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PETITIONED PUBLIC HEALTH ASSESSMENT

LAFARGE CORPORATION - ALPENA PLANT
ALPENA, ALPENA COUNTY, MICHIGAN


SUMMARY

The Lafarge Corporation - Alpena Plant is an operating portland cement production facility in northeast Alpena, Michigan. The plant began operations in 1908, and the Lafarge Corporation bought it in 1986. There has been a long history of cement dust blowing from the plant into the city to the southwest. Lafarge has recently begun using hazardous waste to supplement the fuel in their kilns. The plant has been in consistent violation of a Consent Agreement with the Michigan Department of Natural Resources/Department of Environmental Quality, because the effluent from their kilns contains more hydrogen chloride than the Agreement allows. The plant has also been frequently cited for many other violations of environmental regulations.

Citizens of Alpena are concerned about the potential health and environmental effects of emissions from the Lafarge plant and pollution from other sources in the city. They are also concerned about perceived high rates of incidence of various health problems, including cancer, in the city. A citizen petitioned the Agency for Toxic Substances & Disease Registry (ATSDR) for a health assessment of the hydrogen chloride emissions from the Lafarge plant.

Citizens of Alpena are also concerned about hydrogen chloride in the ambient air. Due to equipment and sampling delays, air data was not available for inclusion in this document. Nonetheless, air data that is currently being collected will be reviewed in a future document.

The contaminants that have been found in Alpena at concentrations potentially of human health concern (that is, the concentrations exceeded screening levels for further investigation) are lead in the soils and benzene and carbon tetrachloride in the air. The concentrations of these chemicals found in Alpena were below those at which adverse health effects have been seen and are comparable to those typically found in urban areas. A preliminary evaluation of available cancer data did not find a significantly high rate of cancer in Alpena County. From the currently available data and information, the Michigan Department of Community Health (MDCH) has not been able to identify an environmental cause for the health problems reported by some residents of Alpena. Therefore, this site is classified as "no apparent public health hazard." Further sampling and analysis of environmental media and further evaluation of health data are under way.


BACKGROUND

A. Site Description and History

The Lafarge Corporation Alpena Plant is located on the northeast(1) side of Alpena, Alpena County, Michigan (Figure 1). The Huron Portland Cement Company (later acquired by National Gypsum Company) built the plant between 1906 and 1908 and manufactured portland cement there from 1908 until approximately 1980, when they closed the plant (1). The Lafarge Corporation bought the plant in 1986 and has resumed cement production.

Cement dust from the plant has blown into the city whenever the wind was from the northeast and the plant was in operation. The operators have collected waste cement kiln dust (CKD) and disposed of it in three areas:

  1. an 80-acre pile along the shore of Thunder Bay east of the plant (Figure 1). This pile has filled in part of Thunder Bay.

  2. a former quarry northwest of the plant, west of Wessel Road, called the Wessel Road Quarry by the MDEQ, which has been closed and covered with soil. The resulting hill has been referred to by local residents as "Pike's Peak."

  3. part of another quarry north-northeast of the plant, east of Wessel Road, which is in current use and regularly covered.

As one way to improve the economics of operating the plant, Lafarge has been mixing hazardous waste, obtained from other sites or producers, with the fuel in their kilns. Theoretically, under optimum conditions, the waste would be totally burned, leaving harmless combustion products, primarily carbon dioxide and water vapor. In May 1986, the Michigan Department of Natural Resources (MDNR) issued a permit to Lafarge Corporation which allowed them to burn hazardous waste at their Alpena Plant. Local citizens and environmental organizations have opposed this operation and petitioned ATSDR to conduct a public health assessment of the situation in Alpena.

The MDNR and Michigan Department of Environmental Quality (MDEQ)(2) have frequently cited the Lafarge Corporation Alpena Plant for many violations of environmental regulations, including releases of hydrogen chloride above the limits specified in their permits. Excess hydrogen chloride emissions have been recorded when the plant was burning only conventional fuels as well as when hazardous waste was mixed with the fuel. The hydrogen chloride is thought to be formed from chlorides in the limestone and other raw material, as well as from chlorinated compounds in the hazardous waste mixed in the fuel (2).

From December 1996 through October 1997, a contractor for the MDEQ conducted field work for an Interim Response Investigation Action (IRIA) at the "National Gypsum Site," which is the pile of cement kiln dust (CKD) east of the plant described above. The IRIA included sampling of the CKD, groundwater in the area of the pile, and water and sediments from Thunder Bay near the pile. They found that the CKD had been transported into the Bay. The groundwater under the pile and surface water in the Bay near the pile had been affected by contact with the CKD (3).

In September 1999, the MDEQ began an investigation of the Wessel Road Quarry, a.k.a. "Pike's Peak." They found that the soil cover had eroded in places to expose the CKD. They also noted groundwater or leachate seeps into a pond in the north end of the former quarry. They collected samples of the CKD and of surface water and sediment from the pond and the creek feeding it. The analytical results are not available as of this writing (4, 5).

A physician (chiropractor) from Alpena has petitioned the federal Agency for Toxic Substances and Disease Registry (ATSDR) for a public health assessment of the hydrogen chloride emissions from the Lafarge Corporation Alpena plant (6). At the request of the ATSDR, the Michigan Department of Community Health (MDCH), working under a cooperative agreement with the Agency, prepared a health consultation in June 1998 regarding the hydrogen chloride emissions. This was to assist the Agency in determining whether a public health assessment is appropriate (2). The ATSDR and MDCH concluded that a public health assessment was needed.

B. Site Visits

On February 19 - 20, 1998, James Bedford and Brendan Boyle of MDCH and Sandie Coulberson, Kathryn Evans, and Ruby Palmer of ATSDR visited Alpena to discuss the community's environmental health concerns. They met with several groups of area residents, toured the plant, and held a public meeting.

On June 16 - 17, 1998, Brendan Boyle and Michael Haars of MDCH and Sandie Coulberson of ATSDR visited Alpena to further discuss the community's environmental health concerns. They participated in a public meeting on the evening of June 16, at which the public comment draft of the health consultation was made available to the public. On June 17, a public availability session was held to further discuss the community's concerns.

On August 25, 1998, Boyle, Haars, John Filpus, and Bob Wahl of MDCH returned to Alpena. MDEQ staff gave them a windshield tour of the CKD pile. That evening they spoke at a public meeting of an environmental action committee, presenting the final draft of the health consultation.

C. Demographics, Land Use, and Natural Resource Use

According to the 1990 U.S. Census, the population of the City of Alpena was 11,307. The population of Alpena Township(3), which surrounds the City, was 9,540. There were approximately 2,600 people living within 1 mile of the Lafarge plant, and 13,700 living within 3 miles. A breakdown of the population in these two areas by age, race, and major ethnic group and selected economic statistics for the areas is given in Table 1. The population in both areas is predominantly white, with a mixture of central and western European ethnic groups (7). The entire population within 1 mile is designated urban by the U.S. Census definition.(4) The only urban area (by that definition) within the 1 mile radius is within the City of Alpena, west and southwest of the plant. The 1 mile radius covers most of the "North Side" of the city, on the left (northeast) bank of the Thunder Bay River. The land within 1 mile east, north, and northeast of the plant is Lafarge or former National Gypsum property, including a quarry and the CKD pile mentioned above, and uninhabited. Most of the City of Alpena (99.7% of the population, compare the "urban" population in the last column of Table 1 with the total city population above) is within 3 miles to the west and southwest of the plant. The area north and east of the plant and quarry is primarily used for recreation, with seasonal residences sparsely scattered in the area.

As shown in Table 1, there is little difference in race or ethnicity between the two areas around the Lafarge plant. The majority of people of Asian/Pacific descent who live in Alpena (relatively few people in all) live within 1 mile of the plant. The people living closer to the plant include a slightly higher percentage of people of Polish descent and a slightly lower percentage of people of German descent than the city as a whole. The population living within 1 mile of the Lafarge plant has a considerably lower median and average household income, a higher fraction living in poverty, and lower median and average home values than does the population living within a 3-mile radius of the plant (7).

The City of Alpena's municipal water supply uses water from Thunder Bay on Lake Huron, using an intake pipe approximately 3 miles southwest of the Lafarge Corporation plant (Figure 2). The MDEQ has no record of private wells in the area northeast of the plant, although it is possible that some seasonal or year-round residences in the area may have wells or private intakes from Lake Huron.

D. Health Outcome Data

A great deal of concern has been expressed by citizens of Alpena about perceived elevated rates of cancer for the general community and for those employed by local industries (2). The contaminants of concern in the community include several chemicals that are considered possible, probable, or proven human carcinogens (Table 3). The assessors have obtained statistical data on cancer incidences among residents of Alpena County from the MDCH Office of the State Registrar and Division of Health Statistics.


COMMUNITY HEALTH CONCERNS

A large number of health and environmental concerns have been voiced by community members. The following is a summary of these concerns. Each concern is listed once; however, some have been expressed as a concern by more than one member of the Alpena community.

Lafarge and Other Local Industry

In addition to the concerns regarding hydrogen chloride emissions that were cited in the petition that requested a Public Health Assessment (6), Alpena citizens have voiced many concerns regarding the Lafarge Corporation operation, and to a lesser extent other industries in the city, and their possible impact on health and the environment in the area.

Citizens have also voiced complaints about sulfur dioxide emissions from the Lafarge plant. Citizens have voiced concerns that a plant designed to make cement would not be able to appropriately and completely burn hazardous waste. Numerous accounts of plumes of smoke and fumes originating from the Lafarge plant have been received by MDCH staff or the Michigan Department of Environmental Quality (MDEQ) via the Pollution Emergency Alerting System (PEAS Hotline 800-292-4706). Citizens have stated that the plumes extended far into Thunder Bay and affected respiratory function in those who come in contact with them. Many concerns have been voiced about the pile of cement kiln dust (CKD) on the shore of Thunder Bay east of the Lafarge plant. The pile is eroding into the bay and may be contributing arsenic, mercury and other heavy metals to bay water and sediments. Fugitive dust from the pile is contributing to particulate matter in the air, which is a respiratory hazard and nuisance. Concerns have been expressed about the presence of asbestos-containing materials on site at the Lafarge plant. Many concerns have been expressed about past and present work practices and environmental conditions at the Lafarge plant.

Several concerns have been expressed about the possible harmful contents of the fill material which was historically provided free of charge to Alpena citizens by Abitibi (now ABT Co.). Citizens have voiced concern that the fill contained fly ash and heavy metals, including lead. The possibility of lead poisoning, especially in children, has been raised by the citizens. There may be no complete or accurate record of where in the Alpena area the Abitibi fill material was used, raising concerns about whether all the potentially affected individuals could be identified.

Concern was voiced over hydrogen sulfide releases from ABT Co., the municipal sewage treatment plant, and the Fletcher Paper Company. These three facilities are located near the mouth of the Thunder Bay River, near the commercial center of Alpena.

In a comment on the health consultation, a citizen noted, "Thunder Bay Manufacturing is not listed in the chart on page RS-15 [of the Health Consultation (Reference 2)]. It is a source of methanol . . . Please refer to toxic release inventories to determine what Thunder Bay Manufacturing contributes to the toxic chemicals in Alpena's air." (8)

One concern about the HCl released from Lafarge is that it might combine with formaldehyde from other plants to form phosgene gas (8).

Cancer

A great deal of concern has been expressed about perceived elevated rates of cancer for the general community and for those employed by local industries (2). Concerns have been expressed that the State of Michigan Cancer Registry may not capture the number of cancer cases in Alpena because many people have sought treatment outside of the area.

Other Symptoms and Diseases

Many people have reported perceived elevated rates of various symptoms and diseases. The following is a list of symptoms and diseases that have been identified as concerns by the community: rare birth defects; attention deficit disorder/attention deficit hyperactivity disorder (ADD/ADHD); migraine and/or cluster headaches; asthma and other respiratory problems; severe nose bleeds; irritation/inflammation of the eyes, nose and throat; multiple sclerosis (MS), amyotrophic lateral sclerosis (ALS, also known as "Lou Gehrig's Disease"); Parkinson's Disease; other central nervous system disorders; and Lupus. There have been numerous accounts of people experiencing symptoms including nose bleeds, respiratory distress including asthma, and headaches which were greatly reduced or absent when not in Alpena.

Students at one Alpena school are perceived to experience a large number of incidents of seizure disorder.

Miscellaneous Concerns

  • A concern has been raised about potential exposure pathways for environmental contaminants that could result in exposure from multiple sources. The exposure pathways identified were fish, soil, and air.

  • The concern was raised that as body burdens of chemicals increase, the immune system's ability to function decreases, adversely impacting humans and animals.
  • The fact that children are more susceptible to chemical exposures was identified as a major concern.

  • Many have voiced concern regarding decreased quality of life due to environmental conditions and events.

  • Several concerns were raised related to the risk from transport of hazardous waste through the streets of Alpena.

  • Perceived elevated rates of mental illness and alcoholism in Alpena, directly or indirectly related to environmental problems, were raised as a concern.
  • Concerns over rumors of napalm being transported to Alpena to be burned in Lafarge's kilns have been raised.

  • Concerns about declining game fish in Thunder Bay and the Thunder Bay River have been expressed.

  • The MDCH has issued an advisory that people should strictly limit their consumption of lake trout taken from Lake Huron (see Table 2 for details), in part because of dioxin contamination (9). This dioxin might come in part from the Lafarge plant, although there have been several other documented or potential sources of the contaminants within the watershed of the lake. The contaminants recently appeared in the fish. People in Alpena perceive that this appearance coincided with the first burning of hazardous waste in the Lafarge kilns (10).

  • Concerns over adverse impact of environmental contaminants on garden plants have been raised.

  • Many concerns related to the health of domestic and wild animals, including contaminated Bald Eagle eggs at South Point, have been raised.

  • Much concern over the historical, widespread dumping of contaminants into the Thunder Bay and Thunder Bay River has been voiced.


ENVIRONMENTAL CONTAMINANTS AND OTHER HAZARDS

The sampling results discussed in this assessment were taken from the available investigations of the Lafarge plant and other environmental concerns in the Alpena area. They are not adjusted for limitations or bias in the sampling programs. The tables presented in this assessment include maximum and median concentrations in the samples collected. Health discussions are based on the maximum concentrations reported and long-term, frequent exposure scenarios, which are reasonably conservative assumptions.

Contaminants of concern for this assessment were selected from those chemicals for which the concentration in at least one environmental medium exceeded a health-based and medium-specific comparison value. Lifetime exposure to concentrations of chemicals at or below the appropriate comparison values is not expected to result in any significant risk of adverse health effects. Comparison values used in this assessment include:

ATSDR Environmental Media Exposure Guides (EMEGs): Concentrations computed from the ATSDR Minimal Risk Levels (MRLs)(5) for chronic exposure of a child, assuming pica behavior for soil ingestion(6)

ATSDR Cancer Risk Evaluation Guides (CREGs)(7)

ATSDR Reference Dose Media Evaluation Guides (RMEGs): Concentrations computed from the U.S. EPA Reference Doses (RfDs)(5) for chronic exposure of a child, assuming pica behavior for soil ingestion

U.S. EPA Reference Concentration (RfCs)(5) for chronic exposure

U.S. EPA Drinking Water Health Advisories, Lifetime (LTHA) (11)

U.S. EPA Safe Drinking Water Act Maximum Contaminant Levels (MCLs) (11)

U.S. EPA Safe Drinking Water Act Maximum Contaminant Level Goals (MCLGs) (11)

If a chemical is found in a medium for which no comparison values exist, or for which there is no CREG available for a carcinogen, the chemical is retained as a contaminant of concern. Contaminants of concern identified from environmental data referenced in this assessment are listed in Table 3.

To identify other chemicals that might contribute to environmental contamination in the Alpenaarea, the MDCH searched the Toxic Chemical Release Inventory (TRI) data base for 1987 through 1997. Industrial facilities that use, produce, or process more than the specified amounts of chemicals on a specified list are required to file annual reports on their releases to the environment or their transfers to other facilities with the U.S. EPA. These reports are compiled into the TRI. The TRI database includes information on releases or transfers from seven facilities within the Alpena postal ZIP code: ABT Company (formerly Abitibi-Price), Fletcher Paper Company, two Lafarge Corporation locations (their main plant and the M-32 Paxton Quarry located approximately 10 miles west of Alpena, reported in 1992 only), Panel Processing, Inc. (1988-92), Systech Environmental Corporation (1992-1993), and Thunder Bay Manufacturing (1994-97). ABT Company and Fletcher Paper Company are located along the Thunder Bay River in the center of Alpena. Panel Processing, Inc. was located approximately 3 miles north of downtown Alpena. Systech Environmental Corporation is a subsidiary of Lafarge Corporation and is located adjacent to the main Lafarge Corporation Alpena plant. Thunder Bay Manufacturing is located approximately 1 mile northwest of downtown Alpena. The chemicals on which each facility filed at least one report and the nature of the releases and transfers reported are summarized in Table 4 (12).

A. On-Site Contamination

Groundwater

During the IRIA in 1997, the contractor installed a total of 14 monitoring wells in the vicinity of the CKD pile (Figure 1). They installed 11 wells on the property in January 1997, and collected samples from them late in the month. In June 1997, they installed three additional wells on the property and one more approximately 8 miles away to provide a background sample (Figure 3). They collected samples from all 14 wells in late June and early July 1997. They collected two samples from every well each time the wells were sampled. One sample of each pair was filtered to determine the concentrations of metals dissolved in the water. The results are summarized in Table 5 (3).

Many of the samples from the wells on or near the CKD pile, both filtered and unfiltered, exceeded U.S. EPA or MDEQ drinking water standards in one or more of these parameters: antimony, arsenic, cadmium, chromium, lead, manganese, mercury, nickel, selenium, sodium, thallium, or pH (11, 13). The pH values of many of the samples from the wells on or near the pile were high enough to pose a hazard for skin contact (14). The unfiltered background sample contained 1,800 parts per billion (ppb) sodium and did not contain any other metals above the detection limit. The filtered background sample contained 8,300 ppb aluminum, 270 ppb barium, 41 ppb copper, 12 ppb lead, 390 ppb manganese, and 1,900 ppb sodium. The background sample had a pH of 7.4. All of these parameters are within drinking water or skin contact standards (3, 11, 13, 14). In several other samples, the concentration of a "dissolved" metal was also higher than the "total" concentration of the same metal in the corresponding split (3).

Surface cement kiln dust (CKD)

In March 1993, the MDNR collected three samples of CKD from a large pile located east of the Lafarge plant (Figure 1), and had the samples analyzed for selected metals (Table 6). In August, the MDNR collected two additional samples from the same pile. These samples were analyzed for a different set of metals (also in Table 6). The available documentation of these sampling events does not include any information on the sample depths or exact locations (3).

During the IRIA in December 1996, the contractor collected samples of material from 0 to 6 inches deep at 11 locations on the pile. They analyzed the samples for yet a third set of metals (also in Table 6) (3). The samples contained arsenic concentrations above MDEQ Clean-up Criteria for Residential Use and background levels typically found in Michigan. Many other metals, such as barium, beryllium, cadmium, chromium, copper, lead, manganese, mercury, molybdenum, nickel, thallium, titanium, and vanadium were present. Some of the samples were at concentrations above background or ATSDR Comparison Values, although not above the MDEQ Clean-Up Criteria (13, 15).

On August 7, 1998, the MDEQ collected 15 samples of CKD from the pile, including eight surface samples (0-6 inches deep) and seven subsurface samples (between 6-12 inches and 3-3.5 feet deep). They mixed portions of these samples with equal weights of water and measured the pH of the resulting fluid. The pH of the surface samples ranged from 9.1 to 12.3, with a median of 11.65. The pH of the subsurface samples ranged from 10.3 to 12.4, with a median of 12.0 (16).

B. Off-Site Contamination

Surface Soil

In April 1992, a resident of Alpena collected two soil samples, one from her property south of the Thunder Bay River (Residence A in Figure 2) and a second from a relative's property north of the river (Residence B, also in Figure 2). She had them analyzed at a commercial laboratory for cadmium, chromium, lead, and mercury. The laboratory reported that the sample from Residence B contained 610 parts per million (ppm) lead, which is above the MDEQ's Generic Clean-up Criteria for Industrial, Commercial, or Residential Uses (400 ppm) (13, 17).(8) The residents reported these results to the MDNR, who initiated an investigation of soil contamination at these properties and in Alpena as a whole. In June and July 1992, the MDNR collected additional soil samples from these properties, from 1 and 6 inches deep. The MDNR collected three samples from each depth at Residence A, and five samples from each depth at Residence B. These samples were analyzed for arsenic, cadmium, chromium, copper, lead, mercury, nickel, and zinc (also in Table 7) (18). None of these samples contained lead concentrations above the MDEQ Generic Clean-up Criteria. Two 6-inch-deep samples collected from Residence B contained arsenic concentrations in excess of the MDEQ Generic Clean-Up Criteria for Residential Use (13). None of the arsenic concentrations was outside the range found in Michigan background soils (15).(9)

From June through August 1992, the MDNR also collected 27 surface soil samples (1" deep) from other residences, school yards, and parks throughout the city of Alpena. They analyzed these samples for arsenic, cadmium, chromium, copper, lead, mercury, nickel, and zinc. Table 8 summarizes the results for these samples and those from Residences A and B discussed in the preceding paragraph. One sample contained a lead concentration in excess of the MDEQ Clean-Up Criteria for Industrial, Commercial, or Residential Use (13). It was collected from a residential yard along a major thoroughfare south of the Thunder Bay River. The highest arsenic concentration (33 ppm) was found in soil from a residential yard north of the river, within 0.5 miles of the Lafarge Plant. The second-highest arsenic concentration (23 ppm) was found in soil from the playground of Ella White Elementary School on the southwest side of the city (Figure 3) (18). These two samples and one collected near a railroad track contained arsenic concentrations outside the range found in background soil in Michigan (15). These three and four other samples, including the sample with the highest lead concentration cited above, contained arsenic concentrations above the MDEQ Generic Clean-Up Criteria for Residential Use (13).

During this time, the MDNR also collected 13 samples of subsurface soil, from 6" to 12" deep, from residential yards, school yards, and parks around the city. These included five samples at the same locations where surface soil samples were collected and five background samples from soil that was 12" deep at five locations around the outskirts of the city. These samples were also analyzed for arsenic, cadmium, chromium, copper, lead, mercury, nickel, and zinc. Table 9 summarizes the results from these sampling events and the 6" deep samples collected from Residences A and B, discussed above. The highest lead concentration (451 ppm, above the MDEQ Generic Clean-Up Levels) was found in a sample collected from 6 inches deep on the grounds of Lincoln Elementary School, north of the Thunder Bay River and not far from Residence B (see Figure 3).

In November 1992 in response to these results, the Alpena Public Schools hired a contractor who, beginning on November 30, 1992, collected 17 surface soil samples (1" deep) from yards of Ella White School (five samples), Lincoln School (7 samples), other schools in their district, and a city park to determine the extent of the arsenic and lead contamination found in school yards by the MDNR (see above) (19). They had these samples analyzed for arsenic and lead (Table 8). The samples with the lead and arsenic concentrations above the MDEQ Clean-Up Criteria were collected from the yard at Lincoln School. The samples from Ella White School contained between 0.2 and 0.9 ppm arsenic (Table 10) (18). On December 22, 1992, a contractor for the Alpena Public Schools collected 14 soil samples from the yard at Lincoln School and nine samples from the yard at Ella White School. These samples were analyzed for lead and arsenic (Tables 8 and 10). The arsenic in the soil at Ella White School was believed to have leached from a bench made of treated lumber located near the sampling point. The bench was replaced by one not made of treated lumber. The Alpena Public Schools removed the lead- or arsenic-contaminated soil from the two school yards and disposed of it appropriately (19, 20).

In 1996, as part of an investigation of regional soil contamination in Alpena, a contractor for a citizen's environmental action group collected samples of surface (0 to 0.4 inches deep) and subsurface (4 to 6 inches deep) soils from 11 locations in ten residential yards in the city. They analyzed the samples for various metals, and the results are summarized in Tables 8 and 9 (21). None of these samples contained any metal at a concentration exceeding the MDEQ Generic Clean-up Criteria (13).

Abitibi Fly Ash

In connection with investigations of specific questions about soil quality in the city between October 1991 and June 1992, the MDNR collected five samples of fly ash originally obtained from Abitibi Corporation at various locations around Alpena, and analyzed them for metals. All five samples contained arsenic at concentrations above the MDEQ Residential Use Criteria (Table 11) (22).

Ambient Air

From March 10, 1995, through March 4, 1996, at 6 or at 12 day intervals, a contractor for Lafarge Corporation, under MDEQ supervision, collected air samples at four sampling stations in and near Alpena. These locations were as follows: Besser Junior High School (Figure 2), Lincoln Elementary School, on North Point (east of Lafarge), and on the southwest part of the Lafarge Plant property. The samples from the first three locations were analyzed for metals, volatile and semi-volatile organic chemicals, and suspended particulate material (total and less than 10 microns in size). The samples from Lincoln School were also analyzed for chlorinated dibenzodioxins and dibenzofurans. The samples from the station on the Lafarge property were only analyzed for suspended particulate material less than 10 microns in size (PM-10). Table 12 summarizes the results of the chemical analysis, and Table 13 summarizes the results of the sampling for particulate material. There was no discernable pattern for the detection of the metals or for most of the volatile organic chemicals. The concentrations of benzene, ethylbenzene, toluene, and xylenes (BTEX) at any one sampling site all tended to peak on the same date, although that date varied from site to site. Peak concentrations occurred at Besser School on April 27, 1995, at Lincoln School on both August 1, 1995, and January 4, 1996, and at North Point on July 8, 1995. Relatively high concentrations of semi-volatile organic chemicals were found on November 29, 1995 and again during January 1996. Relatively high concentrations of particulate matter were detected at all locations on March 28, 1995; June 20, 1995; July 14, 1995; and October 12, 1995. In general, the PM-10 measurements on the Lafarge property were the highest, followed by Lincoln School, Besser Junior High School, and North Point, although there were exceptions to the sequence. Octachlorodibenzodioxin was found in nearly every sample. Hepta- and hexachlorodibenzodioxins, and octa-, hepta-, and hexachlorodibenzofurans were found in many samples collected primarily in March through May 1995 and again in November 1995 into March 1996. Other chlorinated dibenzodioxins and dibenzofurans were detected less frequently. The highest concentrations of all the congeners were found mainly on April 15, 1995, and again on January 1996 (23).

The MDEQ did not accept the data from the 1995 sampling because it did not meet the agency's quality control standards. They requested another year of sample data, which Lafarge collected from May 4, 1997, through May 11, 1998. Samples were collected from the following locations: from the Immanuel Lutheran School; adjacent to Besser Junior High School on the south; from the north and south sides of the Sunrise Center; approximately 3 blocks northwest of Lincoln School (see Figure 2); from the same locations on North Point; and, from the same locations on the southwest corner of the Lafarge property. They analyzed the samples from Immanuel Lutheran School, the Sunrise Center, and North Point for volatile organic chemicals and PM-10 only. They analyzed the samples from Lafarge again for PM-10 only. The results are summarized in Tables 12 and 13. Again, the BTEX concentrations at each site tended to rise and fall together, with peaks occurring at Immanuel Lutheran School on December 6, 1997, at the south side of the Sunrise Center on April 29, 1998, at the north side of the Sunrise Center on May 11, 1998, and on North Point on January 11, 1998. During this sampling there was little correlation between PM-10 measurements on the Lafarge property with those elsewhere. In general the PM-10 measurements on the Lafarge property were the highest, followed by the Sunrise Center, Immanuel Lutheran School, and North Point, although there were exceptions to the sequence (24).

Citizens of Alpena have expressed concerns about hydrogen chloride in the ambient air. Due to equipment and sampling delays, air data was not available for inclusion in this document. Nonetheless, air data that is currently being collected will be reviewed in a future document.

Surface Water

During the IRIA, the contractor collected samples of surface water from eight locations along the Thunder Bay shoreline near the CKD pile on January 23, July 2, and September 3, 1997. They analyzed the samples for selected metals (Table 14) and also filtered the samples collected on January 23 and July 2, 1997, to determine the concentrations of metals dissolved in the water. The only metal detected in the filtered samples was aluminum. The two samples collected on July 2, 1997, that contained the highest total concentrations of metals also had the highest pH levels. One sample collected on January 23, 1997, had a pH level outside the U.S. EPA's acceptable range for drinking water, and all eight samples collected on July 2, 1997, had pH levels outside that range, with six samples also containing higher lead concentrations than the U.S. EPA Drinking Water Action Level (11). The IRIA report did not include the pH levels for the September 3, 1997, samples (3).

For information on background levels on October 1 and 2, 1997, the contractors also collected five water samples apiece from Squaw Bay (a subunit of Thunder Bay approximately 6 miles southwest from the CKD pile, see Figure 3) and from Misery Bay (approximately 5 miles east of the CKD pile, and outside of Thunder Bay, Figure 3). They analyzed the background samples without filtering for selected metals, and found only low concentrations of aluminum, potassium, and thallium (Table 15). The IRIA report did not include the pH values for these samples (3).

Municipal Water Supply

The MDEQ Division of Drinking Water and Radiological Protection monitors all municipal water supplies in the state by analyzing samples of the water they produce on a regular basis. The finished water put out by the Alpena municipal water system is sampled on a regular schedule, with different chemical groups analyzed at different intervals. Table 16 lists the schedule and latest sampling dates in MDEQ files. The Michigan Department of Public Health (MDPH)/MDEQ(10) monitoring has never found any chemical in Alpena City water at a concentration in excess of U.S. EPA Maximum Contaminant Levels (MCLs) except in transient events (25, 26, 27). The results of recent monitoring, sampling and analysis are summarized in Table 17. The only chemicals that were found generally at concentrations less than health-based standards for drinking water in these recent samples were arsenic, barium, bis(2-ethylhexyl)phthalate, chlorodibromomethane, chloroform, chromium, dibromoacetic acid, dichloroacetic acid, dichlorobromomethane, sodium, and trichloroacetic acid. Once, on March 22, 1995, the chloroform concentration exceeded the MCL for total trihalomethanes (chlorodibromomethane, chloroform, dichlorobromomethane, and other similar chemicals). A follow-up sample on June 15, 1995, as well as other later samples contained much lower concentrations of these trihalomethanes which totaled less than the MCL. The MDPH concluded that the exceedance of the MCL on March 22, 1995, was a transient event and no further action was required (25). The arsenic concentration in one sample, collected on June 12, 1995, exceeded the ATSDR CREG (compare Table 5, for example) but did not exceed the MCL (28). Compounds of chromium with the metal in the hexavalent oxidation state are classified as known human carcinogens (U.S. EPA Class A), but there is not sufficient information available about the metal to produce a CREG. No information is available as to the oxidation state of the chromium detected in the city water on May 30, 1996 (26, 27, 29).

Trihalomethanes (including chlorodibromomethane, chloroform, and dichlorobromomethane) and haloacetic acids (including dibromoacetic acid, dichloroacetic acid, and trichloroacetic acid) can be produced when chlorine is added to water that contains organic material (30, 31, 32, 33). Bis(2-ethylhexyl)phthalate, commonly used as a plasticizer, is found everywhere in the environment, and is a common laboratory contaminant (34). The arsenic, barium, and chromium concentrations in the city water were much lower than those found in the groundwater or surface water near the CKD pile. The surface water and groundwater samples collected during the IRIA were not analyzed for any organic chemicals or for sodium (see preceding sections for the list of metals for which they were analyzed ) (3).

Sediments

During the IRIA in September and October 1997, the contractor collected 31 samples of sediment from offshore in Thunder Bay from the cement kiln dust pile. For data on background levels, they also collected five sediment samples from Squaw Bay (a subunit of Thunder Bay, approximately 6 miles southwest from the CKD pile, Figure 3) and two sediment samples from Misery Bay (approximately 5 miles east of the CKD pile, and outside of Thunder Bay, Figure 3). All these samples were analyzed for selected metals. The samples from the two background areas contained similar concentrations of the metals. The sediment from the area off the CKD pile (Table 18) contained higher concentrations than did the background samples (Table 19) of metals that were also present in the CKD in the pile (Table 6). This result indicated that CKD had been transported from the pile into the bay (3).

Biota - Fish

A 1993 MDNR summary of results of dioxin and furan analyses of fish taken from Michigan waters from 1983 through 1988 lists seven lake trout taken from Lake Huron at Alpena, but does not indicate the dates, lengths, or the collecting agencies. All the fish were analyzed as whole fish samples. One fish was only analyzed for 2,3,7,8-tetrachlorodibenzodioxin (2,3,7,8-TCDD). For the others, only the total concentrations of chlorinated dibenzodioxin or dibenzofuran congeners with each number of chlorines from 4 through 8 and chlorines at the 2, 3, 7, and 8 positions were listed (35).

On October 10, 1985, the MDNR collected five brown trout between 18 and 25 inches in length from Lake Huron at Alpena. Fillets from these fish were analyzed for PCBs, DDT and its metabolites, chlordane and related compounds, and dieldrin.

On July 23, 1986, the MDNR collected ten brown trout between 19 and 25 inches in length from Thunder Bay, and the fillets were analyzed for metals and PCBs.

On June 29, 1989, the MDNR collected nine carp between 21 and 30 inches in length, one 15-inch channel catfish, and ten walleye between 17 and 24 inches in length from the mouth of the Thunder Bay River. The same day, they collected ten carp between 15 and 30 inches in length, one 18.5-inch redhorse sucker, four smallmouth bass between 12 and 19 inches in length, and five walleye between 14.6 and 18.5 inches in length from Lake Besser on the Thunder Bay River (above the Ninth Street Dam) in Alpena. Fillet samples were analyzed for mercury, PCBs, various pesticides, and selected chlorinated organic compounds.(11)

On June 19, 1991, the MDNR collected ten brown trout between 16 and 18 inches in length and had fillet samples analyzed for the standard suite of chemical contaminants.

On June 25, 1991, the MDNR collected ten walleye between 19 and 28 inches in length and subjected extracts of the whole fish to their standard analysis.

On June 1, 1992, the MDNR collected ten brown trout between 20 and 26 inches in length and six lake whitefish between 18 and 24 inches in length from Thunder Bay and subjected fillet samples from the fish to their standard analysis.

On June 4, 1992, the MDNR collected ten carp between 19 and 25 inches in length and nine lake trout between 24 and 31 inches in length from Thunder Bay, and they subjected extracts of the whole fish to their standard analysis. Five of these trout were also analyzed for chlorinated dibenzodioxins and dibenzofurans.

On June 13, 1993, the MDNR collected 100 alewives between 3 and 5 inches in length from Thunder Bay. These were composited as whole fish into two samples of 50 fish each.

On June 14, 1993, the MDNR collected ten carp between 21 and 27 inches in length, eight lake trout between 19 and 26 inches in length, and ten walleye between 15 and 25 inches in length from Thunder Bay.

On June 22 and 23, 1993, the MDNR collected 50 chub, of which five were between 10 to 10.5 inches in length, five of them were between 10.5 to 11 inches in length, the others were between 6 and 7 inches in length. Skinless fillet samples of the ten longer chub were composited into two samples of five fish apiece and sorted by length. The remaining chub were composited as whole fish into two samples containing 20 fish apiece. The samples of alewife and chub, skinless fillets of the carp, and fillets with skin of the lake trout and walleye were all subjected to MDNR's standard analysis. The lake trout fillets were also analyzed for chlorinated dibenzodioxins and dibenzofurans.

Between August 12 and August 25, 1993, the MDNR collected seven brown trout between 18 and 24 inches in length from Thunder Bay. Skin-on fillet samples were subjected to MDNR's standard analysis.

On October 12, 1993, the MDNR collected two channel catfish that were 17.5 and 25 inches in length from Thunder Bay. Skinless fillet samples were subjected to MDNR's standard analysis.

On October 15, 1993, the MDNR collected nine carp between 18 and 28 inches in length from Lake Besser on the Thunder Bay River, and had extracts of the whole fish analyzed for their standard suite of chemicals.

On June 27, 1994, the MDNR collected ten carp between 21 and 24 inches in length and ten lake trout between 25 and 28 inches in length from Thunder Bay and subjected extracts from each whole fish to their standard analysis. Extracts from five of the lake trout (between 25 and 27 inches in length and comprising 5 of the 6 shortest fish of the species collected that day) were also analyzed for chlorinated dibenzodioxins and dibenzofurans.

On June 16, 1995, the MDNR collected 10 carp between 21 and 23 inches in length, 10 lake trout between 25 and 28 inches in length, and 10 walleye between 17 and 24 inches in length from Thunder Bay and subjected extracts of each whole fish to their standard analysis.

On September 15, 1995, the MDNR collected three spottail shiners (length not reported) and five walleye between 21 and 24 inches in length from Thunder Bay and subjected extracts of each whole fish to their standard analysis.

On June 26, 1996, the MDNR collected ten lake trout between 20 and 25 inches in length and ten lake whitefish between 19 and 26 inches in length from Thunder Bay and subjected fillet samples of each fish to their standard analysis.

On August 20, 1998, the MDNR collected ten lake whitefish between 21 and 25 inches in length from Thunder Bay and analyzed fillet samples for the standard suite of chemical contaminants plus chlorinated dioxins and furans.

On August 22, 1998, the MDNR collected 11 lake trout between 23 and 26 inches in length and nine walleye between 20 and 27.4 inches in length and analyzed extracts of the whole fish for the standard suite of chemical contaminants plus chlorinated dioxins and furans. Analytical results are summarized in 20, 21 Tables. The concentrations of contaminants in lake trout and lake whitefish collected from Thunder Bay are similar to those in individuals of the same species collected elsewhere in northern Lake Huron (35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45).

Most fish collected from Thunder Bay contained PCBs in excess of the MDCH's first level of concern, 0.05 ppm. The Department advises that pregnant women, nursing mothers, women who intend to have children, and children under age 15 should not eat more than one meal per week if the fish tissue exceeds 0.05 ppm. One carp and one walleye, the longest of each species, collected from Lake Besser in 1989 contained more than 0.5 ppm of PCBs, and five of the whole carp collected from Lake Besser in 1993 exceeded that level also. Five of the brown trout collected in 1986, some of the carp collected each year from 1989 through 1992, the larger of the two channel catfish collected in 1993, one lake trout collected in 1992, and one walleye collected in 1991 contained PCBs above the U.S. FDA Tolerance Level of 2 ppm. The larger channel catfish collected in 1993, some lake trout collected each year from 1992 through 1994, and one walleye apiece in the 1993 and 1995 collections contained chlordane in excess of the MDCH Level of Concern/U.S. Food and Drug Administration (FDA) Tolerance Level of 0.3 ppm. The larger channel catfish collected in 1993, one walleye apiece in the 1989, 1991, and 1995 collections from the bay, as well as one smallmouth bass and one walleye collected from Lake Besser in 1989, all contained mercury above the MDPH Level of Concern of 0.5 ppm. Most of the lake trout collected from 1983 through 1998 and four of the lake whitefish collected in 1998 which were analyzed for chlorinated dibenzodioxins and dibenzofurans all contained the chemicals that, with a combined toxicity expressed as a toxic equivalent of 2,3,7,8-tetrachlorodibenzodioxin (2,3,7,8-TCDD), were above the MDCH Level of Concern of 10 parts per trillion (ppt) 2,3,7,8-TCDD equivalent (35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45).

C. Quality Assurance and Quality Control

During the IRIA, analysis of filtered groundwater samples sometimes found higher concentrations of metals than did the analysis of the corresponding unfiltered samples (3). It is not known whether this is due to normal variation between samples or to inadvertent contamination during the laboratory analysis.

The 1983-1988 lake trout dioxin analyses were carried out at three laboratories, one in Sweden (five samples), a U.S. EPA laboratory in Duluth (two samples, 2,3,7,8-TCDD only), and a U.S. EPA laboratory in Research Triangle Park (RTP) North Carolina (this was a replicate analysis of one of the samples analyzed at the Duluth laboratory). The split analyzed at RTP contained the highest concentrations of 2,3,7,8-TCDD, octachlorodibenzodioxin, 2,3,7,8-hexachlorodibenzofurans, octachlorodibenzofuran, total chlorinated dibenzodioxins, and total chlorinated dibenzofurans of all these samples. The 2,3,7,8-TCDD concentration in the RTP split was three times that found in the Duluth split of the same sample. The reported detection limits from the RTP laboratory were higher than the concentrations of the same congeners found in the Swedish laboratory, and 100 times the detection limits reported by the Swedish laboratory.

Before 1989, the analysis of fish collected by the MDNR was carried out at an MDNR laboratory. Since 1989, the fish analysis has been carried out at an MDPH/MDCH laboratory. There was some evidence that the MDNR laboratory analysis was not as reliable as the MDPH/MDCH laboratory analysis.

D. Physical and Other Hazards

The City of Alpena, the Lafarge Alpena plant, and the CKD pile pose no special physical hazards that do not occur in any other towns of similar size, with comparable industrial facilities, or in areas of similar topography. Lafarge maintains its own security arrangements to deter unauthorized access to its property. The CKD pile is partially fenced, and trespassers have been observed on the pile. The slopes of the CKD pile are generally stable, except for steep bluffs along the southern shoreline where wave action cuts into and erodes the material (3).


PATHWAYS ANALYSES

To determine whether nearby residents are exposed to contaminants migrating from the site, ATSDR evaluates the environmental and human components that lead to human exposure. An exposure pathway contains five major elements: a source of contamination, transport through an environmental medium, a point of exposure, a route of human exposure, and the presence of an exposed population.

An exposure pathway is considered a completed pathway if there is evidence that all five of these elements are currently present or have been present in the past. An exposure pathway is considered a potential pathway if one or more of these elements is not known to have been present, but could possibly have been present. An exposure pathway can be eliminated from consideration if one of the elements is not present and could never be present. The following sections discuss the most important exposure pathways at this site.

A. Completed Exposure Pathways

Air

Air sampling has found various chemicals in the air in Alpena which, at times, was at concentrations of human health concern (Table 12). There are many ways by which these chemicals could have entered the air, for example: releases from industrial facilities; emissions from vehicles and other combustion engines; and, household use of products containing volatile chemicals. The air in many other cities in the U.S. contains similar concentrations of many of these chemicals (46, 47).

Current and former residents of Alpena have reported a history of cement kiln dust (CKD) blowing from what is now the Lafarge Corporation Alpena Plant into the residential areas of Alpena (48). The density of particulate matter less than 10 microns in diameter in the air in Alpena has exceeded the U.S. EPA standard for the annual average concentration in 16 out of approximately 400 samples collected from 4 locations between March 1995 and June 1998 (Table 13) (23, 24, 49).(12) Anyone living in or visiting Alpena and breathing the air would be exposed to these chemicals.

Soil

Alpena - residential areas

The surface soil in Alpena contains some chemicals at concentrations potentially of human health concern (Tables 7, 8, 9). Many of these chemicals are also found at similar concentrations in the soil in many other American cities (51). There are many possible sources for these chemicals, including: deposition of cement dust from what is now the Lafarge Corporation Alpena Plant; deposition from other airborne sources; transportation of soil from contaminated areas; paint and chemicals flaking from walls and other objects; and, consumer use of household chemicals. People living in or visiting the city might be exposed to the chemicals in the soil by direct contact, ingestion, or inhalation of fugitive dust.

Cement Kiln Dust (CKD) pile

The CKD in the pile east of the Lafarge plant contains various metals at concentrations potentially of human health concern (Table 6). The pile is partially fenced; however, trespassers on the pile have been observed. The nearest residential area to the pile is to the west, with the Lafarge plant in between. The pile's topography attracts motorcycle and off-road vehicle users. Any access to the pile is not likely to be frequent or prolonged. Children of the age likely to be subject to pica behavior are not likely to be on the pile. Trespassers might be exposed to the dust by dermal contact, incidental ingestion, and inhalation of fugitive dust.

Fugitive dust from the CKD pile might blow onto neighboring parcels, including Thunder Bay, the Lafarge plant and quarry, the public road running across the Lafarge property, and recreational parcels to the east. Workers at the plant and quarry as well as people using the road might come into dermal contact with, incidentally ingest, or inhale the dust from the pile. Strong easterly winds might carry the dust from the pile past the Lafarge plant into the City of Alpena. In addition, grinding, transport, and other operations at the Lafarge plant have released large amounts of CKD into the air, where winds can carry it onto neighboring properties. Lafarge has implemented procedures to reduce the release of CKD, although some is still released.

Surface Water

CKD is blown over Thunder Bay from the Lafarge plant and from the piles near the plant by the wind. CKD settles into the water. The CKD in the piles and on the land surface elsewhere by the bay shore is washed into the water by runoff after rains. Groundwater that has leached chemicals out of the CKD discharges into the bay. Water-soluble chemicals in the CKD and suspended CKD particles can be transported through the water to drinking water intakes. As mentioned above, the Alpena City water system takes water from Thunder Bay, approximately 3 miles southwest of the Lafarge plant (Figure 2). It seems unlikely that bay water from the area offshore from the plant would reach the city water intake. The major water inlet to the bay, the Thunder Bay River, is located between the plant and the intake. Flow out of the river would probably divert any water migrating from the plant toward the intake to the southeast, toward the mouth of the bay. However, it is possible that there are other private, unrecorded drinking water intakes on the north shore of Thunder Bay. People using the bay near the CKD pile for recreation, swimming, boating, fishing, water skiing, and similar activities, might incidentally ingest water from the bay.

Thunder Bay Fish

Fish living in Thunder Bay near the CKD pile might ingest contaminated water or biota that has lived in sediments contaminated by water or airborne dust from the CKD pile. Contaminants thus ingested might be absorbed into the fish's tissues. If the fish are caught and eaten by humans, the consumer might be exposed to the contaminants. The fish in Thunder Bay, Lake Huron (as a whole), and Lake Besser do contain contaminants (Tables 20, 21), but there is no available evidence to connect this contamination with the CKD pile. The MDCH has issued advisories that people are to restrict their consumption of several species and sizes of fish taken from Thunder Bay, Lake Huron, and all inland lakes in Michigan(13) including Lake Besser. This information is summarized in Table 2 (9).

B. Potential Exposure Pathways

Groundwater

The groundwater under the CKD pile east of the Lafarge plant is contaminated with various metals at concentrations exceeding U.S. EPA MCLs and other health-based criteria (Table 5). The CKD in the pile extends below the water table. The closed CKD landfill in the Wessel Road Quarry northwest of the plant has no liner, and the former quarry used for the landfill extended below the water table. The quarry had been filled with water before the CKD was deposited there. The creek that had fed that pond still feeds another pond in the north end of the quarry (5). Groundwater seeps into the active quarry currently used as a CKD landfill, and it needs to be continually pumped from the quarry to prevent the water from coming into contact with the CKD. Rainwater and groundwater seeping through the CKD might dissolve various metals from the dust. Groundwater in the area of the CKD pile by the lakeshore flows to the south, southeast, or southwest, directly into Thunder Bay (3). Currently there are no producing wells in the area of the contaminated groundwater or downgradient between the pile and the bay. It is unlikely that such a well could be installed in the future. Alpena County has a well permitting program which began in January 1998. The Alpena municipal water system takes its water from Thunder Bay, approximately 3 miles southwest of the CKD pile (Figure 2). In addition, there may be surface water intakes on Thunder Bay east of the CKD pile that do not appear in any official records. See the "Surface Water" subsection under "Completed Exposure Pathways" above for a more complete discussion of this pathway.


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