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ADDENDUM TO PUBLIC HEALTH ASSESSMENT

UNITED CREOSOTING COMPANY
CONROE, MONTGOMERY COUNTY, TEXAS

CONCLUSIONS

From information reviewed, we judge this site to be a public health hazard as a result of the potential for long-term exposureto hazardous substances. Based on environmental data and citizenconcerns received, exposures to contaminated soil through skincontact and ingestion may have occurred in the past. Anypotential present or future health hazards at this site will beeliminated by appropriate remediation. Present exposure pathwaysare limited as a result of physical barriers (fences, temporarycap, and site drainage alterations). Once the site is remediatedas planned, these exposure pathways will be eliminated, and thesite would pose no public health hazard.

Current exposure may result from contact with contaminated surface soil through dermal contact and ingestion. The potential for inhalation of particles released from contaminatedsurface soil will increase with excavation associated withremediation. Ground water contamination does not pose a currenthealth hazard; however, in the unlikely event contaminatedaquifers are tapped as a potable water source, complete exposurepathways would exist.

The high laboratory detection limits for contaminants in crawfish makes it difficult to determine if this pathway is of concern.

During remedial activities involving excavation of subsurfacesoil, neighboring residential populations may have an increasedrisk of inhalation of contaminated dusts. These exposures can beminimized through appropriate dust control measures during theremedial activities. Remedial workers will have an increasedrisk of exposure to contaminants through inhalation, ingestion,and dermal absorption from soil contact. Those exposures may be minimized through the use of proper personal protectiveequipment, work techniques, and dust control measures.

RECOMMENDATIONS

  1. Attention should be given to insuring the integrity of the temporary cap (until remediation is completed at which time the contaminated soils will be placed under a permanent cap) along with maintenance of fences and posted warnings to reduce possible contact with areas of contamination.
  2. Monitoring of ground-water migration should continue throughout the natural attenuation phase of remediation.
  3. Measures should be taken to assure that future use of contaminated ground water does not occur.
  4. During remedial activities, optimal dust control measures should be used to reduce the possibility of resident and worker exposures to contaminated media.
  5. Workers should be provided with the appropriate personal protection equipment and training in accordance with applicable Occupational Safety and Health Administration (OSHA) regulations and OSHA and National Institute of Occupational Safety and Health guidelines and advisories.
  6. Monitoring of ambient air in residential areas duringremediation should be conducted to determine if nearbyworkers and residents may be exposed to contaminants.

HEALTH ACTIVITIES RECOMMENDATION PANEL (HARP)

In accordance with the Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA) of 1980, as amended, thedata and information of the United Creosoting Company HealthAssessment Addendum has been evaluated for appropriate follow-upby the Health Activities Recommendation Panel (HARP). The HARPdetermined that either a disease and symptom prevalence study orsite-specific surveillance may be indicated. Based on theinformation presented in the health assessment addendum, theATSDR Division of Health Studies concurred that informationpresented in the addendum met criteria for both site-specificsurveillance and a disease and symptom prevalence study. Also,an evaluation of health through biomedical testing may beconsidered. If funding can be obtained, the Texas Department ofHealth will consider conducting such studies at this site. Inresponse to the community health concerns identified, TDH inconjunction with ATSDR will provide community health educationthat responds to these concerns. This education will becoordinated with the Montgomery County Health Department. ATSDRand TDH will continue to review the environmental data as itbecomes available, particularly during the site remediation, andwill reevaluate the site for any other indicated follow-upactivities.

PUBLIC HEALTH ACTION

To respond to community concerns, and based on the HARPrecommendations, the following actions have been or will beperformed to meet the needs expressed by the Recommendations ofthis Public Health Assessment Addendum.

Actions Undertaken

  1. TDH has applied for and received from ATSDR funding to conduct a site-specific surveillance study in the Tanglewood East subdivision.
  2. The Texas Water Commission, in cooperation with EPA, will continue monitoring of the groundwater as specified in the 1986 record of decision (ROD). The ROD requires the groundwater be monitored for 30 years following the completion of the remedy. If significant increases in contamination are detected during this period, additional corrective measures will be evaluated.
  3. TWC will investigate restricting future use of contaminated groundwater.
  4. TWC, in cooperation with EPA, requires strict dust control in the residential remedial action specifications. Additionally, the industrial remediation contract will include similar specifications for strict dust control to minimize the production of dust.
  5. TWC, in cooperation with EPA, will continue to require ambient air monitoring during both the residential and industrial remediations. In the event that any compound exceeds acceptable limits, work will be modified to reduce those levels to within the allowed limits. Further, if levels continue to exceed required limits, work will be shut down until the levels are in compliance with specifications.
  6. TWC and EPA require that contracts for all Superfundremedial actions comply with appropriate OSHA workerprotection requirements. The contractors for theresidential and industrial remediations will be submittingHealth and Safety plans which will detail how they willcomply with safety regulations, including OSHA 1910.120pertaining to work on a hazardous waste site.

Actions Planned

  1. TDH will prepare a summary of this Health Assessment Addendum and will make a copy available to each household in the Tanglewood East subdivision. As part of the summary, information will be provided as to where the full report will be available for examination. Contact numbers for TDH and ATSDR staff will also be provided in the Summary.
  2. The Texas Water Commission, in cooperation with EPA, willmonitor the temporary storage area and site fence on aregular basis following the completion of the residentialremediation to ensure integrity is maintained. Any damageto the cover, fence, or other facilities will be repaired. The permanent cover and fencing will also be monitored andmaintained following the completion of the industrialremediation.


PREPARERS OF REPORT
ReviewersJean D. Brender, R.N., Ph.D.
Director, Environmental
Epidemiology Program
Texas Department of Health

Suzanne D. Hahn, D.V.M.
Health Assessment Coordinator
Environmental Epidemiology Program
Texas Department of Health

Typists and GraphicsMandy Holt
Administrative Technician
Texas Department of Health

Nancy B. Ingram
Administrative Technician
Texas Department of Health

Leticia Cano
Secretary
Texas Department of Health

ATSDR REGIONAL REPRESENTATIVES
Carl Hickam, R.S.
Senior Regional Consultant
ATSDR - Region 6

George Pettigrew, P.E.
Regional Representative
ATSDR - Region 6

ATSDR TECHNICAL PROJECT OFFICER
William Greim, M.S., M.P.H.
Environmental Health Scientist
Remedial Programs Branch
Division of Health Assessment
    and Consultation


CERTIFICATION

This Public Health Assessment Addendum was prepared by the TexasDepartment of Health under a cooperative agreement with theAgency for Toxic Substances and Disease Registry (ATSDR). It isin accordance with approved methodology and procedures existingat the time the Public Health Assessment Addendum was initiated.

William J. Greim
Technical Project Officer, SPS, RPB, DHAC

The Division of Health Assessment and Consultation, ATSDR, hasreviewed this Public Health Assessment Addendum and concurs withits findings.

Robert C. Williams
Director, DHAC, ATSDR

REFERENCES

  1. Roy F. Weston, Inc. for the Texas Water Commission incooperation with the United States EnvironmentalProtection Agency. Site Investigation, UnitedCreosoting Company Site, Volume I, Conroe, Texas. 1985.
  2. Roy F. Weston, Inc. for the Texas Water Commission incooperation with the United Sates EnvironmentalProtection Agency. Site Investigation, UnitedCreosoting Company Site, Volume II, Conroe, Texas.1985.
  3. Roy F. Weston, Inc. for the Texas Water Commission incooperation with the United States EnvironmentalProtestion Agency. Feasibility Study, United CreosotingCompany Site, Volume I, Conroe, Texas. 1986.
  4. Roy F. Weston, Inc. for the Texas Water Commission incooperation with the United States EnvironmentalProtection Agency. Feasibility Study, UnitedCreosoting Company Site, Volume II, Conroe, Texas.1986.
  5. Roy F. Weston, Inc. for the United States EnvironmentalProtection Agency. Data Evaluation Report Focused Site Investigation United Creosoting, Conroe, Texas. 1990.
  6. 1990-1991 Texas Almanac, copyright 1989, published by the Dallas Morning News, Mike Kingston, editor.
  7. ATSDR (Agency for Toxic Substances Disease Registry)1990. Toxicological Profile for PolycyclicHydrocarbons. Prepared by Clements Associates, Inc.,Public Health Service, U.S. Department of Health andServices.
  8. ATSDR (Agency for Toxic Substances Disease Registry)1989. Toxicologic Profile for 2,3,7,8-Tetrachloro-dibenzo-p-dioxin. Prepared by the Syracuse ResearchCorporation. Atlanta, Ga.: ATSDR, Public HealthService, U.S. Department of Health and Human Services.
  9. ATSDR (Agency for Toxic Substances Disease Registry)1989. Toxicological Profile for Pentachlorophenol.Prepared by Clement Associates. ATSDR, Public HealthService, U.S.Department of Health and Human Services.
  10. 1980 Census Data, Texas Natural Resources InformationSystem, Census of Population and Housing, 1980 Summarytape 1.
  11. National Library of Medicine, Toxic Chemical ReleaseInventory Database, Accessed February, 1991.

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