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PUBLIC HEALTH ASSESSMENT

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

APPENDICES

Appendix 1
Figures 1 and 2

Figure 1
Figure 1

Figure 2
Figure 2

Appendix 2
Health Comparison Values

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

Cancer Risk Evaluation Guides (CREGs) are contaminant concentrations estimated to cause nomore than one excess cancer in a million (10E-6) persons exposed over a lifetime. CREGs arecalculated from U.S. Environmental Protection Agency's (EPA's) cancer slope factors.

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

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

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

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

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

Appendix 3
Response to Comments Received During the Public Comment Period

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

Comments and responses are summarized below. The comment letter can be requested from ATSDR through the Freedom of Information Act.
Comment: It is not understood why your Dec. 12 meeting is confidential. The residents were also divided in your Jan. 25 meeting.
Response: The Agency for Toxic Substances and Disease Registry (ATSDR) frequency holds Public Availability Sessions at which people can, if they wish, speak to ATSDR scientists inprivate. This is a service ATSDR provides to the community. ATSDR has found that frequentlypeople prefer to talk to ATSDR scientists in private. It is not intended to divide the community. Nor would ATSDR discourage anyone from speaking out about their concerns.

In addition to the two Public Availability Sessions held on December 11 and 12, 1994, ATSDRdid hold a Public Meeting on December 12. The Public Meeting was arranged by ATSDR sothat the community could, if they wish, present their concerns to ATSDR in a open forum. ATSDR does not direct or indicate to anyone which forum (Public Availability Sessions orPublic Meeting) they should attend. It is a decision made by each individual.

Comment: Can a health judgement be made without independent drinking water tests? The city does not test Kunia Camp.
Response: As indicated in the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment (Page 12, Quality Assurance and Quality Control section), several samplesfrom the Kunia well and the three monitoring wells were sent to different laboratories (i.e., DelMonte, Hawaii Department of Health, and University of Hawaii). The analytical result for thesesplit samples were comparable. This comparability would tend to indicate that data submitted toATSDR is truly reflective of the conditions at the Del Monte Corporation Oahu PlantationNational Priorities List (NPL) site.

ATSDR was not able to obtain quality assurance and quality control (QA/QC) information forthe data presented in the public health assessment. Therefore, ATSDR has and will continue torecommend that appropriate QA/QC procedures be conducted for any future environmentalsampling conducted at this NPL site.

The Hawaii Department of Health does test the drinking water supply currently being provided tothe Kunia village. The results of these tests are included in the Public Comment Del MonteCorporation Oahu Plantation Public Health Assessment (Page 10, Off-Site Contamination section and Table 2).

Comment: Your superfund study asks for (very weak) "EPA sampling and analysis protocols."
Response: ATSDR believes that the analysis protocols recommended by the U.S. Environmental Protection Agency (EPA) are appropriate and are not weak. The detection limits and othermethodology required by the EPA protocols are rigorous enough for ATSDR to determine whether there may be any possible health concerns at the Del Monte Corporation Oahu Plantation NPL site.
Comment: Kunia Camp is surrounded by contaminated wells. Your report does not use USGS numbers.
Response: The USGS numbers for the drinking water wells discussed in the Del Monte Corporation Oahu Plantation Public Health Assessment have been added.
Comment: The new "clean" camp water contains ethylene dibromide (EDB), 1,2-dibromo-3-chloropropane (DBCP), tetrachloroethylene, trichloroethylene, trichloropropane (TCP), carbontetrachloride and dichloroethylene.
Response: On pages 10 through 12 of the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment, ATSDR discusses the contaminants found in the two wells that presently provide drinking water to Kunia. No contaminants were detected in the wells above ATSDR health comparison values. Therefore, it is unlikely that any adverse health effects will occur to people ingesting the water from these wells. Table 2, page 11, summarizes the analytical results and comparisons values of the samples taken from the two wells.

In February, 1989, a packed tower aeration facility was installed at the Kunia village. This towerreduces the concentration of volatile organic compounds even further below health comparison values, most below the analytical detection limits. By reducing the concentrations of these contaminants in the drinking water supply for Kunia, it is even more unlikely that any adverse health effects will occur to people ingesting the water from these wells. This information is also found in Table 2, page 11 of the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment.

Comment: The Kunia/Poamoho health study may be flawed. DBCP, dichloropropane (DCP),and TCP were found in that Poamoho square mile. Poamoho is only four miles from Kunia.
Response: As discussed on page 22 through 24 (Health Outcome Data Evaluation section) of the Public Comment Del Monte Corporation Oahu Plantation Public Health Assessment, ATSDRfound several problems with several of the Kunia/Poamoho health studies. That is why ATSDR did not use most of the Kunia/Poamoho studies to develop our conclusions and recommendations concerning this NPL site.

However, the information contained in the Kunia/Poamoho studies indicate that the Poamohodrinking water well did not contain DBCP, DCP, or TCP above detection limits at the time of thestudy. This is not to say that no DBCP, DCP, or TCP were detected within a square mile ofPoamoho village. Even if DBCP, DCP, or TCP were present in the Poamoho well just belowdetection limits, the differing amounts (concentrations) of these compounds in the drinking waterfor Kunia and Poamoho would be large enough (over 1,000 times) to allow a valid scientificcomparison to be made.

Comment: Is the Kunia filter install date actually in our records?
Response: The installation and start up of the Kunia pack tower aeration facility is a matter of public record. The Hawaii Department of Health has inspected the Kunia pack tower aerationfacility and will continue to inspect and take water samples from the facility.
Comment: Your "EPA target compound list" does not name the health effects for all of our 37 toxins.
Response: The EPA Target Compound List is apart of the contract EPA has with various laboratories through out the United States. The Target Compound List specifics what compounds the laboratory should test for in each environmental sample. The EPA Target Compound List does not provide any information on the health effects of the compounds.

In the public health assessment, ATSDR recommended that any future environmental samplestaken at the Del Monte Corporation Oahu Plantation NPL site be analyzed for all of thesubstances on the EPA Target Compound List. ATSDR made this recommendation becausenone of the environmental samples taken at this NPL site have been analyzed for anycontaminants besides EDB, DBCP, and metals. In addition, ATSDR has recommended that anyfuture environmental samples taken at the NPL site also be analyzed for all of the pesticides usedat the Del Monte Oahu Plantation. Therefore, any future environmental samples taken at the DelMonte Corporation Oahu Plantation NPL site should be analyzed for the 37 compounds youdiscuss and more.

Comment: Does any reference name the health effects of mixtures, or the possible synergistic or generational effects on a fetus? Is mothers food, air, and water considered?
Response: The two ATSDR toxicological profiles referenced in the Del Monte Corporation Oahu Plantation Public Health Assessment discuss the possible effects of EDB and DBCP on thefetus and mothers. The profiles also state that both of these compounds do not accumulate in thebody. Therefore, it is unlikely that there would be any generational effects caused by these twocompounds.

The studies conducted by Wong et al. evaluated California populations exposed to DBCP-contaminated drinking water. No adverse health effects were found by these studies.

During the evaluation of this site, ATSDR did consider whether EDB and DBCP could cause anyhealth effect through the additive combination of these two compounds. It is ATSDR'sconclusion that it is unlikely that the combine exposures that occurred at Kunia could result inany adverse health effects.

Comment: Do no harm. A comprehensive health effect and birth defects search should be done on the present and former Kunia children.
Response: ATSDR has determined that no health effects are expected in children because of the past exposures to EDB and DBCP in the Kunia drinking water. No Kunia children were bornwith birth defects during the period of highest drinking water contamination (1977 through1979). Because EDB and DBCP do not bioaccumulate, it is not likely that any children presentlyliving in Kunia would have any birth defects or other health affects related to the past drinkingwater exposures to EDB and DBCP. Therefore, ATSDR is not considering conducting anyfollow-up health activities at this NPL site at this time. However, if data suggesting that humanexposure to hazardous substances at levels of public health concern is currently occurringbecome available, ATSDR will reevaluate this site for any indicated follow-up.
Comment: The pumping of the Kunia well no longer occurs. During our investigation of the Del Monte site, EPA noted that untreated water from the Kunia well was being spread on the siteas a dust suppressant. Since EDB and DBCP are both listed wastes, EPA believes this activitymay violate the Resource, Conservation & Recovery Act ("RCRA") which expresses prohibitionon use of material which has been mixed with any hazardous waste for dust suppressionpurposes. It may also violate RCRA's general prohibition on disposal of contaminants to land. Del Monte has agreed to cease spreading the water in response to EPA concerns.
Response: The Del Monte Corporation Oahu Plantation Public Health Assessment has been modified to indicate this change.
Comment: During ATSDR's site visit, no standing water was seen in the 60-foot deep pit. EPA has observed standing water in this area during a site visit last year.
Response: The Del Monte Corporation Oahu Plantation Public Health Assessment has been modified to reflect this observation.
Comment: Recommendations on page 27 of the Public Comment Release are consistent with EPA's RI/FS objectives.
Response: ATSDR appreciates EPA's support in this effort.
Comment: EPA will assure that any downgradient wells are monitored annually for site-related contaminants to the extent possible. Also, EPA will assure that future samples will be collectedin accordance with EPA sampling and analysis protocols.
Response: ATSDR appreciates EPA's support in this effort.


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