Comments on American Crossarm and Conduit
Public Health Assessment
The following responses were made during and after the public comment period. No comments
were received from people who live in the area adjacent to the site. This list of comments does not include editorial or procedural comments. If the accuracy of a statement was questioned, the statement was verified or corrected. If the same comments were received from more than one
source, only one comment and response is listed. The comments were paraphrased by the health
assessor for brevity or clarity.
Comment 1: Incineration of pentachlorophenol wastes as a cleanup measure may have contributed
additional dioxin to the soils in the community. This source of dioxin is not mentioned in the
assessment.
Response to Comment 1: The assessment states on page 2, last paragraph, last 2 sentences,
"In 1988 and 1989, EPA incinerated on-site some of the contaminated soil, sludge and debris
(1). Incineration generated about 207 tons of ash which is presently stored on-site (5)."
EPA's On-Scene Coordinator Report states the burn efficiency was 99.99%. Because the
burn occurred in 1988 and 1989, and the environmental samples discussed in the health
assessment were collected in 1990 and 1991, any increment of dioxin added to area soils by
the burn would have been detected. This possible source of dioxin is mentioned in the
health assessment on page 20, 4th paragraph, 6th sentence, "It (dioxin) can be inadvertently
produced in very small amounts as an impurity during the manufacture of certain herbicides
and germicides and has been detected in products of incineration of municipal and industrial
wastes."
Comment 2: Some people in the community believe that there have already been health impacts
from the Crossarm site. They believe that children have been particularly affected with
developmental problems, hormonal disorders, possible immune system problems, reproductive
problems, and tumors. The level of dioxin in the yards yet to be cleaned up is high enough to
support those fears, particularly in the light of the recently released Dioxin Reassessment. I would have liked to see a recommendation for some study of health problems described by citizens.
Response to Comment 2: A health study of citizens was not recommended because
the levels of contaminants (including dioxin) found off-site have not been reported
to be associated with detectable human adverse health effects. The recently released
EPA Dioxin Reassessment added additional adverse health outcomes which may be
possible from exposure to dioxin, but it did not lower the level at which adverse
outcomes might be expected to occur. A recommendation to do a health study in this
community should not be made until an association is found that can be used to focus
the study design. If an association is found that links an adverse health outcome to
the level of contaminants found off-site, this situation will be reassessed, and a health
study may be proposed.
Comment 3: An earlier draft of the Health Assessment recommended testing of fish caught in the immediate area. This should be recommended. Did it occur?
Response to Comment 3: ATSDR's Preliminary Health Assessment for American Crossarm
and Conduit was written in 1990. One recommendation stated, "Sampling of fish tissue
from Dillenbaugh Creek should be considered, so that a determination can be made
regarding the human health concern from the dioxins in the sediments." There was very
little environmental data on this site in 1990. EPA's remedial investigation was completed
during September 1992. The results of testing of sediment and water samples from
Dillenbaugh Creek and the Chehalis River did not justify a follow-up sampling of the biota.
For that reason it was not recommended in the current health assessment.
Comment 4: In the testing of well water it was not clear that the wells that are being used for
irrigation were tested for contamination. In terms of animals feeding on the crops grown from the
areas serviced by these wells, would not it be important to know the levels of contamination (if any)
since the chemicals of concern have the ability to accumulate in fatty tissue of animals or people
who may consume them?
Response to Comment 4: The assessment states, "Thirty-three domestic, irrigation, and
municipal wells are located within a two-mile radius of ACC. The majority of these wells
are in the outlying areas of Chehalis to the south and southwest, and are separated from the
facility by the Chehalis and Newaukum rivers and Dillenbaugh Creek. Area well water
levels range from 30 to 110 feet below ground surface, with about 75 percent of the wells
used for domestic purposes. The wells closest to ACC (within a 1/4 mile radius) are used
for irrigation (1)."
EPA's Remedial Investigation (RI) found groundwater contamination on-site in the
immediate vicinity of the probable sources. Therefore, no off-site production wells were
tested. The RI stated in part that the contaminants in groundwater are flowing
southwestward toward the Chehalis/Newaukum river system and will discharge about 3,500
feet west of the site. Travel time for groundwater to move from the site to the river system
is in the range of 40 to 400 years.
Comment 5: What sort of uptake is expected in plants grown on contaminated soil? To date I have
seen or heard nothing to indicate that the public has been warned in any way about these potential
risks.
Response to Comment 5: Plant uptake of soil constituents is dependent on the type of plant,
the constituent, and a multitude of soil conditions (e.g., acidity, alkalinity, organic matter,
etc.). The levels of contaminants of concern off-site are low. However, some plants may
biologically concentrate the soil contaminants. A prudent person would not grow plants for
consumption in the vicinity of ACC.
Over the years several warnings have been issued to local residents by the Lewis County
Health District, not to eat plants grown near ACC. The Health Assessment recommended
that, "People should be advised not to grow gardens in the off-site contaminated area."
Comment 6: The health assessment did not physically attain information from people claiming to have adverse health affects.
Response to Comment 6: Adverse health effects from residents near the site were
reported to DOH in a one-page "fact-finding survey" designed and administered by
one of the residents, and by telephone interviews with residents who contacted DOH.
The name and telephone number for a DOH contact was published in a local
newspaper article during December of 1992 so residents with adverse health effects
would have the opportunity to report to DOH. All of the collected information was
considered in the writing of the health assessment.
Comment 7: During the flood, pentachlorophenol was deposited on wood surfaces throughout the
surrounding neighborhood. There has been no mention of removal of these items, just soil around
the homes.
Response to Comment 7: The assessment states on page 2, last paragraph, last sentence, "In
1988 and 1989, EPA incinerated on-site some of contaminated soil, sludge and debris
[which includes wood] (1). Incineration generated about 207 tons of ash which is presently
stored on-site (5)." EPA's Record of Decision states in part (page 1-1) "An emergency
removal action was initiated during late 1986 to remove contamination distributed during
a flood in the Chehalis Avenue area. In 1988, an incinerator was brought onto the facility
to incinerate the principle threat (e.g., contaminated material from that cleanup)."
