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This health consultation has been prepared at the request of the U.S. Environmental ProtectionAgency, Region I (EPA) by the New Hampshire Department of Health and Human Services,Office of Community and Public Health, Bureau of Environmental and Occupational Health(BEOH) through a combined cooperative agreement with the Agency for Toxic Substances andDisease Registry (ATSDR). This health consultation reviews environmental sampling data thatEPA collected from the area of the former Winchester Tannery, where tannery waste may bepresent, for the purpose of identifying current public health risk associated with exposure tochemical contaminants on the site.

Site Description and History

The Winchester Tannery was the predecessor of the A.C. Lawrence Tannery. It was located onthe east side of North Main Street. The tannery operated from 1831 until it burned down in 1909. During this period of time, the Winchester Tannery site included bark piles, leach pits, a barkmill, splitting, finishing rooms, and a tan yard. When it burned down, it was rebuilt on theopposite side of the river (this is known as the A.C. Lawrence Tannery site).

Part of the Winchester Tannery site is now a residential property. One house was built on the siteshortly after the tannery burned down [DES Personal Communication 2002]. In December 2000,New Hampshire Department of Environmental Services (DES) took soil samples from theproperty; these samples showed elevated levels of lead. The New Hampshire Childhood LeadPoisoning Prevention Program (CLPPP) was also made aware of high levels of lead at the site. Due to the contamination, the Environmental Protection Agency (EPA) conducted a PreliminaryAssessment/Site Investigation (PA/SI) of the residential property on the site, to determine theextent of contamination and whether it was the result of the Winchester Tannery.

Upon finalization of the PA/SI in November 2002, DES issued a Certificate of No Further Actionfor the site. However, this does not equate to a lack of a public health hazard. While DES didnote that several soil samples exhibited concentrations of lead, arsenic and polycyclic aromatichydrocarbons (PAHs) at concentrations exceeding state standards, it did not have data to supportthat these contaminants were due to releases from the former Winchester Tannery [DES 2002]. Additionally, DES does not have regulatory authority regarding cleanup of contaminationresulting from coal and coal ash, or resulting from material such as lead paint applied in a mannerconsistent with practices used when the material was applied [DES 1998].

Overview of Sampling Data:

Surface soil samples were collected systematically over the entire property, using a grid. Thissampling protocol is important since it characterizes the location and the extent of contaminationon the entire site. Forty-six soil samples were tested for inorganic compounds (Table 1) and semivolatile (Table 2) compounds.

In preparing this document, BEOH relied on the information provided by outside sources. Onlydata collected using appropriate sampling and laboratory methods were considered in thisanalysis. Data with demonstrated QA/QC problems were excluded unless they provided uniqueand relevant information. Certified laboratories performed all chemical testing. Measurements ofchemical concentrations were taken directly from laboratory data sheets to avoid transcriptionerrors.


BEOH evaluated sampling data from the PA/SI to determine if there was any contamination thatwould present a health risk to residents of the property. BEOH first compared the sampling datato ATSDR's health comparison values (HCVs). An HCV represents the amount (orconcentration) of a chemical contaminant in an environmental medium, such as soil, air or water,that is used as a first step in evaluating whether actual exposure may likely result in an adversehealth effect. HCVs are screening levels. When the concentration of a contaminant is below theHCV, it is highly unlikely that any kind of harmful effect will result. If a contaminantconcentration is greater than the HCV, it doesn't necessarily mean that exposure is going to resultin a health problem. It only means that additional evaluation of the circumstances in whichhumans may be exposed to it and the public health implications of that exposure are needed.

As a conservative measure, BEOH selected chemicals of concern by evaluating the maximumlevel of each contaminant on the site. If a soil sample contained a chemical above its respectiveHCV, additional evaluation of that chemical was conducted.

Chemicals of Concern

Lead, arsenic, antimony, iron, vanadium, copper and three PAH compounds (benzo[a]anthracene,benzo[b]fluoranthene and benzo[a]pyrene) were selected as chemicals of concern since at leastone soil sample showed each of these chemicals above its comparison value (Tables 1 & 2).

Although the property is on the site of the former Winchester Tannery, it is difficult to ascertain ifthese contaminants were the result of tannery waste. Tannery waste is often associated withchemicals such as chromium, acids and a variety of organic compounds.

Exposure Pathways

Residents could be exposed to chemicals of concern through dermal (skin) contact and ingestion(swallowing) of contaminated soil.

Public Health Implications of Exposure

Antimony, Copper, Vanadium and Iron

Although the maximum values of antimony, vanadium copper and iron were above theircomparison values, the average concentration of these compounds was far below the comparisonvalue and within the range of their respective background levels. No adverse health effects fromexposure to current levels of these chemicals are expected.


Lead is a naturally occurring element in the earth's crust. Most of the high levels foundthroughout the environment come from human activities. Sources of soil contamination includelead that falls to ground from the air, and chipping of lead-based paint from buildings and otherstructures. These materials, especially lead-based paint, deteriorate over time and accumulate insoil. Levels of lead may build up in plants where soil is contaminated with lead.

Lead was found in varying concentrations on the property, from below background levels to1,350 parts per million (ppm). Many of the samples taken near the house, and in the area used forthe vegetable garden, showed levels of lead above the HCV of 400 ppm.

The best measure of lead exposure is the concentration of lead in a person's blood, which is known as the Blood Lead Level (BLL). The BLL can be measured directly in the laboratory from a small blood sample. Alternatively, the BLL can be estimated using relationships between BLL and exposure from the scientific literature, which are summarized in Appendix D of ATSDR's Toxicological Profile for Lead [ATSDR 1999]. Since lead is a common and pervasive contaminant, a small amount of lead is present in the blood of all people. For example, the average BLL for the general population was 2.3 micrograms of lead per deciliter of blood (µg/dL) in 1991-1994 [ATSDR 1999]. Therefore, when evaluating lead exposures, the goal is to estimate the increase in a person's BLL as a result of the exposure, and to determine whether the cumulative exposure would be above a level of health concern.

The Centers for Disease Control and Prevention considers blood lead levels higher than 10 µg/dL to be elevated for children, the most sensitive population to lead [CDC 1991]. Assuming a conservative (worst case) scenario, BEOH used the 95% upper confidence limit of 353 ppm as a realistic level of lead that a child living at the residence could be exposed to. This level of lead was used in the Integrated Exposure Uptake Biokinetic Model for Lead in Children (IEUBK), a computer simulation developed by EPA to predict the probability of lead poisoning in children. IEUBK predicted that a child living in an area with 353 ppm of lead in soils would have an 8.4% probability of experiencing blood lead levels higher than 10 ug/dL. In contrast, EPA guidance for evaluating the risks from lead exposures at hazardous waste sites is that a child should not have more than a 5% chance of elevated blood lead levels [EPA 1994; EPA 1998].

According to the sample grid, many samples around the house show levels of lead that are abovethe 95% upper confidence limit of 353 ppm. Children living in the residence are more likely toplay within the vicinity of the house. Therefore, it is likely that the IEUBK model predictionunderestimates the probability of lead poisoning in young children.

As stated above, it is difficult to ascertain if the levels of lead in the soil are related to theoperations of the former Winchester Tannery. Generally, lead is not associated with tannerywaste. Since the house was built shortly after the tannery burned down [DES PersonalCommunication 2002], it is likely that deteriorated lead paint from the house contributed to thecurrent levels of lead in the soil.

Polycyclic Aromatic Hydrocarbons (PAHs)

PAHs comprise a group of over 100 different chemicals that are formed during the incompleteburning of coal, oil, gas, garbage, and other organic substances such as tobacco or charbroiledmeat. PAHs are usually found as a mixture containing two or more of these compounds. Because of the complexity of these mixtures, the most active compound, benzo[a]pyrene, is usedas the indicator compound. While not all PAHs are considered carcinogenic (e.g., pyrene), theEPA has determined that benz[a]anthracene, benzo[a]pyrene, benzo[b]fluoranthene,benzo[k]fluoranthene, chrysene, dibenz[a,h]anthracene, and indeno[1,2,3-c,d]pyrene are probablehuman carcinogens [ATSDR 1995].

From an environmental perspective, PAHs can usually be found at very low concentrationseverywhere in the environment. The PAH levels that exist in surface soils throughout theproperty are lower than the average levels of PAHs that are found in surface soils in urban,nonindustrial areas of New England [Bradley et al. 1994]. From these comparisons, it is possibleto conclude that the levels of PAHs in the soil do not pose a hazard to occupants of the property.


Arsenic is another element that is widely distributed in the earth's crust, especially in northernNew England. It can be found in drinking water, in most types of soil and in rocks such asgranite. EPA classifies arsenic as a known human carcinogen.

Arsenic is present at low levels throughout much of the soils naturally occurring in NH. Theaverage level of arsenic detected in surface soils on the property is within the range of knownbackground levels in the state of New Hampshire [DES 1998]. Exposure to background levelsrepresents only a slight increase risk of cancer over a person's lifetime. Moreover, it is possibleto conclude that these levels do not pose a hazard to occupants of the property beyond the riskdue to background arsenic levels.


Children are at a greater risk than adults from certain kinds of exposure to hazardous substancesemitted from waste sites. They are more likely to be exposed for several reasons (e.g., they playoutdoors more often than adults, increasing the likelihood that they will come into contact withchemicals in the environment). Because of their smaller stature, they may breathe dust, soil, andheavy vapors close to the ground. Children are also smaller, resulting in higher doses of chemicalexposure per body weight. The developing body systems of children can sustain permanentdamage if certain toxic exposures occur during critical growth stages. Most importantly, childrendepend completely on adults for risk identification and management decisions, housing decisions,and access to medical care.

With specific regard to contaminants in soil, children are at higher risk of exposure because theyare more likely to come in contact with soil than adults. This occurs through playing outdoors,frequent contact with soil, and soil sticking to their exposed skin. Contaminated soil can bespread, resulting in indirect exposures by other children. Levels of lead in the blood can beespecially a concern for young children since they are more vulnerable to the effects of leadpoisoning.


  1. The levels of PAHs, arsenic and other compounds in the soil of the property on theformer Winchester Tannery represent no apparent public health hazard. The levels of thesechemicals on the property are within background concentrations.

  2. The levels of lead in the soil of the property on the former Winchester Tannery representsa public health hazard to children that may reside on the property. This is most likely due toaging lead paint that accumulated in the soil over time.


  1. Residents should not use the garden in its current location.

  2. Residents should take appropriate action to reduce exposure to lead in the soil.


The purpose of the Public Health Action Plan is to ensure that this document not onlyidentifies any current or potential exposure pathways or related health hazards, but also providesa plan of action to mitigate and prevent adverse human health effects resulting from exposures tohazardous substances in the environment. The first section of the Public Health Action Plancontains a description of completed or ongoing actions to mitigate exposures to environmentalcontamination. In the second section, there is a list of additional public health actions that will beimplemented in the future.

Completed or Ongoing Actions:

  1. In December 2000, DES took soil samples from the former Winchester Tannery.

  2. In August 2002, EPA completed a Preliminary Assessment/Site Investigation, whichcharacterized contamination on the site.

  3. In November 2002, DES issued a Certificate of No Further Action since contamination did not appear to be related to tannery waste.

Planned Actions:

  • DHHS will review new data for the site and provide health advice to DES whennecessary.


Todd C. Hudson
Environmental Health Risk Analyst
Bureau of Environmental and Occupational Health
New Hampshire Department of Health and Human Services
Concord, New Hampshire
(603) 271-4664
(603) 271-3991 (fax)


The Health Consultation on the former Winchester Tannery in, Winchester, New Hampshire wasprepared by the New Hampshire Department of Health and Human Services under a cooperativeagreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is inaccordance with approved methodology and procedures existing at the time the HealthConsultation was begun.

Gregory V. Ulirsch, M.S.
Technical Project Officer
Superfund Site Assessment Branch (SSAB)
Division of Health Assessment and Consultation (DHAC)

The Division of Health Assessment and Consultation, ATSDR, has reviewed this HealthConsultation and concurs with its findings.

Roberta Erlwein


Agency for Toxic Substances and Disease Registry (ATSDR). 1999. Toxicological Profile forLead. Atlanta, Georgia: Agency for Toxic Substances and Disease Registry, U.S. Department ofHealth and Human Services.

Agency for Toxic Substances and Disease Registry (ATSDR). 1995. Toxicological Profile forPolycyclic Aromatic Hydrocarbons. Atlanta, Georgia: Agency for Toxic Substances and DiseaseRegistry, U.S. Department of Health and Human Services.

Bradley, LJN; Magee, BH; Allen SL. 1994. Background levels of polycyclic aromatichydrocarbons (PAH) and selected metals in New England Urban Soils. Journal of SoilContamination, 3(4): 349-361.

Centers for Disease Control and Prevention. 1991. Preventing Lead Poisoning in YoungChildren. Atlanta, Georgia: Centers for Disease Control, U.S. Department of Health and HumanServices.

Department of Environmental Services. 1998. Contaminated Sites Risk Characterization andManagement Policy. Concord, New Hampshire.

Department of Environmental Services. 2002. Re: Former Winchester Tannery, Certificate ofNo Further Action. Concord, New Hampshire.

Environmental Protection Agency. 1994. Revised Interim Soil Lead Guidance for CERCLA Sitesand RCRA Corrective Action Facilities. OSWER Directive # 9355.4-12. EPA/540/F-94/043.Washington, DC: Office of Solid Waste and Emergency Response, Environmental ProtectionAgency.

Environmental Protection Agency. 1998. Clarification to the Revised Interim Soil Lead Guidancefor CERCLA Sites and RCRA Corrective Action Facilities. OSWER Directive # 9200.4-27P.EPA/540/F-98/030. Washington, DC: Office of Solid Waste and Emergency Response,Environmental Protection Agency.

Environmental Protection Agency, Region IV. 2000. Region IV Human Health Risk AssessmentBulletins; Supplement to Risk Assessment Guidance for Superfund (RAGS). Atlanta, Georgia:Waste Management Division, Environmental Protection Agency. Exiting ATSDR Website


Table 1.

Maximum levels of Inorganics.
Chemical Max. Conc. (ppm) Comparison Value
Amount Source
Aluminum 16700 100000 Intermediate EMEG - Child
Antimony 42.8 20 RMEG - Child
Arsenic 41.7 0.5 CREG
Barium 448 4000 RMEG
Beryllium 1.7 100 Chronic EMEG - Child
Cadmium 0.99 10 Chronic EMEG - Child
Chromium (VI) 223 230 Residential RBC
Copper 6640 2000 Intermediate EMEG -Child
Iron 60400 23000 Residential RBC
Lead 1350 400 Residential PRG
Manganese 2450 3000 RMEG - Child
Mercury 0.61 23 Residential PRG
Nickel 20 1000 RMEG - Child
Selenium 2.3 300 Chronic EMEG - Child
Silver 1.1 300 RMEG - Child
Thallium 1.5 5.2 Residential PRG
Vanadium 351 200 Intermediate EMEG - Child
Zinc 40.2 20000 Chronic EMEG - Child

EMEG – Environmental Media Evaluation Guide, developed by ATSDR
RMEG – Reference Dose Media Evaluation Guide, developed from EPA’s Reference Dose
CREG – Cancer Risk Evaluation Guide, developed by ATSDR
RBC – Risk-Based Concentration, developed by EPA, Region IV
PRG – Preliminary Remediation Goal, developed by EPA, Region IX

Table 2.

Maximum levels of PAHs.
Chemical Max. Conc. (ppm) Comparison Value
Amount Source
Fluoranthene 1.9 3100 RBC Residential
Pyrene 2.3 2300 RBC Residential
Benzo[a]Anthracene 1.4 0.87 RBC Residential
Chrysene 1.4 87 RBC Residential
Benzo[b]Fluoranthene 1.4 0.87 RBC Residential
Benzo[k]Fluoranthene 0.47 8.7 RBC Residential
Benzo[a]Pyrene 0.99 0.1 CREG
Indeno[1,2,3-c,d]Perylene 0.5 0.87 RBC Residential

CREG – Cancer Risk Evaluation Guide, developed by ATSDR
RBC – Risk-Based Concentration, developed by EPA, Region IV

Table of Contents The U.S. Government's Official Web PortalDepartment of Health and Human Services
Agency for Toxic Substances and Disease Registry, 4770 Buford Hwy NE, Atlanta, GA 30341
Contact CDC: 800-232-4636 / TTY: 888-232-6348

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