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1. ATSDR > Public Health Assessments & Consultations

PUBLIC HEALTH ASSESSMENT

PACKAGING CORPORATION OF AMERICA
FILER CITY, MANISTEE COUNTY, MICHIGAN

APPENDIX A. - FIGURES

LIST OF FIGURES

Figure 1. Site Location

Figure 2. Site Features

Figure 1. Site Location


Figure 2. Site Features

APPENDIX B. - TABLES

LIST OF TABLES

Table 1.	Population of civil divisions near the Packaging Corporation site.
Table 2.	Concentrations of contaminants of concern detected in surface water samples from Manistee Lake, 1957-1983.
Table 3.	Contaminants of concern at the Packaging Corporation of America site
Table 4.	Maximum concentrations of contaminants of concern detected in "surficial soil" samples from the lagoon areas in September 1986
Table 5.	Maximum concentrations of contaminants of concern detected in deeper sub-surface soil samples from the lagoon area in September 1986
Table 6.	Concentrations of contaminants of concern detected in surface water from Lagoons 2 and 3 in September 1986
Table 7.	Maximum concentrations of contaminants of concern detected in sediment samples from lagoons 2 and 3 in September 1986
Table 8.	Concentrations of contaminants of concern detected in groundwater from on-site monitoring wells in 1987, 1988, and 1992
Table 9.	Concentrations of contaminants of concern detected in groundwater from monitoring wells near the PCA site in 1987, 1988, and 1992
Table 10.	Concentrations of contaminants of concern detected in groundwater from beneath Manistee Lake in December 1988 and September 1992
Table 11.	Concentrations of contaminants of concern detected in groundwater from residential and industrial wells near the PCA site, November 1988
Table 12.	Maximum concentrations of contaminants of concern detected in sediment samples from Manistee Lake.
Table 13.	Concentrations of contaminants of concern detected in pore-water in sediment from Manistee Lake in September 1992
Table 14.	Concentrations of chemical contaminants in fish collected from Manistee Lake, 1991
Table 15.	Number of cancer deaths, by age group, in Filer and Stronach Townships, Manistee County, Michigan, 1980 -- 1991
Table 16.	Number of cancer deaths, by site, in Filer and Stronach Townships, Manistee County, Michigan, 1980 -- 1991
Table 17.	Number of cancer deaths, by age and sex, in Filer and Stronach Townships, Manistee County, Michigan, 1980 -- 1991
Table 18.	Number of New Cases of Cancer Observed and Expected for Zip Code 49660, 1985-1990.
Table 19.	Numbers of Cancer Cases and Age-Adjusted Rates: Michigan Residents and ZIP Code 49660, 1985-1990
Table 20.	Numbers of New Cases Observed and Expected for Cancers of Selected Sites: Residents of ZIP Code 49660, 1985-1990

Table 1. Population of civil divisions near the Packaging Corporation site.

Table 2. Concentrations of contaminants of concern detected in surface water samples from Manistee Lake, 1957-1983.

Contaminants of concern that were not detected in this medium are not listed.

Shaded chemicals exceed comparison values.

NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
C -- ATSDR Cancer Risk Evaluation Guides (CREGs)
R -- Concentration derived from U.S. EPA Reference Dose (Chronic) by Ingestion, assuming child exposure
A -- U.S. EPA Drinking Water Health Advisory (Lifetime)
PL -- U.S. EPA Proposed Action Level for Lead in Drinking Water

Table 3. Contaminants of concern at the Packaging Corporation of America site

Table 4. Maximum concentrations of contaminants of concern detected in "surficial soil" samples from the lagoon areas in September 1986

Reference: 3
Contaminants of concern that were not detected in this medium are not listed.
Shaded chemicals exceed comparison values.
ND -- Not Detected (with highest detection limit reported)
NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available
Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
C -- ATSDR Cancer Risk Evaluation Guides (CREGs)
R -- Concentration derived from U.S. EPA Reference Dose (Chronic) by Ingestion, assuming child exposure and pica behavior

Table 5. Maximum concentrations of contaminants of concern detected in deeper sub-surface soil samples from the lagoon area in September 1986

Reference: 3

Contaminants of concern that were not detected in this medium are not listed.

Shaded chemicals exceed comparison values.

ND -- Not Detected (with highest detection limit reported)
NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
C -- ATSDR Cancer Risk Evaluation Guides (CREGs)
R -- Concentration derived from U.S. EPA Reference Dose (Chronic) by Ingestion, assuming child exposure and pica behavior

Table 6. Concentrations of contaminants of concern detected in surface water from Lagoons 2 and 3 in September 1986

Reference: 3
Contaminants of concern that were not detected in this medium are not listed.
Shaded chemicals exceed comparison values.
NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
C -- ATSDR Cancer Risk Evaluation Guides (CREGs)
R -- Concentration derived from U.S. EPA Reference Dose (Chronic) by Ingestion, assuming child exposure
A -- U.S. EPA Drinking Water Health Advisory (Lifetime)
PL -- U.S. EPA Proposed Action Level for Lead in Drinking Water
PM -- U.S. EPA Proposed Maximum Contaminant Level under the Safe Drinking Water Act

Table 7. Maximum concentrations of contaminants of concern detected in sediment samples from lagoons 2 and 3 in September 1986

Reference: 3

Contaminants of concern that were not detected in this medium are not listed.
Shaded chemicals exceed comparison values.
J -- Estimated Value
NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
C -- ATSDR Cancer Risk Evaluation Guides (CREGs)
R -- Concentration derived from U.S. EPA Reference Dose (Chronic) by Ingestion, assuming child exposure and pica behavior

Table 8. Concentrations of contaminants of concern detected in groundwater from on-site monitoring wells in 1987, 1988, and 1992

Contaminants of concern that were not detected in this medium are not listed.

Shaded chemicals exceed comparison values.

ND -- Not Detected, with Detection Limit

NR -- Not Analyzed for, or not reported

NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Comparison Value Bases :

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
C -- ATSDR Cancer Risk Evaluation Guides (CREGs)
R -- Concentration derived from U.S. EPA Reference Dose (Chronic) by Ingestion, assuming child exposure
A -- U.S. EPA Drinking Water Health Advisory (Lifetime)
PL -- U.S. EPA Proposed Action Level for Lead in Drinking Water
PM -- U.S. EPA Proposed Maximum Contaminant Level under the Safe Drinking Water Act

Table 9. Concentrations of contaminants of concern detected in groundwater from monitoring wells near the PCA site in 1987, 1988, and 1992

Contaminants of concern that were not detected in this medium are not listed.

Shaded chemicals exceed comparison values.

ND -- Not Detected, with Detection Limit

NR -- Not Analyzed for, or not reported

NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Comparison Value Bases :

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
C -- ATSDR Cancer Risk Evaluation Guides (CREGs)
R -- Concentration derived from U.S. EPA Reference Dose (Chronic) by Ingestion, assuming child exposure
A -- U.S. EPA Drinking Water Health Advisory (Lifetime)
PL -- U.S. EPA Proposed Action Level for Lead in Drinking Water
PM -- U.S. EPA Proposed Maximum Contaminant Level under the Safe Drinking Water Act

Table 10. Concentrations of contaminants of concern detected in groundwater from beneath Manistee Lake in December 1988 and September 1992

Contaminants of concern that were not detected in this medium are not listed.
Shaded chemicals exceed comparison values.

J -- Estimated Value, less than Contract Required Detection Limit but above Instrument Detection Limit
ND -- Not Detected, with Detection Limit
NR -- Not Analyzed for, or not reported
NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Comparison Value Bases :

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
C -- ATSDR Cancer Risk Evaluation Guides (CREGs)
R -- Concentration derived from U.S. EPA Reference Dose (Chronic) by Ingestion, assuming child exposure
A -- U.S. EPA Drinking Water Health Advisory (Lifetime)
PL -- U.S. EPA Proposed Action Level for Lead in Drinking Water

Table 11. Concentrations of contaminants of concern detected in groundwater from residential and industrial wells near the PCA site, November 1988

Reference: 3

Contaminants of concern that were not detected in this medium are not listed.

Shaded chemicals exceed comparison values.

ND -- Not Detected, with Detection Limit

NR -- Not Analyzed for, or not reported

NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
C -- ATSDR Cancer Risk Evaluation Guides (CREGs)
R -- Concentration derived from U.S. EPA Reference Dose (Chronic) by Ingestion, assuming child exposure
A -- U.S. EPA Drinking Water Health Advisory (Lifetime)
PL -- U.S. EPA Proposed Action Level for Lead in Drinking Water
PM -- U.S. EPA Proposed Maximum Contaminant Level under the Safe Drinking Water Act

Table 12. Maximum concentrations of contaminants of concern detected in sediment samples from Manistee Lake.

Contaminants of concern that were not detected in this medium are not listed.

Shaded chemicals exceed comparison values.

NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
C -- ATSDR Cancer Risk Evaluation Guides (CREGs)
R -- Concentration derived from U.S. EPA Reference Dose (Chronic) by Ingestion, assuming child exposure and pica behavior

Table 13. Concentrations of contaminants of concern detected in pore-water in sediment from Manistee Lake in September 1992

Reference: 5

Contaminants of concern that were not detected in this medium are not listed
Shaded chemicals exceed comparison values.
ND -- Not Detected (with detection limit)
NA -- Not Available
carcinogen -- Carcinogen (proven, probable, or possible), but CREG is not available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
C -- ATSDR Cancer Risk Evaluation Guides (CREGs)
R -- Concentration derived from U.S. EPA Reference Dose (Chronic) by Ingestion, assuming child exposure
A -- U.S. EPA Drinking Water Health Advisory (Lifetime)
PL -- U.S. EPA Proposed Action Level for Lead in Drinking Water
PM -- U.S. EPA Proposed Maximum Contaminant Level under the Safe Drinking Water Act

Table 14. Concentrations of chemical contaminants in fish collected from Manistee Lake, 1991

Reference: 20

J -- Estimated concentration

NA -- Not Available

Table 15. Number of cancer deaths, by age group, in Filer and Stronach Townships, Manistee County, Michigan, 1980 -- 1991

Reference: 29

Table 16. Number of cancer deaths, by site, in Filer and Stronach Townships, Manistee County, Michigan, 1980 -- 1991

Reference: 29

Table 17. Number of cancer deaths, by age and sex, in Filer and Stronach Townships, Manistee County, Michigan, 1980 -- 1991

Table 18. Number of New Cases of Cancer Observed and Expected for Zip Code 49660, 1985-1990.

Reference: 29

Table 19. Numbers of Cancer Cases and Age-Adjusted Rates: Michigan Residents and ZIP Code 49660, 1985-1990

Reference: 29

* Rate is considered statistically unreliable, due to small number of cases.

Includes cases diagnosed between 1985 and 1990 and reported to the Michigan Department of Public Health by December 31, 1991.

Table 20. Numbers of New Cases Observed and Expected for Cancers of Selected Sites: Residents of ZIP Code 49660, 1985-1990

Reference: 29

RESPONSIVENESS STATEMENT

The MDPH released a draft of this Public Health Assessment for public comment on March 29, 1995. The public comment period was open until April 28, 1995. MDPH received comments from the Environmental Manager for PCA (Reference 10) and from the MDNR site manager. Those comments, with MDPH's responses, are repeated below. Page and paragraph references are to the Initial Release of the Assessment.

Comments from the Environmental Manager for the Packaging Corporation of America:

Comment: We note that the six conclusions are matched by six recommendation that pertain to the same respective subject matter, and therefore we will comment on these six items in order:

1. We disagree with conclusion Number 1 that the PCA site poses an "indeterminate" public health hazard at this time and that samples of "actual surface material" should be collected and analyzed for contaminants of concern. We believe there is no public health risk and there is no need for further sampling and testing.

   The ATSDR conclusion seems to be based on (a) the belief that surface samples were taken from just below the surface instead of "actual surface material" and (b) the test results showed elevated levels of some chemicals of concern in lagoon #1, and to a lesser extent in lagoons #2 and #3.

   The surface samples were "actual surface material". The Remedial Investigation report states on page 45 that "Surficial soil samples were collected with trowels after organic litter (grass, leaves and roots) were removed by shovel and gloved hand." Thus surface samples were taken from the true surface soil, with only the natural organic material removed because this would have affected the analysis of the soil for organic chemicals. Therefore, there is no need for additional samples and tests to characterize the surface soil.

   The Baseline Risk Assessment (BRA) concluded that the level of chemicals that were present in the surface sampled did not pose a risk to human health. Both Trespasser and Hunter scenarios were evaluated and no Hazard Index (HI) exceeded 0.04. The EPA agreed with this conclusion, stating in the Declaration of the Record of Decision (ROD): "EPA has determined that conditions at the site pose no current or potential unacceptable risk to human health or to the environment."

   Moreover, the ongoing "Landfill Closure" of lagoons #1, 2, and 3 has reduced risks even more. Lagoons #2 and 3 are being eliminated according to the "Preliminary Closure Plan for PCA Landfill" that had been approved by both the EPA and the Michigan Department of Natural Resources (DNR). The cellulose fiber sludge is being removed from lagoon #2 and in several years it will be revegetated and restored to its original condition. Lagoon #3, the landfill lagoon, will be capped with an impervious membrane and covered with 3 ft. of a clean soil vegetative layer. About 25% of it is already capped.

   In lagoon #1, all of the "soap skimmings" residue referred to on page 5 have already been removed.

   While this work is going on, access to lagoons #2 and #3 is controlled by the fence and gates mentioned in the ATSDR report.

   Lagoons #4 through 8 are not a concern because, as the ATSDR report says on page 10, "The RI contractors reported that residues from the wastes were not detected in lagoons 4, 5, 6, 7, and 8."

2. We agree with recommendation #2 that it is a good idea to have restrictions on the area above the groundwater plume to deter the installation of new wells, even though, as the ATSDR report notes, this is unlikely to occur. However, we believe that there already are sufficient safeguards in place. Let us bring to your attention a number of restrictions that already exist that prevent water well development:
   
   

   --	The Michigan Department of Public Health has forbidden the drilling of any new wells in any area above the plume.
   --	PCA owns most of the land above the plume and we have no objection to placing a deed restriction on it to complement the Department of Health's proscription.
   --	There already are deed restrictions on the property owned by the Village of Eastlake and on the former Stronach Township property (which PCA has recently acquired), that limit the use of this property to park and recreational.
   --	Martin Marietta has place a deed restriction on their property that prohibits the drilling of water wells as a result of negotiations with PCA.

3. We agree with recommendation #3 that groundwater should continued to be monitored to detect any movement of contaminants from the plume to private or municipal wells. As you know, such monitoring is included in the EPA ROD.

   In September, 1994, PCA submitted a "Work Plan for Groundwater and Surface Water Monitoring" to the EPA and it was approved on October 17, 1994. It calls for annual sampling of 6 residential or municipal wells, and 15 [monitoring] wells in the plume or between the plume and private and municipal wells, for the parameters listed in the ROD. The first sampling will take place in June, 1995, and it will continue indefinitely -- perhaps for 60 years or more.

4. We disagree with recommendation #4 that additional hydrogeological studies should be made to establish the structure of the geological formations underneath Manistee Lake and the extent of the groundwater plume, to determine whether any private or municipal wells might be reached by the contamination. We believe the geological formation and the extent of the plume have been well established as described in the RI report. The EPA agreed in their response to comment #6 on page 17 of the Responsiveness Summary of the ROD, saying, "The Agency believes that enough information has been gathered to make an appropriate decision about groundwater at the site which would be protective of human health and the environment."

   We certainly share your desire to insure the safety of private and municipal wells, but we believe this is being accomplished by the comprehensive groundwater monitoring program described in item #3.

   Additional facts further attest to the security of private and municipal wells.
   
   

   --	The groundwater modeling that was done for the RI report shows that the plume reached its maximum extent some time ago. Approximately ninety percent of the contaminant mass has already vented into Manistee Lake and the plume will only decrease in size and concentration over the next 60 years.
   --	Both modeling and other data from the RI indicate that Manistee Lake is an effective barrier to prevent contaminants from migrating to the west side of the Lake, and any private or municipal wells on the west side will not be impacted. Aquifer testing and modeling show that wells on the west side of Manistee Lake would have been impacted many years ago if the Lake were not an effective barrier.
   --	This is supported by test data on monitoring well #106 that has been taken since 1978. This well is on the south edge of the plume where it is the closest to private residences. It shows that the plume is retreating and not spreading.

   SUMMARY OF ARSENIC AND COLOR CONCENTRATIONS IN MONITORING WELL #106

   Date	Arsenic (ppb)	Color (APHA units)
   October 20, 1978		1,300
   October 25, 1979		700
   January 14, 1980	14	550
   September 7, 1983	< 10
   November 11, 1983	7.7	150
   October 7, 1987	ND (10.J)	32
   November 15, 1990	5.B	55

   Thus, arsenic has declined from 14 ppb in 1980 to 5 in 1990, and color declined from 1,300 APHA units in 1978 to 55 in 1990. This indicates that the edge of the plume is retreating.

   We expect the monitoring program will continue to show a gradually diminishing plume.

   
   

   Response:

   The plume is apparently diminishing because it is being washed into Manistee Lake and the source has been eliminated. There are other possible routes for the dispersal of the contaminant plume, and we do not agree that the available data is sufficient to eliminate them from consideration.

5. We agree with the last sentence on the item #5 conclusion which states that: "There are many other potential sources for the contamination of the lake besides the PCA site and the PCA plant." That is one of the principal problems we have with the 1992 MDNR-contracted survey of Manistee Lake. We are enclosing a copy of our July 30, 1993 comments that we sent to the EPA on the draft DNR report.

   Conclusion #5 recommends additional sampling of sediments and surface water in Manistee Lake. We believe there is value in some continued monitoring of Lake conditions and we well be conducting continued lake water testing as described in the "Work Plan for Groundwater and Surface Water Monitoring". Lake water tests, together with bioaccumulation factors will track effects on fish. However, if recommendation #5 means that PCA should carry on the DNR-contractor study, we believe that this is not appropriate for the reasons stated in our June 30, 1993 comments.
   
   

   Response:

   The specific actions in response to Public Health Assessment recommendations for environmental actions such as monitoring are left to the environmental agencies to determine.

   
   

6. We agree with recommendation #6 that the existing MDPH advisory on consumption of fish from Manistee Lake is sufficiently protective of human health.
   
   

   Response:

   Thank you for your support.

   Additional minor corrections or explanations:

   a. On page 2, 4th paragraph, wastewater flowed through lagoons #1 through #7 in numerical order, but lagoon #8 was an alternate destination to lagoons #4-5-6-7 for wastewater pumped out of lagoon #3.
   
   

   Response:

   The assessment has been revised to include this information.

   b. On page 2, last paragraph, lagoon #2 was not pumped out in the early 1970s because it was full of cellulose fiber sludge, not liquor that would seep into the ground.
   
   

   Response:

   The assessment has been revised to include this information.

   c. On page 3, first paragraph, approximately one-third of lagoon #3 was capped in 1994, not mid-August, 1993.
   
   

   Response:

   The assessment has been revised to include this information. The original statement was based on observations made during the MDPH visit to the site on August 10, 1993.

   d. On page 3, first paragraph, lagoon #2 now contains cellulose fiber sludge with a little rainwater, not the "black liquor" that was originally l agooned.
   
   

   Response:

   The assessment has been revised to include this information.

   e. On page 8, last paragraph, the 1 lb. of PCB in 1988 was a leak from a transformer into a moat that surrounded it. It was properly cleaned up and disposed of in accordance with all applicable regulations. No PCB got onto the ground at the Filer Mill. This also applies to page 9, second paragraph.
   
   

   Response:

   The assessment has been revised to include this information.

   Comments from the Michigan Department of Natural Resources site manager:
   
   

   Comment:	Page 16, Potential Exposure Pathways, Surface Water: The last sentence states that dilution of groundwater as it discharges to surface water will likely reduce the concentrations of contaminants to below levels of concern. In our estimation, the data available to date is insufficient to be able to reach strong conclusions regarding the human health risks posed by groundwater discharging to surface water. We do know that the groundwater discharge poses significant ecological risks, as evidenced by the high toxicity of groundwater to Ceriodaphnia dubia, and by the abnormal distribution and numbers of pollution tolerant benthic organisms present in the area of plume discharge. It remains to be determined to what degree these ecological impacts signify human health impacts. Several data gaps remain: volatiles and semivolatiles in groundwater had very high detection limits; no surface water measurements have been made; very few of the tentatively identified compounds in the groundwater have been positively identified; the cause of the extreme groundwater toxicity is unknown; and no fish from Manistee Lake have been sampled to look for bioconcentration of site indicator compounds. These data gaps may be addressed by the site monitoring studies required in the U.S. Environmental Protection Agency's (EPA) Record of Decision.
   Response:	The text has been revised to reflect these uncertainties.
   Comment:	Page 22, Recommendations, number 6: The assessment states that the current MDPH advisory on consumption of fish from Manistee Lake is sufficiently protective of human health. We recommend awaiting the results of the post-ROD monitoring studies before making a final assessment of the risks posed by consumption of fish from the lake. In our meeting ... you expressed similar sentiments regarding the need for additional data. If your agency has specific recommendations regarding additional data necessary to move from an indeterminate to a more specific overall health assessment, please provide these suggestions to the EPA or us for possible inclusion in the monitoring plan for this site.
   Response:	After internal review of the assessment and discussions with the MDNR, the text of the recommendation has been changed to provide for evaluation of new data on fish from the lake and reconsideration of the advisory.

1. The company has since carried out this removal (10).
2. Pica behavior is an abnormal consumption of non-food materials, such as soil, most often seen in children under 5 years of age.
3. The estimates were computed by multiplying the national age- and sex-specific cancer incidence rates compiled by the SEER Program by the number of people in each age group living in the zip code area according to U.S. Census data and estimates. These products are then summed to give the total cancer rate estimate (28).
4. Includes unincorporated villages
5. Unincorporated village(s), not listed in Census Report.
6. Based on U.S. Food and Drug Administration (FDA) Action Levels, except for mercury (U.S. FDA -- 1.0 ppm).
7. Unidentified chemical similar to toxaphene
8. Total DDT, DDD, and DDE.
9. Includes cases diagnosed between 1985 and 1990 and reported to the Michigan Department of Public Health by December 31, 1991.
10. Calculated by applying the age- and sex-specific incidence rates for Michigan to the age- and sex-specific ZIP code population estimates (28).
11. Includes cases diagnosed between 1985 and 1990 and reported to the Michigan Department of Public Health by December 31, 1991.
12. Calculated by applying the age- and sex-specific incidence rates for Michigan to the age- and sex-specific ZIP code population estimates (28).

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