore, have not occurred. It is unlikely that production wells will be installed in the future.
Site 12
(Griffin Street) 		Between the 1940s and 1950s, Site 12 was used for ordnance disposal. Soil: No contaminants were detected above regulatory requirements. (No contaminants above Model Toxics Control Act [MTCA] criteria.)
Groundwater collected prior to corrective activities: Arsenic, beryllium, cadmium, manganese, and nickel detected above health guidelines.
Groundwater collected after corrective activities: Several metals detected. Only manganese detected above health guidelines. 		Corrective Activities:
• Soil excavated in 1994 and 1995. (Approximately 1,800 tons of metal slag, ordnance debris, bomblets, and soils were screened and 320 tons were properly disposed offsite.)
Current Status:
• Groundwater underlying the site will be further evaluated. A sampling plan has been drafted to monitor nickel concentrations. 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary. Excavation activities further reduced the hazards associated with potential current and future exposures.
Groundwater: No drinking water wells are located in this area. Past and current exposures to groundwater, therefore, have not occurred. It is unlikely that production wells will be installed in the future.
PPE = Personal Protective Equipment
Site 13 (Gas Station) In 1992, a 3,000 gallon tank leaked (<500 gallons was lost). The tank was repaired, but failed a precision tightness test later in 1992. Soil: Soil contaminated with petroleum.

Corrective Activities:
• Tank removed.
• Contaminated soil excavated and disposed offsite.
Current Status:
• No further action required. 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary. Excavation activities further reduced the hazards associated with potential current and future exposures.
Groundwater: No drinking water wells are located in this area. Past and current exposures to groundwater, therefore, have not occurred. It is unlikely that production wells will be installed in the future.
Site 15
(North Slab Storage) 		Between the 1940s and 1970s, Site 15 was used as a storage area for paints, solvents, and unknown wastes. Soil Gas and Soil: No contaminants were detected above regulatory requirements. (No MTCA exceedences for SVOCs or VOCs). Current Status:
• No remedial efforts required. 		No public health hazard is associated with this site. No contaminants were detected above regulatory requirements.
Site 16 USTs were located in Site 16. No record of sampling activities. Corrective Activities:
• USTs removed in 1992.
Current Status:
• No further action required. 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary.
Groundwater: No drinking water wells are located in this area. Past and current exposures to groundwater, therefore, have not occurred. It is unlikely that production wells will be installed in the future.
UST= Underground Storage Tank • VOC= Volatile Organic Compound • MTCA= Model Toxics Control Act • SVOC= Semivolatile Organic Compound
PPE= Personal Protective Equipment
Site 17 (Imhoff tanks) Two 5,000 gallon Imhoff tanks were located in this area. Gas: Field monitoring detected combustible gas at explosive concentrations within the buried tank. Corrective Activities:
• Tanks removed and gas vented in 1987.
Current Status:
• No further action required. 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary.
Groundwater: No drinking water wells are located in this area. Past and current exposures to groundwater, therefore, have not occurred. It is unlikely that production wells will be installed in the future.
Site 18
(Net Depot) 		Between the 1940s and 1950s, Site 18 was used as a building and repair area for submarine nets. Soil Gas and Soil: No contaminants were detected above regulatory requirements. (No MTCA exceedences of SVOCs or VOCs.)
Storm Sewer sediments collected prior to corrective activities: PAHs detected.
Storm sewer sediments collected after corrective activities: Some VOCs and SVOCs detected, but at concentrations that do not pose a health hazard.
Groundwater: Tetrachloroethylene detected. 		Corrective Activities:
• Sediments excavated in August 1994. (Approximately 0.5 cubic foot of sediments removed from storm drain catch basin and properly disposed.)
Current Status:
• No further action required. 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary. Excavation activities further reduced the hazards associated with potential current and future exposures.
Groundwater: No drinking water wells are located in this area. Past and current exposures to groundwater, therefore, have not occurred. It is unlikely that production wells will be installed in the future.
Site 19
(Former Public Works) 		Between the 1940s and 1970s, Site 19 was used to facilitate public-works-related activities. Soil Gas and Soil: No contaminants were detected above regulatory requirements. (No MTCA exceedences of SVOCs or VOCs.) Current Status:
• No further action required. 		No public health hazard is associated with this site. No contaminants were detected above regulatory requirements.
PPE= Personal Protective Equipment • VOC= Volatile Organic Compound • MTCA= Model Toxics Control Act • SVOC= Semivolatile Organic Compound
PCB = Polychlorinated biphenyls • PAH = Polycyclic Aromatic Hydrocarbon
Site 20
(Upper and Lower Bone-yards) 		Site 20 was used as storage areas (all uncovered) for primarily inert materials. One storage area was used for oil and solvent drums in the 1940s to the 1970s. Soil Gas and Soil: No contaminants were detected above regulatory requirements. (No MTCA exceedences of SVOCs or VOCs.) Current Status:
• No further action required. 		No public health hazard is associated with this site. No contaminants were detected above regulatory requirements.
Site 21
(Central Island disposal site) 		Site 21 was used as a disposal site for waste oils, solvents, electrical equipment, and paint.

Backup water supply wells Nos. 1 and 2 could potentially be impacted by the activities at Site 21.

Soil: Metals detected.
Groundwater under Site 21:
Results from 1995 RI/FS: Metals, hexachlorobutadiene, BEHP, and benzene were detected.
Results from 2-year monitoring program: BEHP, arsenic, and manganese detected above ATSDR comparison values.
Groundwater in backup water supply wells Nos. 1 and 2: No sampling data are available to indicate the quality of the water between 1941 and 1945. 		Corrective Activities:
• An additional monitoring well was installed in 1995.
• A 2-year groundwater monitoring program was recently completed.
• The Washington Department of Ecology, EPA, and the Navy are analyzing groundwater monitoring data to determine if future remedial actions are necessary.
Current Status:
• Agencies are reviewing recent data.
• Backup water supply wells Nos. 1 and 2 are not in service.
• A sampling plan has been developed to monitor arsenic. 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary.
Groundwater (see applicable section in this PHA): Past exposures to potentially impacted groundwater could have occurred between 1941 and 1945 via consumption of groundwater from backup water supply wells Nos. 1 and 2. No groundwater data are available to determine whether these exposures posed a health hazard. Current exposures are not occurring. The Washington Department of Ecology, EPA, and the Navy are analyzing groundwater monitoring data collected from the area. If these agencies decide that contaminant concentrations pose a public health hazard, backup water supply wells Nos. 1 and 2 will be abandoned and deed restrictions will be implemented to prevent the installation of future wells.
Site 22
(Old Bomb Overhaul Area) 		Site 22 was used to recondition bombs from the 1940s to 1970s. Soil: Subsurface arsenic concentrations exceeded MTCA Method B standards but was within Puget Sound levels. Current Status:
• No further action required. 		No public health hazard is associated with this site. All contaminant concentrations were within regulatory requirements or within background concentrations.
PPE= Personal Protective Equipment • VOC= Volatile Organic Compound • MTCA= Model Toxics Control • SVOC= Semivolatile Organic Compound
RI/FS= Remedial Investigation/Feasibility Study • BEHP= Bis(2-ethylhexyl)phthalate • EPA= U.S. Environmental Protection Agency • PHA= Petitioned Health Assessment
Site 30 Site 30 has contaminated soils. Soil: Diesel and heavy oils detected. Corrective Activities:
• Contaminated soil excavated.
• Confirmation samples indicate that the area is clean.
Current Status:
• No further action required. 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary. Excavation activities further reduced the hazards associated with potential current and future exposures.
Groundwater: No drinking water wells are located in this area. Past and current exposures to groundwater, therefore, have not occurred. It is unlikely that production wells will be installed in the future.
Site 33 (Old Rifle Range) Site 33 was previously used as a rifle range. Soil: Lead was detected, but an investigation determined that the lead is not migrating.

Corrective Activities:
• A removal action will be conducted when the Rifle Range Rule is finalized.
Current Status:
• Investigations are ongoing. (A site hazard assessment is going to be performed in the future.) 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary. Excavation activities planned for the future will further reduce the hazards associated with future exposures.
Groundwater: No drinking water wells are located in this area. Past and current exposures to groundwater, therefore, have not occurred. It is unlikely that production wells will be installed in the future.
PPE= Personal Protective Equipment
Site 34 Open Burn/Open Detonation (OB/OD) Area
and North Satellite Area 		From the late 1970s to approximately 1990, the OB/OD area was used to burn and detonate military energetic materials (i.e., ammunition and explosives). From the 1970s to 1988, operations at the OB/OD area were conducted in open, unlined pits. The OB/OD area is still used for occasional emergency burning and detonation of ordnance. The North Satellite area may have been used for testing ordnance and for training activities. Soil: Lead, total petroleum hydrocarbons (TPH), and PAHs were detected at high levels. Groundwater and Surface Water: Site 34 contaminants do not impact groundwater or surface water. Corrective Activities:
• Soil removal activities were completed in the fall of 1996. 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary. Excavation activities further reduced the hazards associated with potential current and future exposures.
Groundwater and Surface Water: No public health hazards are associated with these media. Site 34 contaminants do not impact groundwater or surface water.
Site 35 Site 35 consists of an old shed that was previously used to store solvents. The shed has a drain at the bottom. The drain is suspected to discharge directly to the ground. Soil: No contaminants were detected above EPA or state standards. Sampling activities are planned for the future. Current Status:
• No further action required. 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary.
Groundwater: No drinking water wells are located in this area. Past and current exposures to groundwater, therefore, have not occurred. It is unlikely that production wells will be installed in the future.
Site 36 Site 36 was used as a storage area for primarily inert materials. Sampling activities are planned for the future. Current Status:
• Investigations are ongoing. 		Soil: Access has always been highly restricted and it will continue to be so in the future. Past, current, and future exposures to the general public, therefore, are unlikely. Past, current, and future exposures to workers do not pose a public health hazard because visits are infrequent and/or conducted with PPE if necessary.
Groundwater: No drinking water wells are located in this area. Past and current exposures to groundwater, therefore, have not occurred. It is unlikely that production wells will be installed in the future.

PAH=Polycyclic Aromatic Hydrocarbons • PPE= Personal Protective Equipment

Sources: ATSDR 1999; EFA Northwest 1995, 1996a, 1996b, 1996c, 1996d, 1996e 1997a, 1997b, 1998b, 1998d; Ecology 1998; EPA, 1989, 1991, 1997, 1998; FDA 1993; Foster Wheeler 1996a, 1996b, 1997; Navy 1996; SCS Engineers 1987; Toy 1996; URS 1995a, 1995b, 1996a, 1996b, 1996c, 1997; WDOH 1991


Appendix B - Glossary

Background Level
A typical or average level of a chemical in the environment. Background often refers to naturally occurring or uncontaminated levels.

Carcinogen
Any substance that might produce cancer.

CERCLA
The Comprehensive Environmental Response, Compensation, and Liability Act of 1980, also known as Superfund. This is the legislation that created ATSDR.

Comparison Values
Estimated contaminant concentrations in specific media that are not likely to cause adverse health effects, given a standard daily ingestion rate and standard body weight. The comparison values are calculated from the scientific literature available on exposure and health effects.

Concentration
The amount of one substance dissolved or contained in a given amount of another. For example, sea water contains a higher concentration of salt than fresh water.

Contaminant
Any substance or material that enters a system (the environment, human body, food, etc.) where it is not normally found.

Dermal
Referring to the skin. Dermal absorption means absorption through the skin.

Dose
The amount of substance to which a person is exposed. Dose often takes body weight into account.

Environmental contamination
The presence of hazardous substances in the environment. From the public health perspective, environmental contamination is addressed when it potentially affects the health and quality of life of people living and working near the contamination.

EPA's cancer slope factors
The additional risk of cancer posed by the ingestion of 1 milligram of a substance, per kilogram of body weight, per day, over a lifetime.

EPA's chronic oral reference dose (RfD)
An estimate (uncertainty spanning perhaps an order of magnitude) of a daily exposure (milligram per kilogram per day [mg/kg/day]) to the general public (including sensitive subgroups) that is likely to be without an appreciable risk of harmful effects during a lifetime exposure or exposure during a limited time interval.

Exposure
Contact with a chemical by swallowing, by breathing, or by direct contact (such as through the skin or eyes). Exposure may be short term (acute) or long term (chronic).

Hazard
A source of risk that does not necessarily imply potential for occurrence. A hazard produces risk only if an exposure pathway exists, and if exposures create the possibility of adverse consequences.

Ingestion
Swallowing (such as eating or drinking). Chemicals can get in or on food, drink, utensils, cigarettes, or hands where they can be ingested. After ingestion, chemicals can be absorbed into the blood and distributed throughout the body.

Inhalation
Breathing. Exposure can occur from inhaling contaminants because they can be deposited in the lungs, taken into the blood, or both.

Media
Soil, water, air, plants, animals, or any other parts of the environment that can contain contaminants.

Minimal Risk Level (MRL)
An MRL is defined as an estimate of daily human exposure to a substance that is likely to be without an appreciable risk of adverse effects (noncancer) over a specified duration of exposure. MRLs are derived when reliable and sufficient data exist to identify the target organs of effect or the most sensitive health effects for a specific duration via a given route of exposure. MRLs are based on noncancer health effects only. MRLs can be derived for acute, intermediate, and chronic duration exposures by the inhalation and oral routes.

Model Toxics Control Act (MTCA)
MTCA is Washington State's equivalent to Superfund. MTCA standards are as stringent or more stringent than those used by EPA.

National Priorities List (NPL)
The Environmental Protection Agency's (EPA) listing of sites that have undergone preliminary assessment and site inspection to determine which locations pose immediate threat to persons living or working near the release. These sites have the greatest for need for cleanup activity.

No Apparent Public Health Hazard
Sites where human exposure to contaminated media is occurring, or has occurred in the past, but the exposure is below a level of health hazard.

Ordnance Compounds
Compounds that are used in military weapons.

Personal Protective Equipment
Clothing (including coveralls, gloves, protective footwear and headware) and/or respirators worn by workers to prevent exposures to known or potentially hazardous materials.

Pesticides
Any organic or inorganic substance used to destroy or inhibit the action of plant or animal pests, including insecticides, herbicides, fungicides, rodenticides, miticides, fumigants, and repellants. All pesticides are toxic to humans to some degree. Pesticides vary in biodegradability.

Polychlorinated biphenyls (PCBs)
A group of synthetic organic chemicals that contain 209 individual chlorinated biphenyl compounds (known as congeners). There are no known natural sources of PCB in the environment. PCBs are either oily liquids or solids. Because they do not burn easily and are good insulating materials, PCBs have been used widely as coolants and lubricants in transformers, capacitors, and other electrical equipment. The manufacture of PCBs stopped in the United States in October 1977 as a result of evidence that they build up in the environment and cause harmful effects.

Public Health Assessment
The evaluation of data and information on the release of hazardous substances into the environment in order to assess any current or future impact on public health, develop health advisories or other recommendations, and identify studies or actions needed to evaluate and mitigate or prevent human health effects; also, the document resulting from that evaluation.

Public Health Hazard
Sites that pose a public health hazard as the result of long-term exposures to hazardous substances.

Risk
In risk assessment, the probability that something will cause injury, combined with the potential severity of that injury.

Route of Exposure
The way in which a person may contact a chemical substance. For example, drinking (ingestion) and bathing (skin contact) are two different routes of exposure to contaminants that may be found in water.

Superfund
Another name for the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), which created ATSDR.

Superfund Amendments and Reauthorization Act (SARA)
The 1986 legislation that broadened ATSDR's responsibilities in the areas of public health assessments, establishment and maintenance of toxicologic databases, information dissemination, and medical education.

Semivolatile Organic Compounds (SVOCs)
A class of organic (containing carbon) chemicals similar to VOCs, but that evaporate or volatilize less rapidly.
 
Slag
 
A man-made sediment that looks like black sand, but has a high metal content.
 
Sludges
 
Any solid, semisolid, or liquid waste generated from a municipal, commercial, or industrial waste water treatment plant, water supply treatment plant, or an air pollution control facility.
 
Volatile Organic Compounds (VOCs)
Substances containing carbon and different proportions of other elements such as hydrogen, oxygen, fluorine, chlorine, bromine, sulfur, or nitrogen; these substances easily become vapors or gases. A significant number of the VOCs are commonly used as solvents (paint thinners, lacquer thinner, degreasers, and dry cleaning fluids).

Appendix C: Comments On the Port Hadlock Public Health Assessment

The Port Hadlock Public Health Assessment (PHA) was released for public comment on April 21, 1998. The comment period ended on June 1, 1998. Comments were received during the comment period. As necessary, ATSDR contacted those that commented for additional clarification of their concerns. Factual comments were confirmed and changed in the text.

  1. Comment: One commenter objected to the PHA's statement that "it is unlikely that contaminants found on the north-northwestern shores of Marrowstone Island are attributable to Port Hadlock's Site 10." The commenter noted that the data presented in the public comment version of the PHA showed a correlation between Site 10 contaminant concentrations and concentrations detected along the north-northwestern shores of Marrowstone Island. Such agreement, he noted, could be evidence that the two could be related and from the same source. The commenter also noted that very strong tides exist in the area and are capable of carrying sediment long distances. Specifically, he observed sediment being carried from the Boggy Spit area to Mystery Bay.

    Response: ATSDR noted the commenter's observations within the main body of the text. (See Evaluation of Environmental Contamination and Exposure Pathways--Consumption of Contaminated Shellfish Along the North-Northwestern Shores of Marrowstone Island.) In the interest of public health, ATSDR performed additional shellfish sampling along Marrowstone Island to determine if there were levels of contaminants which could result in adverse health effects. Based on this investigation, current and future consumption of shellfish is unlikely to pose health hazards.

  2. Comment: Two commenters expressed concern about potential health hazards associated with consuming shellfish along the north-northwestern shores of Marrowstone Island.

    Response: In April 1998, ATSDR collected shellfish samples from the Marrowstone Island shores (See Figure 9). (These data were unavailable when the public comment version of the PHA was released.) In August 1998, ATSDR's Exposure Investigation and Consultation Branch released the results. These results have been added to the PHA. (See Table 6 and Evaluation of Environmental Contamination and Exposure Pathways--Consumption of Contaminated Shellfish Along the North-Northwestern Shores of Marrowstone Island.) The results indicate that current and potential future shellfish exposures are unlikely to be associated with public health hazards.

  3. Comment: One commenter questioned ATSDR's decision to discuss the possibility of Marrowstone Island drinking wells becoming impacted by Port Hadlock's contaminants. Specifically, the commenter objected to the statement that "[r]esidents on Marrowstone Island report that their drinking water wells are impacted by salt water intrusion." The commenter said that data do not support this claim and asked where ATSDR first learned of this community concern.

    Response: ATSDR included a discussion on this topic because the agency is mandated to address all community concerns. ATSDR read about this community concern in a Navy document (Navy 1996). An EFA Northwest representative confirmed that the community had expressed concern about potential impacts to Marrowstone Island drinking water wells (EFA Northwest 1996c).

  4. Comment: One commenter concurred with ATSDR's statement that no information is available substantiating the claim that oil leaked from ships. The commenter said that he has lived on a Kilisut Harbor beach since 1936. Although the beach has been dug repeatedly, he continued, no evidence of an oil leak has been reported. Another commenter said that the ships that were moored between Indian Island and Marrowstone Island never contained fuel.

    Response: ATSDR incorporated this information into the text.

  5. Comment: One commenter disagreed with ATSDR's statement that people could wade from Marrowstone Island to Boggy Spit during low tide. The commenter noted that the water is much too deep to enable walking between the two islands even during the lowest tides.

    Response: ATSDR modified Appendix A to reflect this information.

  6. Comment: One commenter asked whether children wading on the shores of Port Townsend could be adversely affected by Port Hadlock's contaminants.

    Response: Given the dynamic nature of waves, ATSDR cannot say, with absolute certainty, that Site 10 contaminants have not migrated to Port Townsend. It does appear to be highly unlikely, however. Shoreline analyses indicate that Site 10 sediments accumulate in Boggy Spit and the broad underwater sandbar located directly offshore (see Figure 11). It is unlikely, therefore, that Site 10 sediments are carried to Port Townsend. It is also unlikely that dissolved contaminants are carried to Port Townsend via waves. Long Spit, which consists of Sandy Spit and Rat Island (see Figure 11), is located immediately offshore of Port Hadlock's Site 10. For the most part, Long Spit serves as a wave barrier between Port Townsend Bay and Site 10 (Foster Wheeler 1996b). A small gap is located between Sandy Spit and Rat Island, however. If contaminants did travel to Port Townsend, they would be greatly diluted and likely not of health concern.

  7. Comment: One commenter noted that nuclear materials are transported via train from Bangor Submarine Base to Port Hadlock. The commenter asked whether nearby residents could be adversely effected by materials released to the air.

    Response: The Department of Transportation has specific rules and regulations regarding the transport of hazardous materials. These rules and regulations are designed to prevent any releases of hazardous materials into the environment. ATSDR has forwarded this comment to the health assessors working on the Bangor Submarine Base.

  8. Comment: One commenter said that he owns an active clam bed at the entrance of Kilisut Harbor. According to the commenter, his bed is located at sediment sample location #12 (see Figure 12). The commenter provided sediment sampling data for this location and asked ATSDR to (1) evaluate the sediment data and (2) collect shellfish samples from his bed.

    Response: ATSDR evaluated the sediment data provided by this commenter. No SVOCs, pesticides, or PCBs were detected. Nine metals were detected at low concentrations that are not likely associated with health effects if people were to contact these sediments. (ATSDR compared the contaminant concentrations against ATSDR's soil comparison values. Only arsenic (7.0 ppm) exceeded health guidelines. Soil comparison values were used because sediment comparison values do not exist. Using soil comparison values as a screen is a conservative [or protective] approach because ATSDR's soil comparison values are generated assuming that people will have regular exposure to soils for long periods of time. Exposures to sediment are typically much more sporadic than exposures to soil. At sediment location #12, it is unlikely that people regularly contact the submerged sediment.)

    The commenter's concern regarding shellfish contamination in this area is more difficult to address. No shellfish samples have been collected at sediment location #12 and not enough data are available to predict shellfish contaminant concentrations based on sediment data. (Determining the correlation between sediment concentrations and shellfish contaminant concentrations is complicated by many factors [e.g., bioaccumulation].)

    In the absence of shellfish data for location #12, ATSDR carefully reviewed shellfish data that have been collected in the vicinity of location #12. Historical data for shellfish location #15 (see Figure 8) was provided in the RI/FS. Although several constituents were detected in the sample, arsenic was the only contaminant detected above EPA's Region III RBCs and its concentration--0.6 ppm--was not high enough to pose a health hazard. More recently (May 1998), the Navy collected samples in the vicinity of Site 10. Figure 7 shows sampling locations. The locations do not correspond exactly with sediment location #12 (figure 12), but shellfish sample location #15 and #101 are in relative close proximity. As discussed in the main body of the text, "total" arsenic was the only detected contaminant that was present above EPA's Region III RBCs. (ATSDR's analysis indicated that concentrations would not pose health hazards if only 1 % of the "total" arsenic detected was in toxic inorganic forms. Even assuming 10 % inorganic arsenic, estimated doses only slightly exceeded health-based guidelines.) Also, some of the contaminants that were listed as "nondetect" had detection limits that exceeded their RBCs. As a result, it is impossible to conclusively state that exposures to these contaminants did not slightly exceed health-based guidelines.

  9. Comment: One commenter said that the shellfish ban should cover a larger area.

    Response: ATSDR assumed that the commenter was implying that the ban should extend to the Marrowstone Island area. As noted in the main body of the text, the Final Site Work Plan; Site 10 North End Landfill, and the ROD indicate that it is unlikely that Port Hadlock's contaminants migrated to Marrowstone Island. ATSDR evaluated the Marrowstone Island area simply to be extra protective and to address concerns expressed by the community. Data collected in April 1998 indicated that detected contaminant concentrations are too low to pose current or potential future health hazards.

  10. Comment: One commenter asked why ATSDR has not evaluated the interactive effects of the carcinogenic contaminants detected at Marrowstone Island.

    Response: Several complicating factors come into play when toxicologists try to estimate how chemicals will interact. For this reason, ATSDR typically evaluates each contaminant separately but also considers the potential for cumulative effects. Other agencies have adopted approaches to estimate cumulative risks; simply summing the quantitative risk estimates for each chemical is one such method. Although ATSDR realizes that this approach is associated with some uncertainties, ATSDR used this approach to evaluate the potential for cumulative carcinogenic risks at Marrowstone Island. ATSDR determined that the concentrations detected during the April 1998 shellfish sampling were too low to pose health hazards even when the individual chemicals are looked at collectively. Scientists continue to research the behavior of multiple chemical interactions and explore the best way to evaluate possible effects of cumulative exposures.

  11. Comment: One commenter said that the PHA supports the old axiom that "dilution is the solution to pollution." The commenter believes that a higher standard of public health and safety is needed given the accumulative effects over time that toxic compounds can have on the human body.

    Response: When calculating exposure doses, ATSDR uses highly conservative (or protective) ingestion rates and exposure frequencies. The exposure dose, which estimates the amount of a contaminant consumed per day, is calculated assuming that people will be exposed for long durations. For carcinogenic effects, ATSDR calculated two different exposure doses based on the number of years a person is expected to be exposed to shellfish. Using the EPA's guidelines, ATSDR assumed that exposures might result over 30 years (upper-bound estimate at one residence) or 9 years (median-time estimate at one residence) and averaged these values over a 70 year life time (EPA 1989). For noncarcinogenic effects, ATSDR assumed that people would be exposed to shellfish for 30 years.

  12. Comment: One commenter indicated that the public comment version of the PHA contained some outdated information. He recommended updating the information in Appendix A.

    Response: ATSDR contacted the commenter and acquired updated information. ATSDR edited Appendix A based on the new information that was provided.

  13. Comment: One commenter said that a detailed discussion on background concentrations in shellfish should be included in the PHA. He said that arsenic concentrations are naturally high in the area surrounding Port Hadlock and that past Naval activities are not responsible for elevated arsenic concentrations. He noted that several investigation reports have used Samish Bay to represent background concentrations, but said that this location does not accurately represent the natural concentrations that exist closer to Port Hadlock.

    Response: ATSDR agrees that understanding background concentrations helps put potential exposures into better perspective and enables investigators to identify base-related sources of contamination. However, because detected arsenic concentrations exceed available comparison values, ATSDR retained arsenic as a contaminant of potential concern for further evaluation. The purpose of the PHA is to review available environmental data and to provide the public with an evaluation of potential health hazards. Therefore, ATSDR has provided an interpretation of potential health hazards associated with arsenic levels in shellfish.

  14. Comment: One commenter said that information on ATSDR's April 1998 sampling effort should be included in the PHA. He asked for information on laboratory analysis procedures, field sampling information, sampling objectives, sampling stations, collection procedures, and sample handling and documentation procedures.

    Response: ATSDR has incorporated information about the April 1998 sampling event (See Table 6 and the "Evaluation of Environmental Contamination and Exposure Pathways--Consumption of Contaminated Shellfish Along the North-Northwestern Shores of Marrowstone Island section.) ATSDR did not include information on sampling collection procedures or sample handling and documentation, but provided a reference so that readers know where to find these details.

  15. Comment: In the public comment version of the PHA, the "Summary" section indicated that contaminants have been detected in shellfish samples that are adjacent to Site 10 and along Boggy Spit. One commenter asked that the following be added to this statement:

    Response: In an effort to keep the "Summary" section brief and concise, ATSDR chose not to incorporate the commenter's suggestions into the "Summary" section because (1) the text already notes that detections do not always translate into health hazards, (2) it is incorrect to say that EPA has not established health guidelines for shellfish because Region III has established risk-based concentrations, and (3) some of the inorganics detected at background stations were lower than those detected near Site 10 (e.g., during the RI/FS, arsenic was detected at 0.19 ppm at background locations, but at 3.3 ppm near Site 10).

  16. Comment: In the public comment version of the PHA, the "Summary" section indicated that ATSDR analyzed data that was collected prior to 1988. The commenter asked ATSDR to add information about this sampling event.

    Response: In an effort to keep the "Summary" section brief and concise, ATSDR chose not to incorporate the commenter's suggestions into the "Summary" section. The information requested is clearly stated in the "Evaluation of Environmental Contamination and Exposure Pathways--Consumption of Contaminated Shellfish Located Adjacent to Site 10 and Along Boggy Spit" section. Under the discussion on past exposure, ATSDR notes that 28 shellfish samples were collected between 1987 and 1988. ATSDR notes the species sampled and directs the reader to Table 2 for a list of contaminants above EPA's Region III RBCs. In addition, ATSDR provides a reference (i.e., WDOH 1991) for more detailed information.

  17. Comment: In the public comment version of the PHA, the "Summary" section indicated that shellfish consumption along the north-northwestern shores of Marrowstone Island could pose a past, current, and future potential public health hazard. One commenter asked ATSDR to add information about which data are being referred to and when the data were collected.

    Response: In an effort to keep the "Summary" section brief and concise, ATSDR chose not to incorporate the commenter's suggestions into the "Summary" section. The information requested is already clearly stated in the "Evaluation of Environmental Contamination and Exposure Pathways--Consumption of Contaminated Shellfish Along the North-Northwestern Shores of Marrowstone Island" section.

  18. Comment: One commenter objected to ATSDR's statement that bans have been in place since 1988 to restrict all fishing (shellfish and finfish) and recreational activities along beach 19. He said that the shellfish bans do remain in place, but that the finfish and recreational bans were lifted after remedial activities were completed at Site 10.

    Response: ATSDR confirmed this information and then modified the text to reflect this comment.

  19. Comment: One commenter objected to ATSDR's statement that the beaches along Boggy Spit were used for subsistence, commercial, and ceremonial harvesting activities prior to the 1988 ban. The commenter stressed that there are no records of subsistence fishing in the area. He said that the historical harvesting records do not indicate that beaches 1, 2 and 19 were used for shellfish harvesting. He said that tribal members were granted access to these beaches in 1989, one year after the ban was established.

    Response: ATSDR confirmed this information and then modified the text to reflect this comment.

  20. Comment: One commenter said that he was confused about which populations ATSDR considered in the evaluation of past exposures to shellfish near Site 10.

    Response: ATSDR changed the sentence that caused the confusion.

  21. Comment: One commenter noted that high levels of arsenic do not always translate into a human health risk. The commenter noted that the body does not ingest insoluble forms of arsenic and asked ATSDR to elaborate on the effects that arsenic has on humans.

    Response: ATSDR added toxicologic information about arsenic to provide added perspective.

  22. Comment: In Appendix A of the public comment version of the PHA, ATSDR noted that shellfish samples were collected along the shores of Marrowstone Island. One commenter requested that this information be removed because an RI/FS was not performed at Marrowstone Island.

    Response: ATSDR did not change the document as the commenter requested. As written, the text does not imply that a full RI/FS was conducted at Marrowstone Island.


1. The lowest observed adverse effect levels for arsenic (primarily skin and gastrointestinal effects) generally range from 0.014 mg/kg/day to >0.05 mg/kg/day (ATSDR 1998a). Several epidemiologic studies of moderately-sized populations (20-200 people) exposed to arsenic through drinking water have observed no effects at average chronic doses of 0.0004-0.01 mg/kg/day (Mazumder et al. 1988; Valentine et al. 1985; Cebrian et al. 1983; Southwick et al. 1981; Harrington et al. 1978). Cancers (primarily in the skin) have been reported in human studies at doses ranging from 0.001->1 mg/kg/day (ATSDR 1998a).

2. Pentachlorophenol was not actually detected in the sample, but ATSDR assumed that it was present at its reported detection limit concentration because this exceeded EPA's Region III RBC.

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