PUBLIC HEALTH ASSESSMENT
C&D RECYCLING
FREELAND, LUZERNE COUNTY, PENNSYLVANIA
Based on the information reviewed, PADOH and ATSDR have concluded that the non-site related lead identified in private wells is a public health hazard. The C&D Recycling site is an indeterminate public health hazard because information needed to evaluate potential exposure pathways (air monitoring during remediation) is not available. A summary of findings include the following:
- Well #10 may be in the direction of groundwater flow from the site.
- Surface soils in neighboring yards have not been tested using EPA protocols.
- Ambient air in adjacent off-site areas has not been sampled for pertinent contaminants (lead and manganese).
- The likely source of lead in Well #1 occasionally detected above regional levels is a coal mine spoil waste pile.
- Before facility closure, on-site workers may have been exposed to contaminants in air and soils. People living near the site also may have been occasionally exposed to contaminants in the air. Smoke was seen leaving the facility boundary. Data needed to evaluate the public health significance of past exposures are lacking, and no information is available on levels of contaminants released through the air when the facility was operating.
- A ROD was issued September 30, 1992. The selected remedy is protective of public health over the long term; however, short-term exposure to contaminants may be possible if conditions are dry and windy during the remediation. If on-site disposal is accepted as an alternative, ATSDR cannot comment on the effectiveness of such an alternative without reviewing the proposal. Because the process of contaminant stabilization and on-site disposal is relatively new, institutional controls restricting land use may enhance the effectiveness of such an alternative. Land use restrictions could be revised as information becomes available on the effectiveness of the disposal cell over time.
Site Characterization Recommendations
PADOH and ATSDR make the following recommendations:
- Conduct monitoring of residential Well #10 to determine if groundwater quality may degrade in the future.
- Conduct 0-3 inch soil sampling in nearby residential yards and the wooded area near the site to determine the extent of off-site contamination.
- Conduct off-site air monitoring for lead and manganese during remediation.
Cease/Reduce Exposure Recommendation
- Remove the coal mine spoil waste pile that crosses the property where residential Well #1 exists.
- Local authorities should consider institutional controls on land use at and near the site if on-site disposal of stabilized contaminated materials is approved.
- If off-site disposal is selected as the remedy, dust should be controlled as indicated in the ROD.
Health Activities Recommendation Panel (HARP) Recommendation
The information and data developed in the public health assessment for the C&D Recycling site, Luzerne County, Pennsylvania, have been evaluated by ATSDR's Health Activities Recommendation Panel for appropriate followup with respect to health activities. Because of the past, current, and possible future exposure to lead (which is not site related) at levels of public health concern, the Panel determined that community health education and a site-specific biological indicators of exposure study are indicated.
The public health action plan (PHAP) for the C&D Recycling site contains a description of actions to be taken (or that have been taken) by ATSDR and/or other governmental agencies at and in the vicinity of the site subsequent or prior to the completion of this public health assessment. The purpose of the PHAP is to ensure that this public health assessment not only identifies public health hazards, but provides a plan of action designed to mitigate and prevent adverse human health effects resulting from exposure to hazardous substances in the environment. Included is a commitment on the part of PADOH and ATSDR to follow up on this plan to ensure that it is implemented.
Public Health Actions Planned
ATSDR and PADOH have developed the following public health actions based on the HARP recommendations:
- ATSDR, in cooperation with the PADOH, will provide environmental health education for the population residing near the former C&D Recycling facility to assist the community in understanding possible adverse health outcomes associated with exposure to lead that is not believed to be site-related.
- PADOH has requested funding for a site-specific indicators of exposure project. ATSDR's Division of Health Studies will conduct, as resources permit, a blood lead screening project in the vicinity of the site to determine exposures to lead. However, because lead exposures are not limited to the vicinity of the site, HARP advised that a regional approach to the problem is needed. PADOH's Childhood Lead Poisoning Prevention Program has a system to provide case management and environmental investigation services to families of children who have venous blood lead levels at or above 20 g/dL, as resources permit, in non-lead project areas in the Commonwealth.
- PADOH's Health Assessment Team will provide the Childhood Lead Poisoning Prevention Program with copies of this public health assessment and the health consultation that is being prepared for this site. In addition, results of the blood lead screening project, which will be done by ATSDR as resources permit, will be forwarded to the program.
- PADER sampled Well #10 on March 10, 1993. No contamination was found. No data available indicate that further monitoring of that well is needed at this time. Other wells in the area were sampled at that time. Some of those wells are upgradient of the site. No arsenic or selenium were detected in any of the wells tested (see Attachment regarding that community concern). Lead was present in two of the upgradient wells, which further supports the evidence that lead is present in groundwater regionally and is not site related.
- A health consultation is being prepared to address specific community concerns and environmental data that were provided after the close of the public comment period. That consultation should be available for public comment on or around June 28, 1993.
The EPA has indicated that they plan to take the following actions related to the recommendations in the public health assessment.
- EPA has conducted surface soil (less than or equal to 3 inches) sampling in off-site areas to determine the extent of off-site soil contamination. The results of the sampling are evaluated in the health consultation.
- EPA is planning to conduct off-site air monitoring for lead, manganese, and other appropriate contaminants during remediation.
Furthermore, PADER has indicated that they will consider removing the coal mine spoil waste pile identified in this public health assessment. Residential Well #1 was sampled March 10, 1993, as part of an investigation of the mine spoils. Although lead levels were lower than in previous samples, the highest lead concentration detected from the well was 13.5 µg/L. That level is below, but approaching, EPA's Action Level of 15 µg/L.
Preparers of Report:
-
Robert M. Stroman, R.Ph.
Pharmacist
Pennsylvania Department of Health
Kandiah Sivarajah, Ph.D.
Director, Health Assessment Program
and State Toxicologist
Pennsylvania Department of Health
ATSDR Regional Representative:
-
Charles Walters, Jr., Senior Regional Representative
Public Health Advisor
EPA Region III
Office of the Assistant Administrator
ATSDR Technical Project Officers:
-
Gail Godfrey
Technical Project Officer
Remedial Programs Branch
Division of Health Assessment and Consultation
The C&D Recycling Site Public Health Assessment has been prepared by the Pennsylvania Department of Health under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the public health assessment was initiated.
Gail D. Godfrey
Technical Project Officer, SPS, RPB, DHAC
The Division of Health Assessment and Consultation, ATSDR, has reviewed this public health assessment and concurs with its findings.
Robert C. Williams, PE, DEE
Director, DHAC, ATSDR
- C&D Recycling Site, Final Draft Remedial Investigation Report, July 1990.
- Population Characteristics, Pennsylvania Part 40, U.S. Department of Commerce, Bureau of the Census, August 1982.
- 1990 Municipal Population, Pennsylvania U.S. Department of Commerce, Bureau of the Census.
- 1986 Population and 1985 Per Capita Income Estimates, Pennsylvania U.S. Department of Commerce, Bureau of the Census, 1987.
- Public Schools, Elementary Enrollments, 1989-1990; Pennsylvania Department of Education, 1990.
- Directory of Pennsylvania Hospitals, State Health Data Center, Pennsylvania Department of Health, December 1990.
- Nursing Home Directory, State Health Data Center, Pennsylvania Department of Health, August 1989.
- U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry, Toxicological Profile for Lead, June 1990.
- U.S. Department of Health and Human Services/Public Health Service/Centers for Disease Control, Preventing Lead Poisoning in Young Children, January 1985.
- Pennsylvania Vital Statistics Record File, State Health Data Center, Pennsylvania Department of Health, 1991.
- Estimates of Pregnancies and Pregnancy Rates for the United States, 1976-1981; Ventura, Taffel and Mosher; Public Health Reports, January-February, 1985, Vol. 100, No. 1, pp. 31-33.
- January 21, 1992 memorandum, C&D Recycling Site - Blood Lead (Pb) Data and associated data package from Jack Kelly, ATSDR Region III, Regional Representative to Dr. Adrienne Hollis, DHAC/RPB, ATSDR, Atlanta, Georgia.
- Madhaven S, et al. (1989). Lead in soil: Recommended maximum permissible levels. Environ Res 49:136-42.
- Agency for Toxic Substances and Disease Registry. Lead Toxicity: Case Studies and Environmental Medicine. June 1990.
- Agency for Toxic Substances and Disease Registry. Toxicological Profile for Manganese and Compounds. July 1992.
- Centers for Disease Control and Prevention. Preventing Lead Poisoning in Young Children. October 1991.
- Record of Decision. C&D Recycling Site. Foster Township, Luzerne County, Pennsylvania. September 30, 1992.
ATTACHMENT Comments from September 1, 1992, letter:
Comment: The March 1991 draft Public Health Assessment report should be withdrawn for the
following reasons:
Response:
Second: No contaminant plume has been identified at the site; however, lead and manganese are
present in the groundwater. When a citizen expressed concern about the "leach pit," PADOH
and ATSDR conducted a special investigation to closely examine the location of the pit in
relation to nearby residents. That investigation resulted in the determination that lead and
manganese in the groundwater at the site, including at the leach pit, were flowing away from the
community east of the site. Groundwater flow direction is determined by water elevations and
local geology. Figures 10 and 11 illustrate some of the information used to determine
groundwater flow direction. One well, Well #10 discussed in answer 1, was identified as
possibly being downgradient of one area at the site.
Third: As a result of this comment, a statement was added to the Environmental Contamination
and Other Hazards section of this document to explain how and why contaminants are selected as
contaminants of concern. Although processes that took place at the facility may have resulted in
formation of other contaminants, none were identified as contaminants of concern.
Fourth: Groundwater contains lead at levels of public health concern. However, a completed
exposure pathway through groundwater has not been identified. Comment: The report failed to consider groundwater as a pathway, and it failed to consider the
multiplier effect of air and groundwater as joint pathways, cumulatively increasing the risk.
Response: To date, there is no evidence supporting a hydrogeologic connection between the site
and nearby residential wells (except possibly Well #10, which contains no contamination as of
March 10, 1993). Because the groundwater pathway has been eliminated, there is no multiplier
effect between air and groundwater.
Comment: Neither ATSDR nor EPA considered the fact that the materials disposed of at the site
included all of the aforementioned toxic metals, and that the process resulted in their conversion
into enormously more toxic compounds.
Response: The substance, no matter how toxic, cannot hurt people unless people are exposed to
levels of the contaminant that cause health problems. There are undesirable levels of
contaminants in the environment at the site, but no documented exposures to those contaminants
has occurred as far as ATSDR and PADOH can determine.
Comment: Neither ATSDR nor EPA considered the disposal of toxic materials into the
groundwater by a 22-foot deep leach pit.
Response: On October 15, 1992, representatives from PADOH and PADER further investigated
the groundwater flow at the C&D Recycling site. On October 16, 1992, representatives from
ATSDR, EPA, PADOH, and PADER made a site visit to investigate the facility's drainage
system including the area referred to as the "leach pit." Those investigations are discussed in this
public health assessment. The results of the investigation further supported the conclusion that,
although lead and manganese are in the groundwater at the site, the flow direction of the
groundwater prevents the contaminants from entering private wells with the one possible
exception of Well #10. That well is not contaminated now, and recent monitoring substantiates
that finding.
Comment:
Response:
Comment: Neither in the Remedial Investigation nor in any other fashion was ATSDR advised
of the findings of arsenic over 1,000 parts per million in the sediments from the pathways
draining the process work area, by PADER, in 1985.
Response: One sediment sample from a pond south of the site collected in 1985 by PADER
contained arsenic at 1,147.16 ppm (mg/Kg). No additional sampling was conducted at that time
to verify the results. The data validity was questioned by the agencies because the results
appeared to be an anomaly (possibly a laboratory or sampling error because the results have not
been replicated). Additional pond sediment samples were collected in 1988 and 1989 (sampling
locations are identified on Figure 8). Those samples were collected and analyzed using accepted
QA/QC protocols. No contaminants of concern were identified in those samples. Additionally,
no recreational, fishing, or other use by people has been identified for that pond. Therefore,
people are not expected to come into contact with any contaminants that may be present below
levels of public health concern.
Comment: Several sampling events showing higher levels of arsenic, selenium, and other such
materials in groundwater were deleted from the Remedial Investigation, particularly the sampling
events of January 1987 and the sediment results in August 1985.
Response: Chemical concentrations present in groundwater may increase or decrease, depending
on rainfall and other factors, at different times of the year. Therefore, on-site chemical levels in
groundwater are expected to fluctuate. However, groundwater flowing from the site will not
reach private wells east of the site because of groundwater flow direction. Monitoring of the
private well west of the site has been recommended (and conducted) because of the slight
possibility that groundwater from the site may reach that well. The contamination in the
sediment was discussed in the previous response.
Comment: Neither in the Remedial Investigation Report nor any other document is it revealed to
ATSDR that virtually all the negative selenium samples were deemed out of control limits, and
the EPA positive results for arsenic and selenium in groundwater were deemed unusable because
biased extremely low (June 1988 sampling event).
Response: ATSDR and PADOH are aware of the analytical problems associated with some of
the arsenic and selenium samples obtained at the C&D Recycling site. However, other samples
analyzed for arsenic and selenium from residential well water near this site were acceptable.
Conclusions were based on the analyses that were within QA/QC parameters.
Comment: The soil sample results were biased extremely low by reason of having been taken at
depths of 1-6" rather than the top surface layer. When the top surface layers were finally sampled
at Congressional request in November 1991 and June 1992, they showed lead levels in soil in the
residential areas off-site in the range of 400 ppm to 500 ppm in soil. These results were not
provided to ATSDR.
Response: Lead is a metal that occurs naturally in soils in the area. Naturally occurring lead
levels vary from region to region and are dependent on rock formations found in the regions.
Human activities, such as mining operations, can also affect expected surface soil lead levels. At
areas around the C&D Recycling site, the average soil lead levels are expected to average about
3.3-119 ppm.
Madhaven, et. al. derived a "safe" or permissible level of lead in soil. The authors proposed
permissible levels of lead in soil ranging from 250 to 1,000 ppm depending on site conditions
(13). The 250 ppm value applies to a worse case scenario in which an area without grass cover is
repeatedly used by children under 5 years of age. Children in that age group are considered very
likely to put objects (including dirt) in their mouths. In this situation, it was estimated that a soil
lead concentration of 250 ppm would add, at most, about 2 µg/dL to the blood level of children.
Levels of lead in the residential soil in the range of 400 to 500 ppm are not likely to be harmful to
children residing in nearby residences. However, in the public health actions that are planned,
blood lead levels of area residents will be evaluated. Although that evaluation will tell us how
much lead is in the blood of individuals, it will not tell us if that lead came from the water, soil,
paint chips, or other possible sources.
Comment: In the arsenic, selenium and antimony sampling, no effort was made to determine
whether these materials are present in oxide or in compound form.
Response: The toxicity of a chemical can increase or decrease, depending on its form. The type
of compound present may be important for EPA to consider when determining what clean-up
actions may be necessary. However, as previously stated, for any contaminant to be harmful to
human health, people must come in contact with the contaminant at levels that cause illness. A
completed site-related exposure pathway for nearby residents has not been identified at the C&D
Recycling site. (The possible exception was the previously discussed air pathway. The air
pathway only involved those materials burned in the open pit. The compounds named above
were not believed to be in the lead and plastic casings that were burned. More information
would be necessary to evaluate the past air pathway. A health consultation is being prepared that
will assess that information thoroughly. The health consultation should be available for public
comment on or about June 28, 1993.)
Comment: No account was taken or given of the human health effects which have been
presented to EPA: these include miscarriages and other diseases associated with selenium and
arsenic poisoning.
Response: Miscarriages cannot be adequately addressed using Pennsylvania Vital Statistics
(PVS). A very large number of miscarriages (probably in excess of 90%) are not reported
because those that occur under 16 weeks of gestation are not included in the database. Those that
are miscoded as to place of residence or not reported by physicians also may be lost when trying
to capture data. The data obtained from PVS is, however, more comprehensive than most states
in that Pennsylvania is one of the few states that reports fetal deaths at 16 weeks of gestation.
Most states do not report fetal deaths that occur at less than 20 weeks of gestation. Therefore,
since there is no mechanism to evaluate miscarriages under 16 weeks of gestation, except
through special studies, we can only examine the frequency of fetal deaths in this public health
assessment. Specifically, we compared reported fetal deaths for Foster Township with the state
of Pennsylvania. As indicated in the public health assessment, the frequency of fetal deaths is
quite low.
ATSDR and PADOH have evaluated health outcome and environmental data for the site. To
date, the health outcome and environmental data evaluated support the conclusion that no
exposure to arsenic or selenium originating from the C&D Recycling site has occurred and
caused illnesses.
Comment: No effort was made to obtain descriptions of processes utilized from former
employees at the site. Interviews for those employees disclosed to the township and the
surrounding residents the facts that the plant burned lead through 1983, that the plant burned
PVC through 1983 (which PVC contained copper, and the acid from which produced the fumes
that produced the compounds), that the site handled acid from batteries, that the site handled
arsenic, mercury, and PVCs in telephone equipment, and that the hot metal was washed with
water (itself contaminated with acid).
Response: The burning of lead and plastic casings is discussed in this public health assessment.
A likely completed pathway is identified in this document for workers and nearby residents as a
result of that burning. The document states that without more information, those likely
exposures cannot be evaluated. The public health actions planned include blood lead evaluation
for nearby residences. That study should provide needed information on possible health effects
that can be expected if lead is found in the blood; however, the study will not provide
information on the source(s) of the lead.
(Note: The health consultation that is being prepared addresses this issue in more detail.)
Comment: You were evidently not informed of the fact that EPA contractors took split samples
and data validation data, which established that selenium and arsenic concentrations in well
water were biased "extremely low," but failed to make any valid assessment.
Response: As previously stated, ATSDR and PADOH are aware that some sampling data were
rejected because the data were not within established quality control/quality assurance guidance.
However, other sample analyses were acceptable. Conclusions and recommendations in this
document are based on the data that are described in the Quality Assurance and Quality Control
section of the public health assessment.
Comment: Your discussion of soils and sediment is unfortunately irrelevant since you did not
know that AT&T had obliterated the major sediment channel, Mill Hopper Creek, prior to taking
the readings. The actual readings, especially of arsenic, were much higher prior to the
obliteration in December 1987.
Response: ATSDR and PADOH are aware of the fact that AT&T undertook actions to control
erosion and runoff from the site. That was done in accordance with, and subject to, the terms and
conditions of the Administrative Order on Consent, U.S. EPA Docket No. III-87-31-DC.
Although the sediment channel may have been contaminated prior to the implementation of
erosion control measures, the channel was not accessible to people for exposures to occur.
Workers who were involved with the erosion control actions were informed about conditions and
instructed in how to protect themselves from exposure.
Comment: Contrary to the statement on pages 17 and 18, there were two fetal deaths
immediately adjacent to the site in 1984-85. In one of them, blood lead levels were taken, and
Dr. John Rosen testified that lead poisoning is a possible cause, based on his laboratory analysis.
The comparison should be to rural areas, since drug problems in metropolitan areas account for a
high proportion of fetal death rates, and the statewide comparison is thus inappropriate.
Response: The database did not capture those deaths because of miscoding or non-reporting.
We appreciate the mother of one of the children bringing this to our attention and offer the
families our apology for not finding that information sooner. Dr. Rosen's laboratory findings are
evaluated and discussed thoroughly in the health consultation that will be available for public
comment on or about June 28, 1993. However, the letter which ATSDR has from Dr. Rosen
states that no lead was found in fetal tissues.
The comparison of small, similar communities for health outcome data is desirable.
Unfortunately, the databases that are established preclude the capability of doing that at this time.
A new system is under development, Geographical Information System, that will, hopefully,
generate information on similar communities. However, as noted by the miscodings, the health
outcome database that is established, although excellent for state comparisons, may not be as
valuable for small-area comparisons.
Comment: The reference to Taylor for lead levels is erroneous. At Table 13 of Taylor, the
Luzerne County values of lead in the Mauch Chunk formation average approximately .003, and
there is no reason to believe that the Foster Township sites merit a higher value. In fact, the on-site wells more distant from the leach pit show lower than 5.
Response: The Mauch Chunk formation is generally physically and chemically similar
throughout the region. To achieve the best statistical values, one needs to consider the entire
formation and not limit the evaluation to a small area of that region. The median concentrations
of 7.0 µg/l of lead presented in Table 9 of the 1984 Taylor report is likely representative of
averages of the entire region.
Opinion (an opinion was received from a consulting physician that was not in the form of a
comment): Some people in the community around the C&D site appear to have symptoms
consistent with arsenic and selenium poisoning and there is environmental data to support this.
Response: The opinion that was submitted did not contain all the information the consultant
used to form the opinion. Therefore, ATSDR cannot evaluate that opinion. No environmental
data indicate that anyone has been exposed to arsenic or selenium as a result of operations at
C&D. For a person to be poisoned by a chemical, that person must be exposed to the chemical at
a level that can cause harm.*
The available health outcome data are discussed in the Health Outcome Data Evaluation section
of this document. ATSDR and PADOH have reviewed the health outcome data and find no
evidence that the site has affected the health of nearby residents. However, the data have
limitations which are discussed in the document. One limitation is that no specific community
studies have been conducted. That is why a blood lead level test is under consideration as
outlined in the Public Health Actions section of this document.
Arsenic and selenium at the site did not meet the criteria for selection as contaminants of
concern. In addition, no completed exposure pathway was identified for those chemicals.
However, the community does have concern about those chemicals and why those chemicals are
present in their bodies. For that reason, a discussion of the role of those minerals in the body is
warranted.
The biological sampling data indicate that people in the area do not have high arsenic or
selenium levels in their bodies. People are expected to have a certain amount of arsenic and
selenium in their bodies, depending on diet and other factors. For instance, people who eat large
amounts of seafood will usually have more arsenic in their bodies than people who do not eat
seafood. People who drink 2 liters of water per day average about 5 µg/dL blood levels of
arsenic. In areas of the country where natural levels of arsenic are higher, people may have as
much as 100 µg/dL blood levels. Some evidence indicates that small amounts of arsenic in the
normal diet (10-50 ppb) may be beneficial to your health (Toxicological Profile for Arsenic,
1992).
Selenium is an essential mineral (a mineral needed for proper body function that can only be
obtained through the diet). On the average, people in the United States eat from 0.071 to 0.152
mg selenium per day. Whole blood selenium levels in the general United States population range
from 0.08 to 0.30 mg selenium per liter. People who take vitamin and mineral supplements
containing selenium will likely have more selenium in their bodies than people who do not take
those types of vitamins. Also, many over-the-counter medications and shampoos contain
selenium (Toxicological Profile for Selenium, 1989). The levels of arsenic and selenium seen in
biological samples submitted to date are within expected levels.
*(Since the time that opinion was submitted, more information has become available to ATSDR
and PADOH for review. A more thorough discussion of that information will be available when
the health consultation is released for public comment on or about June 28, 1993.)
Figure 11.
PUBLIC COMMENTS AND RESPONSE












