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PUBLIC HEALTH ASSESSMENT

ST. MARIES CREOSOTE
ST. MARIES, BENEWAH COUNTY, IDAHO


APPENDIX A: ST. MARIES CREOSOTE SITE LOCATION AND SAMPLING MAPS

Site Vicinity Map
Figure 1. Site Vicinity Map

Historic Upland and In-Water Sampling Locations
Figure 2. Historic Upland and In-Water Sampling Locations


APPENDIX B: EXPLANATION OF EVALUATION PROCESS

Screening Process

In evaluating these data, ATSDR uses comparison values (CVs) to determine which chemicals to examine more closely. CVs are the contaminant concentrations found in a specific media (air, soil, or water) and are used to select contaminants for further evaluation. CVs incorporate assumptions of daily exposure to the chemical and a standard amount of air, water, and soil that someone may inhale or ingest each day.

As health-based thresholds, CVs are set at a concentration below which no known or anticipated adverse human health effects are expected to occur. Different CVs are developed for cancer and non-cancer health effects. Non-cancer levels are based on valid toxicological studies for a chemical, with appropriate safety factors included, and the assumption that small children (22 pounds or less) and adults are exposed every day. Cancer levels are the media concentrations at which there could be a one in a million excess cancer risk for an adult eating contaminated soil or drinking contaminated water every day for 70 years. For chemicals for which both cancer and non-cancer numbers exist, the lower level is used to be protective. Exceeding a CV does not mean that health effects will occur, just that more evaluation is needed.

If a chemical contaminant is selected for further evaluation, the next step is to identify which chemicals and exposure situations could be a health hazard. Child and adult exposure doses are calculated for COCs in site media (e.g., soil, ground water, surface water, sediment, and biota). Exposure doses are the estimated amounts of a contaminant that people come in contact with under specified exposure situations. These exposure doses are compared to appropriate health guidelines for that chemical. Health guideline values are considered safe doses; that is, health effects are unlikely below this level. If the exposure dose for a chemical is greater than the health guideline, then the exposure dose is compared to known health effect levels identified in ATSDR's toxicological profiles and other scientific references. If the chemical of concern is a carcinogen, the cancer risk is also estimated. These comparisons are the basis for stating whether the exposure is a health hazard.

CVs used in this document are listed below:

Environmental Media Evaluation Guides (EMEGs) are estimated contaminant concentrations in a media where non-carcinogenic health effects are unlikely. The EMEG is derived from the Agency for Toxic Substances and Disease Registry's (ATSDR) minimal risk level (MRL).

Cancer Risk Evaluation Guides (CREGs) are estimated contaminant concentrations that would be expected to cause no more than one additional excess cancer in one million persons exposed over a lifetime. CREGs are calculated from the Environmental Protection Agency's (EPA) cancer slope factors (CSFs).

Lifetime Health Advisories (LTHAs) are derived by EPA from a drinking water equivalent level below which no adverse noncancer health effects are expected to occur over a 70-year lifetime.

Maximum Contaminant Levels (MCLs) are enforceable drinking water regulations established by EPA under the Safe Drinking Water Act that are protective of human health to the extent feasible both technologically and economically. The MCL assumes exposure over a 70-year lifetime and ingestion of 2 liters of water per day.

Reference Media Evaluation Guides (RMEGs) are estimated contaminant concentrations in a media where non-carcinogenic health effects are unlikely. The RMEG is derived from the Environmental Protection Agency's (EPA's) reference dose (RfD).

Preliminary Remediation Goals (PRGs) are the estimated contaminant concentrations in a media where carcinogenic or non-carcinogenic health effects are unlikely. The PRGs used in this public health assessment were derived using provisional reference doses or cancer slope factors calculated by EPA's Region 9 toxicologists.

Risk-Based Concentrations (RBCs) are the estimated contaminant concentrations in which no chance exists for carcinogenic or noncarcinogenic health effects. The RBCs used in this public health assessment were derived using provisional reference doses or cancer slope factors calculated by toxicologists of EPA's Region 3.

EPA Action Levels (ALs) are the estimated contaminant concentrations in water of which additional evaluation is needed to determine whether action is required to eliminate or reduce exposure. Action levels can be based on mathematical models.

Determination of Exposure Pathways

ATSDR identifies human exposure pathways by examining environmental and human components that might lead to contact with contaminants of concern. A pathway analysis considers five principal elements: a source of contamination, transport through an environmental medium, a point of exposure, a route of human exposure, and an exposed population. Completed exposure pathways are those for which the five elements are evident, and indicate that exposure to a contaminant has occurred in the past, is currently occurring, or will occur in the future. Potential exposure pathways are those for which exposure seems possible, but one or more of the elements is not clearly defined. Potential pathways indicate that exposure to a contaminant could have occurred in the past, could be occurring now, or could occur in the future. It should be noted that the identification of an exposure pathway does not imply that health effects will occur. Exposures may, or may not be, substantive. Therefore, even if exposure has occurred, is occurring currently, or is likely to occur in the future, human health effects may not result.

ATSDR reviews site history, information on site activities, and the available sampling data. Based on this review, ATSDR identifies numerous exposure pathways that warranted consideration. Additional information regarding the exposure pathways identified for the St. Maries Creosote site is provided in Appendix C of this public health assessment. If people are unlikely to be exposed to contaminants in a given pathway, then that pathway will not be evaluated further for human health risks.

Evaluation of Public Health Implications

The next step is to take those contaminants that are above the CVs and further identify which chemicals and exposure situations are likely to be a health hazard. Child and adult exposure doses are calculated for the site-specific exposure scenario, using our assumptions of who goes on the site and how often they contact the site contaminants. The exposure dose is the amount of a contaminant that gets into a person's body.


APPENDIX C: EXPOSURE PATHWAYS FOR ST. MARIES CREOSOTE SITE

Table C-1.

Exposure Pathways for St. Maries Creosote Site
PATHWAY NAME ENVIRONMENTAL MEDIA & TRANSPORT MECHANISMS POINT OF EXPOSURE ROUTE OF EXPOSURE EXPOSURE POPULATION TIME NOTES STATUS
Soil Spillage onto soil; erosion of waste to surface soils; deposition of fugitive dust Site soil Incidental ingestion, inhalation, dermal exposure Nearby residents Past, present, future Population may include children 10 years and older. Potential
Surface water Surface water runoff over contaminated soil to river; dissolution of contaminants from sediment Water in St. Joe River Incidental ingestion, inhalation, dermal exposure Fishers and shellfish collectors, recreational users of bay (children and adults) Past, present, future Population may include children 10 years and older. Potential
Sediments Spillage; deposition from surface water runoff into river Along bank of St. Joe River Incidental ingestion, dermal exposure Fishers and shellfish collectors, recreational users of bay (children and adults) Past, present, future Population may include children 10 years and older. Potential
Fish Bioaccumulation of contaminants from surface water and sediments into fish Meal prepared using fish from St. Joe River Ingestion Fishers and their families; purchasers of local seafood Past, present, future Population may include young children Incomplete
Ground-water Infiltration to ground water Ground water wells supplying drinking water taps Ingestion, inhalation, dermal exposure Residents near the site Past, present, future Population may include young children Incomplete
Air Volatilization of contaminants; fugitive dust On or near site soil Inhalation, dermal exposure Residents near the site Past, present, future Population may include young children Incomplete


APPENDIX D: ATSDR INTERIM PUBLIC HEALTH HAZARD CATEGORIES

Table D-1.

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 substance 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 E: ATSDR GLOSSARY OF ENVIRONMENTAL HEALTH TERMS

The Agency for Toxic Substances and Disease Registry (ATSDR) is a federal public health agency with headquarters in Atlanta, Georgia, and 10 regional offices in the United States. ATSDR's mission is to serve the public by using the best science, taking responsive public health actions, and providing trusted health information to prevent harmful exposures and diseases related to toxic substances. ATSDR is not a regulatory agency, unlike the U.S. Environmental Protection Agency (EPA), which is the federal agency that develops and enforces environmental laws to protect the environment and human health. This glossary defines words used by ATSDR in communications with the public. It is not a complete dictionary of environmental health terms. If you have questions or comments, call ATSDR's toll-free telephone number, 1-888-42-ATSDR (1-888-422-8737).

General Terms

Absorption:
The process of taking in. For a person or an animal, absorption is the process of a substance getting into the body through the eyes, skin, stomach, intestines, or lungs.


Acute:
Occurring over a short time [compare with chronic].


Acute exposure :
Contact with a substance that occurs once or for only a short time (up to 14 days) [compare withintermediate duration exposure and chronic exposure].


Additive effect :
A biologic response to exposure to multiple substances that equals the sum of responses of all theindividual substances added together [compare with antagonistic effect and synergistic effect].


Adverse health effect :
A change in body function or cell structure that might lead to disease or health problems


Aerobic :
Requiring oxygen [compare with anaerobic].


Ambient :
Surrounding (for example, ambient air).


Anaerobic :
Requiring the absence of oxygen [compare with aerobic].


Analyte :
A substance measured in the laboratory. A chemical for which a sample (such as water, air, orblood) is tested in a laboratory. For example, if the analyte is mercury, the laboratory test willdetermine the amount of mercury in the sample.


Analytic epidemiologic study :
A study that evaluates the association between exposure to hazardous substances and disease bytesting scientific hypotheses.


Antagonistic effect :
A biologic response to exposure to multiple substances that is less than would be expected if theknown effects of the individual substances were added together [compare with additive effect andsynergistic effect].


Background level :
An average or expected amount of a substance or radioactive material in a specific environment, ortypical amounts of substances that occur naturally in an environment.


Biodegradation :
Decomposition or breakdown of a substance through the action of microorganisms (such as bacteriaor fungi) or other natural physical processes (such as sunlight).


Biologic indicators of exposure study :
A study that uses (a) biomedical testing or (b) the measurement of a substance [an analyte], itsmetabolite, or another marker of exposure in human body fluids or tissues to confirm humanexposure to a hazardous substance [also see exposure investigation].


Biologic monitoring :
Measuring hazardous substances in biologic materials (such as blood, hair, urine, or breath) todetermine whether exposure has occurred. A blood test for lead is an example of biologicmonitoring.


Biologic uptake :
The transfer of substances from the environment to plants, animals, and humans.


Biomedical testing :
Testing of persons to find out whether a change in a body function might have occurred because ofexposure to a hazardous substance.


Biota :
Plants and animals in an environment. Some of these plants and animals might be sources of food,clothing, or medicines for people.


Body burden :
The total amount of a substance in the body. Some substances build up in the body because they arestored in fat or bone or because they leave the body very slowly.


CAP:
[see Community Assistance Panel.]


Cancer :
Any one of a group of diseases that occur when cells in the body become abnormal and grow ormultiply out of control.


Cancer risk :
A theoretical risk for getting cancer if exposed to a substance every day for 70 years (a lifetimeexposure). The true risk might be lower.


Carcinogen :
A substance that causes cancer.


Case study :
A medical or epidemiologic evaluation of one person or a small group of people to gatherinformation about specific health conditions and past exposures.


Case-control study :
A study that compares exposures of people who have a disease or condition (cases) with people whodo not have the disease or condition (controls). Exposures that are more common among the casesmay be considered as possible risk factors for the disease.


CAS registry number :
A unique number assigned to a substance or mixture by the American Chemical Society AbstractsService.


Central nervous system :
The part of the nervous system that consists of the brain and the spinal cord.


CERCLA:
[see Comprehensive Environmental Response, Compensation, and Liability Act of 1980]


Chronic :
Occurring over a long time [compare with acute].


Chronic exposure :
Contact with a substance that occurs over a long time (more than 1 year) [compare with acuteexposure and intermediate duration exposure]


Cluster investigation:
A review of an unusual number, real or perceived, of health events (for example, reports of cancer)grouped together in time and location. Cluster investigations are designed to confirm case reports;determine whether they represent an unusual disease occurrence; and, if possible, explore possiblecauses and contributing environmental factors.


Community Assistance Panel (CAP) :
A group of people from a community and from health and environmental agencies who work withATSDR to resolve issues and problems related to hazardous substances in the community. CAPmembers work with ATSDR to gather and review community health concerns, provide informationon how people might have been or might now be exposed to hazardous substances, and informATSDR on ways to involve the community in its activities.


Comparison value (CV) :
Calculated concentration of a substance in air, water, food, or soil that is unlikely to cause harmful(adverse) health effects in exposed people. The CV is used as a screening level during the publichealth assessment process. Substances found in amounts greater than their CVs might be selectedfor further evaluation in the public health assessment process.


Completed exposure pathway:
[see exposure pathway].


Comprehensive Environmental Response, Compensation, and Liability Act of 1980(CERCLA) :
CERCLA, also known as Superfund, is the federal law that concerns the removal or cleanup ofhazardous substances in the environment and at hazardous waste sites. ATSDR, which was createdby CERCLA, is responsible for assessing health issues and supporting public health activities relatedto hazardous waste sites or other environmental releases of hazardous substances. This law was lateramended by the Superfund Amendments and Reauthorization Act (SARA).


Concentration :
The amount of a substance present in a certain amount of soil, water, air, food, blood, hair, urine,breath, or any other media.


Contaminant :
A substance that is either present in an environment where it does not belong or is present at levelsthat might cause harmful (adverse) health effects.


Delayed health effect :
A disease or an injury that happens as a result of exposures that might have occurred in the past.


Dermal :
Referring to the skin. For example, dermal absorption means passing through the skin.


Dermal contact :
Contact with (touching) the skin [see route of exposure].


Descriptive epidemiology :
The study of the amount and distribution of a disease in a specified population by person, place, andtime.


Detection limit :
The lowest concentration of a chemical that can reliably be distinguished from a zero concentration.


Disease prevention :
Measures used to prevent a disease or reduce its severity.


Disease registry :
A system of ongoing registration of all cases of a particular disease or health condition in a definedpopulation.


DOD :
United States Department of Defense.


DOE :
United States Department of Energy.


Dose (for chemicals that are not radioactive):
The amount of a substance to which a person is exposed over some time period. Dose is ameasurement of exposure. Dose is often expressed as milligram (amount) per kilogram (a measureof body weight) per day (a measure of time) when people eat or drink contaminated water, food, orsoil. In general, the greater the dose, the greater the likelihood of an effect. An "exposure dose" ishow much of a substance is encountered in the environment. An "absorbed dose" is the amount ofa substance that actually got into the body through the eyes, skin, stomach, intestines, or lungs.


Dose (for radioactive chemicals):
The radiation dose is the amount of energy from radiation that is actually absorbed by the body. Thisis not the same as measurements of the amount of radiation in the environment.


Dose-response relationship :
The relationship between the amount of exposure [dose] to a substance and the resulting changesin body function or health (response).


Environmental media :
Soil, water, air, biota (plants and animals), or any other parts of the environment that can containcontaminants.


Environmental media and transport mechanism :
Environmental media include water, air, soil, and biota (plants and animals). Transport mechanismsmove contaminants from the source to points where human exposure can occur. The environmentalmedia and transport mechanism is the second part of an exposure pathway.


EPA :
United States Environmental Protection Agency.


Epidemiologic surveillance:
[see Public health surveillance].


Epidemiology :
The study of the distribution and determinants of disease or health status in a population; the studyof the occurrence and causes of health effects in humans.


Exposure :
Contact with a substance by swallowing, breathing, or touching the skin or eyes. Exposure may beshort-term [acute exposure], of intermediate duration, or long-term [chronic exposure].


Exposure assessment :
The process of finding out how people come into contact with a hazardous substance, how often andfor how long they are in contact with the substance, and how much of the substance they are incontact with.


Exposure-dose reconstruction :
A method of estimating the amount of people's past exposure to hazardous substances. Computerand approximation methods are used when past information is limited, not available, or missing.


Exposure investigation :
The collection and analysis of site-specific information and biologic tests (when appropriate) todetermine whether people have been exposed to hazardous substances.


Exposure pathway :
The route a substance takes from its source (where it began) to its end point (where it ends), and howpeople can come into contact with (or get exposed to) it. An exposure pathway has five parts: asource of contamination (such as an abandoned business); an environmental media and transportmechanism (such as movement through ground water); a point of exposure (such as a private well);a route of exposure (eating, drinking, breathing, or touching), and a receptor population (peoplepotentially or actually exposed). When all five parts are present, the exposure pathway is termed acompleted exposure pathway.


Exposure registry :
A system of ongoing follow up of people who have had documented environmental exposures.


Feasibility study :
A study by EPA to determine the best way to clean up environmental contamination. A number offactors are considered, including health risk, costs, and what methods will work well.


Geographic information system (GIS) :
A mapping system that uses computers to collect, store, manipulate, analyze, and display data. Forexample, GIS can show the concentration of a contaminant within a community in relation to pointsof reference such as streets and homes.


Grand rounds :
Training sessions for physicians and other health care providers about health topics.


Ground water :
Water beneath the earth's surface in the spaces between soil particles and between rock surfaces[compare with surface water].


Half-life (t) :
The time it takes for half the original amount of a substance to disappear. In the environment, thehalf-life is the time it takes for half the original amount of a substance to disappear when it ischanged to another chemical by bacteria, fungi, sunlight, or other chemical processes. In the humanbody, the half-life is the time it takes for half the original amount of the substance to disappear,either by being changed to another substance or by leaving the body. In the case of radioactivematerial, the half life is the amount of time necessary for one half the initial number of radioactiveatoms to change or transform into another atom (that is normally not radioactive). After two halflives, 25% of the original number of radioactive atoms remain.


Hazard :
A source of potential harm from past, current, or future exposures.


Hazardous Substance Release and Health Effects Database (HazDat) :
The scientific and administrative database system developed by ATSDR to manage data collection,retrieval, and analysis of site-specific information on hazardous substances, community healthconcerns, and public health activities.


Hazardous waste :
Potentially harmful substances that have been released or discarded into the environment.


Health consultation :
A review of available information or collection of new data to respond to a specific health questionor request for information about a potential environmental hazard. Health consultations are focusedon a specific exposure issue. Health consultations are therefore more limited than a public healthassessment, which reviews the exposure potential of each pathway and chemical [compare withpublic health assessment].


Health education :
Programs designed with a community to help it know about health risks and how to reduce theserisks.


Health investigation :
The collection and evaluation of information about the health of community residents. Thisinformation is used to describe or count the occurrence of a disease, symptom, or clinical measureand to evaluate the possible association between the occurrence and exposure to hazardoussubstances.


Health promotion :
The process of enabling people to increase control over, and to improve, their health.


Health statistics review :
The analysis of existing health information (i.e., from death certificates, birth defects registries, andcancer registries) to determine if there is excess disease in a specific population, geographic area,and time period. A health statistics review is a descriptive epidemiologic study.


Indeterminate public health hazard :
The category used in ATSDR's public health assessment documents when a professional judgmentabout the level of health hazard cannot be made because information critical to such a decision islacking.


Incidence :
The number of new cases of disease in a defined population over a specific time period [contrastwith prevalence].


Ingestion :
The act of swallowing something through eating, drinking, or mouthing objects. A hazardoussubstance can enter the body this way [see route of exposure].


Inhalation :
The act of breathing. A hazardous substance can enter the body this way [see route of exposure].


Intermediate duration exposure :
Contact with a substance that occurs for more than 14 days and less than a year [compare with acuteexposure and chronic exposure].


In vitro :
In an artificial environment outside a living organism or body. For example, some toxicity testingis done on cell cultures or slices of tissue grown in the laboratory, rather than on a living animal[compare with in vivo].


In vivo :
Within a living organism or body. For example, some toxicity testing is done on whole animals, suchas rats or mice [compare with in vitro].


Lowest-observed-adverse-effect level (LOAEL) :
The lowest tested dose of a substance that has been reported to cause harmful (adverse) healtheffects in people or animals.


Medical monitoring :
A set of medical tests and physical exams specifically designed to evaluate whether an individual'sexposure could negatively affect that person's health.


Metabolism :
The conversion or breakdown of a substance from one form to another by a living organism.


Metabolite :
Any product of metabolism.


mg/kg :
Milligram per kilogram.


mg/cm2 :
Milligram per square centimeter (of a surface).


mg/m3 :
Milligram per cubic meter; a measure of the concentration of a chemical in a known volume (a cubicmeter) of air, soil, or water.


Migration :
Moving from one location to another.


Minimal risk level (MRL) :
An ATSDR estimate of daily human exposure to a hazardous substance at or below which thatsubstance is unlikely to pose a measurable risk of harmful (adverse), noncancerous effects. MRLsare calculated for a route of exposure (inhalation or oral) over a specified time period (acute,intermediate, or chronic). MRLs should not be used as predictors of harmful (adverse) health effects[see reference dose].


Morbidity :
State of being ill or diseased. Morbidity is the occurrence of a disease or condition that alters healthand quality of life.


Mortality :
Death. Usually the cause (a specific disease, a condition, or an injury) is stated.


Mutagen :
A substance that causes mutations (genetic damage).


Mutation :
A change (damage) to the DNA, genes, or chromosomes of living organisms.


National Priorities List for Uncontrolled Hazardous Waste Sites (National Priorities List orNPL) :
EPA's list of the most serious uncontrolled or abandoned hazardous waste sites in the United States.The NPL is updated on a regular basis.


National Toxicology Program (NTP):
Part of the Department of Health and Human Services. NTP develops and carries out tests to predictwhether a chemical will cause harm to humans.


No apparent public health hazard :
A category used in ATSDR's public health assessments for sites where human exposure tocontaminated media might be occurring, might have occurred in the past, or might occur in thefuture, but where the exposure is not expected to cause any harmful health effects.


No-observed-adverse-effect level (NOAEL) :
The highest tested dose of a substance that has been reported to have no harmful (adverse) healtheffects on people or animals.


No public health hazard :
A category used in ATSDR's public health assessment documents for sites where people have neverand will never come into contact with harmful amounts of site-related substances.


NPL:
[see National Priorities List for Uncontrolled Hazardous Waste Sites]


Physiologically based pharmacokinetic model (PBPK model) :
A computer model that describes what happens to a chemical in the body. This model describes howthe chemical gets into the body, where it goes in the body, how it is changed by the body, and howit leaves the body.


Pica :
A craving to eat nonfood items, such as dirt, paint chips, and clay. Some children exhibit pica-related behavior.


Plume :
A volume of a substance that moves from its source to places farther away from the source. Plumescan be described by the volume of air or water they occupy and the direction they move. Forexample, a plume can be a column of smoke from a chimney or a substance moving with groundwater.


Point of exposure :
The place where someone can come into contact with a substance present in the environment [seeexposure pathway].


Population :
A group or number of people living within a specified area or sharing similar characteristics (suchas occupation or age).


Potentially responsible party (PRP) :
A company, government, or person legally responsible for cleaning up the pollution at a hazardouswaste site under Superfund. There may be more than one PRP for a particular site.


ppb :
Parts per billion.


ppm :
Parts per million.


Prevalence :
The number of existing disease cases in a defined population during a specific time period [contrastwith incidence].


Prevalence survey :
The measure of the current level of disease(s) or symptoms and exposures through a questionnairethat collects self-reported information from a defined population.


Prevention :
Actions that reduce exposure or other risks, keep people from getting sick, or keep disease fromgetting worse.


Public availability session :
An informal, drop-by meeting at which community members can meet one-on-one with ATSDRstaff members to discuss health and site-related concerns.


Public comment period :
An opportunity for the public to comment on agency findings or proposed activities contained indraft reports or documents. The public comment period is a limited time period during whichcomments will be accepted.


Public health action :
A list of steps to protect public health.


Public health advisory :
A statement made by ATSDR to EPA or a state regulatory agency that a release of hazardoussubstances poses an immediate threat to human health. The advisory includes recommendedmeasures to reduce exposure and reduce the threat to human health.


Public health assessment (PHA) :
An ATSDR document that examines hazardous substances, health outcomes, and communityconcerns at a hazardous waste site to determine whether people could be harmed from coming intocontact with those substances. The PHA also lists actions that need to be taken to protect publichealth [compare with health consultation].


Public health hazard :
A category used in ATSDR's public health assessments for sites that pose a public health hazardbecause of long-term exposures (greater than 1 year) to sufficiently high levels of hazardoussubstances or radionuclides that could result in harmful health effects.


Public health hazard categories :
Public health hazard categories are statements about whether people could be harmed by conditionspresent at the site in the past, present, or future. One or more hazard categories might be appropriatefor each site. The five public health hazard categories are no public health hazard, no apparent publichealth hazard, indeterminate public health hazard, public health hazard, and urgent public healthhazard.


Public health statement:
The first chapter of an ATSDR toxicological profile. The public health statement is a summarywritten in words that are easy to understand. The public health statement explains how people mightbe exposed to a specific substance and describes the known health effects of that substance.


Public health surveillance:
The ongoing, systematic collection, analysis, and interpretation of health data. This activity alsoinvolves timely dissemination of the data and use for public health programs.


Public meeting :
A public forum with community members for communication about a site.


Radioisotope :
An unstable or radioactive isotope (form) of an element that can change into another element bygiving off radiation.


Radionuclide :
Any radioactive isotope (form) of any element.


RCRA:
[see Resource Conservation and Recovery Act (1976, 1984)]


Receptor population :
People who could come into contact with hazardous substances [see exposure pathway].


Reference dose (RfD) :
An EPA estimate, with uncertainty or safety factors built in, of the daily lifetime dose of a substancethat is unlikely to cause harm in humans.


Registry :
A systematic collection of information on persons exposed to a specific substance or having specificdiseases [see exposure registry and disease registry].


Remedial investigation :
The CERCLA process of determining the type and extent of hazardous material contamination ata site.


Resource Conservation and Recovery Act (1976, 1984) (RCRA):
This Act regulates management and disposal of hazardous wastes currently generated, treated,stored, disposed of, or distributed.


RFA :
RCRA Facility Assessment. An assessment required by RCRA to identify potential and actualreleases of hazardous chemicals.


RfD:
[see reference dose]


Risk :
The probability that something will cause injury or harm.


Risk reduction :
Actions that can decrease the likelihood that individuals, groups, or communities will experiencedisease or other health conditions.


Risk communication :
The exchange of information to increase understanding of health risks.


Route of exposure :
The way people come into contact with a hazardous substance. Three routes of exposure arebreathing [inhalation], eating or drinking [ingestion], or contact with the skin [dermal contact].


Safety factor:
[see uncertainty factor]


SARA:
[see Superfund Amendments and Reauthorization Act]


Sample :
A portion or piece of a whole. A selected subset of a population or subset of whatever is beingstudied. For example, in a study of people the sample is a number of people chosen from a largerpopulation [see population]. An environmental sample (for example, a small amount of soil or water)might be collected to measure contamination in the environment at a specific location.


Sample size :
The number of units chosen from a population or an environment.


Solvent :
A liquid capable of dissolving or dispersing another substance (for example, acetone or mineralspirits).


Source of contamination :
The place where a hazardous substance comes from, such as a landfill, waste pond, incinerator,storage tank, or drum. A source of contamination is the first part of an exposure pathway.


Special populations :
People who might be more sensitive or susceptible to exposure to hazardous substances because offactors such as age, occupation, sex, or behaviors (for example, cigarette smoking). Children,pregnant women, and older people are often considered special populations.


Stakeholder :
A person, group, or community who has an interest in activities at a hazardous waste site.


Statistics :
A branch of mathematics that deals with collecting, reviewing, summarizing, and interpreting dataor information. Statistics are used to determine whether differences between study groups aremeaningful.


Substance :
A chemical.


Substance-specific applied research :
A program of research designed to fill important data needs for specific hazardous substancesidentified in ATSDR's toxicological profiles. Filling these data needs would allow more accurateassessment of human risks from specific substances contaminating the environment. This researchmight include human studies or laboratory experiments to determine health effects resulting fromexposure to a given hazardous substance.


Superfund:
[see Comprehensive Environmental Response, Compensation, and Liability Act of 1980(CERCLA) and Superfund Amendments and Reauthorization Act (SARA)


Superfund Amendments and Reauthorization Act (SARA) :
In 1986, SARA amended the Comprehensive Environmental Response, Compensation, and LiabilityAct of 1980 (CERCLA) and expanded the health-related responsibilities of ATSDR. CERCLA andSARA direct ATSDR to look into the health effects from substance exposures at hazardous wastesites and to perform activities including health education, health studies, surveillance, healthconsultations, and toxicological profiles.


Surface water :
Water on the surface of the earth, such as in lakes, rivers, streams, ponds, and springs [compare withground water].


Surveillance:
[see public health surveillance]


Survey :
A systematic collection of information or data. A survey can be conducted to collect informationfrom a group of people or from the environment. Surveys of a group of people can be conducted bytelephone, by mail, or in person. Some surveys are done by interviewing a group of people [seeprevalence survey].


Synergistic effect :
A biologic response to multiple substances where one substance worsens the effect of anothersubstance. The combined effect of the substances acting together is greater than the sum of theeffects of the substances acting by themselves [see additive effect and antagonistic effect].


Teratogen :
A substance that causes defects in development between conception and birth. A teratogen is asubstance that causes a structural or functional birth defect.


Toxic agent :
Chemical or physical (for example, radiation, heat, cold, microwaves) agents that, under certaincircumstances of exposure, can cause harmful effects to living organisms.


Toxicological profile :
An ATSDR document that examines, summarizes, and interprets information about a hazardoussubstance to determine harmful levels of exposure and associated health effects. A toxicologicalprofile also identifies significant gaps in knowledge on the substance and describes areas wherefurther research is needed.


Toxicology :
The study of the harmful effects of substances on humans or animals.


Tumor :
An abnormal mass of tissue that results from excessive cell division that is uncontrolled andprogressive. Tumors perform no useful body function. Tumors can be either benign (not cancer) ormalignant (cancer).


Uncertainty factor :
Mathematical adjustments for reasons of safety when knowledge is incomplete. For example, factorsused in the calculation of doses that are not harmful (adverse) to people. These factors are appliedto the lowest-observed-adverse-effect-level (LOAEL) or the no-observed-adverse-effect-level(NOAEL) to derive a minimal risk level (MRL). Uncertainty factors are used to account forvariations in people's sensitivity, for differences between animals and humans, and for differencesbetween a LOAEL and a NOAEL. Scientists use uncertainty factors when they have some, but notall, the information from animal or human studies to decide whether an exposure will cause harmto people [also sometimes called a safety factor].


Urgent public health hazard :
A category used in ATSDR's public health assessments for sites where short-term exposures (lessthan 1 year) to hazardous substances or conditions could result in harmful health effects that requirerapid intervention.


Volatile organic compounds (VOCs) :
Organic compounds that evaporate readily into the air. VOCs include substances such as benzene,toluene, methylene chloride, and methyl chloroform.

Other glossaries and dictionaries:
Environmental Protection Agency (http://www.epa.gov/OCEPAterms/ Exiting ATSDR Website)

National Center for Environmental Health (CDC) (http://www.cdc.gov/nceh/dls/report/glossary.htm Exiting ATSDR Website)

National Library of Medicine (NIH) (http://www.nlm.nih.gov/medlineplus/mplusdictionary.html Exiting ATSDR Website)

For more information on the work of ATSDR, please contact:

Office of Policy and External Affairs
Agency for Toxic Substances and Disease Registry
1600 Clifton Road, N.E. (MS E-60)
Atlanta, GA 30333
Telephone: (404) 498-0080


APPENDIX F: ST. MARIES CREOSOTE SITE PUBLIC HEALTH ASSESSMENT PUBLIC RELEASE REVIEW COMMENTS ADDRESSED
AUGUST 2003

The following comments were provided by members of the general public. Responses to reviewer comments immediately follow the comment. All editorial comments were incorporated, as necessary, and are not included in the following narrative.

  1. We wish to be on record as protesting the exceptional scrutiny and attention given to the Carney Pole potential Superfund that covers approximately 0.7 acre within the Exterior Boundary of the Former Coeur d'Alene Indian Reservation. The contamination issues contained within this small, finite area are infinitesimal when compared to the 72-mile long, 150-foot wide Union Pacific Railroad Superfund that covers 2 square miles and runs through the guts of the Coeur d'Alene Basin Superfund. We attended the CERCLA/SARA mandated face-to face public interviews in St. Maries and had our comments recorded by EPA's Debra Sherbina and Hanh Gold. In addition, we were mailed a prompt and thorough summary of our specific comments, as well as those expressed by other citizens. These essential and mandated steps within the CERCLA process were circumvented within the Union Pacific Superfund. We were denied our EPA-identified stakeholder rights to be interviewed. In addition, our long, detailed issues and concerns (sent to Carol Browner, later to Christie Todd-Whitman) were circumvented or answered in a cursory manner. Our requests for information that should have been public were met with referrals to FOIA. In fact, a "special" communications liaison (an employee of the PRP, Union Pacific) was appointed to receive our queries and get back to us a month later (after conference calls with the Governments), thus violating EPA's stated Principles of Customer Service that touted answers within 10 working days. By the time we received the vague, double-speak answers, the problem was no longer relevant. In short, our rights to involvement in a precedent CERCLA Response that affects directly our lives and our land, were abused.

    We note that BEHS recommends (for Carney Pole) that "The public should be prevented from swimming in the river close to the site or entering the site," that "no swimming, no trespassing signs should be posted at the site boundary in obvious locations as well as on the river." The rationale states that "this precautionary measure is needed because the prolonged contact with the site contaminants may result in adverse health effects." Yet at the still incomplete, uncertified Union Pacific Superfund, the 71-mile trail, the institutional controls and signage are either insubstantial or totally lacking. Below Harrison, there are no warning signs, yet there were no removals of railroad contamination (lead, arsenic, cadmium, zinc, creosote) in the lake and other areas. The few "Stay on Trail" signs do little to deter kids and grownups from leaving the asphalt and fishing, swimming, playing along the lake shore. And since there was no separate testing for arsenic (which migrates differently than lead), and our private testing revealed levels as high as 310 ppm in these same areas, we are appalled at the double standard compared to Carney Pole. Further, BEHS recommends that "Access to the site should be restricted," yet this precedent rail trail as Superfund Response actually invites the public to a contaminated area they would otherwise have avoided. For the past two years during the construction phase for this Superfund Response, nothing was done to keep trespassers and vandals away from the active (marked hazardous) site. We note that ATSDR did conduct Interim Public Health Hazard Evaluations for this small area, while none were done for the Union Pacific Response. No health studies were done for the 932 individual (not counting family members, which would increase the number) landowners listed along the abandoned right-of-way. No NEPA-mandated EIS was done, no in-depth Ecological Risk Assessments for the UPRR mess. While we see that a Remedial Investigation/Feasibility Study (RI/FS) will be conducted by EPA for Carney Pole, we note that UPRR was essentially excluded from the Basin-wide RI/FS. The RI/FS section for UPRR stated that this had already been done in the cursory planning documents, the EE/CA (Engineering Evaluation/Cost Analysis), substituted in place of the NEPA EIS. Yet the EE/CA had stated that the ecological risks would be covered in the RI/FS! Double-speak, fatal flaw information that was ignored by EPA. In closing, our comments are intended to register disgust at the over-kill EPA and agency reaction to Carney Pole while the massive and toxic Union Pacific mess was glossed over and accountability to landowners and the public has been largely ignored and circumvented. We find this alarming. We note, also, that the Coeur d'Alene Tribe voiced concerns that they had not been included in the Carney processes, and this was in all local papers. Yet the EPA-identified stakeholders in the Union Pacific Superfund were kept in the dark, out of the media, and remain to this day "invisible." Why the incredible double standards? We have never been given our rightful answers.

BEHS, working under a cooperative agreement with ATSDR, is bound by Congressional mandate to complete a public health assessment for hazardous waste sites in Idaho which have been listed on or proposed to the NPL. This document satisfies that mandate. Comments included which are not relevant to the St. Maries Creosote Site have been forwarded to EPA.

  1. I am writing in response to your request for public comment on the St.Maries, Idaho creosote site..... By IDOH studies, it has been concluded that exposure to the contaminants(?) poses very little chance of adverse health effects for the general public. Why, the would kick a sleeping dog? In my opinion, restoring the site to as close as possible to a before clean up fiasco condition is the best plan. This would probably amount to planting some native vegetation and letting this native vegetation create a natural barrier that would not attract use by the public.

BEHS, working under a cooperative agreement with ATSDR, is bound by Congressional mandate to complete a public health assessment for hazardous waste sites in Idaho which have been listed on or proposed to the NPL. This document satisfies that mandate. Comments included which address site remediation suggestions have been forwarded to EPA.

  1. I certainly agree with the conclusion "that exposure to site contaminants is unlikely to result in any adverse health effects for the general public". One of my long time friends here in St.Maries who is 84 years old and in fairly good health worked at the site for several years. While no one wants to contaminate the St.Joe River with creosote I strongly feel this whole thing has been terribly over done by the EPA and I attribute the cause of EPA action to be motivated by the Coeur d'Alene Tribe. The creosote site and surrounding area has been an industrial site for a great number of years. The businesses that operated at this location paid taxes to our State and provided many good jobs for members of our community as well as employing many jobs for persons living elsewhere in Idaho. When the creosote was being used for treating cedar poles harvested from both State and private lands for market it was done legally and in compliance with laws and regulations with no intent to harm anyone. Now the site appears like a waste land. The employment is gone and our local unemployment rate is consistently one of the highest in the State. The firm which last operated the pole yard has shut it down and run for cover due to the financial burden placed upon it by the EPA. The City of St.Maries has suffered a great financial hardship due to EPA mandates related to the creosote site. Apparently the amount of creosote seeping into the St.Joe River is so insignificant that there is no measurable PPM in the water as none have been reported. It is troubling that our U.S. Congress has empowered the EPA to destroy this business, worsen our local economy and that of the State and place this financial hardship on the City of St.Maries. It is also troubling to me that during the time since this creosote was discovered and dutifully reported by the City of St.Maries in 1999 that the Idaho Division of Health has not early on tested the water from the domestic wells near the site to determine if there are any health risks to the water users. Thank you for your report on this and for accepting these comments. I will be very pleased if you will forward a copy of this correspondence to our State Department of Environmental Quality and also to the EPA.

These comments were largely centered on the political and economic ramifications of EPA actions at the site. These comments will be forwarded to EPA and DEQ.

Table 2 contains the reported ranges of contaminants detected in surface water. Creosote is a mixture of many different chemicals (ingredients). Some of these ingredients were detected above drinking water comparison values.

As stated in section 3.3.4 of this document, "The concentrations of contaminants diminish as the distance from the source areas increases, and seem to be confined within an approximately 90-foot radius of the creosote-treating facility." Additionally, wells used for drinking water are either up-gradient, or on the other side of the St. Joe River. Consequently, site contaminants are not likely to migrate 0.5 miles up or cross gradient and contaminate drinking water wells.

  1. It has been only 3 or 4 years since the supposed problem was first noticed. Therefore about 70 years before some light trace of creosote oil slick was observed on the water. It is my belief EPA is trying to create a mountain out of a molehill. If you stop to think of all the rail lines which line a great portion of our nation's rivers, these rail lines generally consist of creosote treated ties. There are millions and millions of these ties. Rainwater on these rail lines eventually end up in said rivers. Hot sun boils the creosote out of the railroad ties in the summer. Why don't we have major creosote problems on the major rivers lines with railroads? This St. Maries supposed problem has to be miniscule compared to a great portion of other rivers.

The reviewer raises a potentially important point. This comment was sent to EPA and DEQ in the event that they wish to investigate this claim.

  1. After reading the summary of the Public Health Assessment for the St. Maries Creosote Site, in St. Maries, Idaho I am writing to say that I concur completely with the recommendations of IDOH. I feel that your recommendations are adequate for now and for the future. I certainly do not feel there is need for a Superfund Cleanup similar to what happened in the Silver Valley of Idaho. Our site in no way resembles the magnitude of the problems in Kellogg. I feel this probably can be handled at the local level with the oversight of the State of Idaho Dept of Health and Welfare or the DEQ. As a lifelong resident of St. Maries and one who swam every summer day in the St. Joe River I am not worried about the ramifications of this site.

EPA currently is the lead regulatory agency at the site. IDOH will continue its oversight in a public health, non-regulatory capacity.

  1. What concerns me most is the swimming at Aqua Park. The report states that contamination there was unlikely since it is upstream. However, it is extremely close. 0.3 of a mile is not far. In fact it is miniscule in this instance. For many years, I took my grandchildren there to swim each warm day of the summer. I now deeply regret it. I feel you need to be less scientific and more straight forward with people about what will really happen to those children who swam there on a regular basis with the blessing of Potlatch and the city of St. Maries.

The public health assessment states in section 3.4, "Therefore, even if exposure were to occur to contaminated surface water, it is unlikely that this exposure would result in any adverse cancer or non-cancer health effects to a local resident swimmer." It further states in section 3.5, "Only potential exposure routes for children exist at the site. As delineated in the discussions for different exposure pathways, this site is highly unlikely to result in any adverse health effects to local residents, including children." In the "Conclusions" section the document states, "Therefore, it is unlikely that any adverse human health effects have or will occur because of site-related contamination, including contaminated soil, surface water, sediment, ground water, fish and air under current site conditions." A public health assessment summary fact sheet, mailed to all residents of St. Maries, stated, "after reviewing available data, IDOH concluded that exposure to site contaminants is unlikely to result in any adverse health effects for the general public." If children swam in the designated swimming area at the Aqua Park, they would not have been exposed to site contaminants.

  1. Multiple comments pointed out that groundwater contamination was localized (within a 90 foot radius of the site) and hydraulically isolated from drinking water wells, which were at least 0.5 miles from the site. The comments stressed that the ground water pathway should be labeled "no apparent public health hazard" and that no further private well testing should be required.

After reviewing additional site data from the Remedial Investigation/Feasibility Study, being conducted concurrently with this public health assessment, BEHS revised the ground water pathway category from indeterminate public health hazard to no apparent public health hazard. Appropriate revisions to the document were made in order to reflect this change.

  1. BEHS recommends that "no swimming" and "no trespassing" signs should be posted at the Site boundary as well as on the river. We believe that the signage recommendation in the PHA should be re-evaluated once the RI/FS process is concluded and a remedial action has been selected for the site.

Originally, the document stated that signs should be posted at the river and the site discouraging people from entering or swimming near the site. BEHS revised its recommendation to state, "The public should be informed that swimming in the river close to the site or entering the site could expose them to hazardous chemicals. As a precaution, signs should be posted at the site boundary in obvious locations as well as on the river warning the public about the presence of site-related contaminants. This precautionary measure is needed because prolonged contact with the site contaminants may result in adverse health effects. Prolonged contact with site contaminants could occur if exposure is increased through behavior changes such as swimming or wading next to the site. Precautionary signs could prevent potential behavior changes by the public." BEHS believes this is a reasonable and prudent public health recommendation.

  1. The correct conclusion is that the St. Maries Creosote site does not pose potential exposure pathways to the general public, including children. This is supported by the findings and conclusions contained in the draft report that it is "...unlikely the general public, including children, are being exposed to significant levels of site related contamination...it is also unlikely that the public was exposed to significant amounts of site related contaminants...it is unlikely that any adverse human health effects have or will occur because of site related contamination...".

The conclusion, with respect to routes of exposure referenced in the above comment, is correct. Whether or not people are being exposed to significant amounts of contaminants is immaterial with respect to a completed exposure pathway. If a person can touch, eat/drink, or inhale a contaminant, they can be exposed to it. BEHS was unable to completely rule out exposure to site contaminants through the soil, sediment, and surface water in the past, present, or future. Consequently, there is a potential for exposure. This does not mean that BEHS views these exposure routes as completed at present, neither does it mean that the route is incomplete. A person will not necessarily suffer adverse health effects due to a completed exposure pathway. Adverse health effects depend not only on a completed exposure pathway, but also on other factors such as dose, toxicity, duration, and personal characteristics.

Commenter does not have any information regarding the possible exposure to two (2) Carney Products workers and therefore does not comment on this conclusion.

Commenter concurs with the conclusion that all exposure pathways except groundwater are categorized as "no apparent public health hazard." The City submits that the groundwater exposure pathway should also be categorized as "no apparent public health hazard."

This comment was addressed in the response to comment #7 above.

Commenter concurs that current site conditions could change and land use restrictions or covenants could be imposed on the site so as to eliminate any potential risk to human health.

Commenter has also reviewed the recommendations contained in Section 5, pages 15-16. The need for "no swimming" signs is not documented or supported by the draft report. The municipal swimming pool is located on Main Avenue in St. Maries. The only other public swimming area is located at Aqua Park, which is upstream from the Site. Commenter does not have any employees working on the site. Access to the site could be restricted to a reasonable degree and posted with "no trespassing" signs. Finally, there does not appear to be sufficient data developed to justify or require taking groundwater samples from domestic wells near the site, because it has been established that no domestic wells are located within the identified 90 foot radius of the creosote treating facility. In fact, the draft report at page 10 states that City water is obtained from the Rochat Creek and dam, a water source independent of the St. Joe River. The river is not used for domestic water supply. There are no domestic drinking water wells located on or near the Site. The nearest wells are no closer than a 0.5 mile radius from the Site. All residents located within the City limits are required to hook up to the City water system.

The commenter's concern with BEHS's recommendation about signage was addressed in the response to comment #8 above. Since the ground water pathway was determined to be no apparent public health hazard, the recommendation to sample domestic wells was deleted from the document.

  1. Multiple comments from same party are listed below:
    1. Additional Testing of Groundwater
      SUMMARY, Conclusions and Recommendations
      Groundwater samples from the domestic wells near the site should be collected and analyzed.
    2. The conclusion and the resulting recommendation do not logically follow from information presented within the body of the Draft Health Assessment. The Draft Health Assessment identified the following information as being relevant to the site:

      Section 2.4
      There are no drinking water wells within a 0.5-mile radius of the site; however there are 14 domestic wells between 0.5 and 1 mile of the site [4].

      Section 3.3.4
      Most of the contaminated groundwater identified is underneath the creosote-treating facility. The migration of contaminants in groundwater appears to be in the general groundwater flow direction, toward the St. Joe River. The concentrations of contaminants diminish as the distance from the source areas increases and seem to be confined within an approximately 90-foot radius of the creosote-treating facility [4].
      According to the data gaps report [4], groundwater at the site is not used for drinking water purposes; city water is available. According to the integrated assessment [3], there are no drinking water wells within a 0.5 and 1-mile of the site [4].

      Section 3.3.4 states that groundwater impacts are confined within a 90-feet radius of the site. The Draft Health Assessment properly states that there are no groundwater wells within a 2640-feet/0.5 mile radius of the site. It does not logically follow the wells that are 2640 feet, if not further, should be tested, when groundwater impacts are confined within 90-feet of the site. The Draft Health Assessment does not provide any analysis or data to support the testing of a well that is over 2550 feet away from where the site has been determined to impact groundwater. Since the rational to conduct additional groundwater investigation(s) does not correspond to the site specific data presented within the Draft Health Assessments, all such references to additional groundwater data should be removed.

    This comment was addressed in the response to comment #7 above.

    1. Indeterminate Public Health Hazard
      SUMMARY, Conclusions and Recommendations
      The groundwater exposure pathway is categorized as an Indeterminate Public Health Hazard due to lace of environmental data and information (Appendix D) ....Groundwater samples from the domestic wells near the site should be collected and analyzed.
    2. As stated in Appendix D to the Draft Health Assessment, the category for Indeterminate Public Health Hazard is a category used for sites in which "critical" data are insufficient with regard to the extent of exposure and/or toxicological properties at estimated exposure levels. The determination represents a professional judgment that critical that critical data are missing and that the data has been judged as insufficient to support a decision. The determination does not imply that all data are incomplete, but that some additional data are required to support a decision. The Draft Health Assessment calls for additional data to be collected from wells near the site, which at closest range is over 0.5 miles from the site.

      The site should be classified as No Apparent Public Health Hazard for groundwater exposure pathways for several reasons. First, as discussed above, the groundwater well data is not "critical" data when the radius of impact is 90-feet from the site. Second, there is a City ordinance that prevents groundwater wells within the city limits, which is at least over 0.5 miles from the site. Third, an assessment should be made of work conducted pursuant to the Remedial Investigation and Feasibility Study ("RI/FS) on well locations and the groundwater flow. The results of additional research on groundwater use are presented in Section 4.8 of the draft Final Remedial Investigation/Baseline Risk Investigation/Baseline Risk Assessment ("RI/BLRA") (July 2003).2

    This comment was addressed in the response to comment #7 above.

    1. Institutional Controls - Signs
      SUMMARY, recommendations
      The public should be prevented from swimming in the river close to the site or entering the site. As a precaution, "no swimming" and "no trespassing" signs should be posted at the site boundary in obvious locations as well as on the river. This precautionary measure is needed because prolonged contact with the site contaminants may result in adverse health effects.
    2. This conclusion does not directly follow the analysis set forth with the Draft Health Assessment. In several other areas the Draft Health Assessment states that swimming would not occur in this area (e.g., Page 7 last sentence; Page 8, Section 3.3.2, third paragraph). The need for signs is not clearly supported.

    This comment was addressed in the response to comment #8 above.

    1. Unclear Language Per Risk Assessment
      Section 3.5
      Only potential exposure routes for children exist at the site.
    2. This does not make sense in the standard terminology used in EPA risk assessments. Text would be clearer if the sentence was omitted.

    This document is not produced for or by EPA. This document follows ATSDR public health assessment guidelines. Exposure routes are categorized as completed, incomplete, or potential.

    1. Swimming Pools
      Section 2.4
      There are no swimming pools.
    2. There is a public swimming pool located on Main Street in downtown St. Maries, which provides an alternative to swimming at the St. Maries Aqua Park.

    There are no swimming polls at the Site. This public health assessment addresses the Site, not the entire City of St. Maries.

    1. RI/FS
      Summary
      EPA will complete a Remedial Investigation/Feasibility Study (RI/FS) for the site.
      Section 2.2 Regulatory History
    2. EPA has also approved the Final Remedial Investigation/Feasibility Study (RI/RS) Work Plan and Sampling and Analysis Plan, which is targeted for completion by the fall of 2003.

      The St. Maries PRP Group, which comprises of Carney Products Co., Ltd. And the City of St. Maries, Idaho, is completing the RI/FS pursuant to the Administrative Order on Consent for Remedial Investigation and Feasibility Study (CERCLA-10-2001-0137) with the United States Environmental Protection Agency ("EPA") who is in consultation with the Coeur d' Alene tribe ("CDA"). The draft of the final RI/BLRA was submitted to the EPA and CDA in July of 2003. The remedial investigation data was not utilized in the Draft Health Assessment.

      The RI/FS is now scheduled to be completed by February of 2004.

    Noted. Appropriate changes were made.

    1. Incorrect Values
      Section 3.4
      Soil Ingestion Pathway

      For non-cancer health effects, the chemical with the highest ratio (556) of average concentration with respective to its CV is dibenzo(a.h.)anthrancene.
    2. Surface Water Pathway
      For non-cancer health effects, the contaminant with the highest ratio (55) of average concentration with respective to its CV is benzo(a)anthracene.

      Sediment Pathway
      For non-cancer health effects, the contaminant with the highest ratio (121) of average concentration with respective to its CV is benzo(a)anthracene.

      In the above sentences, the contaminants have been incorrectly identified as non-carcinogens through the chemicals are in fact carcinogenic. Also, please review and check all the values listed within the tables. Some of the values listed were incorrect and should be changed.

    Noted. Appropriate changes were made.

    1. Potentially Responsible Parties
      Section 2.2 Regulatory History
    2. On January 26, 1999, EPA issued a Unilateral Administrative Order (UAO) to both the City of St. Maries, who leased the property to various entities since the 1930s and Carney Products, the current property lessee (Potentially responsible parties [PRPs].

      EPA has also named B.J. Barney & Co. as a PRP to the site. Carney Products Co., Ltd. Is no longer the lessee for the property legally described as:

      The West 500 feet of Block Eight (8), Public Reserve, Government Townsite, St. Maries, Idaho, Benewah County, Idaho.

      SUBJECT TO access to the booming area granted to Potlatch Corporation across Block 8, Public Reserve, Government Townsite, St. Maries, Benewah County, Idaho, along the existing old railroad spur grade.

      And the property described as:

      All of Block 8, Public Reserve in Government Townsite, except the West 500 feet thereof, of St. Maries, Benewah County, Idaho.

      SUBJECT TO access to the booming area granted to Potlatch Corporation across Block 8, Public Reserve, Government Townsite, St. Maries, Benewah County, Idaho along the exiting old railroad spur grade.

      The leases for the two properties were terminated effective May 31, 2003. Carney Products Co., Ltd. continues to own property immediately south of the site.

    Noted. Appropriate changes were made.



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