Skip directly to search Skip directly to A to Z list Skip directly to site content

PUBLIC HEALTH ASSESSMENT

POLES, INCORPORATION WOOD TREATMENT FACILITY
OLDTOWN, BONNER COUNTY, IDAHO


APPENDIX H: SITE VISIT PHOTOS

No trespassing sign with school in the background -and- No trespassing sign from school facing the Poles, Inc. facility
Figures H-1 & H-2: No trespassing sign with school in the background -and- No trespassing sign from school facing the Poles, Inc. facility

No trespassing sign put up by Poles, Inc. -and- People trepass through ignoring the sign in the background
Figures H-3 & H-4: No trespassing sign put up by Poles, Inc. -and- People trepass through ignoring the sign in the background

Toy and soda can left behind by trespassers
Figures H-5: Toy and soda can left behind by trespassers


APPENDIX I: RISK CALCULATIONS EQUATIONS

Surface Soil

Estimated daily exposure from ingestion of surface soil:
 

Conc. x EF x IR x ED x AF

 
Dose = S 
 x 10 -6 (kg/mg) --- Equation 1
 

BW x AT x 365

 

Cancer Risk Calculation:

Risk = S Dose x SF -- Equation 2

For soil ingestion pathway, the combination of Equation 1 and 2 is equivalent to the combination of Equation 3 and 4 that is the simplified model from EPA Region IX PRG calculation.

Soil Ingestion Cancer Risk Calculation:
 

SF x Conc. x EF x IR soil-adj x AF

 
Risk
 -- Equation 3
 

AT x 365 x CF

 

 

Where,    
Dose  =  mg/kg/day
Risk  =  estimated excess cancer risk over a lifetime (unitless)
Conc.  =  Concentration (mg/kg)
EF  =  exposure frequency (days)
   
  • Younger children (1-6 years of age): 365 days for residential soil and 0 days for industrial soil
  • Older children (7-18 years of age): 3 days/week, approximately 152 days/year
  • Adult (19 or older): 1 day/week, approximately 52 days/year for trespasser; or regular work week, approximately 250 days/year for worker.
IR  =  soil ingestion rate (mg/day)
  • Younger children (1-6 years of age): 5000 mg/day
  • Older children (7-18 years of age): 200 mg/day
  • Adult (19 or older): 100 mg/day
CF  =  Unit Conversion Factor (1000 mg/kg)
ED  =  exposure duration (years)
  • 20 years for worker
BW  =  body weight (kg)
  • Younger children (1-6 years of age): 15 kg
  • Older children (7-18 years of age): 25 kg
  • Adult (19 or older): 75 kg
AT  =  average time (70 years - lifetime)
AF  = absorption fraction (chemical and media specific)
SF  = cancer slope factor (mg/kg/day)-1, chemical specific
IRsoil-adj  =  Soil Ingested rate adjusted by age factor (mg-year/kg-day)

 

  IR x ED  
IR soil-adj = S 
 -- Equation 4
 

BW

 

Air

Estimated daily exposures from inhalation of air:
 

Conc. x IR x ED x AF

 
Dose = S 
x 10-3 (µg/mg)  -- Equation 5

 

BW x AT x 365

 

Cancer Risk Calculation:

Same as Equation 2.

For soil inhalation pathway, the combination of Equation 5 and 2 is equivalent to the combination of Equation 6 and 7 that is the simplify model from EPA Region IX PRG calculation.

Inhalation Cancer Risk Calculation:
 

SF x Conc. x EF x IRInh-adj

 
Risk
 -- Equation 6
 

AT x 365 x CF

 

 

Where,    
Dose  =  mg/kg/day
Risk  =  estimated excess cancer risk over a lifetime (unitless)
Conc.  =  Concentration (µg/M3)
EF  =  exposure frequency (40 to 120 days)
IR  =  Inhalation rate (M3/day)
   
  • Younger children (1-6 years of age): 10 M3/day
  • Older children (7-18 years of age): 15 M3/day
  • Adult (19 or older): 20 M3/day
ED  =  exposure duration (years)
BW  =  body weight (kg)

  • Younger children (1-6 years of age): 15 kg
  • Older children (7-18 years of age): 25 kg
  • Adult (19 or older): 75 kg
AT  =  average time (70 years - lifetime)
CF  = Unit Conversion Factor (1000 µg/mg)
AF  = absorption fraction (chemical and media specific)
SF  =  cancer slope factor (mg/kg/day)-1, chemical specific
IRinh-adj  = Inhalation rate adjusted by age factor (mg-year/kg-day)

 

  IR x ED  
IRinh-adj = S 
 -- Equation 7

 

BW

 


APPENDIX J: HEALTH CONSULTATION ATSDR


HEALTH CONSULTATION

Review of August 2001 Ambient Air Data

POLES, INCORPORATED
(a/k/a POLES, INCORPORATED WOOD TREATING FACILITY)
OLDTOWN, BONNER COUNTY, IDAHO
EPA FACILITY ID: ID0002406635

December 27, 2001

Preapred by:

Exposure Investigation and Consultation Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry


TABLE OF CONTENTS

BACKGROUND AND STATEMENT OF ISSUES

DISCUSSION

CONCLUSIONS

RECOMMENDATIONS

REFERENCES

PREPARERS OF REPORT

TABLES

FIGURE




BACKGROUND AND STATEMENT OF ISSUES

The Agency for Toxic Substances and Disease Registry (ATSDR) received a request from U.S.Environmental Protection Agency (EPA) Region 10 to evaluate ambient air data for Poles, Inc.,collected in August 2001, and determine whether airborne pentachlorophenol (PCP) andassociated chemicals pose a health hazard to people at the neighboring school or residences (1).

Poles, Inc., located in Oldtown, Idaho, just west of Priest River, is an open vat thermal wood-treating facility, using pentachlorophenol (PCP) as a wood preservative. The facility is closedduring December, January, and February, and operates the other 9 months of the year. Thenearest residence is approximately 400 feet north of the facility and an elementary school islocated approximately 500 feet south of the facility. The elementary school is approximately30 feet higher in elevation than the site. In 1999, an old wood-fired boiler was replaced by a newoil-fired boiler, reducing the treatment process from 13 hours to 8 hours. Because the facilityuses only one dip tank, a maximum of 2 to 2.5 batches are treated a week (2).

In fall 2000, several community members and schoolteachers complained about strong odors emanating from the facility, and expressed concerns of possible health effects. In response to these concerns, the owner changed his schedule, treating the poles during the evening instead of during the day, to reduce possible exposure of nearby community members to airborne PCP. In August 2001, Ecology and Environment, Inc. collected 27 ambient air samples at eight locations on and around the facility during 3 consecutive days. All samples were collected in a 23-hour period with approximately 300 cubic meters total sample volume and analyzed for semivolatile organic compounds (SVOCs) using EPA Method TO-13A. See Table 1 for sampling location description and Table 2 for summary of analytical data.


DISCUSSION

Twelve SVOCs were detected in ambient air samples. The levels of all detected chemicals, except PCP and 2-methylnaphthalene as noted below, were below their respective health-based guidelines. PCP was found at levels ranging from non-detect to an estimated maximum of 1.48 µg/m³. The Idaho ambient air standard for PCP is 25 µg/m³ based on noncancer effects and the EPA Region 9 preliminary remediation goal (PRG) for PCP is 0.056 µg/m³ based on carcinogenicity (2,3).Some issues related to this site are as follows:

  • Due to the chemical and physical properties of PCP, the air pathway is not expected to bea primary route of exposure at this site. Oral ingestion and dermal contact through soiland water pathways should be considered when data becomes available.

  • There are no known health guidelines for inhalation exposure for PCP. The PRG cited inthe data tables is not an appropriate screening value to assess health concerns at the site.First, the PCP PRG value was calculated using a route-to-route extrapolation. Second,PRG is based on a default exposure frequency of 30 years, 350 days per year. Third, PRGcorresponds to a fixed level of 1-in-1 million cancer risk. Wind direction variability andthe limited frequency with which logs are treated at the site will not permit exposuresfrequent enough to cause long-term health effects. Calculation of a realistic exposurescenario at the site indicates no apparent increased cancer risk.

  • The sample quantitation limits were above the PRG value; however, when calculating theaverage dose using half of the detection limits where no PCP was detected, the levelswere below the PRG values.

  • PCP has been identified in at least 313 of the 1,585 hazardous waste sites on the NationalPriorities List (NPL). No site was found in the HazDat database where PCP in airpresented a public health hazard. For example, Laidlaw Environmental Services Facilityin South Carolina had a completed air pathway for PCP, but it was determined to be noapparent public health hazard.

  • 2-methylnaphthalene is another chemical to be evaluated. Because there is no PRG value for 2-methylnaphthalene, the PRG value for naphthalene was used. The maximum value for 2-methylnaphthalene is higher than this PRG value, as well as for the ATSDR chronic inhalation reference-dose media evaluation guide (RMEG) value. However, the RMEG is based on the lowest observed adverse effect level (LOAEL) for animal exposures with a safety factor of 1,000. The LOAEL is approximately 1,280 µg/m³ (4). Also, the RMEG is a screening value that uses an exposure scenario inappropriate for the site. Therefore, current site-related exposures are not expected to result in adverse health effects.

  • The following limitations for this analysis are noted. (1) The data analysis pertains tocurrent exposure levels only. No conclusions can be drawn about past exposure. (2) Thesample method reporting limits for the data exceed the PRGs.

CONCLUSIONS

On the basis of available data and the above discussions, ATSDR concluded that currentexposure to PCP and 2-methylnaphthalene at this site through the air pathway is no apparentpublic health hazard because (1) exposures will not cause imminent adverse health effects in thegeneral population, which (2) will have no apparent increased risk of getting cancer from long-term exposure.


RECOMMENDATIONS

  1. Inform the public that there is no apparent public health hazard posed by the levels of PCP and 2-methylnaphthalene measured in the air.

  2. Evaluate oral ingestion and dermal contact through soil and water pathways when databecomes available.

REFERENCES

  1. Agency for Toxic Substances and Disease Registry. Technical assistance request to theExposure Investigations and Consultations Branch from Karen Larson, ATSDR Region 10representative, concerning possible air contamination at the Poles, Inc., site. Atlanta: US Department of Health and Human Services; October 25, 2001.

  2. Agency for Toxic Substances and Disease Registry. Health consultation for Poles,Incorporated, wood treatment facility. Atlanta: US Department of Health and HumanServices; 2001 Sep 19.

  3. US Environmental Protection Agency. Region 9 preliminary remediation goals. WashingtonDC: US Environmental Protection Agency; 2001. Available at URL: http://www.epa.gov .

  4. Agency for Toxic Substances and Disease Registry. Toxicological profile for naphthalene (update), Atlanta: US Department of Health and Human Services; 1995 Aug.

PREPARED BY

Jane Zhu
Environmental Health Scientist
Exposure Investigations and Consultations Branch
Division of Health Assessment and Consultation

Kara Fincham
Abstractor
Program Evaluation, Records, and Information Services Branch
Division of Health Assessment and Consultation


Reviewed by

Karen L. Larson, PhD
Regional Representative
Office of Regional Operations
Agency for Toxic Substances and Disease Registry

Gregory M. Zarus
Strike Team Leader
Exposure Investigations and Consultations Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry

Maurice West, PE, DEE
Deputy Branch Chief
Exposure Investigations and Consultations Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry


Table 1.

Air Sampling Locations/Descriptions for Poles, Inc.
August 22-25, 2001
Location ID Description of sample location
PY04AM Background
PY01AM Metstation (downwind during all three sampling events)
PY02AM Near bluff (downwind during all three sampling events)
PY03AM Residence (downwind only during August 22-23 sampling event)
PY05AM Next to process area (on-site) (downwind during all three sampling events)
PY06AM Inside school
PY07AM Across river (downwind during all three sampling events)
PY08AM Downwind


Table 2.

Summary of Air Samples Pentachlorophenol (PCP) Analytical Results Poles, Inc. Oldtown, Idaho (µg/m3)
Location ID August 22-23 August 23-24 August 24-25
PY04AM 0.18 U 0.18 U 0.16 U
PY01AM 0.16 U 0.18 U 0.03 JQK
PY02AM 0.10 JQK 0.03 JQK 0.06 JQK
PY03AM 1.48 JQK 0.16 U 0.16 U
PY05AM 0.01 JQK 0.63 JL 0.49 JL
PY06AM* 0.18 U 0.16 U 0.16 U
PY07AM 0.05 JQK 0.16 U 0.15 U
PY08AM R 0.16 U 0.14 U

KEY:
*indoor air sample in school
U = The analyte was detected. The associated numerical result is the sample quantitation limit.
J = The analyte was positively identified. The associated numerical result is an estimate.
K = Unknown bias.
L = Low bias.
Q = Analyte detected below the adjusted sample quantitation limit.
R = Rejected.


Demographic Statistics
Figure 1. Demographic Statistics

Table of Contents



APPENDIX K:

ATSDR INTERIM PUBLIC HEALTH HAZARD CATEGORIES
Category/Definition Data Sufficiency Criteria

Urgent Public Health Hazard

This category is used for sites where short-term exposures (<1yr) to hazardous substances or conditions could result in adverse health effects that require rapid intervention.

 

This determination represents a professional judgment based on critical data, which ATSDR has judged sufficient to support a decision. This does not necessarily imply that the available data are complete; in some cases additional data may be required to confirm or further support the decision made. Evaluation of available relevant information* indicated that site-specific conditions or likely exposures have had, are having, or are likely to have in the future, an adverse impact on human health that requires immediate action or intervention. Such site-specific conditions or exposures may include the pre of serious physical or safety hazards.

Public Health Hazard

This category is used for sites that pose a public health hazard due to the existence of long-term exposure (>1yr) to hazardous substances or conditions that could result in adverse health effects.

This determination represents a professional judgment based on critical data, which ATSDR has judged sufficient to support a decision. This does not necessarily imply that the available data are complete; in some cases additional data may be required to confirm or further support the decision made. Evaluation of available relevant information* suggests that, under site-specific conditions of exposure, long-term exposures to site-specific contaminants (including radionuclides) have had, are having, or are likely to have in the future, an adverse impact on human health that requires one of more public health interventions. Such site-specific exposures may include the presence of serious physical or safety hazards.

Indeterminate Public Health Hazard

This category is used for sites in which "critical" data are insufficient with regard to extent of exposure and/or toxicological properties at estimated exposure levels.

This determination represents a professional judgment that critical data are missing and ATSDR has judged the data are insufficient to support a decision. This does not necessarily imply all data are incomplete; but that some additional data are required to support a decision. The health assessor much determine, using professional judgment, the "criticality" of such data and the likelihood that the data can be obtained and will be obtained in a timely manner. Where some data are available, even limited data, the health assessor is encouraged to the extent possible to select other hazard categories and to support their decision with clear narrative that explains the limits of the data and the rationale for the decision.

No Apparent Public Health Hazard

This category is used for sites where human exposure to contaminated media may be occurring, may have occurred in the past, and/or may occur in the future, but the exposure is not expected to cause any adverse health effects.

This determination represents a professional judgment based on critical data, which ATSDR considers sufficient to support a decision. This does not necessarily imply that the available data are complete; in some cases additional data may be required to confirm or further support the decision made. Evaluation of available relevant information* indicates that, under site-specific conditions of exposure, exposures, exposure to site-specific contaminants in the past, present, or future are not likely to result in any adverse impact on human health.

No Public Health Hazard

This category is used for sites that, because of the absence of exposure, do NOT pose a public health hazard.

Sufficient evidence indicates that no human exposures to contaminated media have occurred, none are now occurring, and none are likely to occur in the future.  

*: Such as environmental and demographic data; health outcome data; community health concerns information; toxicological, medical, and epidemiological data; monitoring and management plans.


APPENDIX L: LETTER FROM SCHOOL DISTRICTS

Letter page 1

Letter page 2

2nd Letter page 1

2nd Letter page 2


APPENDIX M: OLDTOWN IDAHO COMMUNITY CONCERNS SURVEY

Oldtown, Idaho
February 25, 2002 Community Meeting
Community Concerns Survey

The Bureau of Environmental Health and Safety (BEHS) is developing a public health assessment for the site. A public health assessment is a non-regulatory document used to assess the human health impacts of a specific hazardous waste site and to identify appropriate public health interventions. Part of the development of a public health assessment is to gather community concerns and address those concerns in the public health assessment. Please provide us with your comments and concerns about your health and the health of your community as they relate to the pole treating facility. Thank you for your time.
Your input is welcome and appreciated!

Issue/Concern Response
Are you concerned your health and your children's health is being impacted by the pole treating facility? If yes, how?  
Do you, or someone you know, have a health condition that you feel is related to the site? If yes, what is the condition and how would you like us to address it, if possible?  
Have the odors (intensity, duration, smell, etc.) coming from the facility changed in time?  
Do you, or does anyone you know, walk/play on the facility property (this includes the log piles, the treatment buildings, the railroad tracks)? If yes, how often?  
What is your primary drinking water source? - City Supply
- Private Well
- Bottled
- Other (please specify)
- Don't Know
How far do you live from the facility?  
How long have you lived at your current address? How long have you lived in this area? Time at current address:
Time in area:
Do you have children living with you at this address? If so, what are their ages and gender?  
How do you receive news about your local community? (check all) - Mailings
- Radio
- TV
- Library
- Newspaper (which one(s))
- Health Department Office
- Other (please specify)
How would you like to receive public health information relating to the facility? (check all) - Mailings
- Radio
- TV
- Library
- Newspaper (which one(s))
- Health Department Office
- Other (please specify)
What is your general feeling about this site? (check one) - It does NOT affect my health.
- It DOES affect my health.
- I am not sure.
What is your interest level in this site? (check one) - Very interested.
- Somewhat interested.
- Not interested.
Please provide us with any information you feel is relevant to our public health assessment for the site.  


Name:_________________________________________________

Address:_______________________________________________

______________________________________________________

Phone Number:__________________________________________


Thank you for completing our survey!

The information you have provided will be kept confidential and only viewed by Health Department employees.


APPENDIX N:

OLDTOWN COMMUNITY CONCERNS SURVEY, OVERVIEW OF RESULTS
Information Number Percent
Number of Surveys Mailed 626  
Number of Surveys Distributed at Public Meeting 30  
Number of Respondents 91 13.87%
Are you concerned your health and your children's health is being impacted by the pole treating facility? If yes, how? 20 21.98%
Do you, or someone you know, have a health condition that you feel is related to the site? If yes, what is the condition and how would you like us to address it, if possible? 12 13.19%
Have the odors (intensity, duration, smell, etc.) coming from the facility changed in time? 28 30.77%
Do you, or does anyone you know, walk/play on the facility property (this includes the log piles, the treatment buildings, the railroad tracks)? If yes, how often? 18 19.78%
What is your primary drinking water source?
City Water. 36 39.56%
Private Well. 49 53.85%
Bottled. 1 1.10%
Other. 8 8.79%
Don't Know. 0 0.00%
How far do you live from the facility?
< 1 mile 41 45.05%
1-1.9 miles 11 12.09%
2-2.9 miles 12 13.19%
3-3.9 miles 7 7.69%
4-4.9 miles 5 5.49%
>5 miles 13 14.29%
How long have you lived at your current address?
< 5 years 20 21.98%
5.1 - 10 years 19 20.88%
10.1 - 15 years 8 8.79%
15.1 - 20 years 8 8.79%
>20 years 30 32.97%
How long have you lived in this area?
< 5 years 8 8.79%
5.1 - 10 years 17 18.68%
10.1 - 15 years 6 6.59%
15.1 - 20 years 9 9.89%
>20 years 46 50.55%
Do you have children living with you at this address?
Yes. 25 27.47%
0-5 years 7 28.00%
>5<10 years 7 28.00%
>5<18 years 13 52.00%
>18 years 7 28.00%
How do you receive news about your local community?
Mailings. 51 56.04%
Radio 38 41.76%
TV. 39 42.86%
Library. 4 4.40%
Newspaper. 77 84.62%
Health Dept. 6 6.59%
Other. 16 17.58%
How would you like to receive public health info relating to this facility?
Mailings. 62 68.13%
Radio 16 17.58%
TV. 39 42.86%
Library. 4 4.40%
Newspaper. 77 84.62%
Health Dept. 6 6.59%
Other. 16 17.58%
What is your general feeling about this site?
Does NOT affect my health. 56 61.54%
DOES affect my health. 5 5.49%
I am not sure. 26 28.57%
What is your interest level about this site?
Very interested. 46 50.55%
Somewhat interested. 34 37.36%
Not interested. 8 8.79%


APPENDIX O: DRAFT PUBLIC HEALTH ASSESSMENT REVIEW COMMENTS AND RESPONSES

Oldtown Public Health Assessment CAG/Public Release

Review Comments Addressed

August 2002

The following comments were provided by members of the Oldtown Community Advisory Group. No members of the general public submitted comments on the document. Each reviewer's comments were extensive and have been modified for brevity. Responses to reviewer comments immediately follow the comment. All editorial comments were incorporated, as necessary, and are not included in the following narrative.

REVIEWER #A:

  1. The public health assessment focuses on individual chemicals in the body and does not address the total chemical burden now present in the body.
  2. BEHS considered current peer reviewed toxicological and epidemiological information on the chemicals present in environmental samples, including information currently available about body burdens. It is true that toxicological evaluations of individual chemicals do not take into account the potential for adverse health effects from the combined exposure to mixtures of these contaminants, although research on the toxicity of mixtures indicates that adverse health effects are unlikely when the mixture components are present at levels well below their individual toxicologic thresholds (Bond et al., 1997; Groton et al., 1997; Seed et al., 1995; and Yang et al., 1989). Because documented contaminant levels indicate that the exposures were well below their respective individual toxicological thresholds, the toxicological evidence suggests that exposures to combinations of known contaminants detected in onsite surface soil or other environmental media at the Poles, Inc. site are not likely to lead to adverse health effects. To be conservative or protective, BEHS in the development of the public health assessment assumed the chemical effects were additive.

  3. The public health assessment only focuses on cancer as a health endpoint, not fetal development leading to diminished quality of life.
  4. The potential for exposures to chemicals to result in adverse health effects are determined by several factors. These include: the toxicity of the chemical, the route of exposure (eating, breathing, skin contact), the amount of exposure, and the duration of exposure. BEHS evaluated all of these factors during the public health assessment process. The potential for non-cancer health effects, such as effects on the fetus and reproduction, were evaluated. The potential for cancer was also considered. Worst case, site-specific exposure doses were calculated and used in the public health assessment. Based on this evaluation, BEHS concluded that present exposures are not occurring at levels high enough to result in non-cancer health effects. No conclusions can be drawn about past exposure.

    The public health assessment process uses multiple methods to assess potential impacts in communities. In addition to the evaluation described above, BEHS was able to examine actual data about cancer cases in residents of Oldtown and nearby communities. BEHS and the Cancer Data Registry of Idaho (CDRI) are continuing their cancer investigation. Surveillance data for non-cancer health effects are not currently tracked.

  5. The public health assessment defines health as the absence of diagnosed disease.
  6. The public health assessment does not define health as the absence of diagnosed disease. During the evaluation process, briefly reviewed in response to question #2, BEHS considered toxicological and epidemiological information about all potential health effects from likely exposures to the contaminants of concern. BEHS evaluated the likelihood of any effect on health including more subtle effects that would not be diagnosable as overt disease. In addition, health data about one disease (cancer) was available for the community--BEHS and the CDRI evaluated these data and, as mentioned in response to question #2, are continuing with their investigation.

  7. The conclusion does not accurately represent the health implications of the community's toxic exposure: fails to take current science into account; uses qualifying language to mislead; makes document unacceptable to community.
  8. BEHS utilized the most current, peer reviewed science available from multiple sources to evaluate the chemical releases from Poles, Inc. BEHS also assumed maximum or worst case exposures when assessing potential health impacts. BEHS used qualifying language when it was essential to carefully document the limitations of the public health assessment. BEHS also conducted a public health concerns survey (results can be found in Appendix N of the public health assessment) and addressed these concerns in this public health assessment.

  9. The public health assessment should evaluate the data, including dioxin sampling results and dioxin exposure, in the context of current science.
  10. BEHS did evaluate the data in the context of current, peer reviewed science. Dioxin sampling results were not available at the time of the initial public health assessment development to determine dioxin exposure. However, an evaluation of the limited dioxin and furan sampling, conducted by EPA, was completed and results are incorporated in the final public health assessment. BEHS did not find dioxin and furan levels to be at levels of public health concern.

REVIEWER #B:

  1. The recommendations of the public health assessment are conservative and designed to protect public health, but the conclusions do not support this.
  2. The conclusions of the public health assessment are derived from evaluating the potentialimpact of the site-related chemicals on human health. BEHS did not find that the currentchemical exposure from Poles, Inc. was sufficient to cause people to become ill. However,it is prudent public health practice to recommend that people stay away from or minimizetheir exposure to the contamination onsite.

  3. Most of the recommendations showed concern for the future, as opposed to past orpresent exposures.
  4. BEHS did not find the current site-related exposures to be at levels of public health concern.For past exposures, there is no way to determine what the exposures were as there are noenvironmental sampling data available. BEHS did evaluate health outcome data to determineif cancer rates are elevated in the community. These types of data are used by BEHS andATSDR to determine the overall health status of a community. Moreover, these types ofdata, along with other information, may provide clues as to what effect past exposures mayhave on the community.

  5. Air:
    1. Air contamination of penta is above the comparison value, yet BEHS determines there is no apparent public health hazard.
    2. BEHS uses conservative comparison values as a screen to identify contaminants that need further evaluation. Once those chemicals were identified, BEHS, again using a very conservative or protective method, calculated a site-specific exposure dose. This is the dose that is applicable to the people living, working or attending school nearby the site. The estimated doses were below health guidelines. The most recent exposure from the site, while it was still treating poles, is not expected to result in adverse health effects in the community.

    3. Night operations will improve contamination potential. What about residents that live in Oldtown and breathe at night?
    4. BEHS did not state that night operations will improve the contamination potential. BEHS stated that "Poles, Inc. changed their pole-dipping schedule so the treatment process occurred when Idaho Hill Elementary was not in session."

    5. BEHS minimizes non-cancerous health effects possible (damage to liver, kidneys, blood and nervous system).
    6. See the response to Reviewer A's question #2.

    7. BEHS attributes the majority of the estimated cancer risk for groundwater to heavy metals, not the related penta contamination.
    8. The cumulative cancer risk from using contaminated groundwater was calculated by adding cancer risk contribution from antimony, arsenic, chromium, and penta. BEHS estimates that there may be an increased risk of developing cancer if people are exposed to contaminated groundwater. It is important to note, however, the majority of the estimated cancer risk was not attributable to the site-related penta contamination, rather to the heavy metals. Arsenic is considered a more potent human carcinogen and weighs more heavily in the cancer risk evaluation.

    9. BEHS recommends further action be taken at the site, but the assessment characterizes exposure as indeterminate public health hazard.
    10. It is unclear if this statement refers to the air or groundwater pathway. For the air pathway, BEHS recommended in the initial public health assessment release that further action be taken to address odor issues from existing pole treating operations. This recommendation was given before BEHS learned of the site ceasing its pole treatment process. BEHS categorized the site's air pathway as "no apparent public health hazard" from current exposures. BEHS did not categorize the air pathway as "indeterminate." The groundwater pathway is given an "indeterminate" categorization because the groundwater pathway cannot be fully established. It is not known if private drinking water wells are located in the same aquifer as the EPA monitoring wells onsite from which environmental samples were taken.

  6. Odor:
    1. The odor is less noticeable since facility installed a vapor condensing system.
    2. Based upon comments received on the Community Health Concerns Survey(Appendix M), 30.77% of respondents stated that the odors have changed recently.The site is no longer treating poles and the odor issue will likely be resolved.

  7. Soil:
    1. Penta was detected east of the school playground area near trees and a nearbyresidence, even at low levels; this shows off site evidence of chemicaltransference, with what long-term potential affect?
    2. A completed exposure pathway currently exists for offsite surface soil. Nearbyresidents, particularly gardeners, children playing in the school playground, schoolteachers and staff could be exposed to soils that contain metals, chlorinatedpesticides, SVOCs (including penta) and VOCs. Young children frequently putforeign objects in their mouth and some children may eat dirt. These children maybe exposed to more contamination due to increased ingestion of soil. However,detected contaminants related to the wood treatment process were all lower thanhealth-based comparison values or health guidelines. Without major changes inoperation, elevated future exposure to offsite surface soil is unlikely because thecontaminants did not transfer offsite significantly during the past decades.

    3. Exposure to contaminated soil leaves question about our community's health when gardening and consuming the harvest.
    4. See answer 5.a. above.

  8. Water:
    1. The public health assessment calls the spring that feeds the public water system "surface water." This water comes up from the groundwater, aquifer source.
    2. According to EPA, the information available at the time of the report, the municipal water supply system uses surface water from a spring approximately 1.5 miles south (up stream) of the site as the primary water source. When additional capacity is required, eight municipal wells, located approximately 0.75 miles southwest (up gradient) of the site, may be blended with the surface water. EPA estimated about 30% of the public drinking water is coming from groundwater.

    3. The hydrology of the area has been studied (Welch, Corner & Associates, May/94) and does not report a separation of aquifers, but one large underground body of water. Hence, county zoning is established to protect the aquifer and the springhead for the public water system, which is the same water source domestic wells draw water from.
    4. BEHS utilized the information available to them at the time of the development of the report. In the document, BEHS states, "it is not known if those domestic wells are drawing groundwater from the same aquifer as EPA's monitoring wells or if those private wells are impacted by the groundwater contamination on site. Since none of the private wells are located down gradient of the Oldtown site (EPA 2002), the wells are not likely to be sampled. However, domestic wells were not sampled during the START IA and the exposures cannot be determined." Therefore, BEHS concludes that no matter what aquifer is being utilized by the domestic wells, they are not located down gradient of the site. Public and domestic wells drawing from any aquifer down gradient from the site are not likely to be impacted by the site. However, since there is doubt as to whether or not the private wells draw from the same aquifer as EPA's monitoring wells; BEHS has recommended that a beneficial use survey and additional groundwater monitoring be conducted.

    5. Regarding the public health assessment analysis of biota from the Pend Oreille River, was the Idaho Department of Fish and Game consulted about how much fish is caught? What about the foodchain and the impacts of dioxin settling in fatty tissue? The public health assessment reports no risk because of the unknown risk.
    6. The public health assessment does not report "no risk" from consumption of biota. BEHS states, the "potential exposure pathway exists for individuals that consume biota such as fish or other aquatic organisms caught/collected in the River." Although fish were not sampled, low levels of site-related contaminants found in river sediment. It is unlikely that a significant amount of penta would accumulate in fish. Additionally, penta is less likely to stay in water than in sediment due to its chemical properties.

    7. The categorization of groundwater risk as an "indeterminate public health hazard," based upon the fact that the status of the risk is unknown or untested is a conclusion based upon no facts at all. How can this be logical or scientific?
    8. An "indeterminate public health hazard" is a category that is used for sites in which 'critical' data are insufficient with regard to extent of exposure and/or toxicological properties at estimated exposure levels. This determination represents a professional judgment that critical data are missing and the health assessor has judged the data are insufficient to support a decision. This does not necessarily imply all data are incomplete; but that some additional data are required to support a decision. In this case, the groundwater pathway was considered an "indeterminate public health hazard" because it is not known whether private wells are drawing from the same aquifer as the EPA monitoring wells. A recommendation was made to collect that information.

  9. Dioxins
    1. The public health assessment does not consider the results of EPA's dioxin testing. It was requested that the final assessment include these results.
    2. At the time of the development of the public health assessment, initial and publiccomment release, the dioxin sampling results were not available. However, dioxinsampling data became available for the finalization of the document and have beenincorporated into the document. BEHS did not find the levels of dioxins and furansto be of public health concern either on or offsite.

    3. The report uses scientific rationale to minimize the impact of the potential risk from [dioxin] exposure.
    4. The initial release of the document did not address the impact of dioxin exposure.See response to 7.a. above.

  10. Conclusive Comments
    1. BEHS should reconsider the conclusions drawn in this assessment because the implications of the labels "no apparent public health hazard," and "indeterminate public health hazard."
    2. The important message of the public health assessment is that exposures are below health guidelines and BEHS does not believe that people will get ill as a result of those exposures that occurred preceding the discontinuation of pole treating at the site. The conclusions made in the health assessment are well supported by the public health assessment process used by BEHS and ATSDR. Revisions have been made to the text of the document to address confusion about the conclusion categories.

    3. BEHS should commit to follow up on the recommendations made in the publichealth assessment.
    4. BEHS will follow up with the recommendations over time, as well as continue toremain involved with the community offering health education about the site. Ifnecessary, BEHS will reevaluate the conclusions of this public health assessment ifnew data become available regarding exposures related to the site.

REVIEWER #C:

  1. The health agency's assessment of the situation as expressed in the above paragraph [regarding a categorization of "no apparent public health hazard for on-site surface soil] represents a betrayal of public health in that it falsely assures the public that concerns about exposure to Poles, Inc.'s effluent are groundless, while it is in fact the agency's assurances that are without adequate grounds.
  2. The potential for exposures to chemicals to result in adverse health effects are determined by several factors. These include: the toxicity of the chemical, the route of exposure (eating, breathing, skin contact), the amount of exposure, and the duration of exposure. BEHS evaluated all of these factors during the public health assessment process. The potential for non-cancer health effects, such as effects on the fetus and reproduction, were evaluated. The potential for cancer was also considered. Worst case, site-specific exposure doses were calculated and used in the public health assessment. Based on this evaluation, BEHS concluded that present exposures are not occurring at levels high enough to result in health effects. No conclusions can be drawn about past exposure.

  3. To say that "current exposure to onsite surface soil at Poles, Inc. is categorized…as a 'no apparent public health hazard''' is not the same as saying such exposure is no public health hazard. How a situation is categorized by a government agency or any other entity has absolutely no determinative effect on degree of hazard. Neither does apparency determine degree of hazard, especially as it regards agencies with a vested interest in maintenance of the status quo.
  4. See comments in reply to #1.

  5. Saying that only trespassers may be exposed to contaminated surface soil overlooks obvious significant offsite exposure of non-trespassers via blowing dust.
  6. BEHS, EPA, and IDEQ all found that no significant amounts of site-related contamination has deposited off-site in the soil and dust at the Idaho Hill Elementary School. While there may have been episodic events in the past, the sampling conducted by EPA and IDEQ did not find any long-lived evidence of such releases. Additionally, BEHS recently learned that adjacent to the Poles, Inc. site is a log storage area, the Oldtown Log Yard. On this site, untreated logs are stored prior to sale and shipment offsite. There is also a high volume of traffic in this area that generates large amounts of dust. No conclusions can be drawn about past exposures.

  7. To say that the exposure levels that trespassers may be subjected to "are not expected to cause adverse health effects" is not the same as saying these exposure levels will cause no harm to human health.
  8. Specifics about each individual trespasser such as their genetic susceptibility to chemical effects, their immune system status, the exact amount of time they spend on the site, the exact locations they occupy on site, and the exact amount of contamination they consume and breathe while trespassing, are not known. However, when BEHS calculated exposure dose and risk for the trespasser scenario, the worst-case exposure scenario was applied. The maximum chemical concentrations were utilized along with other conservative assumptions. BEHS is confident that the scenario is assumed for the trespasser is protective. However, since contamination on the site exists, BEHS felt that it is prudent public health practice to recommend that people avoid trespassing on site.

  9. BEHS statements about current exposures not posing a health hazard does not take into consideration past non-standard operating events.
  10. BEHS evaluated current operating conditions and current environmental data. There may have been situations or operating conditions in the past that produced very strong odors and or high levels of chemical concentrations, but BEHS does not have a way to evaluate these past exposures.

  11. BEHS based its assessment on flawed EPA sampling data.
  12. BEHS is presuming this comment is in regards to air monitoring data and sampling at the elementary school during a time when the wind was blowing in another direction. The most common wind direction during the EPA air sampling was west southwesterly following the Pend Oreille River Valley. A meteorological station 1000 feet east of the treatment shed recorded the weather information. Penta is the only compound that was detected in the outdoor air at concentrations above the comparison value. In general, the highest penta concentrations were found next to the wood treatment area (0.01 to 0.63 microgram penta per cubic meter air, ug/M3) with an exception of the first day when the highest concentration was detected at a nearby residence (1.48 ug/M3) downwind from the facility at the time of sampling. Even though EPA's sampling did not capture wind conditions blowing toward Idaho Hill Elementary school, BEHS applied the highest air concentrations found in the environmental sampling data and assumed similar exposures to persons at the school.

  13. BEHS is betraying public trust by stating that long term exposure to some of the most toxic chemicals known is not a public health hazard, especially in light of the recommendations made by BEHS.
  14. BEHS evaluated the site by utilizing a very protective or conservative approach. When determining exposure doses for the site, BEHS looked at a worst-case exposure scenarios. The maximum concentrations from environmental sampling data were used to calculate doses and the exposure doses were compared to health-based exposure guidelines. BEHS did not find that exposure to site-related contamination would likely cause health effects. As a prudent public health measure, however, BEHS recommended that exposure to site-related contamination be avoided.

References:

Bond JA, Leavens TL, Seaton MJ, and Medinsky MA, 1997. Predicting the toxicity of chemical mixtures based on knowledge of individual components. CITT Activities 17: 1-7.

Groton JP, Schoen ED, van Bladeren PJ, Kuper CF, van Zorge JA, and Feron VJ, 1997. Subacute toxicity of a mixture of nine chemicals in rats: detecting interactive effects with a fractionated two-level factorial design. Fundamental and Applied Toxicology 36: 15-29.

Seed J, Brown RP, Olin SS, and Foran JA, 1995. Chemical Mixtures: Current Risk Assessment Methodologies and Future Directions. Regulatory Toxicology and Pharmacology 22: 76-94.



Table of Contents

  
 
USA.gov: The U.S. Government's Official Web PortalDepartment of Health and Human Services
Agency for Toxic Substances and Disease Registry, 4770 Buford Hwy NE, Atlanta, GA 30341
Contact CDC: 800-232-4636 / TTY: 888-232-6348

A-Z Index

  1. A
  2. B
  3. C
  4. D
  5. E
  6. F
  7. G
  8. H
  9. I
  10. J
  11. K
  12. L
  13. M
  14. N
  15. O
  16. P
  17. Q
  18. R
  19. S
  20. T
  21. U
  22. V
  23. W
  24. X
  25. Y
  26. Z
  27. #