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PUBLIC HEALTH ASSESSMENT

SAUK COUNTY LANDFILL
EXCELSIOR, SAUK COUNTY, WISCONSIN




APPENDIX A: DEFINITION OF TERMS
CREG:Cancer Risk Evaluation Guide. A person drinking two liters of water per day over a 70 year lifetime with this level of contamination would have a one in a million increased cancer risk.
EMEG: Environmental Media Evaluation Guide developed by ATSDR. A person could drink two liters of water per day over a 70 year lifetime with this level of contamination without expecting to have adverse health effects.
LTHA: EPA's Lifetime Health Advisory for drinking water. A person could drink two liters of water per day over a 70 year lifetime with this level of contamination without expecting to have adverse health effects.
RMEG: Reference Dose Media Evaluation Guide developed from EPA RfD. A person could drink two liters of water per day over a 70 year lifetime with this level of contamination without expecting to have adverse health effects.
MCL: Maximum Contaminant Level (MCL) established be the EPA. A person could drink two liters of water per day over a 70 year lifetime with this level of contamination without expecting to have adverse health effects.
MRL: Minimal Risk Level developed by ATSDR. A person could breath twenty cubic meters per day of air with this contaminant concentration without expecting to have adverse health effects.
RfC:Reference Concentration developed by EPA. A person could breath twenty cubic meters per day of air with this contaminant concentration without expecting to have adverse health effects.

APPENDIX B: RESPONSES TO PUBLIC COMMENTS
1)General Comment. The PHA does not adequately quantify the chronic or acute risks posed by completed off-site exposure pathways (e.g., well water systems). Although present concentrations of individual contaminants in completed off-site exposure pathways appear below respective "comparison values", the cumulative effect from all the contaminants has not been determined. the risks from completed off-site exposure pathways for each contaminant of concern should be quantified and accumulated to determine whether cumulative risks from present (or potential) exposure pathways are acceptable, and so that individuals can evaluate the risks which they may have been or may be exposed to. The generally recognized risk is expressed as 10-6 or 1 in a million chance of an increase in health effects related to exposure of contaminants. What is the quantified risk (past, present and future) to off-site groundwater users?
Response: The only completed off-site exposure pathway occurs in one private well. Thecontaminants in this well have not been detected at concentrations that are expected tocause any health effects. Unlike compounds with a cancer slope factor there is a thresholdconcentration below which no health effects are expected. For this reason there is no riskof increased health effects based on current exposures. The point about cummulativeeffects of the two contaminants in this well is more difficult to address. However, becausethey both are expected to cause similar health effects their detected concentrations can becombined and are still many times below a level that could cause health effects. As forquantifying health risks from future exposures at this or any other well, any exceedance ofgroundwater standards from contaminants coming from the landfill will be considered tobe unacceptible. The groundwater standards developed for Wisconsin are based onquantified risk assessment for lifetime exposures.
2) General Comment. It has been expressed to EPOA that there is a high probability that concentrations in the off-site private well(s) will increase over time. This document evaluates current exposure rate, but does not assess future risk with changes in the groundwater quality. Additional information would appear necessary to determine: 1) what additional groundwater contaminants may be expected in off-site well, 2) what ranges in concentrations of groundwater contaminants may be expected, and 3) what are the risks associated with anticipated groundwater conditions? What are the long-term risks to residents if the concentration of contaminants change and if new contaminants (e.g., vinyl chloride) are detected?
Response: Based on the investigation to date WDOH does not believe that contaminantconcentrations will increase to concentrations near those expected to cause health effects. The WDOH and the WDNR will both review all private well sample results as they arereceived. If there is a significant change in the concentrations of contaminants alreadypresent, we will reevaluate our health advisory for that well. In addition, if newcontaminants reach the well we will also reevaluate our health advisory. This informationis clarified in this document in the "Response to Community Health Concerns" section (#5 for Groundwater). Because vinyl chloride is believed to be a potent carcinogen, detection in a private well would likely cause the WDOH to recommend the use of an alternative water supply.
3) General Comment. The PHA utilized several different "comparison values", obtained from several different sources, for the on-site and off-site contaminants. Although these "comparison values" were referenced in the report, they were not sufficiently defined to allow an accurate determination of the cross relationship or consistency between published risk assessment information. Without a complete definition of each type of "comparison value", the consistency in their application to the site can not be determined. If the "comparison values" do not have a high degree of consistency, their application to site data cannot be relied upon to determine contaminants of concern or cleanup action levels. Rather than use "comparison values" to determine unacceptable contaminant concentrations, that result in a 10-6 change of adverse health effects, individual and cumulative calculations of the risk of each compound may have been more effective in determining the contaminants of concern (see General Comment 1).
Response: The comment is correct. The comparison values used in the Public Comment Release were not well defined. Definitions have been added and improved in this document where the comparison values are used. In general these comparison values are developed by ATSDR based on the most conservative exposure scenerios for each contaminant at each pathway. The comparison value reflects a 1 x 10-6 risk from an exposure greater than any likely to occur at this site. For this reason, only contaminant concentrations that exceed their respective comparison values are evaluated further. This further evaluation then considers the possible exposure scenerios for the site.
SUMMARY
Paragraph 1: The Sauk County landfill is a closed landfill; it is not abandoned, based upon common usage of the term.
This wording has been changed.
    It is inappropriate to assume that people will use TW-25, or other wells near the landfill, as a source of drinking water. It is not reasonable to state that there would be an increased risk of getting cancer for performing an action which will not occur.

The comment is correct. However, the contamination in TW-25 generally reflects the worst groundwater contamination at the site. For this reason it is used as worst case contamination that could potentially migrate to an off-site private well. This documentalready states that such migration is extremely unlikely. That slim potential, as unlikely asit is, is what drives our recommendation for the groundwater monitoring component in thefinal remedy. The wording in the document has been revised, so as not to assume thatpeople would actually be drinking water from TW-25.

Paragraph 3: VOC concentrations in ground water are decreasing, further reducing the future risk these pose in drinking water.
This information is now included in the document.
Paragraph 5: It is possible for VOCs to "migrate to the ambient air at concentrations that could cause a health hazard." However, the possibility that these compounds would not be greatly diluted and dispersed in the air prior to reaching a potential receptor is very remote. This is further discussed below.
The potential is very remote, but cannot be ruled out with existing data. Because an active gas collection system is part of the remedy, collecting additional data to rule out this exposure is not necessary.

Background

Paragraph 1:       The landfill is closed, rather than abandoned.

The wording has been changed.

Page 4 Para4:       Four ground-water flow patterns were identified.

The wording has been changed.

Page 6 para. 1:
This section refers to several site visits. Deer have occasionally been noted grazing on the landfill cap; they do not do so frequently.
This is a comment from a representative of the County at that time. Clearly such grazing will no longer be possible with the addition of the landfill fence.
Page 6 Para 2: This paragraph refers to the most recent grading and revegetation of the landfill cap occurring in 1988. This was true at the time of the 1989 site visit, but is no longer true. Regrading and revegetation also occurred in 1993.
This information has been added.

Water collected in depressions on the landfill cap; it is not appropriate that these would be described as "ponds".
The wording has been changed.
Para 3: Vandalism was a problem at the tie of the 1989 site visit.
The wording has been changed.

Runoff from the western side of the site flowed into a sand (not gravel) borrow pit about 100 feet west of the site. At no time would the borrow pit have been "full of water". While it may have contained some standing water, it would not have been possible for a borrow pit in the sandy soil of the site to remain full of water.
The wording has been changed.
Para.5: The erosion gully noted in 1992 was repaired in 1993.
This information has been added.
Para. 6. While all-terrain vehicles are occasionally driven on the property, signs have been posted which say that such activity is prohibited. The County will prosecute anyone caught trespassing on the landfill property.
This information has been added.
Environmental Contamination and Other Hazards
Page 9, Para.4 Based upon the results of the RI, no off-site contamination above a drinking water standard exists.
This information is discussed at the beginning "Off-Site Contamination" section.
Page 11, Table 2: It should be noted that all of the semi-volatiles were detected below their quantitation limit and are estimated values.
This information has been added.
Page 13, Top Para: It is unclear why lead was retained as a contaminant of concern as it is found commonly in the environment. As the proposed NR720 standards for lead are health-based, these could have been used for Comparison Values.
This level of lead is not considered naturally occuring. Because an official comparison value isn't available lead is retained as a contaminant of concern. In the "Toxicological Evaluation" section the available toxicological information is used to explain why the highest level doesn't pose a public health hazard.
Page 14, Bottom Para: "Limited monitoring of residential indoor air quality was one in October 1993," apparently by the WDNR. The data generated by this monitoring has not been published, and is not available for review.
WDOH conducted the limited air sampling. The sampling was done at the request of the homeowner, not as part of the remedial investigation. The results did not detect contamination from the site and were sent to the homeowner.
Page 16, Para 2: Carbon tetrachloride was detected in the Hinze well in samples collected in November and December 1987. This compound was also detected in trip blanks at this sampling.

Carbon tetrachloride was analyzed in samples collected in monitor wells TW-25, TW-J, and TW-26A in March, April, May , and August 1991. For each of the four samples from these three wells, carbon tetrachloride was not detected. Because of this, and because this compound is not included on the list of VOCs to be analyzed under standard CLP procedures, it was not a contaminant of concern, and ground-water samples were not analyzed for it during the Remedial Investigation (RI).
Because the compound was detected in the samples and the respective blanks, it is likely that the compound was not actually in the well water. However, these wells should have been resampled at that time for this compound in order to properly rule it out.
Pathway Analysis
Page 17, Figure 3: This figure shows the extent of ground-water plumes do not extend as far to the northwest, nor do they extend as far south in the vicinity of the landfill.
The definition of the plume in these areas has not been done in detail. For this reason a conservative plume boundary is shown in the figure. This has now been noted in the figure caption.
Public Health Implications
Page 19, Para 3. The discussion of contaminant toxicity is not based upon past, current or future exposures. The assumption that a water supply well would be drilled next to the landfill is not reasonable; no one is going to construct a water supply well at this location. In addition, such a well would need to be constructed in the near future in order to encounter the concentrations of VOCs used in this assessment; contaminant concentrations are decreasing exponentially with a half-life of one year.
The wording has been clarified so as not to assume drinking water is drawn from TW-25. The assumption that the highest contaminant concentrations could migrate from the site is very conservative.
Page 20, Top Line: The limitations of the second study regarding 1,1 DCA (poor survival in both treated and control animals") would indicate that the results of the only other study are valid; no carcinogenic relationship exists for the substance.
The discussion of this study is presented as part of the review of this compound. The discussion of its weakness is also included.
Page 20, First full Para: What are the "extreme conditions" that would form vinyl chloride from 1,1, TCA and 1,1, DCA in the well of concern?
Because a double bond must be formed in order to create vinyl chloride, an energy source is needed which would require a chemical or biological reaction. Because there isn't enough organic material and chemical concentrations are low (and compatible), neither reaction could be sustained.
Page 20, Para 2 The highlighted sentence, "Persons who drink ground water ever day, over a lifetime, with the highest concentrations of the contaminants detected in on-site monitoring wells would be at an increased risk of getting cancer," is misleading in that it is not possible for this worst case scenario to occur. A water supply well will not be constructed next to the landfill, and contaminant concentrations are decreasing exponentially.
This has been clarified. Though, the assumption of contaminant migration from the site at these levels is still very conservative.
Page 21: The health effects from the inhalation of manganese dust, which would be elemental manganese, are likely to be different than from ionic forms of manganese present in ground-water. In addition, inhalation of manganese dust is a different exposure route than would be possible for manganese present in ground water. As a result, the health effects are likely to be different.
Correct. The description of health effects has been modified to show the relationship to the exposure pathway.
Page 22, Para 2: The "high levels" of manganese dust which cause health effects should be quantified for comparison to the highest levels of this element found on-site.
This information has been added.
Page 22, Para. 4: While it may be difficult to estimate the potential ambient air concentrations of these VOCs based upon soil gas samples, these concentrations would be expected to be very small because of dilution and dispersion, and the distance of the gas probes to the nearest buildings. If these compounds were an actual concern, additional test could and would have been done during the RI. However, because they were not present in the ambient air sample near the gate, and because the active gas collection system proposed for the landfill will alleviate the potential for these compounds to migrate from the site, these VOCs are not of health concern.
This likelihood discussion has been added.

While actual concentration of these VOCs cannot be known without additional measurements, relative concentrations could be referred to. For example, amibient concentrations of benzene near the landfill would be much less than what is experienced during refueling an automobile, or at a residence located near a gas station. Ambient concentrations of tetrachloroethylene near the landfill would be much less than the exposure from wearing clothing that was recently dry-cleaned.
This document does not compare volunary risks to involuntary risks. Though, it is true that most people are not aware of voluntary risks, such as these you've mentioned.
Community Health Concerns evaluation
Item 4: A ground-water monitoring plan has been prepared, and it was approved by the WDNR on August 11. Sampling and private wells and monitor wells will begin in October 1994.
This information has been added.
Item 5: It is not appropriate to render a legal opinion of responsibility for providing an alternative water supply for a hypothetical case.
This is an existing regulatory policy, not a legal opinion.
Conclusion
Paragraph 1: The landfill is closed, but not abandoned.
The wording has been changed.
Paragraph 2: This paragraph neglects to mention that at this time, the locations where ground water exceeds Enforcement Standards is limited to areas less than 500 feet east and west of the landfill. In addition concentrations of VOCs have fallen exponentially over time, and are likely to be below Preventative Action Limits or Quantitation Limits in the near future. Therefore, it is highly unlikely that impacted ground water will pose a public health hazard in the future.
This discussion has been expanded where appropriate.
Paragraph 4: It may not be possible to determine if VOC contaminants in soil gas pose a potential public health hazard in ambient air. However, it is not true that "the likelihood of such an exposure cannot be estimated from the soil gas results". the likelihood of exposure would be low for the following reasons:
  1. The soil gas measurements were taken adjacent to the landfill. The nearest home is at least 1,000 feet from the site. Became of the sandy nature of soils in the are, VOCs are likely to be dispersed to the atmosphere within a short distance from the landfill.
  2. Any gases released from the soil to the atmosphere would undergo significant dilution and dispersion. the average concentration of VOCs in the three gas probes and landfill gas well is about 19 parts per million (by volume); the ambient concentration would likely decreased by several orders of magnitude.
  3. The one sample of ambient air taken at the gate detected toluene and 1,1,1 trichoroethane at concentrations 40 times, and 67 times lower, respectively, than the Comparison values shown in Table 6.
  4. Limited monitoring of homes near the landfill indicated no measurable concentrations of VOCs in air.
Therefore the likelihood of significant exposure of nearby residents or site workers to VOCs inthe ambient air in the past is low. As is indicated in the last paragraph of the Conclusions, theoperation of an active gas collection system will eliminate the possibility of ambient air exposurein the future.

This information has been noted. However, existing monitoring data does not rule out theremaining low potential. The remaining potential and the potential for methane gasbuildup are the reasons for recommending and supporting the active gas collection systemin the final remedy.

I am very displeased to learn the Wisconsin Division of Health (WDOH) has not interviewed anyresidents as to current health problems and concerns that they associate with their proximity tothe Sauk County landfill and their exposure to drinking water, air, and surface soils.

These concerns are so powerful that citizens have prepared their own health evaluation form andare planning on conducting a door to door health survey. I am told that citizens were advised ahealth survey would not be conducted by the State because their health problems could not be ofstatistical significance as their numbers (population) were too small to produce a statistically balidhealth assessment. I find it very disturbing that these residents are being penalized anddiscriminated against because they live in a sparsely populated, rural community.

No health effects are expected as a result of exposure to contamination from the site. Basedon our evaluation of the site, residents have not been exposed to contamination from thesite at levels likely to cause health effects. Residents living near the Sauk County Landfillrequested that the Wisconsin Division of Health conduct a door to door health evaluationof local residents. Our epidemiologists and representatives of the federal Agency for ToxicSubstances and Disease Registry reviewed site information and determined that such astudy would not be useful at this site. Instead, we encouraged all residents who wereexperiencing health problems to contact their physicians. We are willing and anxious towork with citizens and their physician on individual health concerns. We believe workingcooperatively with the physician is the most productive way of addressing health problems. Our agency has contacted the residents living near the landfill and discussed with themtheir health concerns related to the site. We have also met with a representative from theSauk County Health Department and a number of residents to discuss citizen healthproblems and the value of doing a health survey.

Furthermore, aside from toxicological profiles from ATSDR, the exclusive source of informationis from the responsible party's contractor. The contract between Sauk County and [theircontractor] clearly states that the contractor is to provide the County with information "to aid intheir legal defense"; a glaring, self-evident conflict of interest as residents living near the landfillare considered potential future litigants.

The data used for the health assessment did come from the investigation done by aconsulting firm under contract with Sauk County. To make sure that the quality of data isaccurate, appropriate, and unbiased, our agency and the Department of Natural Resourceshave reviewed all investigation activities. In addition, the Department of NaturalResources sampled all area private wells and found their results to be consistent with thoseof the consulting firm. Public funding is not used for the investigation and cleanup of siteswhen a responsible party is available and willing to pay for those activities. Agencyoversight of those activities, however, is designed to prevent possible conflicts of interestfrom effecting the quality of the investigative results.

The health assessment was prepared by a hydrogeologist; the assessment of risk to public healthshould be conducted by a physician together with a toxicologist and epidemiologist or otherqualified health professional.

You mentioned concern that as a hydrogeologist, the preparer of this report is not qualifiedto conduct health assessments. The WDOH would like to assure you that the author is wellqualified to conduct health assessments. The author has a masters degree with emphasis in"Human Health and Environmental Risk Assessment" and extensive training in bothpublic health assessment and risk assessment. You are correct that a health assessmentrequires support from multiple disciplines. WDOH would like to assure you that ourhealth assessors receive support from our toxicologists and epidemiologists whileconducting the health assessment. In addition, our Chief Medical Officer forEnvironmental and Occupational Health, is available to address medical issues as theyarise.

I am angry that the health concerns of the very people that this report is intended to protect, havebeen purposefully excluded and that the Wisconsin Division of Health is responsible.

WDOH believes that public health concerns have been included in the process. We rely oncommunity health concerns to evaluate and make suggestions to improve the investigationand suggest appropriate cleanup alternatives. The Evergreen Property Owners Associationhas been very forth coming in providing us with community health concerns and privatewell information. Those health concerns are presented and discussed in the "Community Health Concerns Evaluation" section of this document.

HEALTH OUTCOME DATA REVIEW

"Health outcome data" is a phrase referring to records of death and disease. When there is evidence that people near a site have been exposed to contaminants at levels that could lead to an increase in rates of death or disease, a review of health outcome data may be appropriate. A review also may be appropriate if there are reports of unusual clusters of disease near a site.

COMMUNITY HEALTH CONCERNS

This section addresses the community health concerns identified earlier in the document.

Groundwater
  1. What will the contaminants found in our drinking water do to our health?
  2. How will the mixtures of more than one contaminant affect our health?
  3. Are the standards set for groundwater contamination protective for children and infants?
  4. How often can our private wells be monitored to protect us from contaminated drinking water?
  5. What should we do if our well becomes contaminated?

Air

  1. Occasionally there are very strong odors coming from the site.
  2. What is in the air and can it affect the health of the nearby residents?
  3. What are the health risks to the workers who will be installing the gas extraction system?

Other

  1. Kids occasionally enter the site on all-terrain vehicles. Are they being exposed to contaminants from the site?
  2. The residents near the site would like a house by house study of everyone's health. Citizens have expressed concerns about the title of this document.
  3. The term "Public Health Assessment" is unclear and can be taken to mean actual evaluations of the health of individuals living near the site.


REFERENCES

  1. Simon Hydro-Search. Technical Memorandum #3; Contaminant Extent Characterization. Sauk County Landfill, Sauk County, Wisconsin. October 8, 1993.

  2. Simon Hydro-Search. Technical Memorandum #4: Additional Investigation. Sauk CountyLandfill, Sauk County, Wisconsin. March 4, 1994.

  3. Simon Hydro-Search. Technical Memorandum #4: Additional Investigation. Sauk CountyLandfill, Sauk County, Wisconsin. March 4, 1994.

  4. Simon Hydro-Search. Technical Memorandum #4: Additional Investigation. Sauk CountyLandfill, Sauk County, Wisconsin. March 4, 1994.

  5. Simon Hydrosearch. Technical Memorandum #3; Contaminant Extent Characterization. SaukCounty Landfill, Sauk County, Wisconsin. October 8, 1993. Table 4-11.

  6. ATSDR. "3/31/94 ATSDR Comparison Value Newsletter." Atlanta, GA. Expires March 31,1994.

  7. Ales, Stephen M.. Letter to [Private Well Owner]. "Results of sampling from your well." January 19, 1994.

  8. ISOPIA. Dermal Exposure Assessment: Principles and Applications. January, 1992.

  9. Agency for Toxic Substances and Disease Registry. Toxicological Profile for 1,1,1Trichloroethane. December 1990.

  10. Agency for Toxic Substances and Disease Registry. Toxicological Profile for 1,1Dichloroethane. December, 1990.

  11. ATSDR. Toxicological Profile for Benzene. February 18, 1992.

  12. ATSDR. Toxicological Profile for Polycyclic Aromatic Hydrocarbons. December, 1990.

  13. ATSDR. Toxicological Profile for 1,1 Dichloroethylene. February 19, 1993.

  14. ATSDR. Toxicological Profile for Tetrachloroethylene. February 18, 1992.

  15. ATSDR. Toxicological Profile for Vinyl Chloride. February 18, 1992.

  16. ATSDR. Toxicological Profile for Manganese. July, 1992.

  17. ATSDR. Toxicological Profile for Polycyclic Aromatic Hydrocarbons. December, 1990.

  18. ATSDR. Toxicological Profile for Lead. February 18, 1992.

  19. ATSDR. Toxicological Profile for Benzene. February 18, 1992.

  20. HSDB. "Dichlorodifluoromethane." Produced by Micromedex, Inc.. Expires January 31,1994.

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