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PUBLIC HEALTH ASSESSMENT

AMERICAN CREOSOTE WORKS INCORPORATED (PENSACOLA)
PENSACOLA, ESCAMBIA COUNTY, FLORIDA


SUMMARY

The American Creosote Works, Inc., National Priorities List (NPL) site, is near Pensacola Bay in Pensacola, Florida. American Creosote operated a wood preserving business from 1902 until 1981. Soils, buried sludge, ground water, sediments, and air are contaminated with numerous of chemicals including; pentachlorophenol, polycyclic aromatic hydrocarbons (PAHs), polychlorinated dibenzodioxins (PCDDs), polychlorinated dibenzofurans (PCDFs), and benzene. Ground water contamination extends about 1,500 feet south of the site to within about 500 feet of Pensacola Bay. Approximately 1,000 people live in the neighborhood adjoining the site and all are on municipal water supply. The residents are concerned about health effects from past exposure to contaminants in ground water and ingestion of home grown vegetables. Florida Department of Health and Rehabilitation Service (HRS) epidemiologists found that the rates of cancer and birth defects near American Creosote are not unusual.

The site is fenced; however, site trespass continues to occur. Children trespassing on the site are likely to be exposed topentachlorophenol, PAHs, and PCDDs/PCDFs in the soil viaincidental ingestion and may suffer chloracne, liver damage, andan increased risk of cancer. Incidental ingestion of off-sitesoil by children may also increase their risk of chloracne andliver damage, but actual health effects depend on the frequencyand duration of the exposure. Inhalation of benzene in the on-site air may increase the lifetime risk of cancer for childrenand other site trespassers.

Vegetables from gardens near the site are not contaminated fromeither being grown in contaminated soil or watered withcontaminated ground water. It is unlikely that past exposures tocontaminated ground water via lawn irrigation or car washingcaused any health effects. Ingestion of contaminated fish andother aquatic life from Pensacola Bay near this site is apotential exposure pathway, but no samples have been tested.

This site is a public health hazard due to the risk of adversehealth effects from long term exposure to hazardous chemicals inthe air, soil, and ground water. The soil at this site should beremediated as soon as possible. Until soil remediation iscomplete, an adequate number of warning signs should be posted toprevent continued vandalism of the fence and site trespass. During soil remediation, effective dust control measures shouldbe used to prevent off-site migration of contaminated dust andappropriate air monitoring should be conducted at the peripheryof the site to ensure the safety of nearby residents. Contaminated ground water should not be used for potable purposesuntil it is remediated.

The Agency for Toxic Substances and Disease Registry (ATSDR),Health Activities Recommendation Panel reviewed this publichealth assessment and determined that community health education is needed. This determination is based on indications that long-term exposure to hazardous chemicals in the air, soil, and groundwater is likely to have occurred and may currently be occurring. This site is also being considered for a disease- and symptom-prevalence study by the Division of Health Studies, ATSDR.


BACKGROUND

A. Site Description and History

The American Creosote site is located within the Pensacola citylimits in Escambia County, one mile southwest of downtownPensacola, Florida near the corner of Barrancas Avenue and "L"Street, (see map in Appendix A). This level, 18-acre tract isbounded on the north and west by an industrial/commercial areaand on the south and east by a residential neighborhood. Pensacola Bay is about 2,000 feet south of the site.

American Creosote Works, Inc. (American Creosote) operated a woodpreserving business at this site from 1902 to 1981. AmericanCreosote used creosote to treat wood for use as telephone poles,railroad ties, fence posts, etc. After the 1950s, increasingamounts of technical grade pentachlorophenol were also used. Wood was treated under pressure in an air-tight cylinder usingdiesel fuel as a carrier solvent for the preservatives. AmericanCreosote discharged the excess diesel fuel, creosote, andpentachlorophenol into two wastewater lagoons located in thesouthwest corner of the site. The soil under the entire site isporous sand which allowed rapid infiltration of the wastewater. About 14,000 gallons of wastewater were discharged to the lagoons(1) monthly. Before 1970, the lagoons often overflowed due toheavy rains or too much wastewater. Wastewater overflow from thelagoons flowed south to a drainage ditch and into Pensacola Baynear Bayou Chico. After 1970, when the lagoons were full,American Creosote pumped the wastewater to an "overflow" pond orother areas on the site and allowed it to soak into the ground.

In March 1980, while installing underground utilities south ofthe site, Escambia County employees discovered ground watercontaminated with an "oily/asphaltic/creosote" substance. TheU.S. Geological Survey (USGS) installed nine monitor wells andconfirmed that the ground water was contaminated with creosote. Further investigations by the USGS and the EPA delineated theextent of the soil, sediment, and ground water contamination.

American Creosote closed in 1981 and filed for bankruptcy. TheEnvironmental Protection Agency (EPA) has supervised sitecharacterization and remediation since the site was added to the"Superfund" National Priorities List (NPL) in 1983. This sameyear, in an emergency action, EPA dewatered the wastewaterlagoons; added lime and fly ash to the remaining sludge; andcovered the resulting solids with a clay cap. EPA then conductedan initial Remedial Investigation/Feasibility Study (RI/FS) andsigned a Record of Decision (ROD) in 1985, proposing toconsolidate contaminated soil in an on-site landfill. TheFlorida Department of Environmental Regulation (DER) objected tothe ROD since it did not address ground water contamination. In1986, EPA removed the former structures at this site and fencedthe western three quarters of the property. Also in 1986, theAgency for Toxic Substances and Disease Registry (ATSDR) prepareda health assessment for this site (2). After a "Post"-RI/FS andRisk Assessment, EPA signed a second ROD in 1989 for cleanup ofon-site and off-site soils (Operable Unit I). The FloridaDepartment of Health and Rehabilitative Services (HRS) hasprepared this public health assessment for ATSDR in anticipationof a ROD (Operable Unit II) scheduled for release in the springof 1992. This ROD will primarily address the cleanup of theground water and solidified sludge.

After design studies are completed in the spring of 1992, EPAwill clean the soils using bioremediation techniques (OperableUnit I). EPA is finalizing the Risk Assessment and FeasibilityStudy for the solidified sludge and ground water (Operable UnitII) and is expected to hold a public meeting in the fall of 1991to discuss cleanup options. The property is currently inreceivership. After remediation is complete, it is anticipatedthat the property will be sold and the proceeds applied towardthe cleanup costs.

B. Site Visit

Chuck Pietrosewicz, ATSDR Regional Representative for Region IV,and Beverly Houston, of the Environmental Protection Agency,Region IV conducted a site visit on September 6, 1989. Communityhealth concerns were expressed at a pubic meeting that evening(see Community Health Concerns section).

Randy Merchant, HRS, and Robert Merritt of the Escambia CountyPublic Health Unit (CPHU) conducted a second site visit on April19, 1991, from about 1:30 to 3:00 pm. They observed a six-footchain link fence enclosing the western three-quarters of thesite. There were numerous fence repairs which indicate past siteaccess. Although the fence had recently been repaired, a newhole had already been cut at the time of this visit.

There are not enough warning signs posted at this site todiscourage trespassers. Trespass across this site is a short-cutfrom the residential neighborhood south of the site to commercialareas north of the site. There were few warning signs at thesite and those were not posted at the entrances to the site norspaced to be visible from any approach. Chapter 403.704 and403.7255, Florida Statutes, and Rule 17-736, FloridaAdministrative Code require warning signs be posted every 100feet at all Superfund National Priority List sites and be visiblefrom any approach.

Weeds and grasses cover the entire site. The clay cap over theformer wastewater lagoons was intact and in most places, wascovered with grass. Drums from previous remedial work werelocked inside a second fence. There were no obvious signs ofcontamination of the drainage ditch south of the site at thePensacola Yacht Club.

Mr. Merritt and Mr. Merchant drove through the neighborhoodsurrounding the site. No vegetable gardens were noticed. Neither Merritt nor Merchant collected any environmental samplesduring this site visit.

Mr. Merchant reviewed the Escambia CPHU file on American Creosoteand discussed the history of community health concerns with Mr.Merritt. Historically, residents have been concerned abouthealth risks from consuming plants grown in contaminated soil orirrigated with contaminated ground water.

C. Demographics, Land Use, and Natural Resource Use

The American Creosote site is bordered on the south and east by aresidential neighborhood and on the north and west by acommercial/industrial area. The nearest residences are about 100feet from the site. In 1970, about 5,000 people lived within one mile of the site. About 1,000 lived in the 15-blockresidential neighborhood located south and east of the site (3). This neighborhood is predominately white, low to middle income. The population in this area has been fairly stable since the1950s. Most residents in this area are between 45 and 65 yearsold and many have lived here for more than 40 years. Some hadsmall vegetable gardens, but discontinued this practice in themid-1980s. An eight-unit condominium was built near thesouthwest corner of the site in 1980. (see map in Appendix A)

Some of the residents south of the site used shallow wells forlawn and garden irrigation, car washing, etc. Those wells havenot been used since the mid-1980s when ground water contaminationwas widely publicized. In February 1991, EPA plugged andabandoned the private well at the condominiums on "L" Street. Since the 1950s, Escambia County has supplied potable water inthis area via buried water mains. The closest water supply wellis located about 900 feet northeast of the site (hydrologicallyupgradient) at Peoples Ice Company. This well is sampledannually and the results are monitored by the Escambia CPHU.

The Pensacola Yacht Club is located about 1,500 feet south-southwest of the site where Bayou Chico joins Pensacola Bay. Theyacht club property extends north from the bay to within 300 feetof the site. Access to the yacht club property is restricted bya fence. The gate to the yacht club property; however, is leftopen during the day and the drainage ditch outfall on the yachtclub property is easily accessible from Sanders Beach by walkingalong the beach. A public park, Sanders Beach, is located onPensacola Bay, about 1,400 feet south of the site and immediatelyeast of the yacht club drainage ditch outfall. This park is usedfor picnicking and fishing. The bridge over Bayou Chico, west ofthe yacht club, is also used for fishing.

The Florida Department of Environmental Regulation (DER) hasclassified the waters of Pensacola Bay near the site as Class III(recreation, propagation and maintenance of healthy, wellbalanced populations of fish and wildlife). The nearest Class IIwaters (usable for shellfish propagation or harvesting) inPensacola Bay are located about four miles to the east.

Access to the site was not restricted between the time AmericanCreosote closed in 1981 and in 1986 EPA erected a fence. No onelives on this site and except for sampling and remedial workers,no one has worked on this site since 1981. Exposure data andmedical records for workers at this site are unavailable. Thereare no schools, day-care centers, nursing homes, or hospitals inthe immediate vicinity of the site.

D. State and Local Health Data

HRS epidemiologists reviewed the state birth defect and cancer registry data bases for the 32501 zip code. This zip code includes the area around American Creosote and most of downtown Pensacola. In 1980, the population in this zip code was 19,266. The population in the residential neighborhood around the site (about 1,000 in 1970) makes up about 5% of the total population in this zip code (4). The birth defect data base was searched even though there have been no allegations or indication of elevated birth defect rates near this site. The birth defect data base covers birth defects reported from 1980 through 1982 and the cancer data base covers cancers reported from 1981 through 1987. The results of the review of the cancer and birth defects data are discussed in the Public Health Implications, Health Outcome Data Evaluation section.

Since 1988, one complaint of contaminated stormwater runoff fromthe American Creosote site has been received by the EscambiaCPHU. Results of this complaint investigation are discussed inthe Public Health Implications, Health Outcome Data Evaluationsection.


COMMUNITY HEALTH CONCERNS

Members of the community around American Creosote expressedhealth concerns at EPA sponsored public meetings on August 15,1985 (5) and September 6, 1989 (6). Health concerns were alsoexpressed through a telephone/mail survey conducted by HRS in May1991. A copy of this telephone/mail survey can be found inAppendix B. Residents around American Creosote are concernedabout the following:

The community is concerned about the toxicity ofcreosote components and pentachlorophenol, and exposureleading to cases of skin and lung cancer and/or deathin the surrounding neighborhood.

The community is concerned about exposure of humans tocontaminated ground water where it discharges intoPensacola Bay at Sanders Beach.

The community is concerned that contaminated soil,blown by the wind or hauled to nearby homes, hascontaminated home-grown produce.

The community is concerned that use of contaminatedground water for irrigation, car washing, etc. hasresulted in exposure.

The community is concerned that children and other sitetrespassers are being exposed to hazardous chemicals.


ENVIRONMENTAL CONTAMINATION AND OTHER HAZARDS

The following chemicals or chemical groups were selected asrepresentative of the distribution and toxicity of the hundredsof individual chemicals associated with this site.

Pentachlorophenol

Carcinogenic polycyclic aromatic hydrocarbons (PAHs)

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene
Indeno(1,2,3-cd)pyrene

Polychlorinated dibenzodioxins and polychlorinated dibenzofurans (PCDDs/PCDFs)

Benzene

Pentachlorophenol was selected since American Creosote used largequantities of this chemical. Carcinogenic (cancer causing) PAHswere selected due to their toxicity and their occurrence increosote, which American Creosote also used in large quantities. PCDDs and PCDFs were selected due to their toxicity and theirexistence as impurities in technical grade preparations ofpentachlorophenol. In addition, benzene was selected due to itstoxicity and its detection in several on- and off-site wells. Mere selection of these chemicals or chemical groups, however,does not imply that a human health threat exists at this site. The basis for the comparison values and the health implicationsof these chemicals will be discussed in the Public HealthImplications section.

The toxicity equivalency factor (TEF) method was used to simplifythe public health assessment of the complex mixture of thepolychlorinated dibenzodioxins and polychlorinated dibenzofurans(PCDDs and PCDFs) found at this site. This method relates thetoxicity of the 210 structurally related PCDDs and PCDFs to thehighly studied 2,3,7,8-tetrachlorodibenzo-p-dioxin. Concentrations of the PCDDs and PCDFs are expressed as "2,3,7,8-tetrachlorodibenzo-p-dioxin toxicity equivalence" (2,3,7,8-TCDDTEQ). When concentrations of PCDD and PCDF homologs and notindividual PCDDs and PCDFs were identified by the laboratory,method "A" was used to estimate the toxicity equivalency factor. Method "A" is health protective, assuming that all of the PCDDand PCDF homologs are the more toxic 2,3,7,8-isomers (7).

Soil and ground water contamination both on and around this sitehas been adequately characterized by extensive sampling. Sampling of surface water and sediments in the Pensacola YachtClub drainage ditch and Pensacola Bay near the drainage ditchhave also been adequate to determine the extent of contaminationin these media. Sampling of pecans and vegetables around thissite has been adequate to demonstrate that plants have notaccumulated contaminants from the soil. Food fish and otheraquatic life in Pensacola Bay near this site have not been testedto determine if they have accumulated significant concentrationsof contaminants. It may be difficult to link contaminated foodfish or other contaminated aquatic life directly to AmericanCreosote since this area is commercialized and there have beenother sources of discharge to the Pensacola Bay. There is norecord of worker exposure or air quality sampling during the timeAmerican Creosote was operational.

To identify facilities that could possibly contribute to thesoil, air, and ground water contamination near the AmericanCreosote site, the authors searched the 1987, 1988, and 1989Toxic Chemical Release Inventory (TRI). TRI is developed by theU.S. Environmental Protection Agency (EPA) from the chemicalrelease (air, water, soil) information provided by certainindustries. TRI did not contain information on toxic chemicalreleases in the area surrounding American Creosote (32501, 32505,32507 ZIP codes).

A. On-Site Contamination

The definition of "on site" in this public health assessment isthe area within the property owned by American Creosote (see mapin Appendix A). This is the same definition used in the EPARemedial Investigation/Feasibility Studies.

Soils, solidified sludge, ground water, and air on this site arecontaminated. PAHs are the contaminants at highest concentrationat this site and are concentrated in the solidified sludge buriedat the west end of the site.

Site Surface Soils

In 1988 and 1990, EPA collected surface soil samples (0 to 1 ft.below land surface) on site (8,9). Some of these soil sampleswere taken from the unfenced area on the east end of the site. Pentachlorophenol was found in 13 of 19 surface soil samplestested. The concentrations of pentachlorophenol were above thehealth-based comparison value in all 13 of those samples . Avariety of polycyclic aromatic hydrocarbons (PAHs) were found in18 out of 19 surface soil samples tested. In three of thosesamples, the concentrations of one PAH, benzo(a)pyrene, exceededthe health-based comparison value. Health-based comparisonvalues for the other PAHs are not available. Benzene was foundin one of the 19 surface soil samples tested. The concentrationof benzene in this sample exceeded the health-based comparisonvalue. The background soil sample collected two blocks north ofthe site was not contaminated.

A variety of polychlorinated dibenzodioxins and polychlorinateddibenzofurans (PCDDs and PCDFs) were found in all 12 surface soilsamples tested. In all 12 of these samples, the concentrationsof PCDDs and PCDFs, expressed as equivalent concentrations of2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD TEQ), exceededthe health-based comparison value. None of the surface soilsamples contained the extremely toxic compounds 2,3,7,8-tetrachlorodibenzo-p-dioxin or 2,3,7,8-tetrachlorodibenzofuran.

On-Site Subsurface Soils

In 1988 and 1990, EPA collected 38 subsurface soil samples (1-6.5feet below land surface) on site (8,9). Pentachlorophenol wasfound in eight of 19 subsurface soil samples tested. Theconcentrations of pentachlorophenol exceeded the health-basedcomparison value in those eight samples. A variety of PAHs werefound in 12 of the 19 subsurface soil samples tested. Theconcentration of one PAH, benzo(a)pyrene, exceeded the health-based comparison value in one sample. Health-based comparisonvalues for the other PAHs are not available.

A variety of PCDDs and PCDFs were found in all 10 subsurface soilsamples tested. In five of those samples, the concentrations ofPCDDs and PCDFs, expressed as equivalent concentrations of2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD TEQ), exceededthe health-based comparison value. None of the subsurface soilsamples contained the extremely toxic compounds 2,3,7,8-tetrachlorodibenzo-p-dioxin or 2,3,7,8-tetrachlorodibenzofuran. The concentration of benzene, found in one subsurface soilsample, did not exceed the health-based comparison value.

Table 1.

Contaminant Concentrations in On-Site Surface Soil (0-1 ft. deep)
Contaminants of Concern Concentration (mg/kg) Comparison Values (mg/kg)

Pentachlorophenol nd - 110 0.15a
Benzo(a)anthracene nd - 170 na
Benzo(a)pyrene nd - 23* 7.5b
Benzo(b and/or k) fluoranthene nd - 90 na
Dibenzo(a,h)anthracene nd - 12 na
Indeno(1,2,3-cd)pyrene nd - 46 na
2,3,7,8-TCDD TEQ 0.0005 - 0.01 0.00005c
Benzene nd - 0.005 0.003d

Source : EPA 1989 and 1990 Remedial Investigations (8,9)
mg/kg - milligrams per kilogram
nd - not detected (detection limits not reported)
na - Health-based comparison values are not available.
* - Quality control indicates that the data are unusable and the compound may or may not be present. The value is that reported by the laboratory. Resampling and reanalysis is necessary for verification.
a - Based on 1991 ATSDR oral Minimal Risk Level of 0.002 mg/kg/day (intermediate exposure duration and an uncertainty factor of 1000), assuming a 15 kg child consumes 0.2 g of soil per day.
b - Based on 1991 ATSDR Minimal Risk Level of 0.1 mg/kg/day assuming a one- to six-year old, 15 kg child consumes 0.2 g of soil per day.
c - 1991 ATSDR, Preliminary Draft, Soil Environmental Media Evaluation Guide (EMEG) for child.
d - Based on the 1989 ATSDR 10-6 individual upper-bound estimate of cancer risk of 0.000036 mg/kg/day, assuming a 15 kg child consumes 0.2 g of soil per day.

On-Site Solidified Sludge

In 1988 and 1990, EPA collected 24 samples from the solidified sludge buried on site (8,9). The solidified sludge is located at the western end of the site and was created by an emergency dewatering of the wastewater lagoons in 1983. Pentachlorophenol was found in three of nine solidified sludge samples tested. The concentrations of pentachlorophenol exceeded the health-based comparison value in all three of those samples. A variety of PAHs were found in all nine solidified sludge samples tested. The concentrations of one PAH, benzo(a)pyrene, exceeded the health-based comparison value in eight of those samples. Health-based comparison values for the other PAHs are not available. In all five solidified sludge samples tested, the concentrations of PCDDs and PCDFs, expressed as equivalent concentrations of 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD TEQ), exceeded the health-based comparison value. None of the solidified sludge samples contained the extremely toxic compounds 2,3,7,8-tetrachlorodibenzo-p-dioxin or 2,3,7,8-tetrachlorodibenzofuran. Benzene was found in four of the 11 solidified sludge samples tested. The concentrations of benzene exceeded the health-based comparison value in all four of those samples.

Table 2.

Contaminant Concentrations in On-Site Subsurface Soil (1-6.5 feet deep)
Contaminants of Concern Concentration (mg/kg) Comparison Values (mg/kg)

Pentachlorophenol nd - 17 0.15a
Benzo(a)anthracene nd - 300 na
Benzo(a)pyrene nd - 160* 7.5b
Benzo(b and/or k) fluoranthene nd - 240 na
Dibenzo(a,h)anthracene nd - 1.7 na
Indeno(1,2,3-cd)pyrene nd - 38 na
2,3,7,8-TCDD TEQ 0.000001 - 0.016 0.00005c
Benzene nd - 0.003 0.003d

Source: EPA 1989 and 1990 Remedial Investigations (8,9)
mg/kg - milligrams per kilogram
nd - not detected (detection limits not reported)
na - Health-based comparison values are not available.
* - Quality control indicates that the data are unusable and the compound may or may not be present. The value is that reported by the laboratory. Resampling and reanalysis is necessary for verification.
a - Based on 1991 ATSDR oral Minimal Risk Level of 0.002 mg/kg/day (intermediate exposure duration and an uncertainty factor of 1000), assuming a 15 kg child consumes 0.2 g of soil per day.
b - Based on 1991 ATSDR Minimal Risk Level of 0.1 mg/kg/day assuming a one- to six-year old, 15 kg child consuming 0.2 g of soil per day.
c - 1991 ATSDR Soil Environmental Media Evaluation Guide (EMEG) for child.
d - Based on the 1989 ATSDR 10-6 individual upper-bound estimate of cancer risk of 0.000036 mg/kg/day, assuming a 15 kg child consumes 0.2 g of soil per day.


Table 3.

Contaminant Concentrations in On-Site Solidified Sludge
Contaminants of Concern Concentration (mg/kg) Comparison Values (mg/kg)

Pentachlorophenol nd - 250 0.15a
Benzo(a)anthracene nd - 130 na
Benzo(a)pyrene nd - 49 7.5b
Benzo(b and/or k) fluoranthene nd - 63 na
Dibenzo(a,h)anthracene nd na
Indeno(1,2,3-cd)pyrene nd - 0.02 na
2,3,7,8-TCDD TEQ 0.003 - 0.051 0.00005c
Benzene nd - 5.2 0.003d

Source: EPA 1989 and 1990 Remedial Investigations (8,9)
mg/kg - milligrams per kilogram
nd - not detected (detection limits not reported)
na - Health-based comparison values are not available.
a - Based on 1991 ATSDR oral Minimal Risk Level of 0.002 mg/kg/day (intermediate exposure duration and an uncertainty factor of 1000), assuming a 15 kg child consumes 0.2 g of soil per day.
b - Based on 1991 ATSDR Minimal Risk Level of 0.1 mg/kg/day assuming a one- to six-year old, 15 kg child consuming 0.2 g of soil per day.
c - 1991 ATSDR Soil Environmental Media Evaluation Guide (EMEG) for child.
d - Based on the 1989 ATSDR 10-6 individual upper-bound estimate of cancer risk of 0.000036 mg/kg/day, assuming a 15 kg child consumes 0.2 g of soil per day.

On-Site Ground Water

In 1990, EPA collected ground water samples from five wellslocated in the southwest corner of the site (8). Those wellswere located 10 feet south (hydraulically downgradient) of theformer wastewater lagoons (now solidified sludge). The screenedintervals for these wells ranged from 17 to 98 feet below landsurface. Ground water contamination in this area is concentratedat from 40 to 60 feet below land surface.

Pentachlorophenol was found in two of the five wells. In both wells, the concentrations of pentachlorophenol exceeded the health-based comparison value. A variety of PAHs were found in all five of the wells tested. In two of those wells, the concentrations of two PAHs, benzo(a)anthracene and benzo(b and/or k)fluoranthene, exceeded the health-based comparison values. On-site ground water was not tested for PCDDs and PCDFs. Benzene was found in three of the four wells tested. In those three wells, the concentrations of benzene exceeded the health-based comparison value. Except for very low levels of phenol (0.002 mg/L), the two upgradient, background wells were free from contamination.

Table 4.

Contaminant Concentrations in On-Site Ground Water
Contaminants of Concern Concentration (mg/L) Comparison Values (mg/L)

Pentachlorophenol nd - 3.9 0.001a
Benzo(a)anthracene nd - 120 0.0002b
Benzo(a)pyrene nd ---
Benzo(b and/or k) fluoranthene nd - 98 0.0002b
Dibenzo(a,h)anthracene nd ---
Indeno(1,2,3-cd)pyrene nd ---
2,3,7,8-TCDD TEQ not tested ---
Benzene nd - 0.1 0.001c

Source: EPA 1990 Remedial Investigation (8)
mg/L - milligrams per Liter
nd - not detected (detection limits not reported)
a - 1991 EPA Maximum Contaminant Level for drinking water.
b - EPA Proposed Maximum Contaminant Level for drinking water.
c - Florida Primary Drinking Water Standard: Rule 17-550.310, Florida Administrative Code.

On-Site Air

There is no record of air quality sampling during the timeAmerican Creosote was operational. EPA collected five airsamples on site in 1982 and 1983 (3). Those air samples were nottested for pentachlorophenol or PAHs. Concentrations of PCDDsand PCDFs were below detection limits. Concentrations of benzenein all five samples exceeded the health-based comparison value.

Table 5.

Contaminant Concentrations in On-Site Air
Contaminants of Concern Concentration (µg/m3) Comparison Values (µg/m3)

Pentachlorophenol not tested ---
Benzo(a)anthracene not tested ---
Benzo(a)pyrene not tested ---
Benzo(b and/or k) fluoranthene not tested ---
Dibenzo(a,h)anthracene not tested ---
Indeno(1,2,3-cd)pyrene not tested ---
2,3,7,8-TCDD TEQ nd ---
Benzene 0.26 - 22 0.12a

Source: EPA 1985 Remedial Investigation (3)
µg/m3 - micrograms per cubic meter
nd - not detected (detection limits not reported)
a - Based on the September 1990 EPA Health Effects Assessment Summary Tables (HEAST). The 10-6 additional lifetime cancer risk was calculated from a inhalation unit risk (slope factor) of 0.029 mg/kg/day assuming a 70 kg adult inhales 20 m3 of air per day.

B. Off-Site Contamination

The definition of "off site" in this public health assessment isthe area outside the property owned by American Creosote (see mapin Appendix A). This is the same definition used in the EPARemedial Investigation/Feasibility Studies.

Off-site surface soils, ground water, and sediments arecontaminated due to migration of contaminants from AmericanCreosote. Food fish and other aquatic animals in Pensacola Bayhave not been tested. Off-site soils and sediments arecontaminated with PAHs and dibenzodioxins/dibenzofurans. Off-site ground water taken from monitoring and irrigation wells iscontaminated with PAHs and benzene.

The soils with the highest concentrations of contaminants arelocated south and west of the southwest corner of the site (8,9). Contamination of off-site surface soils is likely due tostormwater overflows from the former wastewater lagoons. Transport of soils from the site for gardening has alsocontributed to off-site soil contamination.

Contaminated ground water is migrating south toward Pensacola Bay from the former wastewater lagoons. Contaminated ground water is not discharging directly into Pensacola Bay, but discharges into the drainage ditch which empties into the Bay. Contamination of surface water in the Pensacola Yacht Club drainage ditch and Pensacola Bay; however, is minimal due to dilution and tidal mixing. The sediments in this drainage ditch and Pensacola Bay near the ditch outfall; however, are contaminated. This contamination is likely the result of past wastewater lagoon overflows and/or ground water discharge.

In 1985, Florida HRS and EPA tested seven plant samples (pecans,greens, and peppers) from six residential gardens near the siteand found them to be free of contamination (11,12). Those pecantrees and gardens were located south and west of the site andwere representative of plants grown in the area. The closestgarden was at the north end of "K" Street, about 100 feet southof the site and the former wastewater lagoons. The most distantwas between "G" and "H" Streets, about 500 feet south of thesite. All of those gardens or pecan trees were in the path ofground water flow from the site and three were located within thearea of contaminated ground water.

Off-Site Surface Soils

In 1988 and 1990, EPA collected 31 off-site composite surface soil samples (0 to 1 ft. below land surface) (8,9). These samples were from the grounds of the Pensacola Yacht Club and from residential yards south and west of the site. The soils south and west of the southwest corner of the site had the highest concentrations of contaminants. Pentachlorophenol was found in one sample. The concentration of pentachlorophenol in this sample exceeded the health-based comparison value. A variety of PAHs were found in 15 out of 31 off-site surface soil samples. The concentration of one PAH, benzo(a)pyrene, did not exceed the health-based comparison value. Health-based comparison values for the other PAHs are not available. A variety of PCDDs and PCDFs were found in eight of nine surface soil samples tested. In one sample, the concentrations of PCDDs and PCDFs, expressed as an equivalent concentration of 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD TEQ), exceeded the health-based comparison value. None of these surface soil samples collected off site contained the extremely toxic compounds 2,3,7,8-tetrachlorodibenzo-p-dioxin or 2,3,7,8-tetrachlorodibenzofuran. Benzene was not found in any of the off-site surface soils sampled. Concentrations of site related chemicals in the background soil sample, collected two blocks north of the site, were below detection limits.

Table 6.

Contaminant Concentrations in Off-Site Surface Soils (0-1 ft. deep)
Contaminants of Concern Concentration (mg/kg) Comparison Values (mg/kg)

Pentachlorophenol nd - 0.54 0.15a
Benzo(a)anthracene nd - 6.2 na
Benzo(a)pyrene nd - 1.8 7.5b
Benzo(b and/or k) fluoranthene nd - 11 na
Dibenzo(a,h)anthracene nd - 4.7 na
Indeno(1,2,3-cd)pyrene nd - 9.2 na
2,3,7,8-TCDD TEQ nd - 0.001 0.00005c
Benzene nd ---

Source: EPA 1989 and 1990 Remedial Investigations (8,9)
mg/kg - milligrams per kilogram
nd - not detected (detection limits not reported)
na - Health-based comparison values are not available.
a - Based on 1991 ATSDR oral Minimal Risk Level of 0.002 mg/kg/day (intermediate exposure duration and an uncertainty factor of 1000), assuming a 15 kg child consumes 0.2 g of soil per day.
b - Based on 1991 ATSDR Minimal Risk Level of 0.1 mg/kg/day assuming a 1 to 6 year old, 15 kg child consuming 0.2 g of soil per day.
c - 1991 ATSDR Soil Environmental Media Evaluation Guide (EMEG) for child.

Off-Site Ground Water

Contaminated ground water has migrated off site, south toward Pensacola Bay. In the early 1980s, the U.S. Geological Survey (USGS) investigated this site and found contaminated ground water in monitoring wells located from near the former wastewater lagoons to about 1,200 feet south of the site. The contaminated ground water extended to about 110 feet below land surface (10). In 1988 and 1989, EPA collected ground water samples from 28 additional monitoring wells south of the site (8,9). The extent of the ground water contaminated was inferred from these monitoring wells. There are no potable wells in the area; however, one residential irrigation well located about 200 feet south of the former waste water lagoons was contaminated.

Pentachlorophenol was found in only one out of 28 off-site wells tested. The concentration of pentachlorophenol in this well, a residential irrigation well no longer in use, exceeded the health- based comparison value. A variety of PAHs were found in 14 of the 26 off-site monitoring and in both off-site irrigation wells tested. In 1 of the off-site monitoring wells, the concentration of one PAH, benzo(a)anthracene, exceeded the health-based comparison value. Off-site ground water was not tested for PCDDs or PCDFs. Benzene was found in 16 of the 29 off-site wells. In 15 of these wells, the concentration of benzene exceeded the health-based comparison value. The comparison values for pentachlorophenol and benzene assume use of the water for drinking. Except for very low levels of phenol (0.002 mg/L), the two upgradient, background monitoring wells were free from contamination.

Table 7.

Contaminant Concentrations in Off-Site Ground Water
Contaminants of Concern Concentration (mg/L) Comparison Values (mg/L)

Pentachlorophenol nd - 0.18 0.001a
Benzo(a)anthracene nd - 0.034 0.0002b
Benzo(a)pyrene nd ---
Benzo(b and/or k) fluoranthene nd ---
Dibenzo(a,h)anthracene nd ---
Indeno(1,2,3-cd)pyrene nd ---
2,3,7,8-TCDD TEQ not tested ---
Benzene nd - 0.12 0.001c

Source: EPA 1989 and 1990 Remedial Investigations (8,9)
mg/L - milligrams per Liter
nd - not detected (detection limits not reported)
a - 1991 EPA Maximum Contaminant Level for drinking water.
b - EPA Proposed Maximum Contaminant Level for drinking water.
c - Florida Primary Drinking Water Standard: Rule 17-550.310, Florida Administrative Code.

Off-Site Surface Water

In 1988, EPA collected five surface water samples downgradientfrom the site (8). Three samples were taken from the PensacolaYacht Club drainage ditch and two were taken from Pensacola Baynear the drainage ditch. Pentachlorophenol and PAHs were notfound. Samples were not tested for PCDDs or PCDFs. Benzene wasfound in one sample, but at a concentration that did not exceedthe comparison value. Since surface waters do not existupgradient from this site, there are no background samples forcomparison.

Table 8.

Contaminant Concentrations in Off-Site Surface Water
Contaminants of Concern Concentration (mg/L) Comparison Values (mg/L)

Pentachlorophenol nd ---
Benzo(a)anthracene nd ---
Benzo(a)pyrene nd ---
Benzo(b and/or k) fluoranthene nd ---
Dibenzo(a,h)anthracene nd ---
Indeno(1,2,3-cd)pyrene nd ---
2,3,7,8-TCDD TEQ not tested ---
Benzene nd - 0.0008 0.071a

Source: EPA 1988 Remedial Investigation (8)
mg/L - milligrams per Liter
nd - not detected (detection limits not reported)
a - Florida Class III surface water standard, Rule 17-302.530, Florida Administrative Code. Florida Class III surface water standards are designed to protect surface waters for recreation, propagation and management of fish and wildlife.

Off-Site Sediments

  1. Drainage Ditch - In 1988, EPA collected three sediment grabsamples (0-3" in depth) from the Pensacola Yacht Clubdrainage ditch (8). Although this drainage ditch is notdirectly connected to American Creosote, it receivesstormwater runoff from the site. It is likely that thisdrainage ditch also receives contaminated ground waterdischarge. Pentachlorophenol was not found in any of thesamples from this drainage ditch. PAHs were found in allthree samples. Health-based comparison values for these PAHs are not available. One sedimentsample was tested for PCDDs and PCDFs, but none were found. Benzene was not found in any of those sediment samples. There are no surface water bodies, and thus no sedimentsupgradient from this site for comparison.


  2. Pensacola Bay - In 1988 and 1990 EPA collected 11 sedimentgrab samples (0-1 ft. in depth) from Pensacola Bay near thedrainage ditch (8,9). Pensacola Bay ultimately receives allof the surface water and ground water discharge from thissite. Pentachlorophenol was not found in any of thesediment samples. A variety of PAHs were found in five ofthe 11 samples. Health-based comparison values for thesePAHs are not available. Samples were not tested for PCDDsor PCDFs. Benzene was not found in any of the sedimentsamples. American Creosote may not be the only source ofsediment contamination in Pensacola Bay; however, since thisarea is commercialized and there have been other discharges.

Table 9.

Contaminant Concentrations in Off-Site Sediments (0-1 ft. deep)
Contaminants of Concern Concentration (mg/kg) Comparison Values (mg/kg)

Pentachlorophenol nd ---
Benzo(a)anthracene nd - 12 na
Benzo(a)pyrene nd - 17 na
Benzo(b and/or k) fluoranthene nd - 23 na
Dibenzo(a,h)anthracene nd - 2.4 na
Indeno(1,2,3-cd)pyrene nd - 8 na
2,3,7,8-TCDD TEQ not tested ---
Benzene nd ---

Source: EPA 1988 and 1990 Remedial Investigation (8,9)
mg/kg - milligrams per kilogram
nd - not detected (detection limits not reported)
na - Health-based comparison values are not available.

Off-Site Biota

In 1985, the Florida HRS Toxicology Laboratory tested pecans froma pecan tree in the neighborhood south of the site forpentachlorophenol, PAHs, 2,3,7,8-tetrachlorodibenzo-p-dioxin(2,3,7,8-TCDD) and benzene. None of those chemicals were found(11). Also in 1985, EPA collected plant samples (pecans, greens,and peppers) from six residential gardens in this neighborhoodand tested for PAHs. No PAHs were found (12). No food fish orother aquatic organisms (shell fish, crabs, etc.) from PensacolaBay have been tested.

Table 10.

Contaminant Concentrations in Off-Site Biota (pecans, greens, and peppers)
Contaminants of Concern Concentration (mg/kg) Comparison Values (mg/kg)

Pentachlorophenol nd ---
Benzo(a)anthracene nd ---
Benzo(a)pyrene nd ---
Benzo(b and/or k) fluoranthene nd ---
Dibenzo(a,h)anthracene nd ---
Indeno(1,2,3-cd)pyrene nd ---
2,3,7,8-TCDD TEQ nd ---
Benzene nd ---

Source: 1985 letter from R.L. DuBose to K. Kelson (11) and EPA Site Investigation Report (12).
mg/kg - milligrams per kilogram
nd - not detected (detection limits not reported)

C. Quality Assurance and Quality Control

In preparing this public health assessment, Florida HRS and ATSDRrelied on the information provided in the referenced documentsand assumed that adequate quality assurance and quality controlmeasures were followed regarding to chain-of-custody, laboratoryprocedures, and data reporting. The validity of the analysis andconclusions drawn for this public health assessment is determinedby the completeness and reliability of the referencedinformation. The data on which this public health assessment isbased are assumed to be reliable since the samples were collectedand tested directly by the EPA and the USGS or their contractors. EPA has not prepared a formal Data Review Summary for this site.

D. Physical and Other Hazards

No physical hazards were observed during the site visits. Allstructures at this site have been removed. EPA has locked drumsfrom a previous remedial action inside a second fence.


PATHWAYS ANALYSES

As discussed in the Site Description and History Subsection, pastwastewater disposal at this site has caused air, soil and groundwater contamination. Movement of contaminants has resulted inoff-site contamination of soil, ground water, and sediments southand west of the site. The environmental and human exposurepathways associated with the site are discussed in the followingsubsections.

A. Environmental Pathways (Fate and Transport)

Air

Testing has shown that the air at this site is an environmentalpathway for the movement of volatile contaminants, such asbenzene. Although wind-blown dust has not been tested, duringperiods of low rainfall it is likely that contaminated dust wasalso a pathway for the movement of non-volatile contaminants. The spread of contaminants via wind blow dust, however, is likelyto be small compared with the transport via stormwater runoff. Currently, vegetation on the site limits the spread ofcontaminated dust.

Soil remediation plans call for excavation, sorting, andstockpiling of the contaminated soil before on-sitebioremediation (6). If dust suppression techniques are not used,these operations are likely to create a large amount ofcontaminated dust, especially during periods of low rainfall.

Soil

The main source of soil contamination at this site waspentachlorophenol and creosote disposed of in two on-sitewastewater lagoons. In addition, American Creosote's practice ofdiverting wastewater to other areas when the lagoons were fullresulted in low levels of soil contamination throughout the site.

Most of off-site soil contamination was caused by overflows fromthe former wastewater lagoons. Wind and stormwater erosion hasalso contributed to contamination of off-site soils. Due to theinfluence of nearby Pensacola Bay, the predominate winds are fromthe south during the day (sea breeze) and from the north at night(land breeze). Some residents near the site report transportingsoil from the site for use in their vegetable gardens.

Surface Water

The Pensacola Yacht Club drainage ditch and Pensacola Bay receivesurface runoff from the site. In addition, the Pensacola YachtClub drainage ditch receives contaminated ground water discharge. The concentrations of contaminants in these two surface waterbodies are low due to tidal mixing and dilution.

Sediments

Past overflows from the wastewater lagoons spread contaminants tosediments south along a drainage path. Sediments in the Pensacola Yacht Club drainage ditch and Pensacola Bay near thedrainage ditch are contaminated. American Creosote may not bethe only source of sediment contamination in Pensacola Bay,however, since this area is commercialized and there have beenother discharges.

Ground Water

The former wastewater lagoons are the main source of ground watercontamination. The more water soluble chemicals (pentachloro-phenol, benzene, etc.) in the wastewater moved through the poroussands of the lagoons to the shallow ground water below. Naturalground water flow has spread contamination south toward PensacolaBay. A 20-foot thick clay layer south of the former wastewaterlagoons divides the contaminated ground water into an upper andlower portion. Contamination in the upper portion (0 - 50 feetdeep) has moved about 1,000 feet south of the site, halfway toPensacola Bay. Microbial degradation and discharge into thedrainage ditch has slowed migration of the contaminated groundwater in the upper portion. Contaminated ground water in thelower portion (70 - 120 feet deep) has moved about 1,500 feetsouth of the site, to a point within 500 feet of Pensacola Bay(10).

In the past, residents in the neighborhood south of the site usedprivate wells (< 120 feet deep) as a source of water for lawnirrigation, car washing, etc. Most of those wells were abandonedin the mid-1980s. The nearest potable well is located about 900feet northeast (hydraulically upgradient) of the site. It is notcontaminated and is sampled annually to insure its continuedsafety.

Biota

Some residents of the neighborhood south of the site hadvegetable gardens and pecan trees. Testing has shown that theseplants have not accumulated contaminants from the soil. Althoughfishing occurs in Pensacola Bay near this site, no fish or otheraquatic life have been tested. Therefore, it is not known iffish, crabs, etc., near this site are contaminated.

B. Human Exposure Pathways

Skin Absorption

It is likely that workers at American Creosote were exposed topentachlorophenol or creosote liquids via skin contact withcontaminated wastewater or contaminated soil. There are no data;however, to document this exposure.

Use of contaminated ground water from off-site irrigation wellsfor lawn irrigation, car washing, etc., is not likely to haveresulted in significant exposures through skin absorption. Thoseactivities were too infrequent and too short in duration toresult in significant absorption. Dermal contact with on-sitesubsurface soils or off-site sediments in the Pensacola YachtClub drainage ditch or Pensacola Bay is unlikely.

Ingestion

Currently, incidental ingestion of on- and off-site surface soilsis a potential exposure pathway. Recurring vandalism of thefence around the site allows for frequent trespass. Children,ages one to six, playing on this site are likely to ingest about0.2 kg of soil per day. The average weight for children in thisage group is 15 kg (13).

Ingestion of contaminated ground water is unlikely since wells incontaminated areas south and west of the site have never beenused for drinking water. Although contaminated ground water wasused to irrigate home vegetable gardens, plants were notcontaminated.

Ingestion of contaminated fish or other aquatic animals fromPensacola Bay is a potential exposure pathway. Pensacola Bay atSanders Beach and the Bayou Chico bridge have been used forfishing, but the extent of fish contamination or the amount offish consumed is unknown.

Inhalation

It is likely that workers at American Creosote were exposed to pentachlorophenol or creosote via inhalation of vapors; however, there are no data to document this exposure. Inhalation of contaminants from the site may have been a significant route of exposure for nearby residents before 1981. Inhalation of vapors and gases, such as benzene, from the site is a potential exposure pathway. Currently, inhalation of contaminated dust is unlikely since the site is vegetated. Future site remediation has the potential to release volatile contaminants and suspend contaminated dust in the air, thus increasing the exposure of nearby residents to PAHs, PCDDs/PCDFs, and benzene.

PATHWAY NUMBER EXPOSURE PATHWAY ELEMENTS TIME
SOURCE ENVIRONMENTAL MEDIA POINT OF EXPOSURE ROUTE OF EXPOSURE EXPOSED POPULATION

1. wastewater disposal surface soil (dust) on site inhalation workers 1902-1981

2. wastewater disposal surface soil on site skin workers 1902-1981

3. wastewater disposal air on site inhalation children,
trespassers
1981-present

5. wastewater disposal surface soil on site ingestion children 1981-present

6. wastewater disposal water,
sediments
fish in Pensacola Bay ingestion local fish eaters 1902-present



PUBLIC HEALTH IMPLICATIONS

As discussed in the Environmental Contamination and Other Hazardsand Pathways Analyses Sections, workers may have been exposed tosite contaminants via inhalation and skin absorption. Childrenand other trespassers on this site are likely to be exposed tosite contaminants via incidental ingestion and inhalation. Although no testing has been done, ingestion of fish caught inPensacola Bay near this site may also be a source of exposure.

A. Toxicological Implications

Pentachlorophenol

Pentachlorophenol can cause damage to the liver and kidneys. Thecentral nervous system and the immune system also appear to beaffected by pentachlorophenol exposure, generally as a result ofhyperthermia induced by the uncoupling of oxidativephosphorylation (central nervous system), or due to the presenceof impurities such as polychlorinated dibenzo-p-dioxins (immunesystem effects). Humans are generally exposed to technical gradepentachlorophenol which usually contains such toxic impurities aspolychlorinated dibenzo-p-dioxins and dibenzofurans (14). EPAhas also classified pentachlorophenol as a Class B2 carcinogen(probable human carcinogen) (15).

The most likely human exposure pathway to pentachlorophenol fromthis site is incidental ingestion of surface soil by children. The health-based comparison value of 0.15 mg/kg for ingestion ofpentachlorophenol in soil (Tables 1,2,3, and 6) was calculatedfrom the 1991 ATSDR oral Minimal Risk Level of 0.002 mg/kg/day,assuming a 15 kg child consumes 0.2 g of soil per day. The 1991ATSDR oral Minimal Risk Level of 0.002 mg/kg/day is based onliver effects, intermediate exposure duration, and an uncertaintyfactor of 1000 (16).

The on-site surface soil with the highest concentration ofpentachlorophenol (110 mg/kg) is about 1,000 times greater thanthis health-based comparison value. In a worst case, a child whoplayed on this site every day for the past 10 years and wasexposed via incidental ingestion to 0.2 g/day of soil with thehighest pentachlorophenol concentration, would likely sufferliver damage. Also kidney, central nervous system, and immunesystem damage would be possible. Actual health effects woulddepend on the frequency and duration of contaminated soilingestion.

The highest concentration of pentachlorophenol in off-sitesurface soils (0.54 mg/kg) is about 4 times the health-basedcomparison value of 0.15 mg/kg. Children playing in the off-sitesoil may suffer health effects (liver damage, etc) fromincidental ingestion of pentachlorophenol in the soil dependingon the frequency and duration of their exposure.

The risk of cancer for children from incidental ingestion of 0.2g/day of on-site soil with the highest concentration ofpentachlorophenol is low. The risk of cancer for children fromincidental ingestion of off-site soil with the highestconcentration of pentachlorophenol is insignificant.

On- and off-site ground water is neither suitable nor used forhuman consumption. Concentration of pentachlorophenol in bothon- and off-site ground water exceed the EPA drinking waterMaximum Contaminant Level (MCL). EPA established the MCL of0.001 mg/L for pentachlorophenol based on a cancer slope factorof 0.12 per mg/kg/day (15). Consumption of 2 L/day of water with0.001 mg/L of pentachlorophenol by a 70 kg adult would result inan upper bound cancer risk of three in a million. Ingestion ofthe on-site ground water for 70 years would result in a moderateincreased risk of cancer, while ingestion of the off-site groundwater for 70 years would result in a low increased risk ofcancer.

Polycyclic Aromatic Hydrocarbons (PAHs)

Benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene,benzo(k)fluoranthene, dibenzo(a,h)anthracene, and indeno(1,2,3-cd)pyrene are PAHs that have caused cancer in laboratory animalsthrough ingestion, skin contact, and inhalation. Long-termingestion of PAHs in food has resulted in adverse effects on theliver and blood in mice. Reports in humans show that individualsexposed by inhalation or skin contact to mixtures of PAHs andother compounds for long periods, may also develop cancer. Reproductive effects have occurred in animals that were fedcertain PAHs. These effects may also occur in humans, but thereis no evidence to prove this. These PAHs as a group cause skindisorders, however, specific effects of individual PAHs, exceptfor benzo(a)pyrene have not been reported (17).

The most likely human exposure pathway to PAHs from this site isincidental ingestion of surface soil by children. The health-based comparison value of 7.5 mg/kg for ingestion ofbenzo(a)pyrene in soil (Tables 1,2,3, and 6) was calculated fromthe 1991 ATSDR oral Minimal Risk Level of 0.1 mg/kg/day, assuminga 15 kg child consumes 0.2 g of soil per day. The 1991 ATSDRoral Minimal Risk Level of 0.1 mg/kg/day for benzo(a)pyrene isbased on developmental effects, acute exposure duration, and anuncertainty factor of 100 (18). Health-based comparison valuesfor the other PAHs are not available.

The on-site surface soil with the highest concentration ofbenzo(a)pyrene (23 mg/kg) is about three times greater than thishealth-based comparison value. Children who play on this sitedaily and are exposed via incidental ingestion to 0.2 g/day ofsoil with the highest benzo(a)pyrene concentration, may sufferdevelopmental effects. Actual health effects will depend on thefrequency and duration of children playing on this site andingesting the contaminated soil. The concentrations ofbenzo(a)pyrene in off-site surface soils are below the health-based comparison value.

On- and off-site ground water is neither suitable nor used forhuman consumption. Concentration of benzo(a)anthracene andbenzo(b and/or k)fluoranthene in on-site ground water, andconcentrations of benzo(a)anthracene in off-site ground water,exceed the proposed EPA Maximum Contaminant Level (MCL). EPAproposed a MCL of 0.0002 mg/L for benzo(a)anthracene,benzo(b)fluoranthene, and benzo(k)fluoranthene based on theoccurrence of these PAHs with benzo(a)pyrene (19). Benzo(a)pyrene has been shown to be carcinogenic in a number ofanimal studies.

Although no testing has been done, ingestion of fish and otheraquatic organisms (oysters, crabs, etc.) caught in Pensacola Baynear this site may also be a source of exposure to PAHs. PAHscan accumulate in aquatic organisms from water, sediments, andfood. Bioconcentration factors of PAHs in fish and crustaceanshave frequently been reported to be in the range of 100 to 2,000(17).

Polychlorinated dibenzodioxins and polychlorinated dibenzofurans (PCDDs and PCDFs)

In humans, 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD)causes chloracne, a severe skin lesion that usually occurs on thehead and upper body. Unlike common acne, chloracne is moredisfiguring and often lasts for years after the initial exposure. There is suggestive evidence that 2,3,7,8-TCDD causes liverdamage in humans, as indicated by an increase in levels ofcertain enzymes in the blood. Animal studies have demonstratedsevere liver damage in some species. There is suggestiveevidence that 2,3,6,7-TCDD causes loss of appetite, weight loss,and digestive disorders in humans. Animal exposure to 2,3,7,8-TCDD results in severe loss of body weight prior to death. Thehuman evidence for 2,3,7,8-TCDD alone is inadequate todemonstrate or reflect a carcinogenic hazard. Based on thepositive evidence in animal studies; however, 2,3,7,8-TCDD isprobably carcinogenic in humans (20).

Although a variety of polychlorinated dibenzodioxins andpolychlorinated dibenzofurans (PCDDs and PCDFs) were found in on-and off-site soils, none contained the extremely toxic compounds2,3,7,8-tetrachlorodibenzo-p-dioxin or 2,3,7,8-tetrachlorodibenzofuran. Little toxicity data exists for most ofthe PCDDs and PCDFs. The toxicity equivalency factor (TEF)method was used to simplify the public health assessment for thePCDDs and PCDFs (7). This method relates the toxicity of the 210structurally related PCDDs and PCDFs to the highly studied2,3,7,8-tetrachlorodibenzo-p-dioxin. Concentrations of the PCDDsand PCDFs are then expressed as "2,3,7,8-tetrachlorodibenzo-p-dioxin toxicity equivalence" (2,3,7,8-TCDD TEQ).

The most likely human exposure pathway to PCDDs and PCDFs fromthis site is incidental ingestion of on- and off-site surfacesoil by children. The health-based comparison value of 0.00005mg/kg for ingestion of 2,3,7,8-TCDD TEQ in soil (Tables 1,2,3,and 6) is the preliminary draft 1991 ATSDR Environmental MediaEvaluation Guide (EMEG) for soil (21). This EMEG assumesincidental ingestion of 0.2 g of soil per day by a 15 kg child.

The highest concentration of 2,3,7,8-TCDD TEQ in the on-sitesurface soil exceed the health-based comparison value by 200times. Children who play on this site daily and are exposed viaincidental ingestion to 0.2 kg/day of soil with the highest2,3,7,8-TCDD TEQ concentration, may suffer chloracne. Actualhealth effects will depend on the frequency and duration ofingesting the contaminated soil. The highest concentration of2,3,7,8-TCDD TEQ in the off-site soil exceeds the health-basedcomparison value by 20 times. Children who are exposed to2,3,7,8-TCDD TEQ in the off-site soil via incidental ingestionare less likely to suffer chloracne.

The increase in risk of cancer from incidental ingestion of on-or off-site soil with the highest concentrations of 2,3,7,8-TCDDTEQ is insignificant. This is based on an EPA estimate of anincreased lifetime cancer risk of 10-6 for the lifetime ingestionof 0.0064 µg/kg/day 2,3,7,8-TCDD (20). EPA is reviewing its riskassessment of 2,3,7,8-TCDD. New data suggest the human cancerrisk from 2,3,7,8-TCDD exposure may be less than originallythought.

Benzene

From overwhelming human evidence and supporting animal studies,benzene is known to be a human carcinogen. Leukemia (cancer ofthe tissues that form the white blood cells) and subsequent deathfrom cancer have occurred in some workers exposed to benzene forperiods of less than five or up to 30 years. Long-term exposuresto benzene may affect normal blood production, possibly resultingin severe anemia and internal bleeding. In addition, humanstudies indicate that benzene is harmful to the immune system,increasing the chance for infections and perhaps lowering thebody's defense against tumors. Exposure to benzene has also beenlinked with genetic changes in humans and animals (22).

Although the concentration of benzene in the on-site surfacesoils exceeds the health-based comparison value by two times, theincreased risk of cancer or other health effects from incidentalsoil ingestion is insignificant.

On- and off-site ground water is neither suitable or used forhuman consumption. Concentration of benzene in both on- and off-site ground water exceed the Florida Primary Drinking Waterstandard. Florida established a Primary Drinking Water standardof 0.001 mg/L for benzene based on the 10-6 lifetime cancer riskfor lifetime consumption. Concentrations of benzene in both on-and off-site ground water exceed this standard by about 100times. Ingestion of the on- or off-site ground water for 70years would result in a low increased risk of cancer.

The highest concentration of benzene measured in the air at thissite (22 µg/m3) exceed the health-based comparison value by about180 times. This comparison value is based on the 10-6 additionallifetime cancer risk calculated from a inhalation unit risk(slope factor) of 0.029 mg/kg/day assuming a 70 kg adult inhales20 m3 of air per day (23). Inhaling air with benzene at thisconcentration 24 hours per day for 70 years, would result in alow increased risk of cancer.

B. Health Outcome Data Evaluation

The Escambia County Public Health Unit (CPHU) has been involvedin public health at the American Creosote site, but has notconducted any independent health studies or investigations. Escambia CPHU received one complaint of contaminated stormwaterrunoff, but did not take a sample since they felt the concentrations of contaminants in the stormwater were not likelyto be of health concern.

HRS epidemiologists found that the rates of cancer and birthdefects in the population near the American Creosote site are notunusual. However, since the actual number of birth defects andcancer in this zip code are low, a comparison with rates for theentire county or the state would not be statistically valid.

C. Community Health Concerns Evaluation

  1. The community is concerned about the toxicity of creosote components and pentachlorophenol, and exposure leading to cases of skin and lung cancer and/or death in the surrounding neighborhood.
  2. The greatest risk from this site is due to incidental ingestion of the contaminated soils by children trespassing on the site and from drinking the contaminated ground water.

    The contaminated ground water on and off the site is not used as a drinking water supply. HRS epidemiologists found that the rates of cancer and birth defects in the 32501 ZIP code that includes the American Creosote site are not unusual.

  3. The community is concerned about exposure of humans to contaminated ground water where it discharges into Pensacola Bay at Sanders Beach.
  4. Contaminated ground water is not discharging directly into Pensacola Bay, but is discharging into the drainage ditch which empties into the Bay. The public health threat from contaminants dissolved or suspended in the waters of Pensacola Bay is minimal. The concentrations of contaminants in the water of the drainage ditch and Pensacola Bay are low due to tidal mixing and dilution.

  5. The community is concerned that contaminated soil, blown by the wind or hauled to nearby homes, has contaminated homegrown produce.
  6. Eating plants grown near the site is not a health risk. EPA and HRS collected pecans, greens, and peppers from gardens in the neighborhoods around the site and found that these plants had not accumulated concentrations of contaminants at levels of health concern from the soil.

  7. The community is concerned that use of contaminated ground water for irrigation, car washing, etc., has resulted in exposure.
  8. It is unlikely that past use of contaminated ground water for irrigation, car washing, etc., will cause any health effects since exposure was short and infrequent.

  9. The community is concerned that children and other site trespassers are being exposed to hazardous chemicals.
  10. Children trespassing on the site may suffer chloracne, liver damage and an increased risk of cancer from incidental in-gestion of the contaminated soil. Children and residents in this area should not walk across the site.

    In December 1991, the Florida HRS mailed a one page fact sheet to the local residents, media, and elected officials summarizing the preliminary findings of this public health assessment. This fact sheet announced the availability of the draft public health assessment at the local document repository and solicited public comment until January 31, 1992. No inquiries or comments were received.


CONCLUSIONS

From the information reviewed, this site is judged to be a publichealth hazard because of the likelihood of past and currentexposure to hazardous substances in the air, soil and groundwater.

  1. In spite of a fence, site trespass continues to occur. There are not enough hazardous waste warning signs to complywith the State of Florida requirements for warning signs atcontaminated sites: Chapter 403.704 and 403.7255, FloridaStatutes, and Rule 17-736, Florida Administrative Code. Children trespassing on the site are likely to be exposed topentachlorophenol, PAHs, and PCDDs/PCDFs in the soil viaincidental ingestion and may suffer chloracne, liver damage,and an increased risk of cancer. Inhalation of benzene inthe on-site air may increase the lifetime risk of cancer forchildren and other site trespassers.


  2. The risk of liver damage and chloracne in children, due toincidental ingestion of off-site soil contaminated withpentachlorophenol and PCDDs/PCDFs, depends on the frequencyand duration of their exposure.


  3. Planned remediation at this site is likely to exposecontaminated surface and subsurface soils, increase the off-site transport of PAH contaminated dust and benzene vapors,and increase nearby residential exposure.


  4. Wastewater disposal by American Creosote contaminated groundwater making it unsuitable for domestic use. It is unlikelythat past use of this contaminated ground water for lawnirrigation, car washing, etc., has caused or will cause anyhealth effects since exposure was short and infrequent.


  5. Past overflows and stormwater runoff from this site havecontaminated the sediments of Pensacola Bay near the site. American Creosote may not be the only source of sedimentcontamination in Pensacola Bay; however, since this area iscommercialized and there have been other discharges. Although fishing occurs in this area, there are no data todetermine the level of fish contamination or consumption.


  6. Eating plants grown near the site is not a health risk sincethey have not concentrated contaminants from the soil.


  7. The public health threat from contaminants dissolved orsuspended in the waters of Pensacola Bay is minimal.


  8. The rates of cancer and birth defects in the population nearthe American Creosote site are not unusual.

RECOMMENDATIONS

  1. Remediate the on-site surface soils. Until on-site soilremediation is complete, site access should be strictlylimited and nearby residents (especially children) shouldnot go on this site. Post an adequate number of warningsigns to discourage vandalism of the existing fence andcontinued site trespass. This site should comply with theState of Florida requirements for warning signs atcontaminated sites: Chapter 403.704 and 403.7255, FloridaStatutes, and Rule 17-736, Florida Administrative Code.


  2. Remediate the off-site surface soils near this site as soonas possible.


  3. Employ effective dust control techniques during soilremediation to prevent further off-site migration of PAHsand PCDDs/PCDFs. Conduct appropriate air monitoring at theperiphery of the site to ensure the safety of nearbyresidents.


  4. Prevent the use of contaminated ground water for potable,agricultural, or industrial purposes until it is remediated.


  5. Test aquatic life in Pensacola Bay (fish, oysters, crabs,clams, etc.) for PAHs and other site related contaminants. Estimate the quantity of fish or other aquatic life caughtin this area for human consumption.


  6. The data and information developed in the Public HealthAssessment of the American Creosote Works, Inc., has beenevaluated for appropriate follow-up health activities. TheHealth Activities Recommendation Panel (HARP) determinedthat community health education is needed. Thisdetermination is based on indications that long-termexposure to hazardous chemicals in the air, soil, and groundwater is likely to have occurred and may occur in thefuture. The Division of Health Studies, ATSDR hasdetermined that a disease- and symptom-prevalence study isappropriate for this site.

PUBLIC HEALTH ACTION PLAN

Based on the data evaluated and the recommendations made by theHARP, ATSDR and Florida HRS will coordinate to conduct thefollowing actions:

  1. Community health education to assist the community inunderstanding their potential for exposure or in assessingpossible adverse health outcomes associated with exposuresto hazardous substances present in the environment.


  2. A disease- and symptom-prevelance study is appropriate forthis site because of long-term exposure to hazardouschemicals in the air, soil, and ground water are likely tohave occurred and may be currently occurring.

The U.S. Environmental Protection Agency and the Florida Depart-ment of Environmental Regulation have been informed of recommendations 1 through 5. They have not committed to carrying out these recommendations.


PREPARERS OF REPORT

E. Randall Merchant
Biological Administrator
Office of Toxicology and Hazard Assessment
Florida Department of Health and Rehabilitative Services

Dr. Joseph H. Sekerke
Biological Scientist
Office of Toxicology and Hazard Assessment
Florida Department of Health and Rehabilitative Services


ATSDR TECHNICAL PROJECT OFFICER

Richard Gillig
ATSDR Technical Project Officer
Remedial Programs Branch
Division of Health Assessment and Consultation


ATSDR REGIONAL REPRESENTATIVE

Chuck Pietrosewicz
ATSDR Regional Representative
Regional Services
Office of the Assistant Administrator


CERTIFICATION

This public health assessment was prepared by the FloridaDepartment of Health and Rehabilitative Services under acooperative agreement with the Agency for Toxic Substances andDisease Registry (ATSDR). It is in accordance with approvedmethodology and procedures existing at the time the public healthassessment was begun.

Richard Gillig
Technical Project Officer, SPS, RPB, DHAC


The Division of Health Assessment and Consultation, ATSDR, hasreviewed this public health assessment, and concurs with its findings.

Director, DHAC, ATSDR


REFERENCES

  1. United States Geological Survey. Phenolic Contamination inthe Sand-and-Gravel Aquifer from a Surface Impoundment ofWood Treatment Wastes, Pensacola, Florida. U.S. GeologicalSurvey, Water-Resources Investigation Report 84-4230, 1984.


  2. Agency for Toxic Substances and Disease Registry. HealthAssessment for American Creosote Works: Cerclis No.FLD008161994, Pensacola, Florida January 6, 1986.


  3. Environmental Protection Agency, Region IV. RemedialInvestigation Report Volume I. American Creosote Works,Inc. Site. Pensacola, Florida. EPA Work Assignment #30-4L45, NUS Corporation. January, 1985.


  4. Personal communication with Cathy Clay, Epidemiologist,Florida Department of Health and Rehabilitative Services,Environmental Epidemiology Section. July 1991.


  5. Environmental Protection Agency, Region IV. ResponsivenessSummary for the American Creosote Works, Inc. NPL SitePensacola, Florida. Based on Comments from the PublicMeeting of August 15, 1985.


  6. Environmental Protection Agency, Region IV. Record ofDecision, American Creosote Site, 1990.


  7. Environmental Protection Agency. Interim Procedures forEstimating Risks Associated with Exposures to Mixtures ofChlorinated Dibenzo-p-Dioxins and -Dibenzofurans (CDDs andCDFs) and 1989 Update. EPA/625/3-89/016, March 1989.


  8. Environmental Protection Agency, Region IV. Post RemedialInvestigation, American Creosote Works, Pensacola, Florida. U.S. Environmental Protection Agency, Environmental ServicesDivision, 1989.


  9. Environmental Protection Agency, Region IV. RemedialInvestigation, Phase II, American Creosote Works, Pensacola,Florida. U.S. Environmental Protection Agency, Region IV,Environmental Services Division, 1990.


  10. United States Geological Survey. Point-Source Ground-WaterContamination, Distribution and Movement of Wood-PreservingCompounds in a Surficial Aquifer, Pensacola, Florida. National Water Summary 1986 - Ground-Water Quality: Water-Quality Issues. U.S. Geological Survey Water Resources Water-Supply Paper 2325, 1986.


  11. Letter dated December 26, 1985 from R.L. DuBose, AssistantEnvironmental Health Director of the Escambia County PublicHealth Unit to Mr. Kenneth Kelson, Escambia CountyCommissioner.


  12. Environmental Protection Agency, Region IV. AmericanCreosote Investigation Report: Emergency Response, November11, 1985. ESD Project #86-082.


  13. Environmental Protection Agency. Exposure Factors Handbook. Office of Health and Environmental Assessment, Washington,D.C. EPA/600/8-89/043. July 1989.


  14. ATSDR, Toxicological Profile for Pentachlorophenol,ATSDR/TP-89/19, December 1989.


  15. Federal Register, Vol. 56, No. 126. Monday July 1, 1991.


  16. ATSDR, Minimum Risk Level for Pentachlorophenol, July 1991.


  17. ATSDR, Toxicological Profile for Polycyclic AromaticHydrocarbons, ATSDR/TP/90/20, December 1990.


  18. ATSDR, Minimum Risk Level for Benzo(a)pyrene, July 1991.


  19. Federal Register, Vol. 55, No. 143. Wednesday July 25, 1990.


  20. ATSDR, Toxicological Profile for 2,3,7,8-Tetrachlorodibenzo-p-dioxin, ATSDR/TP-88/23, June 1989.


  21. ATSDR, Preliminary Draft - Environmental Media EvaluationGuides (EMEGs), July 1991.


  22. ATSDR, Toxicological Profile for Benzene, ATSDR/TP/88/03, May 1989.


  23. Environmental Protection Agency. Health Effects SummaryTables, Fourth Quarter FY-1990. OERR 9200 6-303 (90-4),September 1990.

SELECTED BIBLIOGRAPHY

ATSDR, Toxicological Profile for Creosote, ATSDR/TP-90/09,December 1990.

Environmental Protection Agency, Region IV. Draft Baseline RiskAssessment for the American Creosote Works Site Pensacola,Florida. January 21, 1991.

Environmental Protection Agency, Region IV. Draft FeasibilityStudy Report, Operable Unit II for the American Creosote WorksSite Pensacola, Florida, March 1, 1991.

Environmental Protection Agency, Region IV. Post-FeasibilityStudy: Options for Remediation at the American Creosote Works,Inc. NPL Site. Pensacola, Escambia County Florida, September1989.

Environmental Protection Agency, Region IV. Record of Decisionfor American Creosote Site, Pensacola, Florida 1985.

Environmental Protection Agency, Region IV. Risk Assessment,American Creosote Works Site, Escambia County, Florida, June1989.

United States Geological Survey. Hydrogeology and Flow of Waterin a Sand and Gravel Aquifer Contaminate by Wood-PreservingCompounds, Pensacola, Florida. U.S.G.S. Water-ResourcesInvestigations Report 87-4260, 1988.

United States Geological Survey. Movement and Fate of CreosoteWaste in Ground Water, Pensacola, Florida: U.S. Geological SurveyToxic Waste-Ground-Water Contamination Program. U.S.G.S. Water-Supply Paper 2285, 1986.


APPENDIX A: SITE MAP

Site Map
Appendix A. Site Map


APPENDIX B: STATE OF FLORIDA DEPARTMENT OF HEALTH AND REHABILITATION SERVICES COVER LETTER AND SURVEY

Date

Resident
Street Address
Pensacola, FL 32501


Dear Resident:

Thank you for talking with me on the phone (Date) about the American Creosote site, located along "L" street south of Barrancas Avenue. Please write down any health concerns you may have about working near this site on the enclosed survey and return it to me. Feel free to pass this survey along to others who may be interested or have them call me. If you have any questions or think of something else, please call me at (904) 488-3385 between 8:00 and 5:00 (Eastern). I will include your health concerns (anonymously) when I write the Health Assessment and send you a copy of the draft when it becomes available this summer.

Health Assessments

The Florida Department of Health and Rehabilitative Services (HRS) prepares a Health Assessment report for each "Superfund" hazardous waste site in Florida. The Agency for Toxic Substances and Disease Registry (ATSDR), a division of the U.S. Public Health Service, pays HRS to prepare these reports. The purpose of a Health Assessment is to consider what chemicals have been released, evaluate possible health effects, and recommend any follow-up health studies that may be needed. Follow-up health studies, if needed, could include annual surveys to look for unusually high rates of disease, medical monitoring, etc. Equally important, the Environmental Protection Agency (EPA) considers Health Assessments when deciding how best to clean-up hazardous waste sites. In the next few weeks, I will be preparing the Health Assessment report for the American Creosote site. It is important that any concerns you may have for your health from living near this site be expressed so they can be considered when the site is cleaned-up and any follow-up health studies conducted.

Background - American Creoste

American Creosote was a wood preserving plant that treated timber with creosote and pentachlorophenol (PCP) from 1902 until it went out of business in 1981. During its years of operation, liquid wastes were discharged into two large unlined lagoons near "L" Street. Prior to 1970, the liquid wastes in these lagoons were allowed to overflow and follow a drainage course into Bayou Chico and Pensacola Bay . After 1970, the liquid wastes were routinely pumped from these lagoons and allowed to soak into the ground on the site. However, these lagoons still overflowed during periods of heavy rainfall. In 1983, EPA designated American Creosote a "Superfund" hazardous waste site, dewatered the two large lagoons, solidified the remaining sludge and covered it with a layer of clay.

The soils on this site are contaminated with pentachlorophenol (PCP) and chemicals common to creosote: polyaromatic hydrocarbons (PAHs), phenols, dioxins/dibenzofurans, and phthalates. The ground water is contaminated with PCP, PAHs, and phenols.

EPA Clean-up Plans

EPA plans to break down the contaminants in the soils on the site by adding water, nutrients, and bacteria. The design for this system should be completed by September 1991 and actual clean-up of the soil to start soon after. EPA has not decided on how to clean-up the contaminated ground water and buried sludge but will hold a public meeting this fall to present its plans.

Thanks again for talking with me on the phone. Please complete and return the survey on health concerns as soon as possible.


Sincerely

E. Randall Merchant
Biological Administrator
Toxicology and Hazard Assessment
(904) 488-3385


RM/rm

enclosure


HEALTH EFFECTS SURVEY
AMERICAN CREOSOTE HAZARDOUS WASTE SITE
PENSACOLA FLORIDA

The purpose of this survey is to determine the health concerns of people who live near the American Creosote "Superfund" hazardous waste site in Pensacola. Expressing these concerns will insure that clean-up of this site will protect the health of the people who live near the site and also determine if any follow-up health studies are needed. Your name will not be used in the Health Assessment report. Please fill out this survey as soon as possible and return to:

Mr. E. Randall Merchant
Florida Department of Health and Rehabilitative Services
HSET
1317 Winewood Blvd.
Tallahassee, FL 32399-0700
(904) 488-3385


1. Name:

Address:

2. How long have you lived near the American Creosote site?

3. Did you ever work at this site? If so, for how long?

4. Have you been on this site? If so, for how long?

5. Do you think living near this site has effected your health or the health of your family?If so, how?

6. Do you think living near this site will affect your health or the health of your family in the future? If so, how?

Thank you for completing this survey. Please mail it as soon as possible to Mr. Merchant at the above address or call him at (904) 488-3385 in Tallahassee if you any questions.

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