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1. ATSDR > Public Health Assessments & Consultations

1.    The site once posed a public health hazard for former workers because of exposures to chromium in waste solids, sludge, and floor systems and exposure to lead in dust, waste solids, sludge, and soils.

2.    The site currently poses an indeterminate public health hazard because of uncertainty about whether the facilities will be used and the specific type of any reuse and also uncertainty about whether additional removals or remediations will be conducted. Conclusions about reuse follow next.

3.    Facility reuse:

1. Reuse of the plating building as a recycling center was addressed in ATSDR's Public Health Consultation of November 28, 1995 (10). That assessment concluded the following:
   • Air sampling, taken in the plating building two weeks after completion of the cleanup, showed that there is not currently a public health threat through inhalation for recycling reuse. Although there has been no confirmation sampling of the concrete floor, it is unlikely that any residual lead or chromium in the floor (or in soil beneath the building) would present a health threat to individuals infrequently using the facility. ATSDR concludes that use of the plating building as a recycling center would be acceptable from a public health perspective as long as several constraints are addressed (see Recommendations Section).

   The preceding recommendations would not apply to reuses of the plating building that might result in more substantive or intensive exposures. Public health consequences of any such reuse need to be evaluated before implementation.

2. Reuse for indoor athletic practice, student dormitory, or equipment maintenance was addressed in ATSDR's Public Health Consultation of January 30, 1996 (11). That assessment concluded that there is insufficient sampling/analytical data to determine if a potential health threat would exist from these uses.

3. There has been no sampling in the machine shop building and the small office space in the plating building, and neither area has undergone remediation to date. Thus, public health considerations relating to past and future use of those areas cannot be evaluated. Sampling and associated public health evaluations would be needed for those areas before they are reused for any purpose.

4.    The one private well reported to be currently in use east of the site within the city limits is now the closest active private well and has never been sampled. ATSDR believes that well should be sampled, and chromium should be speciated [chromium (VI) and total chromium].

5.    The elevated nitrate levels that have been reported in 7 of the 167 private wells sampled (since 1991) in the county by the NorthWest Local Environmental Protection Group (state-funded) make that well water unsuitable for infant consumption. There is no documentation to show whether owners of those wells responded appropriately to the information provided to them. Also, at least a few of the many other private wells in the county that have not been sampled are likely to contain elevated nitrates. Samples from the public water system show nitrates are not elevated in the municipal water.

Site/Area Characterization Recommendations

1. Sample the one active private well within the city limits east of the site that has never been sampled and speciate chromium [chromium (VI) and total chromium] to confirm whether residents' potable uses of the water pose a health hazard. City water department staff can identify the property. Speciation data for that well then should be reviewed to decide whether any of the currently active private wells farther east (beyond city limits) that were previously sampled warrant resampling and speciation. Data should also be reviewed to decide whether other unsampled private wells beyond the city limits warrant sampling and speciation.

Cease/Reduce Exposure Recommendations

1. Regarding reuse of the facility:
   • Within the plating building, additional sampling of floor dust and interior air should be conducted periodically during reuse to confirm whether activities (e.g., recycling, vehicle parking, etc.) disturb or release any residual contaminants in concrete flooring.
   • If the specific reuse selected for the plating building might result in greater or different exposures than recycling, the public health consequences of such reuse should be evaluated before implementation.
   • In the plating building office area and the machine shop building, sampling should be conducted prior to any type of reuse to confirm whether there is a potential for substantive exposures.
   • More sampling should be done prior to allowing children in any part of the facility.
   • Further characterization is needed prior to use as an athletic practice facility, dormitory, or county maintenance facility.
   • In the future, laboratory results should identify concentrations of chromium (VI), total chromium, and lead for all samples.

Health Activities Recommendation Panel (HARP) Recommendations

The data and information developed in the public health assessment have been evaluated by the ATSDR Health Activities Recommendation Panel (HARP) for appropriate public heath actions. HARP notes the potential exposures to nonsite-related nitrates in some of the private wells in the county. Notification of local public health officials about this contaminant is advised because of potential effects on infants. HARP also recommended that additional professional health education information about nitrate exposure be provided to doctors in the county. HARP concluded that site-related past exposure by former ACE workers to chromium and lead, although substantive, is not now present. Thus, there is not a current need for either health provider education or a health study. While chromium had been present in the public drinking water at elevated levels in the past, HARP concurs that chronic health conditions from this level of exposure is no longer likely be found in the community. Therefore, health follow up is not possible. HARP concurs with recommendations that are provided in this document with respect to reuse of the facilities. ATSDR will reevaluate the site for appropriate follow-up public health actions if additional information becomes available that human exposures to site-related contaminants has occurred or is occurring at levels, durations, or frequencies that constitute a public health concern.

PUBLIC HEALTH ACTIONS

A Public Health Action Plan (PHAP) is developed as part of this public health assessment to document actions that are desirable to mitigate and prevent adverse human health effects resulting from exposure to hazardous substances in the environment.

Actions Taken

ATSDR staff initiated discussion with county health personnel about nitrates in private wells and learned that they request NWLEPG to test private well water for women who undergo pregnancy testing and are not served by the municipal system. That information has been described in the body of this document. ATSDR has provided health education information about nitrate toxicity to some doctors in the county and to some elsewhere in the state.

Actions Proposed

ATSDR will write to doctors in the county who had been sent the earlier education information and remind them about the potential nitrate exposure. Nitrate toxicity education packages will be sent to other doctors in the county who did not participate in ATSDR's previous education project. Future environmental or health outcome data might determine the need for additional actions.

PUBLIC COMMENTS

This document was released for public comment on April 18, 1996; the comment period ended May 24, 1996. No comments were received. ATSDR separately requested selected persons to evaluate the clarity of the document. Two of those responders provided some comments that address programmatic and technical issues; the context of those issues are presented below, along with our response.

Issue: A responder says that the government has effectively taken over the property. The government should provide funds to correct any problems and release the property for productive use.
Response: ATSDR, as required by legislation, examines public health issues at sites that EPA proposes for its National Priority List. ATSDR has not taken over the property and does not fund corrective actions.

Issue: A responder who worked at the property observed no health problems and believes that those observations should be the basis for releasing the property for reuse.

Response: ATSDR does not prevent reuse and stands by its conclusions and recommendations concerning future use.

Issue: A responder believes that since thousands of dollars were spent to clean up the plating building floor, it is unnecessary to sample floor dust in the future. The soil should be clean enough now.

Response: ATSDR stands by its conclusions and recommendations concerning floor dust and building reuse. ATSDR concurs that soil cleanup is sufficient and has not recommended further sampling or cleanup of that medium.

Issue: A responder who was born and lived in Colby questions what someone from ATSDR could know about health in the town.

Response: ATSDR has used background information about the site, chemical concentrations measured in environmental media, and its considerable experience in environmental exposures and chemical toxicity to assess possible health effects to workers and residents.

Issue: A responder is concerned about the facility being reused and raises special concern about children.

Response: ATSDR has expressed its concerns about reuse and children and has provided recommendations pertaining to these concerns.

Issue: A responder is concerned that there probably was a lot of employee contamination exposure and wonders whether they have been contacted.

Response: ATSDR concluded that since the employee exposure occurred in the past, but is not occurring now, no follow up actions are warranted.

Issue: A responder wonders why follow-up testing has not been done to confirm the effectiveness of the floor treatment.

Response: EPA in Kansas City Kansas should be contacted for further information about cleanup protocols. ATSDR has recommended additional sampling appropriate for future use of the facility.

Issue: A responder sometimes was unsure whether the chemical concentrations expressed in the document were elevated.

Response: ATSDR authors find it extremely difficult to discuss chemical concentration information in a context that is meaningful to readers. "Elevated" is a relative term and thus is open to broad interpretation by authors and readers. In addition, authors often cannot find enough information about "background" levels to decide whether a specific chemical concentration is "elevated". Furthermore, under given circumstances, a chemical exposure at "background" levels can have public health consequences; conversely, a chemical exposure at elevated levels might not have health consequences. Thus, readers should focus on discussions in the Public Health Implications section to understand whether chemical exposures pose a health concern.

Shan-Ching Tsai, Ph.D.
Toxicologist
Superfund Site Assessment Remedial Programs Branch
Division of Health Assessment and Consultation

Don Gibeaut
Environmental Health Engineer
Superfund Site Assessment Remedial Programs Branch
Division of Health Assessment and Consultation

ATSDR Regional Representative:
Denise Jordan-Izaguirre
Public Health Advisor
Region VII

1. U.S. Environmental Protection Agency. Ace Services site, Colby, Kansas, hazard ranking system documentation record. January 25, 1995. [ATSDR Code A.1]

2. Kansas Department of Health and Environment, Bureau of Environmental Remediation. Listing site investigation report for the Ace Services Incorporated site in Colby, Kansas. May 31, 1991. [ATSDR Code A.6]

3. Kansas Department of Health and Environment, Bureau of Environmental Remediation, Preremedial Section. Colby public water supply well #8, Colby, Kansas – Thomas County. September 1989 [ATSDR Code A.5]

4. Kansas Department of Health and Environment. Subject: Ace Services, Inc. site – information request. August 1, 1995. [ATSDR Code A.50]

5. Kansas Department of Health and Environment, Bureau of Environmental Remediation. Memorandum, removal of liquids and sludges. May 8, 1992. [ATSDR Code A.21]

6. Reidel Environmental Services. Ace Services health and safety plan. October 10, 1991. [ATSDR Code A.51]

7. U.S. Environmental Protection Agency. Memorandum, Completion of removal activities at Ace Services, Inc., site. July 28, 1994. [ATSDR Code A.44]

8. U.S. Environmental Protection Agency. Memorandum, federal on-scene coordinator's report for the Ace Services, Inc. site, Colby, Kansas. October 24, 1994. [ATSDR Code A.40]

9. U.S. Environmental Protection Agency. Draft memorandum. Request for a removal action at Ace Services site. February 24, 1994. [ATSDR Code A.43]

10. Agency for Toxic Substances and Disease Registery. Public Health Consultation, for reuse of Ace Services property, per Record of Activity of November 28, 1995. [ATSDR Code A.53]

11. Agency for Toxic Substances and Disease Registry. Public Health Consultation, for reuse of facilities, per Record of Activity of January 30, 1996. [ATSDR Code A.71]

12. U.S. Environmental Protection Agency. Toxic Chemical Release Inventory. 1991. [ATSDR Code A.41]

13. U.S. Environmental Protection Agency. Memorandum, Trip report for ace services removal assessment. October 15, 1993. [ATSDR Code A.42]

14. U.S. Environmental Protection Agency. Letter to Kansas State Board of Health concerning effluent. January 25, 1972. [ATSDR Code A.17]

15. U.S. Environmental Protection Agency. Sampling data sheets for removal planning. 1993. [ATSDR Code A.46]

16. U.S. Environmental Protection Agency. Sampling data sheets for removal implementation. 1994 [ATSDR Code A.47].

17. Kansas Department of Health and Environment. Groundwater analytical results, Ace Services Inc. Site. January 1996 [ATSDR Code A.61]

18. Continental Analytical Services Inc. Water quality data sheets for monitoring wells at county landfill. 1995. [ATSDR Code A.62]

19. Kansas Health and Environmental Laboratories. Water quality data sheets for public wells. 1994, 1995. [ATSDR Code A.52]

20. Northwest Local Environmental Protection Group. Letter and attached private well nitrate data. January 30, 1996 [ATSDR Code A.70].

21. ATSDR, Toxicological Profile for Lead. Atlanta, Georgia: Agency for Toxic Substances and Diseases Registry, April, 1993; DHHS publication no. (PHS)TP-92/12.

22. ATSDR, Toxicological Profile for Chromium. Atlanta, Georgia: Agency for Toxic Substances and Diseases Registry, April, 1993; DHHS publication no. (PHS)TP-92/08.

23. IRIS, 1992. Integrated Risk Information System. U.S. Environmental Protection Agency, Office of Health and Environmental Assessment, Environmental Criteria and Assessment Office, Cincinnati, OH.

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