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PUBLIC HEALTH ASSESSMENT

HANFORD 1100-Area (USDOE)
RICHLAND, BENTON COUNTY, WASHINGTON


APPENDIX

APPENDIX A. Letter from J. Monhart, Director of Richland Operations, DOE




APPENDIX B. Demographic Data

Table B-1.

Population Data: By Counties
Variable Benton
County
Franklin
County
Total persons 112,560 37,473
Total area, square miles 1,703 1,242
Persons per square mile 66.1 30.2
% Male 49.4 51.3
% Female 50.6 48.7
% White 91.4 71.8
% Black 1.0 3.5
% American Indian, Eskimo, or Aleut 0.8 0.7
% Asian or Pacific Islander 2.0 2.3
% Other races 4.9 21.6
% Hispanic origin 7.7 30.2
% Under age 10 17.2 19.9
% Age 65 and older 10.1 10.0

Source: 1990 Census of Population and Housing, Summary Tape File 1 (Washington). Prepared by the Bureau of the Census, Washington, DC, 1991.


Table B-2.

Housing Data: By Counties
Variable Benton
County
Franklin
County
Households* 42,227 12,196
Persons per household 2.65 3.03
% Households owner-occupied 63.1 59.7
% Households renter-occupied 36.9 40.3
% Households mobile homes 9.3 12.3
% Persons in group quarters 0.5 1.2
Median value, owner-occupied households, $ 66,200 56,000
Median rent, renter-occupied households, $ 283 234

* A household is an occupied housing unit, not including group quarters, e.g., college dormitories, fraternity and sorority houses, prisons, nursing homes, or hospitals.

Source: 1990 Census of Population and Housing, Summary Tape File 1 (Washington). Prepared by the Bureau of the Census, Washington, DC, 1991.


Table B-3.

Population Data: Tri-Cities
Variable Kennewick Pasco Richland
Total persons 42,155 20,337 32,315
Total area, square miles 20.1 22.8 32.0
Persons per square mile 2,095 892 1,008
% Male 49.0 51.2 48.8
% Female 51.0 48.8 51.2
% White 89.9 59.9 93.0
% Black 1.1 5.6 1.4
% American Indian, Eskimo, or Aleut 0.8 0.9 0.7
% Asian or Pacific Islander 2.0 2.5 3.3
% Other races 6.2 31.1 1.6
% Hispanic origin 8.7 40.8 3.0
% Under age 10 18.7 20.9 15.2
% Age 65 and older 9.1 11.2 12.6

Source: 1990 Census of Population and Housing, Summary Tape File 1 (Washington). Prepared by the Bureau of the Census, Washington, DC, 1991.


Table B-4

Table B-4.

Housing Data: Tri-Cities
Variable Kennewick Pasco Richland
Households* 16,074 6,842 13,162
Persons per household 2.61 2.91 2.44
% Households owner-occupied 53.1 47.4 62.0
% Households renter-occupied 46.9 52.6 38.0
% Households mobile homes 6.5 10.4 2.7
% Persons in group quarters 0.6 2.1 0.4
Median value, owner-occupied households $64,800 $44,100 $69,200
Median rent paid, renter-occupied households 279 228 293

*A household is an occupied housing unit, but does not include group quarters such as college dormitories, fraternity and sorority houses, prisons, nursing homes, or hospitals.

Source: 1990 Census of Population and Housing, Summary Tape File 1 (Washington). Prepared by the Bureau of the Census, Washington, DC, 1991.


APPENDIX C. Toxic Chemical Release Inventory (TRI) Data

Table C-1.

Releases to Land, Benton County, Washington State
Chemical County Facility Pounds released to the Soil
1987 1988 1989 1990
Aluminum Oxide Benton DOE Hanford 300 Area 666 -- -- --
Ammonia Benton Chevron East End 0 304 200 5
Ammonia Benton Chevron Kennewick 0 0 3,400 0
Ammonia Benton DOE Hanford 200 Area -- -- 8,075 --
Ammonium Nitrate Benton Chevron Kennewick 750 750 750 250
Ammonium Nitrate Benton Chevron Finley -- 25,709 8,700 26
Ammonium Nitrate Benton Columbia Crest -- -- -- 88,000
Ammonium Nitrate Benton DOE Hanford 200 Area 785 -- -- --
Chlorine Benton DOE Hanford 100 Area -- -- -- 8,000
Chlorine Benton DOE Hanford 200 Area -- -- -- 880
Chlorine Benton Lamb Weston -- -- 16,000 22,000
Copper Benton DOE Hanford 200 Area 150 -- -- --
Ethylene Glycol Benton DOE Hanford 200 Area -- 75 -- --
Hydrazine Benton DOE Hanford 100 Area 20 -- 55 --
Hydrazine Benton DOE Hanford 200 Area 1 -- -- --
Hydrochloric Acid Benton DOE Hanford 200 Area 7 -- -- --
Hydrochloric Acid Benton DOE Hanford 300 Area 113 -- -- --
Hydroquinone Benton DOE Hanford 100 Area 146 -- -- --
Hydroquinone Benton DOE Hanford 200 Area 803 -- -- --
Hydroquinone Benton DOE Hanford 300 Area 377 -- -- --
Lead Benton DOE Hanford 200 Area 507 -- -- --
Nitric Acid Benton DOE Hanford 200 Area 3,496 -- 12 --
Nitric Acid Benton DOE Hanford 300 Area 1,102 14 15 12
Phosphoric Acid Benton Lamb Weston -- 16,100 -- --
Sodium Hydroxide Benton Lamb Weston 0 148,000 10,443 7,328
Sodium Hydroxide Benton DOE Hanford 100 Area 500,000 430,000 -- --
Sodium Hydroxide Benton DOE Hanford 200 Area 49,760 14,706 -- --
Sodium Hydroxide Benton DOE Hanford 300 Area 468 209 -- --
Sodium Hydroxide Benton Seneca Foods 131,742 0 -- --
Sodium Sulfate Benton DOE Hanford 100 Area 890,000 900,000 -- --
Sodium Sulfate Benton DOE Hanford 200 Area -- 28,635 -- --
Sulfuric Acid Benton DOE Hanford 100 Area 1,000,000 644,000 -- 13,000
Sulfuric Acid Benton DOE Hanford 200 Area 16,181 10,916 2 6
Sulfuric Acid Benton DOE Hanford 300 Area 45 9 7 7


Table C-2.

Releases to Surface Water, Benton County, Washington State
Chemical County Facility Pounds Released into Water
1987 1988 1989 1990
Ammonia Benton Chevron East End 3,996 7,985 0 9,327
Ammonia Nitrate Benton Chevron Kennewick 10,347 10,777 0 6,800
Sodium Hydroxide Benton Chevron East End 15,860 2,790 10,443 7,328
Sodium Hydroxide Benton DOE Hanford 100 Area -- 53 -- --
Sodium Sulfate Benton DOE Hanford 100 Area -- 350 -- --


Table C-3.

Releases to Air by the Department of Energy, Benton County, WA
Chemical County Facility Pounds Released into the Air
1987 1988 1989 1990
Acetone Benton DOE Hanford 1100 Area 1 -- -- --
Methyl Ethyl Ketone Benton DOE Hanford 1100 Area 7 -- -- --
Sulfuric Acid Benton DOE Hanford 1100 Area 2 0 -- --
1,1,1 Trichloroethane Benton DOE Hanford 1100 Area 13 -- -- --
Acetone Benton DOE Hanford 100 Area 513 -- -- --
Ammonia Benton DOE Hanford 100 Area 1,200 -- -- --
Freon 113 Benton DOE Hanford 100 Area 16 -- -- --
Methyl Ethyl Ketone Benton DOE Hanford 100 Area 923 -- -- --
Tetrachloroethylene Benton DOE Hanford 100 Area 127 -- -- --
1,1,1 Trichloroethane Benton DOE Hanford 100 Area 528 -- -- --
Acetone Benton DOE Hanford 200 Area 3,068 -- -- --
Ammonia Benton DOE Hanford 200 Area 18,150 -- 18,874 --
Carbon Tetrachloride Benton DOE Hanford 200 Area 17,140 -- -- --
Copper Benton DOE Hanford 200 Area 10 -- -- --
Ethylene Glycol Benton DOE Hanford 200 Area 2 -- -- --
Freon 113 Benton DOE Hanford 200 Area 202 -- -- --
Hydrochloric Acid Benton DOE Hanford 200 Area 20 -- -- --
Hydrogen Fluoride Benton DOE Hanford 200 Area 16 -- -- --
Lead Benton DOE Hanford 200 Area 10 -- -- --
Methyl Ethyl Ketone Benton DOE Hanford 200 Area 12 35 -- --
Nitric Acid Benton DOE Hanford 200 Area 87 23 0 47,002
Sulfuric Acid Benton DOE Hanford 200 Area 10 0 0 0
1,1,1 Trichloroethane Benton DOE Hanford 200 Area 1013 -- -- --
Acetone Benton DOE Hanford 300 Area 9 -- -- --
Ammonia Benton DOE Hanford 300 Area 6 -- -- --
Ammonium Nitrate Benton DOE Hanford 300 Area 73a 0 -- --
Ethylene Glycol Benton DOE Hanford 300 Area -- 5 -- --
Lead Benton DOE Hanford 300 Area 4 -- -- --
Methyl Ethyl Ketone Benton DOE Hanford 300 Area 187 542 -- --
Nitric Acid Benton DOE Hanford 300 Area 98 91 0 --
Tetrachloroethylene Benton DOE Hanford 300 Area 760 -- -- --
1,1,1 Trichloroethane Benton DOE Hanford 300 Area 47a -- -- --
Chlorine Benton DOE Hanfordb 3,000 0 0 0
Methyl Ethyl Ketone Benton Unknown Hanford Areas 2,555 -- -- --

a. An unknown proportion of this quantity was released in the 700 Area (in downtown Richland).
b. Released throughout Hanford at water distribution points; the proportion released at each NPL site was not available.
c. Releases from the 1100 Area are indicated by shading.

Table C-4.

Releases to Air by Other than the Department of Energy, Benton County, WA
Chemical County Facility Pounds Released into the Air
1987 1988 1989 1990
Ammonia Benton Chevron 235,128 172,368 159,400 147,275
Ammonia Benton Chevron-Bowle 1,109,639 1,137,448 1,537,780 1,498,879
Ammonia Benton Kerley Ag. Products 1,645 1,719 1,839 22,751
Ammonia Benton Seneca Foods -- -- 1,300 1,600
Chlorine Benton Lamb Weston -- -- 20,000 --
Chlorine Benton Columbia Crest 11,550 9,750 4,050 5,250
Nitric Acid Benton Chevron-Bowle 1,000 1,641 1,742 1,817


APPENDIX D. Toxicological Information

Lead -- Children who may in the future live on residential lots on the northeast corner of a redevelopedHorn Rapids Landfill could play in soil containing as much as 482-854 parts per million (ppm) lead(1,2). This compares to background soil concentrations in the 1100-Area and the State of Washingtonthat range up to 8.1 and 30 ppm, respectively (3). The exact relationship between the lead concentrationin soil and that in children's blood is in dispute among scientists. According to one theory, the averageconcentration of lead in their blood could be increased by 6 micrograms (µg) lead per deciliter (dl) ofblood to 12.3 µg/dl, depending on many factors, such as the chemical form of the lead, the soil particlesize, and the nutritional state of the children (4). In one case, this increase was calculated using therelationship reported between soil and blood lead concentrations observed in Helena Valley in Montanaand Silver Valley in Idaho (4). The following equation was derived:

    Natural log (blood lead in µg/dl) = 0.879 + 0.241 X Natural log (soil lead in ppm)

Some factors (soil particle size, chemical species of lead, nonsoil lead sources, population demographicssuch as age and distribution of wealth, nutritional status, etc.) upon which a soil-lead relationshipdepends are site-specific. By varying assumptions about these and other factors, it is possible to drawdifferent conclusions about the future potential for lead-induced harm. Similarly, different conclusionswould be drawn if lead hot spots were remediated.

Young children are at risk from lead ingestion during ages 2-4, the years in which they are prone to picabehavior (ingestion of nonnutritive substances, such as soil). Their ingestion of small amounts of lead isassociated with depressed IQ scores, slow growth, and hearing deficits (5). Middle-aged men maybecome hypertensive from small increases in their blood lead levels (5).

Environmental Protection Agency (EPA) scientists point out that the health effects of lead, especiallythose on "children's neurobehavioral development, may occur at blood lead levels so low as to beessentially without a threshold" and considers it inappropriate to derive an RfD for oral exposure to lead(6). Since a population's blood lead concentration is directly related to the local soil lead concentration(4), it seems inadvisable to use any soil comparison values or standards.

Arsenic -- Arsenic occurs in the environment in both inorganic and organic forms. In the absence ofspecific information about the form of arsenic in the soil and groundwater, it is prudent to make theconservative assumption that all arsenic found on site in groundwater and soil is in the much more toxicinorganic form. Chronic human ingestion of as little as 0.01 to 0.06 milligrams per kilogram per day(mg/kg/day) of inorganic arsenic has been associated with evidence of impaired circulation in theextremities, such as significantly increased incidence of Blackfoot disease and Raynaud's Syndrome (8). Other noncancer effects of low-level human oral exposure to the inorganic form included abdominalpain, diarrhea, liver damage (hepatomegaly, portal hypertension), skin lesions (melanosis, keratosis),and mild peripheral neuropathy (8). No effects were seen consequent to oral intake of as much as 0.006mg inorganic arsenic/kg/day (8). Human ingestion of 0.009 to 0.04 mg inorganic arsenic /kg/day for 12to 60 years has been associated with increased incidence of cancer of the skin, lungs, and liver (8). Although EPA declined to verify an oral slope factor for inorganic arsenic, that agency did derive a unitrisk in water of 0.00005 per microgram per liter (µg/L) (6). As chemical carcinogenesis is assumed byEPA to be without a threshold, the derived value suggests lifetime exposure to drinking water containingas little as 0.2 parts per billion (ppb) arsenic or soil containing as little as 4 ppm inorganic arsenic mightresult in a slightly increased cancer rate in the exposed public.

Ingestion of less than 250 µg/day (0.004 mg/kg/day) does not affect blood arsenic concentration (9). Ifintake must exceed 250 µg/day (0.004 mg/kg/day) to raise blood levels, the implication is thatelimination mechanisms are adequate at this level of intake. This fits with findings that oral intake ashigh as 0.006 mg/kg/day (420 µg/day) does not cause noncancer effects in humans and that humancancer has been observed only in studies where prolonged intake exceeded 0.009 mg/kg/day (630µg/day) (8). A growing body of evidence suggests that arsenic carcinogenicity may result frommechanisms consistent with such a threshold (10). It follows that adverse public health effects fromarsenic ingestion would be not be expected from inorganic arsenic concentrations less than 120 ppb indrinking water or 2,400 ppm in soil (or an equivalent combination, e.g., 140 ppb in groundwater plus500 ppm in soil, which concentrations are 10 to 100 times those maximally found or estimated at the1100-Area).

Aldrin -- Aldrin and dieldrin, its metabolite, are chlorinated cyclodienes formerly used as insecticides(11). Oral or dermal exposure to aldrin is neurotoxic to people, often causing convulsions well beforeless dramatic effects become evident (12). Repeated exposure to dieldrin caused immune hemolyticanemia in humans, and reproductive, developmental, and carcinogenic effects in rodents in addition tothose seen in people (6,11,12). Aldrin's potential for carcinogenicity is of special concern to this Agencyas well as to EPA (6,11). Lifetime exposure to the soil concentrations of 4 ppm reported for the 1100-2Suboperable Unit could result in a low increased cancer incidence (6).

Tetramethyloxirane (TMO) -- ATSDR investigators did not locate toxicological information ontetramethyloxirane (TMO) -- tetramethylethylene oxide. This chemical is a derivative of oxirane, whichis also known as ethylene oxide. Ethylene oxide itself is a volatile, unstable chemical that is usedprimarily in the manufacture of other synthetic chemicals, such as those in antifreeze. A small fractionis used as a sterilant for dry foods and for surgical instruments and supplies. Its volatility and instabilityresult in a short environmental half-life, so that exposure is more likely to be occupational than environmental. It may be anticipated on the basis of general chemical principals that the tetramethyl derivativewould be less volatile and more stabile than ethylene oxide. These differences would increase the timethe derivative could persist in the environment and the probability of exposure of people in a pathway. It is not clear how substitution of the four hydrogens of ethylene oxide with methyl groups to form TMOmight affect the toxicological properties of the parent compound. These properties of the parentcompound, ethylene oxide, are briefly reviewed below (13).

In animals, the noncancer effects of subchronic inhalation exposure to ethylene oxide include effects onthe developmental, reproductive, respiratory, hematological, renal, immunological, and neurologicalsystems, of which the last is the most sensitive. For humans, chronic inhalation leads to poor hand/eyecoordination (3 ppm) and peripheral neuropathy (10 ppm) as well as nasal irritation at the higher level. There is suggestive evidence of reproductive and developmental toxicity among people occupationallyexposed, but exposure levels are uncertain. Ethylene oxide produced malignancies in animals atmultiple sites, including the brain, uterus, lung, mononuclear cells, mesothelium, and mammary glandsin rodents. Association with occupational exposure (mostly inhalation) in humans, though suggestive, isinconclusive. Oral exposure of rats produced cancer of the stomach, consistent with an increasedincidence of stomach cancer in Swedish ethylene oxide factory workers who followed production bytasting the reaction mixture. Ethylene oxide is ranked as a probable human carcinogen: Weight-of-Evidence group B1 carcinogen by the EPA, and group 2A by the International Agency for Research inCancer (IARC), both because there is adequate evidence in animal studies and limited evidence inhumans (6,13,14).


References for Appendix D

  1. US Department of Energy. Phase 1 Remedial Investigation Report for the Hanford Site 1100-EM-1 Operable Unit. 1990 Aug; DOE/RL90-18 UC-600.

  2. US Department of Energy. Final Remedial Investigation/Feasibility Study-EnvironmentalAssessment Report for the 1100-EM-1 Operable Unit; 1992 Dec 30; DOE/RL 92-67 DOE/EA-0829 Draft B.

  3. Dragun J and Chiasson A. Elements in North American Soils. Green Belt, MD: HazardousMaterials Control Resources Institute, 1991.

  4. Xintaras C. Agency for Toxic Substances and Disease Registry. Impact of lead-contaminatedsoil on public health. Atlanta: US Department of Health and Human Services, Public HealthService; 1992 May.

  5. Agency for Toxic Substances and Disease Registry. Toxicological profile for lead. Atlanta: USDepartment of Health and Human Services, Public Health Service; 1990 June. Report No.: TP-88-17.

  6. Integrated Risk Information System. On-line. Cincinnati, OH: US Environmental ProtectionAgency, Health and Environmental Assessment Office, Environmental Criteria and AssessmentOffice, 1993.

  7. Agency for Toxic Substances and Disease Registry. Toxicological profile for di(2-ethylhexyl)phthalate, draft for public comment. Atlanta: US Department of Health and HumanServices, Public Health Service; 1992 Feb.

  8. Agency for Toxic Substances and Disease Registry. Toxicological profile for arsenic, draft forpublic comment. Atlanta: US Department of Health and Human Services, Public Health Service;1992 Feb.

  9. Valentine JL, Reisbord LS, Kang HK, Schluchter MD. Arsenic effects on population healthhistories. In: Mills CF, Bremner I, Chesters JK, editors. Trace Elements in Man and Animals --TEMA 5. Proceedings of the 5th International Symposium on Trace Elements in Man andAnimals; 1984; Aberdeen (Scotland). Aberdeen (Scotland): Commonwealth AgriculturalBureaux, 1985: 289-292.

  10. Sthrer G. Arsenic: opportunity for risk assessment. Arch Toxicol 1991: 65:525-531.

  11. Agency for Toxic Substances and Disease Registry. Toxicological profile for aldrin/dieldrin,draft for public comment. Atlanta: US Department of Health and Human Services, Public HealthService; 1992 Feb.

  12. Amdur MO, Doull J, Klassen CD editors. Casarett and Doull's Toxicology, 4th edition. NewYork: McGraw-Hill, Inc., 1991.

  13. Agency for Toxic Substances and Disease Registry. Toxicological profile for ethylene oxide. Atlanta: US Department of Health and Human Services, Public Health Service; 1990 Dec. Report No.: TP-90-16.

  14. Hogstedt CO, Rohlen CP, Berndtson BS, Axelson O, Ehrenbert L. A cohort study of mortalityand cancer incidence in ethylene oxide production workers. Br J Ind Med 1979; 36:276-280.

PUBLIC COMMENTS on the HANFORD 1100-AREA (USDOE) PUBLIC HEALTH ASSESSMENT

The following comments were received by ATSDR in response to the public comment period for the Hanford 1100-Area (USDOE) Public HealthAssessment.

APPENDIX E.

Public Comments on the Hanford 1100-Area (USDOE) Public Health Assessment
# Page, Paragraph Comment Summary Response
1. pp.4 & 36 Two commenters expressed concern that DOE's assumption of future industrial or commercial use of the Horn Rapids Landfill and other parts of the 1100-Area is not to be formally incorporated in deeds restrictions. One tribal commenter also indicated that future use is a critical issue. ATSDR agrees and recommended on page 42 that "transfers ["of portions of the 1100-Area . . . from DOE to the public"] should include sufficient safeguards to protect the public from exposure". ATSDR policy does not permit specific risk management recommendations, such as invoking deed restriction. However, ATSDR can recommend institutional controls be considered to protect public health (see page 42). Comments concerning deed restrictions have been forwarded to EPA and DOE.
2. p.14, last para. Why is so much time and effort being spent on the 1100-Area although this area is the one for which the community has the least concern about health effects. No changes. The Summary on page 1 and the second full paragraph, page 3 explain the 1100-Area was the first Hanford NPL site for which ATSDR had enough data to complete a public health assessment. Public health assessments for the other NPL sites are in progress.
3. p.21, para. 7

p.22, Fig. 5

Wells 3 and 17 are upgradient of the plume from Siemens Power Corp. (Advanced Nuclear Fuels) and Horn Rapids Landfill (HRL). It is not correct to discuss contamination in these wells in the context of the Siemens/HRL plume. The discussion was modified. See pages 21 and 22.
4. No page listed. A search of DOE fact sheets found no reference to preliminary geophysical exploration of Hanford. Were land-based non-invasive geophysical techniques used prior to drilling? No changes. Yes, non-invasive geophysical surveys were used. See References 3 and 18.
5. p.22, fig. 5 What is the source and date for the indicated direction of groundwater flow? No changes. Source is indicated in the upper left corner of the figure as Reference 3, 1990.
6. p.13, fig. 4 and text. The report states "no part of the Yakima River is downgradient from any part of the 1100-Area," but Fig. 4 shows the confluence of the Columbia and Yakima Rivers near the 1100-Area, and the Yakima River south of the Horn Rapids Dam appears downgradient of the 1100-Area. No changes. "Downgradient" means a downward trend in groundwater potential; i.e., the direction of water movement underground. The direction of groundwater moving under the 1100-Area is shown in Figure 5 to be towards east and northeast, away from the Yakima River and towards the Columbia River. Surface water (with no 1100-Area contaminants at levels of health concern -- see pages 24 and 25) in the Columbia River is moving downstream towards its confluence with the Yakima River; it would be incorrect and misleading to state the Yakima River is downgradient of the site.
7. p.22, fig. 5 Why are the monitor wells in Fig. 5 in a narrow north-south line parallel to the Columbia River? Are they deep enough to evaluate the fluid flow into the underlying basalt? No changes. Comparison of Figs. 3 and 4 show that monitoring wells are placed near contamination sources to track contaminant movement. These wells do not reach to the underlying basalt. Most of the wells tap the unconfined aquifer (page 21). ATSDR examined well drilling logs for Richland private wells, and obtained depth information for municipal wells. These wells are screened for the unconfined aquifer; they do not draw water from fissures in the underlying basalt.
8. p.20, para. 2
p.20, para. 3
p.42, para. 1
p.44, 1d
What does it mean to try and place a "cap" on an open system? Your method does not hold water. No changes. The "cap of 24 inches of soil" (page 20, paragraph 2 and 3) was applied to the landfill "to prevent dispersal of asbestos fibers as fugitive dust" (page 20, paragraph 4; also see page 44 part 1d), not to prevent rainfall from washing contaminants in the vadose zone into groundwater.
9. p.18-19 What geological layer is referred to in the "soil" contaminant data? No changes. Soil depths are given in Table 2 on pages 18 and 19. The depths of vadose zone soil contamination of primary concern for public health are those which are accessible to people in activities such as gardening, sandlot play, and excavation for building construction. See pages 28-33.
10. p.4-9 The public health assessment states the 1100-EM-1, -EM-2, and -EM3 operable units contain contaminated facilities such as the HEW bus lot, vehicle maintenance and repair facility, storage tanks, etc. since the early '50s. Would there not also be contamination in the original bus lot and garage that was located west of the present Chief Joseph School? No changes. Contamination in the HEW bus lot was not discussed in the public health assessment. No contaminants were reported there at levels of concern for human health. ATSDR has no information about soil contamination in Richland south of the current 1100-Area boundary. ATSDR will be happy to receive and review data on contamination of additional 1100-Area facilities for public health implications.
11. No page listed. The land use based cleanup goal is designated as unrestricted for groundwater and soil for most of the 1100-Area in the Proposed Plan, but the land use based cleanup goal for the Horn Rapids Landfill is restricted. This should be stated in the public health assessment. No change. This distinction is explained in the first full paragraph on page 31.
12. No page listed. The public health implications of not remediating the groundwater plume from Siemens should be explained. No change. The pathway for exposure of people to this plume is "Groundwater Northeast". This pathway is discussed in Table 4 on page 32, and in the second full paragraph on page 33. The public health implications of the major contaminants in the plume are discussed in the paragraphs on TCE and nitrate on pages 39 and 40.
13. p.10, para. 3 The public health assessment fails to recognize the unique status of Tribal governments under CERCLA and federal Indian law. This failure translates into deficiencies in the section on Background, Section C, "Demographics, Land Use, and Natural Resource Use." Little or no direct government-to-government consultation between ATSDR and the tribes has occurred. The interests of the Confederated Tribes of the Umatilla Indian Reservation (CTUIR) were not identified. The discussion was modified. See page 10. ATSDR has attended meetings of the Intertribal Council on Hanford Health Projects (ITCHHP -- formerly the Native American Working Group) to learn tribal concerns about ATSDR health activities, including public health assessments. ATSDR received the Scoping report: Nuclear Risks in Tribal Communities at a presentation by Umatilla Special Sciences and Resources Program staff representatives April, 1995. In May 1992 and June 1995, ATSDR sent letters to tribal chairpersons and ITCHHP liaisons formally requesting meetings with tribal representatives and members to learn their concerns. ATSDR will schedule meetings when responses to those letters are received.
14. p.1, para 1 The public health assessment should be a "stand alone" analysis--especially at Hanford which host 78 CERCLA-operable units with Records of Decision spanning generations. The public health assessment does not address the large number of substances released from Hanford in 50 years of operation. No change. The purpose of the document was to be a stand-alone analysis for the 1100 area. Substances released from Hanford's other NPL sites will be addressed in public health assessments for those sites.
15. p.22, fig. 5 The public health assessment relies heavily on DOE sponsored documentation and does not present information from non-DOE sources. For example, groundwater isopleths are displayed as arrows indicating direction, but not magnitude. Consultation with CTUIR could have alleviated the inadequate illustration. No change. The arrows were ATSDR summaries of the public health significance of numerous groundwater potential maps drawn from data at different dates. The arrows indicate the absence of pathways for contaminants at levels of concern to drinking water sources. Technical data not of public health significance are not discussed in the public health assessment, although they can be found in the list of references by interested readers who wish additional background information. ATSDR will receive and review any additional information of public health significance from any and all concerned parties.
16. p.25-27
Appendix C
Information in the section on "Toxic Chemical Release Inventory" and Appendix C may lead readers to dismiss the four chemicals released to the air from the 1100-Area as the only amounts ever released. Non-1100-Area releases are not shown in their true relationship to the 1100-Area. Table C-3 in Appendix C is regrouped to show the relationship of reported releases from the 1100-Area to those from other DOE NPL sites. Readers' attention is called to the unchanged last paragraph in the "Toxic Chemical Release Inventory" section (page 27), which discusses the limitations of the database.
17. p.6, Table 1
p.18, Table 2
p.23, Table 3
The public health assessment approaches the 1100-Area as a "service station", ignoring spills during the site's use as a point-of-exchange for off-site shipments of materials. No change. ATSDR reviewed an abundance of soil and groundwater analysis data and listed values which could have public health significance in Tables 2 and 3. Table 1 lists 4 spills that lead to soil or groundwater characterization. They are named 1100-5, 1100-6, the Rainwater pool, and the Horn Rapids Landfill (HRL) groundwater plume.
18. No page listed. The public health assessment does not contain complete geologic characterization and hydrogeologic modeling of the 1100-Area. This could show the effect of pumping drinking water in an aquifer that may have a carcinogenic contaminant such as TCE. No change. Historical information on the TCE plume was reviewed by ATSDR; the concentration of TCE in the plume is attenuating, and TCE will be further diluted and volatilized as it reaches the Columbia River and before it reaches water intakes. Detailed geological characterization and hydrogeological modeling are of public health significance when historical plume information is lacking and when there are completed or potential pathways consistent with current or proposed future land use. There is no proposed future land use permitting a completed pathway from well use in the current or future plume area. Please see discussions on the groundwater northeast pathway (Table 4, page 32 and text on page 33) and the toxicological implications of TCE (page 39).
19. No page listed. ATSDR is required to complete public health assessments before the remedial investigations cited in the References section. The record of decision, based on those remedial investigations, was signed in September, 1993, and the public comment version of this public health assessment was released in July 1995. What caused the delay? No change. Preliminary public health assessments for all Hanford NPL sites were released for data validation in October 1989, before the record of decision was signed. This public health assessment addresses additional data provided to ATSDR on 1100-Area soil and groundwater contamination levels and locations when the remedial investigations and limited field investigations were completed in 1993.
20. p.41 ATSDR concludes that no one is or has been exposed. Table C-3 indicates releases to the air in 1987. The public health assessment does not provide air pathway data. No change. The quotation in context is "no one is exposed, has been exposed, or is about to be exposed in the near future to 1100-Area contaminants at levels of health concern" [emphasis added]. Ambient air concentrations (pages 24-25) and pathway analysis (page 33) indicated that the levels are below health concern.
21. p.41 The public health assessment fails to present a "comparison of existing morbidity and mortality data on diseases that may be associated with the observed levels of exposure." -- CERCLA 104(i)(6)(F) No change. In the absence of completed pathways (pages 29-31) there are no "diseases that may be associated with observed levels of exposure."


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