PUBLIC HEALTH ASSESSMENT

McCORMICK & BAXTER CREOSOTING COMPANY (PORTLAND)
PORTLAND, MULTNOMAH COUNTY, OREGON

APPENDIX A--SITE MAPS

LIST OF FIGURES

Figure 1 Site Location Map

Figure 2 Principal Site Features

APPENDIX B--CONTAMINANT AND PATHWAY TABLES

LIST OF TABLES

Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Table 10

Contaminants--On-Site Surface Soils
Contaminants--On-Site Subsurface Soils
Contaminants--On-Site Groundwater
Contaminants--On-Site NAPL (Below Ground)
Contaminants--On-Site Storm Water (Unfiltered)
Contaminants--Off-Site Surface Soils
Contaminants--Off-Site Sediment
Contaminants--Off-Site: Crayfish, Large Scale Sucker
Summary--Completed Pathways and Associated Health-Related Information
Summary--Potential Pathways and Associated Health-Related Information

ACRONYMS, ABBREVIATIONS

ND
ppm
ppb
E
M
LM
L
EMEG
CREG
RMEG
PMCL
LTHA
AL
NAPL
PCDD/PCDF

not detected
parts per million
parts per billion
estimated value
mean value
might be less than the stated mean value
less than the stated value
Environmental Media Evaluation Guide
Cancer Risk Evaluation Guide for 1x10^-6 excess cancer risk
Reference Dose Media Evaluation Guide
Proposed Maximum Contaminant Level
Lifetime Health Advisory
Action Level
nonaqueous-phase liquids
polychlorinated dibenzodioxins and polychlorinated dibenzofurans,presented as 2,3,7,8-tetrachlorodibenzo-p-dioxin toxicequivalents. See discussion under Environmental Contamination and Other Hazards section.

Table 1 Contaminants--On-Site Surface Soils

Contaminants	Maximum Concentration (ppm)	Sample (year)	Comparison Values
						ppm	Source
acenaphthylene	50	1990	none
benz(a)anthracene	420E	1990	none
benzo(a)pyrene	210	1990	0.1	CREG
benzo(e)pyrene	620E	1990	none
benzo(ghi)perylene	66	1990	none
benzofluoranthenes	1,000E	1990	none
carbazole	1,200E	1990	none
chrysene	1,900E	1990	none
dibenz(a,h)anthracene	22	1990	none
dibenzofuran	290E	1990	none
indeno(1,2,3-cd)pyrene	56	1990	none
2-methylnaphthalene	140	1990	none
naphthalene	42	1990	none
PCDD/PCDF (toxic equivalents *)	0.38	1990	0.0007	CREG
pentachlorophenol	4,800E	1990	6	CREG
phenanthrene	4,900	1990	none
2,3,4,5-tetrachlorophenol	65E	1990	none
arsenic	5,100	1990	0.4	CREG
beryllium	0.58	1990	0.2	CREG
lead	150	1990	none
Ref. (1)

Table 2 Contaminants--On-Site Subsurface Soils

Contaminants	Maximum Concentration (ppm)	Sample (year)	Comparison Values
						ppm	Source
acenaphthylene	13	1992	none
benz(a)anthracene	570E	1992	none
benzo(a)pyrene	170	1992	0.1	CREG
benzo(e)pyrene	150	1992	none
benzo(ghi)perylene	30	1992	none
benzofluoranthenes	460	1992	none
carbazole	460E	1992	none
chrysene	770E	1992	none
dibenz(a,h)anthracene	22	1992	none
indeno(1,2,3-cd)pyrene	64	1992	none
naphthalene	23,000	1992	none
PCDD/PCDF (toxic equiv-alents)	0.037	1992	0.0007	CREG
pentachlorophenol	5,200E	1992	6	CREG
phenanthrene	3,600	1992	none
arsenic	61,000	1992	0.4	CREG
copper	19,000	1992	none
Ref. (1)

Table 3 Contaminants--On-Site Groundwater

Contaminants	Maximum Concentration (ppb)	Sample (year)	Comparison Values
						ppb	Source
acenaphthene	2,000,000	1991	600	RMEG
acenaphthylene	150,000	1991	none
anthracene	620,000	1991	3,000	RMEG
benz(a)anthracene	240,000	1991	0.1	PMCL
benzo(a)pyrene	100,000	1991	0.005	CREG
benzo(e)pyrene	5,300	1991	none
benzo(ghi)perylene	20,000	1991	none
benzofluoranthenes	160,000	1991	0.2	PMCL
chrysene	190,000	1991	none
dibenz(a,h)anthracene	17,000	1991	0.3	PMCL
fluorene	1,800,000	1991	400	RMEG
fluoranthene	2,000,000	1991	400	RMEG
indeno(1,2,3-cd)pyrene	5,200	1991	0.4	PMCL
naphthalene	2,400,000	1991	20	LTHA
PCDD/PCDF (toxic equivalents)	0.20	1991	0.00001	CREG
pentachlorophenol	1,200,000	1991	0.3	CREG
phenanthrene	3,900,000	1991	none
pyrene	1,100,000	1991	300	RMEG
2,3,4,5-tetrachlorophenol	190E	1991	none
arsenic	9,000	1991	3	EMEG
chromium	12,000	1991	10,000	RMEG
chromium +6	120	1991	50	RMEG
copper	5,400	1991	1,300	AL
zinc	260,000	1991	3,000	RMEG
Ref. (1)

Table 4 Contaminants--On-Site NAPL Below Ground

Contaminants	Maximum Concentration (ppb)	Sample (year)	Comparison Values
						ppb	Source
acenapthene	30,000,000	1991	600	RMEG
acenaphthylene	490,000	1991	none
anthracene	820,000	1991	none
benz(a)anthracene	610,000	1991	0.1	PMCL
benzofluoranthenes	170,000	1991	0.2	PMCL
carbazole	160,000	1991	none
fluoranthene	32,000,000	1991	400	RMEG
fluorene	36,000,000	1991	400	RMEG
naphthalene	90,000,000	1991	20	LTHA
pentachlorophenol	830,000	1991	0.3	CREG
phenanthrene	88,000,000	1991	none
pyrene	30,000,000	1991	300	RMEG
Ref. (1)

Table 5 Contaminants--On-Site Storm Water (Unfiltered)

Contaminants	Maximum Concentration (ppb)	Sample (year)	Comparison Values
						ppb	Source
PCDD/PCDF (toxic equivalents)	0.024	1991	0.00001	CREG
pentachlorophenol	1,700	1991	0.3	CREG
tetrachlorophenols	68E	1991	none
arsenic	7,600M	1991	3	EMEG
copper	15,000M	1991	1,300	AL
zinc	8,200M	1991	3,000	RMEG
Ref. (1)

Table 6 Contaminants--Off-Site Surface Soils

Contaminants	Maximum Concentration (ppm)	Sample (year)	Comparison Values
						ppm	Source
benz(a)anthracene	A- ND B- 0.21E C- 0.055E D- 0.33 E- ND	1991	none
benzo(a)pyrene	A- ND B- 0.28 C- 0.30E D- 0.26 E- ND	1991	0.1	CREG
benzo(e)pyrene	A- ND B- 0.32 C- 0.21E D- 0.70 E- ND	1991	none
benzo(ghi)perylene	A- ND B- 0.24 C- 0.17E D- 0.26 E- ND	1991	none
benzofluoranthenes	A- ND B- 0.47 C- 0.35E D- 1.3 E- ND	1991	none
carbazole	A- ND B- 0.022 C- ND D- 0.052 E- ND	1991	none
chrysene	A- ND B- 0.36 C- 0.31E D- 1.1 E- ND	1991	none
dibenz(a,h)anthracene	A- ND B- ND C- ND D- 0.098 E- ND	1991	none
indeno(1,2,3-cd)pyrene	A- ND B- 0.3 C- 0.20E D- 0.042 E- ND	1991	none
naphthalene	A- 0.056E B- 0.025 C- 0.11E D- 0.035 E- ND	1991	none
PCDD/PCDF (toxic equivalents)	A- 0.0000081L B- 0.0005 C- 0.000054L D- 0.0011 E- 0.000012L	1991	0.000002	EMEG
phenanthrene	A- 0.054E B- 0.16 C- 0.12E D- 0.27 E- ND	1991	none
arsenic	A- 3.4E B- 11M C- 6.2 D- 17 E- 2.7E	1991	0.4	CREG
Table 6. Contaminants-Off-Site Surface Soils, notes
A- Samples from residential area beyond top of bluff B- Samples from access road C- Samples from adjacent industrial property to the north and from slope of bluff D- Single sample taken on site beside south property line that might represent conditions off-site in that area. E- Background sample taken near university Ref. (1)

Table 7 Contaminants--Off-Site River Sediment

Contaminants	Maximum Concentration (ppm)	Sample (year)	Comparison Values
						ppm	Source
acenaphthylene	17	1990	none
benz(a)anthracene	170	1990	none
benzo(a)pyrene	58	1990	0.1	CREG
benzo(e)pyrene	50	1990	none
benzofluoranthenes	170	1990	none
chrysene	170	1990	none
dibenz(a,h)anthracene	87	1990	none
dibenzofuran	620	1990	none
1,4-dichlorobenzene	0.53	1990	none
2,6-dinitro-toluene	22	1990	none
endrin aldehyde	0.00056E	1990	none
indeno(1,2,3-cd)pyrene	87	1990	none
2-methylnaphthalene	1,300	1990	none
4-methylphenol	0.90M	1990	none
naphthalene	3,500E	1990	none
PCDD/PCDF (toxic equiv-alents)	0.0027	1990	0.00005	EMEG
pentachloro-phenol	7.2	1990	6	CREG
phenanthrene	1,900E	1990	none
arsenic	18E	1990	0.4	CREG
beryllium	0.9	1990	0.2	CREG
lead	44	1990	none
manganese	690	1990	300	RMEG
Ref. (1)

Table 8 Contaminants--Off-Site: Crayfish, Large Scale Sucker

Contaminants	Maximum Concentration (via wet weight) (organic compounds--ppb) (metals--ppm)		Comparison Value
		Crayfish		Sucker
acenaphthylene	21	57	none
fluorene	ND	46	none
naphthalene	57	78M	none
PCDD/PCDF (toxic equiv-alents)	0.0056LM	0.0055LM	none
pyrene	ND	17E	none
arsenic	0.24E	ND	none
chromium	1.6	0.55	none
copper	13	0.5	none
zinc	15M	7.4	none
Sample date not reported Ref. (1)

Table 9 Summary--Completed Pathways and Associated Health-Related Information

PATHWAY NAME:	Air (on site) during operations	Air (off site) during operations	Process chemicals, wastes, soils (on site) during operations	Soils (on site)	Soils (off site)
Source:	McCormick & Baxter	McCormick & Baxter	McCormick & Baxter	McCormick & Baxter	McCormick & Baxter
Medium:	Air	Air	Chemicals, wastes, soils	Surface soils	Surface soils
Exposure Point:	On site	Off site	On site	On site	Off site
Exposure Route:	Inhalation	Inhalation	Skin contact, ingestion	Skin contact, ingestion	Skin contact, ingestion
Receptor Population:	Workers, visitors, trespassers	Nearby residents, nearby workers	Workers	Trespassers	Nearby residents, nearby workers
Exposure Period:	Past	Past	Past	Present, future	Past, present, future
Number Exposed:	Workers--about 50 employed at any one time	Unknown	About 50 employed at any one time	Unknown	Unknown
Contaminants at Levels of Public Health Concern:	Unknown	Unknown	Arsenic, pentachlorophenol, dioxins/furans, creosote	None	None
Exposure Duration:	Maximum of 47 years (operating time of site)	Maximum of 47 years (operating time of site)	Maximum of 47 years (operating time of site)
Potential Health Effects:	cannot determine, see Toxicologic Evaluation section discussion	cannot determine, see Community Health Concerns Evaluation section discussion	various organs: cancer or other disorders, see Toxicologic Evaluation section discussion

Source:	McCormick & Baxter, possibly others upstream	McCormick & Baxter, possibly others along river	McCormick & Baxter, possibly others upstream	McCormick & Baxter or others
Medium:	Sediment	Aquatic biota	Surface water	Air
Exposure Point:	On and off site	Off site	Off site	Off site
Exposure Route:	Skin contact	Ingestion	Skin contact, ingestion	Inhalation
Receptor Population:	Trespassers, children, former workers	Area fishermen	Shoreline users, fishermen, water skiers, swimmers	Nearby residents, on-site and nearby workers
Exposure Period:	Past, present, future for trespassers, children Past for former workers	Past, present, future	Past, present, future	Past, present, future
Number Exposed:	Workers--about 50 employed at any one time	Unknown	Unknown	Unknown
Contaminants at Levels of Public Health Concern:	Unknown	None	Unknown	Unknown
Exposure Duration:	Temporary		Temporary	Unknown
Potential Health Effects:	Unknown		Unknown, none likely	Unknown

 

Table 10 Summary--Potential Pathways and Associated Health-Related Information

PATHWAY NAME:	Soils (on site)	Air (on site)	Sediment (on site and off site)
Source:	McCormick & Baxter	McCormick & Baxter	McCormick & Baxter
Medium:	Soils	Air	Sediment
Exposure Point:	On site	On site	On site, off site
Exposure Route:	Ingestion, skin contact, inhalation	Inhalation	Skin contact
Receptor Population:	Remedial workers, future site users	Site users	Shoreline users
Exposure Period:	Present, future	Future	Future
Number Exposed:	Unknown	Unknown	Unknown
Contaminants at Levels of Public Health Concern:	Unknown	Unknown	Unknown
Exposure Duration:	Unknown	Unknown	Temporary
Potential Health Effects:	Cannot determine	Cannot determine	Cannot determine

APPENDIX C-PUBLIC COMMENTS

The McCormick and Baxter public health assessment was available for public review and comment in the local library and local neighborhood association office for a 60-day period ending April 10, 1995. The public comment period was announced in local newspapers. In addition, the public health assessment was sent to one individual. Several sets of commments were received. Specific comments and responses are summarized below. When duplicate comments on specific and particular issues were received, we responded only once.

1. Comment: Many comments seem to address, in part, elements of the methods that are inherent in our health assessment process (which was described in the Forward of the health assessment document). Thus, as a preliminary to answering specific questions, it seems appropriate to briefly summarize the assessment process.
   
   
   Response:
   
   ATSDR is required by law to conduct a public health assessment at each site that is proposed for the EPA's National Priority List (NPL). An initial release of the document must be made within 1 year of the proposal date. The aim of the assessment evaluations is to:
   • learn whether people are being exposed to hazardous substances, and,
   • if so, decide whether that exposure is harmful and should be stopped, and,
   • decide whether additional media or human exposure information are needed to adequately define important public health issues.

ATSDR scientists review available environmental data (generally supplied by government agencies, businesses, and the public) to identify concentrations of contaminants in pertinent environmental media. If the environmental data base is incomplete (which it usually is), the report will recommend sampling ATSDR believes is pertinent to clarifying substantive public health issues.

If review of data shows that people have or could come into contact with contaminants, ATSDR scientists then evaluate whether or not there may be harmful effects from those exposures. In those evaluations, our scientists generally make use of existing scientific (e.g., medical, toxicologic, epidemiologic, disease registry) information.



ATSDR scientists also need to learn what people in the area know about the site and what concerns they may have about its impact on their health. Throughout the evaluation process, we actively gather information and comments from people who live or work near a site. Initally, community health concerns are usually collected at public availability sessions, which ATSDR generally holds at the beginning of the site investigation. Community members have further opportunity to voice their concerns during the public comment period. The community's health concerns are then addressed in the public health assessment.

The report presents conclusions about the level of health threat, if any, posed by a site. Any indeterminate health issues, which usually result from an inadequate data base, are also described. For indeterminate issues that might have an associated substantive public health connotation, recommendations are made to obtain data that would aid in their future resolution.

2A.

Comment: It is imperative that, because of recreational uses of the Willamette River and concentrations of pollutants due to multiple sources, the community should be able to assess the full level of pollution as well as the residual and ongoing effects of the McCormick & Baxter contaminants--thus, the assessment should be expanded to include river water quality data. Response: ATSDR reported in the assessment that there was no river water quality data for the site vicinity. We have no reason to expect that the low exposure doses associated with incidental ingestion during recreational activities would result in definable human health effects. Therefore, river sampling was not recommended, because we believe that the additional information would not substantively enhance our assessment of the site and community effects. The document has not been changed.

2B.

Comment: People use the river to feed their families. No testing was done of fish other than the large scale sucker and crayfish. It is imperative that, because of recreational uses of the Willamette River and concentrations of pollutants due to multiple sources, the community should be able to assess the full level of pollution as well as the residual and ongoing effects of the McCormick & Baxter contaminants--thus, the assessment should be expanded to include more thorough testing of other species of fish which recreational fishermen might encounter. Response: ATSDR reported the crayfish and fish data and associated subsistence consumption health consequences. We have no reason to expect that exposure doses associated with eating fish other than those already sampled would result in additional definable health effects. Therefore, we did not recommend sampling for other species because we believe that the additional information would not substantively enhance our assessment of the site and community effects. The document has not been changed.

3. Comment: The assessment states that not enough soil sample information is available to make a representative judgement of the true contamination levels in the off site area. The community and future users of the land surrounding the site should be apprised of the true contamination levels. Further soil sampling must take place.
   
   
   Response:
   
   The Public Health Implications Section says that results from several residential soil samples show that contaminant levels are so low that it is unlikely that anyone will get sick from incidentally ingesting soil. Similarly low concentrations were found on the adjacent industrial properties, and, it is for just that area that the document indicates uncertainty about whether the number of samples reasonably represent the true concentrations. Therefore, the first recommendation presented in the document has been expanded to include sampling on more than one adjacent industrial property.



4. Comment: How long will the riverbank be dangerous to the health of the public?
   
   
   Response:
   
   Many of the contaminants present in water front sediments will be potent for a long, undefinable time, and the assessment has been revised to reflect that feature for selected exposure pathways. The assessment reported that ODEQ has plans for remediation of those materials. ATSDR does not know the schedule.



5. Comment: On Page 1 and 22, the document says: "Site should not be developed until contamination levels have been reduced below levels of health concern". Are there standards for each contaminant and, if so, how do the standards compare with what is on site and compare with data in the report tables. Cleanup should be thorough and should go beyond the minimum standard to allow for the possibility of more stringent standards occurring in the future.
   
   
   Response:
   
   We determined that it was important to revise the statement in question because site remediation is expected to be achieved in multiple ways, including contaminant reduction. The statement now reads: "The site should not be developed or otherwise accessed by the public until remediation measures are accomplished in a manner that effectively prevents human exposures from occurring at levels of public health concern."
   
   ATSDR does not determine remediation criteria; those are the purview of the agency (ODEQ) overseeing the activity and typically could vary from site to site.
   
   The comparison values shown in our tables have an public health foundation but are not remediation criteria. As stated in the Environmental Contamination and Other Hazards section of the document, comparison values are used, along with other criteria, to help decide which contaminants warrant further examination in the Public Health Implications (PHI) section. It is in the PHI section that concentrations are coupled with specific exposure scenarios and community concern information to evaluate health issues.



6. Why wasn't a door-to-door survey conducted of people who live on the ridge above the site, as well as a search for and survey of former residents? Residents have had concerns about the plant and its odors for years.
   
   
   Response:
   
   ATSDR often conducts door-to-door surveys as part of a community health study, or investigation. For purposes of gathering community health concerns during the public health assessment process, ATSDR holds public availability sessions. We advertise these meetings through the media and rely on existing community groups to spread the word about the meetings.



7. Anecdotal evidence of considerable community health erosion, including a rash of cancers in the neighborhood, warrants further investigation.
   
   
   Response:
   
   There are (at least) three reasons why community members may request a health investigation. We assume the request may be motivated by one or more of the following questions:
   
   
   • does exposure to a site-related contaminant cause adverse health effects in people,
   
   
   
   • is there an association between exposure and disease in the site community, and
   
   
   
   • do certain members of the community need medical management of an adverse health effect?

   Exposure to site-related contaminants and adverse health effects in people

   A health study is designed to address the question, is there an association between the occurrence of a specific disease (or constellation of related diseases) and exposure to a specific chemical (or group of chemicals). At this site, a study would investigate the specific relationship between exposure to wood treating chemicals and adverse health effects in people.

   Many studies have been conducted with people occupationally exposed to wood preserving chemicals, as described in the Public Health Implications sections above, and adverse health effects resulting from exposure are known. A health study of this community may not show any additional general information.

   Association between exposure and disease in the site community

   A health study of this community is not likely to show an association between exposure and disease. The design of a health study of this community would try to show an association between a particular disease (cancer in general would be inappropriate, for reasons discussed below) and exposure to wood preserving chemicals.

   With no way to determine who was exposed to those chemicals in the community, the only question a study could answer would be, is there a higher rate of a specific disease in the community relative to some standard. Such a study would in no way address the association between exposure and disease. Moreover, such a study would by design substantially underestimate any effect on those truly exposed to chemicals, since the study would be diluted by all the people who lived in the community but who were not exposed.

   Exposure to specific chemicals causes specific diseases. Cancer is not a specific disease. Different cancers have different causes and different courses. Some cancers may be caused by exposure to carcinogens; exposure to a carcinogen does not cause many different cancers in different people. An anecdotal report of a rash of cancers does not imply that many people were exposed to carcinogens, although a report of an increase in certain specific cancers could be an indication of exposure.

   In addition, a health study of this type simply answers whether there is a statistical association between exposure and disease. Therefore, the study requires a minimum number of exposed participants in order to be statistically valid.

   Medical management of an adverse health effect

   As recommended in the Public Health Implications section, concerned individuals should discuss potential chemical exposures when consulting their physicians. As recommended in the Recommendations section, community health education efforts should help raise awareness in potentially exposed people to seek medical help when indicated and to mention potential exposures. Health professionals education should help raise health care practitioners' awareness of signs and symptoms of chemical exposure.

   Recommendations

   Based on what investigations can and cannot do at this site, we have recommended community and health professions education. If a population can be identified that has been exposed to wood treatment process chemicals from the site, ATSDR will evaluate whether a health investigation is appropriate.
   
   
   
8. Why wasn't a health study conducted on former McCormick and Baxter employees and their families?
   
   
   Response:
   
   As a rule, ATSDR refers health issues of former workers to an appropriate federal or state occupational health agency. As discussed above, we know that adverse health effects often result in workers exposed to high levels of wood-preserving chemicals.



9. The public health assessment recommends that individuals concerned about chronic bronchitis and lung tissue damage should discuss potential chemical exposure with their physicians; however, individuals may not know to mention McCormick and Baxter as a possible contributor to health concerns.
   
   
   Response:
   
   

   Individuals and health care providers should be made aware of potential exposures related to the McCormick and Baxter site, as well as the signs and symptoms of exposure to site-specific chemicals, as part of the community and health professionals health education effort recommended in the Recommendations section.




10. ATSDR would not have conducted the public health assessment if the health of the public was not in danger.
    
    
    Response:
    
    ATSDR is required by law to conduct a public health assessment at each site that is proposed for the EPA's National Priority List (NPL). Proposal of a site to the NPL indicates the potential for that site to pose a public health threat and the need for ATSDR to evaluate the site's public health implications, as described in the response to comment #1.



11. The public comment period was too short.
    
    
    Response:
    
    ATSDR usually provides a month-long public comment period. For special circumstances, we schedule a longer time period. The public comment period for this document was approximately two months long. Individuals who contacted the Agency within the public comment period and indicated that comments were forthcoming were assured their comments would be addressed.



12. Since the report indicates that there are few problems due lack of data, only minor cleanup will be conducted and the site will continue to pose a health hazard.
    
    
    Response:
    
    ATSDR disagrees.

    We determined public health hazards posed by the site. We concluded that the site posed a public health hazard for former plant workers, poses a public health hazard for people who might encounter hazardous chemicals along the shoreline, and poses an indeterminate public health hazard for nearby residents because of past, present and future inhalation exposure.

    We asked for additional information. We recommended air monitoring, noting that the adverse lung symptoms reported by people who live near the site are consistent with exposure to site-related contaminants.
    We recommended actions to protect the community's health. We recommended that the site not be developed or otherwise made accessable by the public until remediation measures are accomplished in a manner that effectively prevents human exposures from occurring at levels of public health concern.

    As an advisory agency, we cannot require other agencies to follow our recommendations. However, other agencies often rely on our recommendations when taking actions to protect the public's health.




13. The commentor's personal experience with wood preserving chemicals indicates that exposure does not have to be intense and over many years to have serious detrimental effects.
    
    
    Response:
    
    

    ATSDR concurs, as stated in the Public Health Implications section.




14. Signs and warning in a variety of languages should be provided to the resource agencies that work with non-english speaking groups that fish the slough and rivers for food.
    
    
    Response:
    
    

    ATSDR will include non-english speaking groups that rely on fish and crayfish for food when conducting a needs assessment of the community.




15. The report concludes that lung symptoms are consistent with exposure to site-related contaminants, but did not collect information from residents about lung-related problems in an orderly fashion. Depending upon insufficient data will result in a report that does not safeguard health.
    
    
    Response:
    
    

    Without information about exposure, a link between exposure and adverse health effect cannot be established. We did say that the adverse lung symptoms are non-specific symptoms known to be experienced by people with no known exposure to hazardous waste, but they are also consistent with exposure to site-related contaminants.

    We recommended that the site be prevented from being developed or otherwise accessed by the public until remediation measures are accomplished in a manner that effectively prevents human exposures from occurring at levels of public health concern. We also have recommended gathering additional data on soil and air.




16. The report indicates that, should additional information become available, conclusions will be revised, but is unclear how additional data will be made available. ATSDR needs to require additional study in order to have a meaningful response.
    
    
    Response:
    
    

    ATSDR has identified data gaps (including contaminant levels in soil on adjacent industrial property, air quality on site while air-release-related remediation activities are in progress, and ambient air quality where residents continue to express concern about odors) and has requested more information be gathered. As an advisory agency, we cannot require other agencies to follow our recommendations.




17. How will health professionals and members of the community receive recommended education?
    
    
    Response:
    
    

    ATSDR staff plan to determine appropriate site-specific health education activities for health professionals and community members through a needs assessment. The Public Health Action Plan section of the public health assessment has been revised to reflect this information.

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