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PUBLIC HEALTH ASSESSMENT

AMERICAN CROSSARM AND CONDUIT COMPANY
CHEHALIS, LEWIS COUNTY, WASHINGTON


APPENDICES

A. Area Maps

B. Response to Public Comments


APPENDIX A

Figure 1
Figure 1. Regional Location Map

Figure 2
Figure 2. American Crossarm & Conduit Site Location

Figure 3
Figure 3. Facility Vicinity Plan

Figure 4
Figure 4. American Crossarm & Conduit Site Features

Figure 5
Figure 5. Zoning Map

Figure 6
Figure 6. Chehalis Avenue Area Surface Soil Sample Stations

Figure 7
Figure 7. Dioxins/Furans Concentrations in Surface Soil for the Chehalis Avenue Area

Figure 8
Figure 8. Pentachlorophenol Concentrations in Surface Soil for Chehalis Avenue Area

Figure 9
Figure 9. Total Carcinogenic PAH Concentration in Surface Soil for Chehalis Avenue Area

Figure 10
Figure 10. American Crossarm & Conduit Facility and AOC Features

Figure 11
Figure 11. Approximate Subsurface Extent of PCP in Treatment Area Soil Concentrations Exceeding 1,000 µg/kg

Figure 12
Figure 12. Approximate Subsurface Extent of CPAH in Treatment Area Soil Concentrations Exceeding 1,000 µg/kg

Figure 13
Figure 13. Maximum Credible Extent of Major Groundwater Contamination



APPENDIX B

Comments on American Crossarm and Conduit
Public Health Assessment

The following responses were made during and after the public comment period. No comments were received from people who live in the area adjacent to the site. This list of comments does not include editorial or procedural comments. If the accuracy of a statement was questioned, the statement was verified or corrected. If the same comments were received from more than one source, only one comment and response is listed. The comments were paraphrased by the health assessor for brevity or clarity.

Comment 1: Incineration of pentachlorophenol wastes as a cleanup measure may have contributed additional dioxin to the soils in the community. This source of dioxin is not mentioned in the assessment.

    Response to Comment 1: The assessment states on page 2, last paragraph, last 2 sentences, "In 1988 and 1989, EPA incinerated on-site some of the contaminated soil, sludge and debris (1). Incineration generated about 207 tons of ash which is presently stored on-site (5)." EPA's On-Scene Coordinator Report states the burn efficiency was 99.99%. Because the burn occurred in 1988 and 1989, and the environmental samples discussed in the health assessment were collected in 1990 and 1991, any increment of dioxin added to area soils by the burn would have been detected. This possible source of dioxin is mentioned in the health assessment on page 20, 4th paragraph, 6th sentence, "It (dioxin) can be inadvertently produced in very small amounts as an impurity during the manufacture of certain herbicides and germicides and has been detected in products of incineration of municipal and industrial wastes."

Comment 2: Some people in the community believe that there have already been health impacts from the Crossarm site. They believe that children have been particularly affected with developmental problems, hormonal disorders, possible immune system problems, reproductive problems, and tumors. The level of dioxin in the yards yet to be cleaned up is high enough to support those fears, particularly in the light of the recently released Dioxin Reassessment. I would have liked to see a recommendation for some study of health problems described by citizens.

    Response to Comment 2: A health study of citizens was not recommended because the levels of contaminants (including dioxin) found off-site have not been reported to be associated with detectable human adverse health effects. The recently released EPA Dioxin Reassessment added additional adverse health outcomes which may be possible from exposure to dioxin, but it did not lower the level at which adverse outcomes might be expected to occur. A recommendation to do a health study in this community should not be made until an association is found that can be used to focus the study design. If an association is found that links an adverse health outcome to the level of contaminants found off-site, this situation will be reassessed, and a health study may be proposed.

Comment 3: An earlier draft of the Health Assessment recommended testing of fish caught in the immediate area. This should be recommended. Did it occur?

    Response to Comment 3: ATSDR's Preliminary Health Assessment for American Crossarm and Conduit was written in 1990. One recommendation stated, "Sampling of fish tissue from Dillenbaugh Creek should be considered, so that a determination can be made regarding the human health concern from the dioxins in the sediments." There was very little environmental data on this site in 1990. EPA's remedial investigation was completed during September 1992. The results of testing of sediment and water samples from Dillenbaugh Creek and the Chehalis River did not justify a follow-up sampling of the biota. For that reason it was not recommended in the current health assessment.

Comment 4: In the testing of well water it was not clear that the wells that are being used for irrigation were tested for contamination. In terms of animals feeding on the crops grown from the areas serviced by these wells, would not it be important to know the levels of contamination (if any) since the chemicals of concern have the ability to accumulate in fatty tissue of animals or people who may consume them?

    Response to Comment 4: The assessment states, "Thirty-three domestic, irrigation, and municipal wells are located within a two-mile radius of ACC. The majority of these wells are in the outlying areas of Chehalis to the south and southwest, and are separated from the facility by the Chehalis and Newaukum rivers and Dillenbaugh Creek. Area well water levels range from 30 to 110 feet below ground surface, with about 75 percent of the wells used for domestic purposes. The wells closest to ACC (within a 1/4 mile radius) are used for irrigation (1)."

    EPA's Remedial Investigation (RI) found groundwater contamination on-site in the immediate vicinity of the probable sources. Therefore, no off-site production wells were tested. The RI stated in part that the contaminants in groundwater are flowing southwestward toward the Chehalis/Newaukum river system and will discharge about 3,500 feet west of the site. Travel time for groundwater to move from the site to the river system is in the range of 40 to 400 years.

Comment 5: What sort of uptake is expected in plants grown on contaminated soil? To date I have seen or heard nothing to indicate that the public has been warned in any way about these potential risks.

    Response to Comment 5: Plant uptake of soil constituents is dependent on the type of plant, the constituent, and a multitude of soil conditions (e.g., acidity, alkalinity, organic matter, etc.). The levels of contaminants of concern off-site are low. However, some plants may biologically concentrate the soil contaminants. A prudent person would not grow plants for consumption in the vicinity of ACC.

    Over the years several warnings have been issued to local residents by the Lewis County Health District, not to eat plants grown near ACC. The Health Assessment recommended that, "People should be advised not to grow gardens in the off-site contaminated area."

Comment 6: The health assessment did not physically attain information from people claiming to have adverse health affects.

    Response to Comment 6: Adverse health effects from residents near the site were reported to DOH in a one-page "fact-finding survey" designed and administered by one of the residents, and by telephone interviews with residents who contacted DOH. The name and telephone number for a DOH contact was published in a local newspaper article during December of 1992 so residents with adverse health effects would have the opportunity to report to DOH. All of the collected information was considered in the writing of the health assessment.

Comment 7: During the flood, pentachlorophenol was deposited on wood surfaces throughout the surrounding neighborhood. There has been no mention of removal of these items, just soil around the homes.

    Response to Comment 7: The assessment states on page 2, last paragraph, last sentence, "In 1988 and 1989, EPA incinerated on-site some of contaminated soil, sludge and debris [which includes wood] (1). Incineration generated about 207 tons of ash which is presently stored on-site (5)." EPA's Record of Decision states in part (page 1-1) "An emergency removal action was initiated during late 1986 to remove contamination distributed during a flood in the Chehalis Avenue area. In 1988, an incinerator was brought onto the facility to incinerate the principle threat (e.g., contaminated material from that cleanup)."


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