PUBLIC HEALTH ASSESSMENT
POLES, INCORPORATION WOOD TREATMENT FACILITY
OLDTOWN, BONNER COUNTY, IDAHO
5. DISCUSSION - ADULT AND CHILDREN'S HEALTH ISSUES
After reviewing the site-specific data and information, there are four completed and three potential exposure pathways which people could be or could have been exposed to chemicals from the site. Health effects can only result from site contaminants when people come in contact with them. The public health implication of the exposures is discussed in the following sections. In Section 5.1, the actual exposures or doses to these contaminants of concern (selected from Section 3) are evaluated using estimates of exposure and the toxicological properties and epidemiological information of these chemicals. As a part of the ATSDR Child Health Initiative and in response to community concerns, the susceptibility of young children or developing fetuses to the chemical exposures are part of the toxicological and epidemiological review. In Section 5.2, cancer incidence data for the combined ZIP Codes of Oldtown, ID, Newport, WA, and Priest River, ID are presented. Finally, questions raised by the community during the public health assessment process are presented and addressed in Section 5.3.
5.1 Public Health Implications
In order to understand the health effects that may be caused by a specific chemical, three factors affecting how the human body responds to exposure need to be considered. These factors include exposure concentration, the duration of exposure, and the route of exposure. Lifestyle factors can affect the likelihood of exposure and the exposure duration. Individual characteristics of each human such as age, sex, nutritional status, and overall health can affect how a contaminant is absorbed, distributed, metabolized or eliminated from the body. Together, these factors determine the individuals' response to chemical contaminants and what health effects may occur for that person.
To evaluate health effects, ATSDR developed MRLs for contaminants commonly found at hazardous waste sites. The MRL is an estimate of daily human exposure to a contaminant below which non-cancerous, adverse health effects are unlikely to occur. MRLs are developed for each route of exposure, such as inhalation and ingestion, and for the length of exposure, such as acute (less than 14 days), intermediate (15-364 days), and chronic (greater than 365 days). Acute MRLs are typically higher than chronic MRLs because of the shorter duration of exposure. BEHS also uses EPA's chemical-specific RfDs to determine if non-cancer health effects are possible. RfDs, similar to ATSDR's MRLs, are estimates of daily human exposure to a contaminant that is unlikely to result in adverse non-cancer health effects over a lifetime. For chemicals that are considered to be known, probable, or possible human carcinogens, BEHS uses EPA's chemical-specific cancer slope factors to calculate a theoretical excess lifetime cancer risk. These risks are associated with the exposures that are based on conservative (protective) exposure assumptions. The cumulative cancer risk from exposure to multiple environmental media and multiple site-related contaminants were added together for a total risk estimation. BEHS assumes an additive effect among mixtures of chemicals.
For determining possible exposures to contaminants in soil, maximum surface soil concentrations were used. The exposure scenarios for children were based on an older child (Elementary school age, 7 years or older) playing at the Oldtown site and a young child (1-6 years old) playing in private yards. BEHS assumed that younger children are more closely supervised and would not wander onto the site. It was also assumed that older children would not spend more than three days playing onsite per week and young children would spend time outdoors everyday in private residential yards. For adults, BEHS assumed two exposure scenarios. One was for a site employee who worked for Poles, Inc. for approximately 20 years and the other scenario was for an adult resident living near the site who occasionally visited the site for recreational or personal purposes. Adults living near the site would not spend more than one day a week visiting the site. People reduce outside activities during the cold winter months and have less contact (or no contact) to surface soil. BEHS assumes people are not exposed to surface soil because of snow cover and decreased outdoor activities for three months a year.
Exposure duration, body weight, and age are used to estimate the amount of contaminants that might have entered a person's body. For example, young children between the ages of 1 - 6 years old are known to put almost anything in their mouth, including soil (pica behavior). This behavior increases their chances of exposure to soil contaminants. The assumptions used to calculate exposure for young child are a body weight of 15 kg (approximately 30 pounds) with an ingestion rate of 5000 milligrams (mg) of soil per day. The assumptions for an older child (7 -18 years of age) are a body weight of 45 kg (approximately 100 pounds) and a soil ingestion rate of 200 mg per day. The assumptions for an adult are a body weight of 75 kg (approximately 165 pounds) and a soil ingestion rate of 100 gram per day. Those estimates were chosen in reference to the Exposure Handbook (EPA 1997) and ATSDR's guideline with some Idaho-specific adjustments. According to EPA, young children accidentally eat approximately 150 mg of soil a day. BEHS uses ATSDR's conservative (protective) suggestion of 5000 mg/day (approximately one teaspoon) for young children with pica behavior. Instead of the standard EPA body weight assumption (70kg), BEHS uses the median Idahoan body weight of 75kg to better represent people in Idaho (BVRHS 2001). In addition, the maximum concentration found in surface soil was used for calculating risks and doses, so a worst case scenario was evaluated.
To determine possible exposure to contaminants in air, maximum air sampling concentrations were used to calculate risks and doses to be protective of public health. The inhalation rate assumptions used to calculate exposures are 10 cubic meters of air per day (M3/day) for children less than 6 years of age, 15 M3/day for order children between ages 7 and 18, and 20 M3/day for adults. BEHS assumes that people are living around the Oldtown site for 30 years out of an average 70 year lifetime and people are exposed to the air contaminants 40 to 120 days of the year (Poles, Inc. operates once per week for 9 months of a year/ assuming air contaminants persist in air for 1 - 3 days).
For determining possible exposure to contaminants in drinking water, maximum contaminant concentrations found in groundwater samples were used to calculate risks and doses to be protective of public health. Water consumption rates are assumed to be 1 liter per day (L/day) for children less than 6 years old and 2 liters per day for children aged 7 through adults.
All assumptions are summarized in the following table.
Table 6. Exposure Assumptions Summary
| Exposure Assumptions |
Populationa | ||||
|
Children <7 |
7<Children<18 | Adults > 18 | Workers | ||
| Body Weight (kg) |
15 |
45 | 75 | 75 | |
| Soil | Ingestion Rate (mg/kg) |
5000 |
200 | 100 | 100 |
| Exposure Frequency |
daily offsite |
3 days/week onsite | 1day/week onsite | 5 days/week | |
| Air | Inhalation Rate (M3/day) |
10 |
15 | 20 | 20 |
| Exposure Frequency | 40 -120 year | ||||
| Water | Consumption Rate (L/day) |
1 |
2 | ||
| Exposure Frequency |
daily | ||||
| Years of Exposureb |
6 |
12 | 12 | 20 | |
a: assume average lifetime is 70 years
b: assume people live in Oldtown for an average of 30 years
Once an exposure is determined based upon the previous exposure assumptions, BEHS assigns the exposure pathway a health hazard category, as developed and defined by ATSDR. The categories include: 1) urgent public health hazard, 2) public health hazard, 3) indeterminate public health hazard, 4) no apparent public health hazard, and 5) no public health hazard. A list of these public health hazard categories and their descriptions can be found in Appendix K. These health hazard categories are utilized by ATSDR and its cooperative agreement states to ensure a consistent approach among public health assessors nationwide and to ensure that sites within each state are consistently evaluated.
5.1.2 Evaluation of Toxicology and Epidemiology by Pathway
Two major completed exposure pathways (onsite surface soil and air) that have elevated site-associated contaminants are evaluated in detail. The potential effects of each chemical are discussed individually; the combined effects of multiple chemicals are evaluated; any special child health issues related to the exposures are discussed; and there is an overall summary of the public health implications of the pathways. The remaining completed exposure pathways (offsite surface soil and sediment at the Pend Oreille River) and the potential groundwater exposure pathway are discussed. Even though arsenic is not a site related issue, arsenic exposure is evaluated and discussed in a separate section.
5.1.2.1 Onsite surface soil pathway
Based on IDEQ's surface soil sampling, the START IA and the START dioxin/furan sampling, site-related contaminants were found in onsite surface soil. Six site-related contaminants and background arsenic were found at levels greater than health comparison values. Workers and trespassers (nearby residents or school children) may be exposed. The estimated daily average exposure doses were calculated with site-specific exposure assumptions and the maximum concentrations of each contaminant that exceeded the health comparison values. The results are presented in Table 7. The detailed calculations and equations are summarized in Appendix I. Age-adjusted soil ingestion rates were used for dose estimations to account for children's hand-to-mouth behavior.
Table 7. Estimated Lifetime Exposure from Onsite Surface Soil Pathway
| Compound |
Max. Conc. (mg/kg)a |
Estimated Exposure (mg/kg/day)b,c | Dose Comparison - MRL (mg/kg/day) |
| Benzo(a)anthracene |
0.77 |
0.00000021 | -- |
| Benzo(b)fluoranthene |
1.64 |
0.00000044 | -- |
| Benzo(a)pyrene |
0.615 |
0.00000017 | -- |
| Dibenz(a,h)anthracene |
0.125 |
0.000000034 | -- |
| Ideno(1,2,3-cd)pyrene |
1.28 |
0.00000034 | -- |
| Pentachlorophenol |
600 |
0.00016 | 0.001 |
| Background Arsenic |
15 |
0.000002 d | 0.0003 |
a: The maximum concentrations reported from IDEQ and START
IA
b: Exposure assumption for dose calculation are listed in section 5.1.1 Table 6
c: Detail calculation equations can be found in Appendix I, Equation 1
d: BEHS has applied an addition bioavailability factor for calculation of background
arsenic exposure, see section 5.1.2.5
--: MRL is not available. Cancerous effects discuss in the following section
Adverse health effects have been observed in humans and experimental animals following short- and long-term exposure to penta by inhalation, oral, and dermal exposures. Long-term exposure to technical-grade penta can cause damage to the liver, kidneys, blood, and nervous system. Some of those effects may be caused by chlorinated dibenzo-p-dioxin (dioxin) or other impurities in technical-grade penta. The impurities are unavoidable during the penta manufacturing process. Symptoms of human exposure to penta treated wood include severe skin blisters and rashes. These skin effects may be due to penta impurities. The toxic effects of penta appear to be most serious following high-dose, acute exposure. There are no human studies that have demonstrated a reproductive toxicity of penta. However, there are animal studies that have shown adverse reproductive and developmental effects. Fetuses, infants, and children may be more susceptible to the effects of penta.
The estimated accidental onsite soil exposure to penta from playing/living around Oldtown site for 30 years was 0.00016 milligrams of penta per kilogram body weight per day (mg/kg/day) over a lifetime. This level does not exceed the chronic penta MRL of 0.001 mg/kg/day. School age children playing occasionally onsite would be exposed to 0.00085 mg/kg/day over the course of a year. This level does not exceed the acute MRL of 0.005 mg/kg/day or intermediate MRL of 0.001 mg/kg/day. When the dose is less than an MRL, adverse non-cancer health effects are not expected as a result of exposure.
In the case of penta, the chronic MRL was based on a multi-generation reproductive study. The Lowest Observed Adverse Effect Level (LOAEL) was 1 mg/kg/day where female sheep had a change in thyroid function. The chronic MRL was derived by dividing the LOAEL by an uncertainty factor of 1000 (10 for use of a LOAEL, 10 for interspecies extrapolation, and 10 for human variability). Applying an uncertainty factor is a standard toxicological risk assessment approach to be conservative and protective of human health (IRIS 1987).
A number of animal studies suggest that penta may cause cancer in humans. No convincing human epidemiological evidence has demonstrated that penta causes cancer in humans. Case reports suggest a possible association between cancers and occupational exposure to technical-grade penta that includes impurities (ATSDR 2000a). These cancers include Hodgkin's and non-Hodgkin's lymphoma, soft tissue sarcoma, and acute leukemia. Penta is classified as a probable human carcinogen (Group B2) by EPA. The cancer risk resulting from onsite surface soil exposure to penta is combined with other chemical exposures which may contribute to overall cancer risk. The following paragraphs describe cancer risk estimation from exposure to the mixtures of Oldtown site surface soil contaminants.
Additionally, there are five PAHs detected in onsite soils that have concentrations greater than the comparison values. PAHs are a group of structurally related compounds with similar chemical and physical characteristics. PAHs are part of the emissions from heating the pole treatment oil. There are more than 100 different PAH compounds which generally do not occur alone. Exposure to a mixture of PAHs through accidental ingestion of onsite contaminated soil by workers and trespassers may occur.
Animal studies show that PAHs could cause harmful effects on skin, in body fluids, and on the immune system after short- and long-term exposure. However, those effects have not been seen in humans. Skin contact with certain PAHs may cause deleterious skin conditions. People with pre-existing skin problems may be more sensitive to the adverse dermal effect of PAHs. The mostly likely exposure routes in a work environment are through inhalation and skin contact. This is of particular concern for workers who come into direct contact with the PAH-containing material. Occupational studies of workers provide some evidence that PAH exposure may increase cancer incidence. The five PAHs found at the Oldtown site were benzo(a)anthracene, benzo(b)fluoranthene, benzo(a)pyrene, dibenzo(a,h)anthracene, and ideno(1,2,3-cd)pyrene which are classified as "probable human carcinogens" by EPA (ATSDR 1995).
To determine the cancer risk from exposure to surface soil at Poles, Inc., the cancer risks contributed from penta and PAHs are added together. For PAHs, the relative potency of carcinogenic PAHs is added together as benzo(a)pyrene equivalents because benzo(a)pyrene is known to be the most potent among PAHs (IRIS 1994 a,b,c,d,e). Using the maximum concentration in onsite surface soil, BEHS estimated a 2 x 10-5 risk of developing cancer for trespassers and workers at Poles, Inc. This means two additional cases of cancer out of 10,000 people may be attributed to the site related exposure. Realistically, for communities such as Oldtown where the exposed population is low, people do not expect to develop cancer due to site-related exposures. Furthermore, the estimated excess cancer risk is likely to overestimate the risk of cancer because it is based on the maximum level of penta and PAHs detected in surface soils. It is more likely that long-term exposures occur to the average concentration of penta and PAH's, not to the maximum values.
BEHS does not expect trespassers and workers to get ill from exposures to contaminants in onsite surface soils at the levels in which they are present. Exposure to onsite surface soil is occurring and can occur, but not at levels expected to cause health effects. As a prudent precaution, BEHS recommends further public health actions be taken at the site to eliminate the possibility of exposure. Recommendations and the public health action plans are discussed in Sections 7 and 8.
Based on the START IA air sampling results, 11 site-related contaminants were found in air around the site. Penta was the only compound found at levels greater than the health comparison values. Nearby residents, students, workers, and trespassers could have been exposed to penta through the air pathway during the wood treatment process. In general, higher penta concentrations were detected outdoors close to the treatment area. Penta was not detected in any of the three indoor air samples from the school. The maximum concentration of penta was used to estimate the daily average exposure doses in order to be the most conservative (protective). The dose calculation has considered an age-adjusted factor to account for the higher respiratory rates of children.
The estimated dose from exposure to penta in air from the Oldtown site for 30 years was 0.00003 to 0.00008 mg/kg/day over a lifetime. These levels do not exceed the chronic and intermediate penta MRLs of 0.001 mg/kg/day. When the dose is less than an MRL, adverse non-cancer health effects are not expected as a result of exposure.
Penta is classified as a "probable human carcinogen" (Group B2) by EPA, however, EPA has not published an inhalation cancer slope factor for penta. The current penta oral slope factor is 0.12 (mg/kg/day)-1 based on a mouse study in which male mice exposed to penta orally developed liver tumors. The animal dose was extrapolated to a human dose equivalent. A slope factor was calculated using a linearized multistage model that was known to be the most conservative (protective) model. The State of California published an inhalation slope factor for penta, 0.018 (mg/kg/day)-1, based on the same mouse study. It is not known if the California value more accurately represents the inhalation carcinogenic toxicity of penta than the EPA value. Since cancer risk is calculated by multiplying the dose by the cancer slope factor, the higher the cancer slope factor the higher the caner risk estimate. California's value is less conservative than using EPA's oral value. BEHS adopted EPA's oral value rather than California's inhalation value to assess risk to be more protective of public health. BEHS is aware that there are uncertainties associated with using an oral factor for inhalation purposes.
BEHS used the maximum penta concentration detected in air as well as site-specific exposure assumptions to calculate an estimated cancer risk. Exposures to penta through the air pathway during Poles, Inc. most recent treatment processes does not significantly increase the risk of developing cancer for the communities around the site. This conclusion concurs with ATSDR's evaluation stated in a health consultation to the EPA START (ATSDR 2001) (Appendix J). Past exposure, prior to emission control improvements, may have been higher and posed a public health hazard, however, it is not possible to estimate the past exposure. Poles, Inc. is no longer treating poles at the site.
5.1.2.3 Potential Groundwater Exposure Pathway
START, during the IA, found penta and 12 site-unrelated heavy metals in groundwater at levels greater than the comparison values. EPA does not know whether the private wells draw water from the same aquifer as the EPA's monitoring wells. Therefore, the potential impact to the private wells cannot be estimated. There are 46 domestic wells within a 1-mile radius and 484 domestic wells within a 1- to 4-mile radius of the site. Since none of the private wells are down gradient of the site, the contaminants are unlikely to impact the private wells. According to EPA, the primary drinking water source for most residents in Oldtown is the municipal water supply that draws water from surface water upstream of the Poles, Inc. site. BEHS evaluated both penta and the heavy metal contamination in groundwater and summarizes the results in the following paragraphs. Heavy metal contamination is not a site-related issue. Dioxin and furan contamination will be evaluated further when information about the groundwater pathway is available.
To be conservative or protective, the maximum concentration of penta in groundwater was used to estimate the daily average doses. The dose estimation incorporated the age-adjusted factor to include the appropriate water consumption per body weight for children. If exposure did occur, the estimated dose of penta from consuming contaminated groundwater for 30 years is 0.00068 mg/kg/day. This level is lower than the chronic MRL of 0.001 mg/kg/day, therefore, it is unlikely that a non-cancerous health effect would result from penta exposure by consuming contaminated groundwater.
For heavy metals, BEHS first compared the maximum groundwater concentrations to multiple drinking water criteria. Since some of the drinking water criteria were established for reasons other than health, BEHS estimated a daily average exposure and compared it to health-based criteria, MRL and RfD. The results are summarized in Table 8.
Table 8. Estimated Lifetime Exposure from Groundwater Pathway (if exposure occurred)
|
Compound |
Max. Conc. (mg/L) | Water Quality Criteria - MCL (mg/L) | Estimated Lifetime Exposure (mg/kg/day) | Dose Comparison - MRL or RfD (mg/kg/day) |
| Pentachlorophenol |
0.046 |
0.001 | 0.00068 | 0.001 |
| Aluminum |
115 |
0.05 - 0.2 a | 1.7 | 2 |
| Antimony |
0.014 |
0.006 | 0.0002 | 0.0004 |
| Arsenic |
0.344 |
0.01b | 0.0051 | 0.0003 |
| Barium |
1.97 |
2 | 0.029 | 0.07 |
| Beryllium |
0.009 |
0.004 | 0.00013 | 0.001 |
| Chromium |
0.214 |
0.1 c | 0.003 | 0.003 |
| Cobalt |
0.199 |
-- | 0.003 | 0.01 |
| Iron |
298 |
0.3 a | 4.4 | -- |
| Lead |
0.327 |
0.015 d | 0.0049 | -- |
| Nickel |
0.174 |
0.1 e | 0.0026 | 0.02 |
| Thallium |
0.017 |
0.002 | 0.00026 | -- |
| Vanadium |
0.297 |
-- | 0.0044 | 0.003 |
a: Secondary Drinking Water Regulation
b: Proposed MCL to be implemented in 2003
c: Total Chromium MCL
d: Action Level
e: Lifetime Health Advisory for drinking water
Gray areas represent the maximum concentrations
that are higher than the water quality criteria or the estimated exposure doses
that are higher than the MRL or RfD.
The maximum concentrations of nine out of 12 heavy metals were higher than the drinking water criteria. The estimated lifetime exposure to arsenic and vanadium is greater than the chronic MRL. The details for arsenic exposure are discussed in Section 5.1.2.5. Vanadium is an essential nutrient of the human body. The body's nutritional requirement for vanadium is very low and can be easily met by levels naturally occurring in foods, water, and air (average intake for adult 10-20 µg/day) (NRC 1989). Laboratory animals fed diets extremely low in vanadium showed depressed growth and impaired reproductive performance. People exposed to 0.47-1.3 mg vanadium per kilogram of body weight experienced gastrointestinal distress. Long-term animal studies (2.5 years) showed a decrease in the amount of cystine in hair (brittle hair) after ingesting vanadium (IRIS 1996, ATSDR 1992). The upper limit of the recommended dietary allowances for adult is 1.8 mg/day (approximately 0.024 mg/kg/day). The estimated lifetime exposure to vanadium (0.0044 mg/kg/day) from using contaminated groundwater is lower than this upper limit. Therefore, BEHS does not consider vanadium a health risk even when calculated dose levels are added to the normal daily diet.
The cumulative cancer risk from using contaminated groundwater was calculated by adding cancer risk contribution from antimony, arsenic, chromium, and penta. BEHS estimates that there may be an increased risk of developing cancer if people are exposed to contaminated groundwater. It is important to note, however, the majority of the estimated cancer risk was not attributable to the site-related penta contamination, rather to the heavy metals.
The groundwater exposure pathway cannot be fully established (only a potential pathway). It is not known if domestic wells are drawing groundwater from the same aquifer as EPA's monitoring wells or if private wells are impacted by the groundwater contamination onsite. Since none of the private wells are located down gradient of the Oldtown site (EPA 2002a), the wells are not likely to be impacted. However, domestic wells were not sampled during the START IA and the exposures cannot be determined. The potential for groundwater to impact people exists after review of the groundwater contamination levels. Therefore, BEHS recommends further action be taken at the site to collect more information about the pathway. The recommendations and planned public health actions regarding groundwater are discussed in Sections 7 and 8.
5.1.2.4 Other Exposure Pathways
Other exposure pathways were identified by BEHS as having less public health significance. They are briefly described in the following paragraphs.
EPA detected heavy metals, chlorinated pesticides, SVOCs, and VOCs in offsite surface soil. A few SVOCs and VOC were detected in sediment in the Pend Oreille River. Arsenic, attributed to background levels, was the only chemical found at levels greater than the comparison value. The concerns about background arsenic exposure are discussed in the next section (5.1.2.5). Nearby residents, people in school, recreational sportsmen and children playing along the Pend Oreille River are not currently exposed to site-related contamination at levels that may cause harm. Higher exposure in the future is unlikely.
A potential exposure pathway exists for sportsmen and children who come in contact with surface water from boating, fishing or playing in the Pend Oreille River. The other potential exposure pathway exists for individuals who consume biota such as fish or other aquatic organisms caught/collected in the River. Surface water and fish were not sampled; however, BEHS does not recommend further actions because exposure though these pathways is unlikely and BEHS does not expect people to get ill. Additionally, exposure to onsite subsurface soil contamination and indoor dust contamination is unlikely and BEHS does not consider these pathways of public health concern.
5.1.2.5 Background Arsenic Exposure
Arsenic exists naturally in soils and rocks. Commercial products containing arsenic include, but are not limited to, wood preservatives, pesticides, paints, and leaded gasoline. Poles, Inc. has never used arsenic products to treat wood at this facility (EPA 2002a). Certain industrial activities that release arsenic are desulfuring of gases and/or fossil fuels, burning preserved wood, and metal alloy production. Volcanic eruptions are another source of arsenic. Arsenic was used historically in certain medicines such as anti-syphilis drugs. There are two forms of arsenic in the environment, organic and inorganic forms. The inorganic forms are usually more toxic than organic ones. The normal analytical method for arsenic does not distinguish the specific form of arsenic (ATSDR 2000b). To ensure a conservative or protective toxicological/public health estimate, BEHS assumes all the arsenic detected by START is inorganic arsenic.
Studies show that swallowing a small amount of inorganic arsenic may cause stomach irritation and a decreased blood cell count. The decreased blood cell production may cause fatigue, abnormal heart rhythm, blood vessel damage resulting in bruising, and impaired nerve function causing a "pins and needles" sensation in hands and feet. Long-term exposure may lead to "Blackfoot disease" which is a condition in which blood circulation is lost which ultimately leads to hands and feet necrosis (cell death). The most characteristic effect of long-term oral exposure to arsenic is a pattern of skin changes. These include darkening of the skin and appearance of warts on the palms, soles, and upper body. Some of the warts may ultimately develop into skin cancer. Inorganic arsenic is classified as a "known human carcinogen" by EPA. Exposure to arsenic may increase the risk of liver, bladder, kidney, prostate, and lung cancers.
The human body absorbs different forms of arsenic differently depending on the environmental media in which it is contained. Arsenic in soil is harder to absorb than the commonly found soluble arsenic forms in drinking water. Studies show that arsenic in soil below 40% can be absorbed by the human body once ingested. This is important for calculating human doses. The current arsenic soil CREG (cancer risk evaluation guide) is 0.5 mg/kg that BEHS uses as a screening tool to identify contaminants of concerns. The CREG is a theoretical calculation that assumes a consumption of 100 mg/day by a 70 kg person over lifetime without consideration of the absorption rate. Another similar approach results in a similar comparison value of 0.6 mg/kg by assuming that a child (forever remaining at 10kg) consumes 5000 mg soil everyday over a 70 year lifetime. Obviously, both scenarios are not plausible and the present comparison value is likely to be overly conservative.
People can be exposed to arsenic from the environment by eating food, drinking water, or breathing air. Children, particularly younger children with a tendency of putting hands in their mouth, may be exposed to more arsenic from eating dirt. Skin contact with soil or water that contains arsenic may be another exposure route. As described throughout this public health assessment, background arsenic levels were found in surface soil (5.7 - 15 mg/kg), subsurface soil (6.9 - 16.9 mg/kg), and sediments (5.2 - 5.7 mg/kg). Elevated arsenic (0.15 - 0.34 mg/L) was found in groundwater samples. The site-specific background arsenic levels were 9.7 mg/kg in surface soil and 9.1 mg/kg in the upper and 7.8 mg/kg in the lower portion of the subsurface soil, and 5.3 mg/kg in sediment. The maximum concentration in the offsite surface soil (9.7 mg/kg) is used for estimation of daily exposure. BEHS considered the bioavailability of arsenic from soil to be 50%. Age-adjusted soil ingestion rates were used to calculate lifetime arsenic dose (see Appendix I). The average lifetime daily exposure for people living around the Oldtown site for 30 years is 0.00011 mg/kg/day. This value is lower than the chronic MRL of 0.0003 mg/kg/day. Young children with pica behavior playing in the residential yard daily have an estimated exposure dose of 0.0012 mg/kg/day over the course of a year. The shorter-term (within a year) exposure should be more appropriately compared to the intermediate or acute MRL. This level is lower than the ATSDR provisional acute MRL for arsenic of 0.005 mg/kg/day.
After reviewing many human studies, as reported in ATSDR Toxicological Profile for arsenic, the lowest arsenic Cancer Effect Level (CEL) for lung cancer is 0.0011 mg/kg/day; for bladder cancer is 0.033 mg/kg/day; and for skin cancer is 0.0075 mg/kg/day. The average lifetime exposure dose (0.00011 mg/kg/day) is lower than the lowest CELs of arsenic. BEHS does not expect elevated cancer risk from exposure to background arsenic.
People may be exposed to contamination in onsite surface soil but the exposure levels were low and health effects were not expected (see 5.1.2.1). Current and future exposures to air (5.1.2.2), sediment, and offsite soil (5.1.2.4) are not likely to result in adverse health effects. The groundwater (5.1.2.3) pathway was not positively identified or the point of exposure was not sampled, therefore it is considered an incomplete exposure pathway. Potential exposures to penta from surface water and biota are not considered likely because of the levels of penta found in sediment and because of the physical nature of penta (5.1.2.4). People are not exposed to onsite subsurface soil and indoor dust. Background exposure to arsenic through accidental ingestion of soil is not an immediate health concern. However, even though BEHS does not expect people to become ill as a result of the site, BEHS as a prudent public health practice recommends actions be taken to further reduce exposures, particularly for younger children, and to better clarify the issues. The recommendations and suggested public health actions are discussed in Sections 7 and 8.
5.1.3 ATSDR Child Health Initiative
Children differ from adults in their physiology (e.g., respiratory rates relative to body weight), pharmacokinetics (i.e., distribution, absorption, metabolism, and excretion of chemicals), and pharmacodynamics (i.e., susceptibility of an organ to the exposure). Therefore, it is always important to address chemical exposures of these sensitive populations. Fetuses, infants, and children are more vulnerable to the toxic effects of chemicals because of the following reasons: 1) children are more likely to play outdoors and bring food into contaminated areas; 2) children are closer to the ground (shorter), resulting in a greater likelihood to breathe dust, soil, and heavy vapors laying on the ground; 3) children weigh less resulting in higher doses of chemical exposure per body weight; and, 4) the developing body system can sustain permanent damage if toxic exposures occur during critical growth stages.
For penta, dioxins/furans, and PAHs, animal studies show adverse reproductive and developmental effects. Fetuses, infants, and children may be more susceptible to the effects of penta and PAHs. At the Oldtown site, using the highest onsite surface soil penta concentrations, the soil ingestion exposure did not exceed ATSDR's MRL. ATSDR does not have MRLs for skin or inhalation exposures to penta, therefore, it is difficult to determine the health effects from skin contact or inhalation exposure. Younger children who have pica behavior were assumed to not have contact with the site. Workers and trespassers who have young children at home should take precaution to not track onsite soil into their home. It is a concern for young children who come in contact with the site. BEHS's recommendations are summarized in Section 7.
5.2 Health Outcome Data Evaluation
The potential for exposures to chemicals to result in adverse health effects are determined by several factors. These include: the toxicity of the chemical, the route of exposure (eating, breathing, and skin contact), the amount of exposure, and the duration of exposure. BEHS evaluated all of these factors during the public health assessment process. The potential for non-cancer health effects, such as effects on the fetus and reproduction, were evaluated. The potential for cancer was also considered. Worst case, site-specific exposure doses were calculated and used in the public health assessment. Based on this evaluation, BEHS concluded that present exposures are not occurring at levels high enough to result in non-cancer health effects. No conclusions can be drawn about past exposure.
The public health assessment process uses multiple methods to assess potential impacts in communities. In addition to the evaluation described above, BEHS was able to examine actual data about cancer cases in residents of Oldtown and nearby communities. Surveillance for non-cancer health effects are not currently available. Therefore the health outcome data evaluation from the Oldtown site is based on an analysis of available cancer data from the CDRI.
CDRI is a program of the Idaho Hospital Association that contracts with Idaho Department of Health and Welfare to provide a statewide cancer surveillance system. The Registry is a population-based cancer registry that collects incidence and survival data on all cancer patients who reside in the State of Idaho and/or are treated for cancer in the State of Idaho. Through collaborative efforts with Idaho's neighboring states, CDRI is able to obtain cancer cases of Idaho residents diagnosed and/or treated for cancer in adjacent states. CDRI has been in operation since 1969 and the registry became population based in 1971. Each Idaho hospital, outpatient surgery center, and pathology laboratory is responsible for reporting cancer diagnoses and treatments within six months after services are provided. CDRI has a 99.6% case completeness rate and a 98.6% accuracy rate. In other words, BEHS has great confidence that people in Oldtown and nearby Idaho communities that were diagnosed with cancers in either the State of Idaho or Washington are included in the CDRI's database. For residents of Newport, WA, information on cancer incidence was obtained from the Washington State Cancer Registry.
The period selected for each evaluation of the cancer incidence data was 1991 or 1992 - 1999. This is the most recent data available for ZIP Code analysis (Washington data begins in 1992). Cancer incidence was reviewed for this public health assessment instead of cancer mortality because cancer death rates are affected by how advanced the cancer was at the time of diagnosis, access to health care and other factors not related to exposure. The cancer rates were compared to the remainder of the State of Idaho.
CDRI performed the initial cancer incidence evaluation for the ZIP Code of Oldtown (83822) between 1991 and 1999 and found the reported 24 cancer types were all within or lower than their expected ranges (Attachment D, Table D-1). Since Oldtown is a relatively small community people commute to Oldtown for work or school from different communities or ZIP codes. CDRI could not rule out the possibility of underestimating the risk (Johnson 2001).
With help from the communities, BEHS was able to better identify the potentially impacted population around Poles, Inc. The Idaho Cancer Analysis Working Group (CAWG) requested that CDRI perform another cancer incidence analysis for the Oldtown area. CAWG is comprised of the Idaho State Epidemiologist and representatives from CDRI, the Bureau of Vital Records and Health Statistics, and BEHS. The new analysis for the Oldtown area included Oldtown and Priest River, Idaho and Newport, Washington combined ZIP Codes (1992 - 1999). Newport, WA is immediately adjacent to Oldtown and practically shares the same business district. CDRI was able to gather data from the State of Washington to conduct this ZIP Code analysis. Priest River is a city six miles east of Oldtown. Many residents in Priest River commute to Oldtown for school or work. BEHS is aware of the potential to underestimate cancer incidence associated with the site by including a larger population who might not have a relationship with the facility. However, concerned citizens repeatedly identified this potentially impacted population. Additionally, a combined ZIP Code evaluation included selected cancer sites that are biologically plausible as a result of site-specific and selected non site-specific exposures. The results of this cancer incidence evaluation are the primary focus of this public health assessment and are described in Section 5.2.3.
Cancer incidence for ZIP Codes 83822, 83856, and 99156 combined, corresponding to Oldtown, Priest River, and Newport, was calculated by comparing the observed number of cases to the expected number of cases (also known as standardized incidence ratio). The expected number was calculated by multiplying rates for the remainder of Idaho and the population of the combined ZIP Codes. The rate for the remainder of Idaho was calculated by dividing the observed cases by the person-years for the remainder of Idaho. Person-years were estimated by summing population estimates for the ZIP Codes over the time period of the study.
To help interpret the differences, the "statistical significance" of the difference is calculated. "Statistical significance" for this public health assessment means that there is less than a 5% chance that the observed differences are due to random chance alone (p<0.05). In other words, if the differences were found to be statistically significant, then the difference between the expected and observed cases is probably due to some set of factors that influences the rate of that disease. It could be environmental factors, lifestyle factors, and/or family histories. In the public health assessment, only statistically significant differences are discussed.
Cancer is not a single disease. It is a group of more than 200 different diseases. Because cancer is, unfortunately, a common disease (one of every three of us will develop cancer in our lifetime), every community will experience a certain number of cancers. Different types of cancer have different causes and are likely to be linked to different risk factors. Therefore, BEHS selected the specific cancer types that are biologically plausible as a result of penta exposure according to scientific studies. Those specific cancers are Hodgkin's lymphoma, non-Hodgkin's lymphoma, acute leukemia, and soft tissue sarcoma. Arsenic is not a site related issue; nevertheless, BEHS evaluated the biologically plausible cancer sites that might relate to arsenic. Those cancer sites include bladder, kidney, liver, lung, skin, and possibility prostate.
In addition to the cancer evaluation for the general community members, BEHS attempted to conduct a cancer incidence evaluation targeting past and current teachers and staff of the Idaho Hill Elementary School. The first attempt to gather the names and personal information (e.g., social security number) from the school district was not successful (Appendix L). BEHS and CDRI are currently evaluating other possibilities.
5.2.3 Results of Cancer Incidence Analysis
Overall, cancer incidence in the combined ZIP Code area was not statistically significantly different from that in the remainder of Idaho. There were, however, statistically fewer cases observed (289) than expected (330) among males; about 12 % fewer cases than the remainder of Idaho (Appendix D, Table D-2).
For the four selected cancers that might be associated with penta exposure, there were significantly more sarcoma cases observed than expected when compared to the remainder of the State (Appendix D, Table D-3). Seven sarcoma cases were observed while two cases were expected for the combined ZIP Code area. Soft tissue sarcoma may be associated with penta exposure. Sarcoma is a rare form of tumor. Some risk factors for sarcoma include previous radiation therapy, exposure to chemicals (e.g., vinyl chloride, agent orange), immunodeficiency, chronic tissue irritation, and/or genetic influence.
For the six selected cancers that might be associated with background arsenic exposure, there were significantly more female lung and bronchus cancers and fewer prostate cancers compared to the remainder of the State (Appendix D, Table D-4). Lung cancer and prostate cancer are common cancers that have well established risk factors. The single most important risk factor in the development of lung cancer is cigarette smoking. Prostate cancer is related to older age, family history, and ethnic group/country of residence.
Currently, it is not possible for BEHS to determine the association between exposure to site-related contaminants and the cancer incidence outcome. The influence of established risk factors for each type of cancer was not evaluated. This screening helps to identify the unusual patterns of adverse health effects and to direct future public health actions. CAWG recommends that CDRI follow up with the sarcoma cases to better identify other possible risk factors associated with the disease. The potential site-related relationship needs to be investigated and interpreted with caution. The suggested public health actions for this recommendation are discussed in Section 8.
5.3 Questions from the Community
When performing any public health assessment, BEHS gathers health concerns from people living in the vicinity of the site. The concerns that people expressed are used to direct the focus of the public health assessment so that questions from the community are answered. At the Poles, Inc. Oldtown site, BEHS has collected community questions through the following activities.
Based on the responses from the written survey, e-mail communication, and the availability session, the following sections list the three common types of questions/issues raised.
5.3.1 Environmental Related Questions
After reviewing the START IA final report, the community raised many questions regarding the laboratory and field sampling techniques, as well as the future plans of EPA. Questions related to environmental issues are listed below. Some replies are excerpted from e-mail communication between the EPA START site manager and the communities.
Reply: There are many different types of blanks. For example, the additional samples submitted by the field crews include trip blanks, field blanks, and rinseate blanks. Those blanks insure contamination did not occur while handling and transporting samples. There are also laboratory blanks which are generated to insure there are no contamination in the water and chemicals that laboratory uses to analyze the samples. Blanks are part of the quality assurance (QA) to make sure that the field and laboratory processes are not contributing contamination to the results. Surrogate compounds are chemicals that are added at a known concentration to the sample. The laboratory tests for theses surrogate compounds along with the other analytes per the analytical method. If the recovery of the surrogate compound (detected amount) is low or falls outside the expected range, the sample result does not meet the quality control (QC). That means if the instrument was not able to detect the surrogate and report the known concentration, it probably could not detect the analytes of question. As part of EPA's QC process, a result can be rejected due to low recoveries of the surrogate compound. It is unfortunate that rejection happens. For the Poles, Inc. samples, particularly for the contaminants of concern, PAHs and penta, EPA has the confidence about the data quality after the QA/QC process.
Reply: Preliminary Remediation Goals (PRGs) are tools for evaluating and cleaning up contaminated sites. They are risk-based concentrations derived from standardized equations. They are generic and are calculated without site-specific information. The PRGs used are from EPA Region IX. They are agency guidelines and are not legally enforceable standards. They are typically used for site "screening" and as initial cleanup goals.
Reply: IAAC for penta was established in reference to an occupational standard. A protective factor for public, since general population is more sensitive than healthy workers are, is applied. When the standard was set for Idaho, the carcinogenicity of penta was not considered. IDEQ is now considering revising the IAAC for penta to err on the side of protection. Fifteen states currently have penta ambient air standards ranging from 1.19 to 30 µg/M3. The Idaho criterion is comparable to most states. It is important to note, the IAAC for penta is an incremental increase criteria and is only applicable to a new facility or existing facility that requests operational changes. The EPA residential air PRG is a theoretical calculation assuming a relatively high daily air inhalation rate over a lifetime. Obviously, this scenario is unlikely. The PRG tends to be overly conservative and therefore a great tool for site "screening".
Reply: No, EPA currently does not plan to conduct additional air sampling for the following reasons. First, Poles, Inc. has installed a vapor condensing system prior to EPA's sampling activities. The air emission is better controlled compared to the past. The odor coming from the treatment process has greatly decreased according to nearby residents. It may not be possible to regenerate the past "worst case scenario." Second, it is very difficult and extremely costly to schedule a sampling event around odor and metrological conditions. EPA did conduct air sampling during the butt-dipping process which is believed to represent "the worst case" under the current operating system. Third, air sampling results were evaluated together with dust wipe and off site surface soil samples to determine if deposition of particulates has occurred. Lastly, BEHS uses the maximum detected air concentration to estimate people's exposure through the air pathway. The worst case exposure condition should be well captured by the public health assessment process.
Reply: Sampling for dioxin did not occur in the START IA. Except for the penta concentration in outdoor air, EPA did not find any other site-related contaminants in offsite samples that were above PRGs. Since dioxin is less volatile than penta, it is less likely to be released into the air. Recently, EPA conducted additional soil dioxin and furan sampling both on and off the site. The chemicals were found, but sampling concentrations did not exceed ATSDR's health-based comparison values or meet criteria for further evaluation.
Reply: EPA did not test the river water but did test the sediment in the River. A few contaminants were found at low concentrations in the sediment samples. Since penta stays in soil and sediment better than in water, EPA analyzed sediment as an initial screening tool.
Reply: The EPA START developed a preliminary score for HRS. It is currently under management review. The final score might take another six months to finalize (expected August 2002). As of September 2002, a HRS score was not announced by EPA.
Reply: No, EPA cannot clean up arsenic that exists naturally in the environment. However, BEHS has a fact sheet specifically addressing how to reduce personal exposure to background arsenic. Please contact BEHS for more information.
Reply: The EPA START team is trained to do Spill Prevention Control and Countermeasure Inspections (SPCC) while inspectors from IDEQ are trained to observe hazardous waste disposal. It is unfortunate that the problem was not caught early. Poles, Inc. is in violation of the SPCC regulation and EPA will address this compliance issue for the site.
Reply: Penta found on the school playground could be coming from trespassers tacking dirt from the site. It could also be the donated bark/shavings from the site. It may also be the influence of nearby penta treated utility poles. However, the level of penta found in school playground was not at levels likely to result in adverse health effects. BEHS cannot identify a specific source that contributed to the low level of penta found in the school playground.
5.3.2 Health-Related Questions
Reply: Cancer is not a single disease. Different types of cancer have different causes and risk factors. Since cancer is, unfortunately, a common disease (one of every three of us will develop cancer in our lifetime), every community will experience a certain number of cancers. Because cancers generally take a long time to develop, identifying an exposure that occurred 10-20 years ago is difficult. Even if a potential exposure is identified, epidemiologists and toxicologists may still not know if a person's cancer is a direct result of a specific chemical without knowing other risk behaviors and family history of the individuals. BEHS and CAWG are currently investigating cancer types that are biologically plausible as a result of penta and background arsenic exposures. An elevated rate of sarcoma was observed in the Oldtown, Priest River, ID and Newport, WA area. CAWG currently does not know the cause of the sarcoma cluster.
Reply: Asbestos causes lung cancer as well as one distinct type of disease, called asbestosis. BEHS is not aware any cases of asbestosis in this area for the past decade. The cancers were unlikely to be related to asbestos in the school building.
Reply: There were contaminants detected in both indoor and outdoor air. BEHS and ATSDR determined that exposure to chemicals through the air pathway is unlikely to cause imminent adverse health effects in the general population. There is also no apparent increased risk of getting cancer form long-term exposure. However, annoying odor can cause short-term physical or psychological effects including difficultly concentrating, headache, fatigue, depression, irritability, nausea, dizziness, and nasal stuffiness. IDEQ planned to request an odor management plan and a fugitive dust control plan from Poles, Inc.; however, the site is no longer treating poles and the odor issue has been eliminated.
Reply: Standards or guidelines from oral studies are used to assess inhalation exposure when inhalation data are not available.
Reply: It may be possible for a few cedar-sensitive individuals to express these symptoms. However, most people only experience symptoms while Poles, Inc. is operating. For the majority, their symptoms are more likely to be the result of odor irritation rather than the cedar bark.
Reply: Testing dioxin in body fat is a costly and invasive procedure. Body fat dioxin tests can only prove that a person has been exposed to dioxin, not the source of dioxin. The test results cannot predict whether or not adverse health effects would occur or how severe any effects might be. EPA is currently planning to conduct soil dioxin testing for the site. Before dioxin data is available, BEHS does not recommend body fat dioxin testing for the general population since exposure to other site-related contaminants does not pose a public health hazard
Reply: All eight wells are located up gradient of the facility. Contamination is unlikely to impact the up gradient wells. IDEQ tested one of the municipal wells and did not detect penta and PAHs in the water. Public water systems routinely test for water quality and they have to be under compliance with regulatory standards. It is safe to use public water.
Reply: Penta was not detected in air samples collected inside of school. Classroom dust samples and surface soils from the school playground had none or low levels of contamination. There is one exposure possibility to which children could be more susceptible than adults. Children exposed to onsite soil from trespassing though the facility or playing around the pole storage area may be a concern. BEHS advises children not to trespass through or play at the site.
Reply: Some epidemiological studies and case reports show that exposures to technical grade penta cause certain immunological effects. Immune system-compromised individuals may be more sensitive to penta than healthy adults. BEHS advises those individuals to avoid trespassing through the site and to consult an occupational physician, if they are experiencing symptoms.
Reply: The PEL developed by OSHA is the averaged concentration over an 8-hour workday and 40-hour work week that workers can be exposed to for a long period of time (assuming 25 year employment) without causing adverse health effects. Short-term exposure to high levels of cyanide or hydrogen cyanide can be deadly (approximately 100--500 mg/M3 depending on exposure duration). However, most of the cyanide or hydrogen cyanide at low levels leaves the human body within 24 hours (i.e., worker's body eliminates cyanide during off duty hours). Since cyanide and hydrogen cyanide are not classified as carcinogens, the long-term cancerous effect was not a factor while developing PELs. Penta is a probable human carcinogen, the allowable exposure over a long period of time for penta is expected to be lower. Lower PEL does not mean the acute toxicity of penta is 10 times higher than hydrogen cyanide since the PEL is developed for a long-term exposure duration.
Reply: Banning penta is not the scope of the health agencies at the Oldtown site. The EPA pesticide branch reevaluates all pesticides that were registered before November 1984, of which penta is one. When EPA completes the review and risk management decision for a pesticide that is subject to reregistration, a Reregistration Eligibility Decision (RED) document is issued. The RED summarizes the risk assessment conclusions and outlines any risk reduction measures necessary for the pesticide to continue to be registered in the U.S. For individuals who would like to follow the establishment of a RED for penta, please contact EPA's pesticide branch for more detailed information.
Reply: Poles, Inc. has installed lids on its dip tank in the recent years. Before the lids were installed, sludge was accumulated at a much faster rate. By keeping precipitation out of the tanks by using covers, much less sludge has been formed in recent years. Poles, Inc. distributed the waste sludge to nearby farmers before penta was banned for personal and farming use. It was not known how much and how regularly this practice occurred. People who had received penta sludge previously are encouraged to contact BEHS. According to the IA report, Poles, Inc. has not removed waste sludge from the dip tank since penta was banned for personal use. The capacity of the dip tank is approximately 68,000 gallons. The 385 gallons (seven 55-gallon drums) of sludge removed by EPA was approximately 1 inch deep at the bottom of the dip tank. The sludge did not accumulate to a point to interfere with treatment of the poles because the poles were placed on steel racks in the tank that stood six inches above the bottom of the tank. IDEQ's hazardous waste disposal investigators did not find signs of illegal waste disposal over multiple site visits.
1. BEHS has evaluated the completed and potential exposure pathways related to the Poles, Inc., Wood Treatment Facility. The following conclusions, based on ATSDR's Interim Public Health Hazard Categories (see Appendix K), provide a public health perspective to each of these pathways:
2. The odor issue appears to have been resolved for teachers and children at Idaho Hill Elementary once Poles, Inc. started treating poles at night. Prior to the site ending pole treating, the smell was further reduced and became less noticeable, according to the nearby residents, since the vapor condensing system was installed.
3. Background arsenic was found in soil, sediment, and groundwater. The exposure doses calculated were lower than the lowest CELs for arsenic. BEHS does not expect an increased risk of developing cancer from long-term exposure to regional levels of background arsenic.
4. For the period between 1992 and 1999, the rates of 24 out of 26 cancer types in the Oldtown, Priest River and Newport area were within or lower than their expected ranges at the 95% confidence level. The two types of cancer with significantly elevated rates were sarcoma and female lung and bronchus cancer. Behavioral factors are the primary risk factors for lung and bronchus cancer. The elevated cancer rate of female lung and bronchus cancer is not likely to be caused by site-related exposures. On the other hand, sarcoma is a rare cancer. Soft tissue sarcoma might be associated with penta exposure. Some risk factors for sarcoma include previous radiation therapy, exposure to chemicals (e.g., vinyl chloride, agent orange), immunodeficiency, chronic tissue irritation, and/or genetic influence. The association between site-related exposure and the sarcoma cases is currently unknown and is under investigation.
5. Community concerns included the following general categories: data quality from the START IA, exposure to site contaminants (particularly in school), future testing and other activities, cancer rates in school teachers and the broader community, impurities such as dioxin, and odor control.
1. As a precaution and as prudent public health practice because there is contamination and physical hazards onsite, site access should be restricted by placing obvious signs or barriers at the site boundaries to prevent the public from entering. BEHS should inform the public about the chemical and physical hazards of trespassing and playing at the Poles, Inc. property. Workers should be cautious about tracking dirt back home and mixing work clothes with their family's clothing.
2. A well survey (beneficial use survey) should be conducted to determine if groundwater has been used as drinking water, irrigation, or for any other purpose near the site. Additional down gradient monitoring wells should be installed and monitored frequently. Private wells near the site that are used as a drinking water source should be tested for contamination. BEHS and ATSDR should evaluate the public health implications of any exposures determined from the sampling and survey.
3. The seven sarcoma cases should be further investigated in order to determine the association with the Oldtown site. The relationship of the soft tissue sarcoma cases with Poles, Inc. facility needs to be clarified (i.e., work at the facility or live near the facility). The family history, occupation, and personal experiences that involved additional risk factors associated with soft tissue sarcoma should be noted.
4. Cancer incidence evaluation targeting current and past school employees should be further investigated.
The purpose of the public health action plan is to ensure this public health assessment not only identifies any current and potential exposure pathways and related health hazards, but also to provide a plan of action to mitigate and prevent adverse human health effects resulting from exposures to hazardous substances in the environment, even if those exposures are not expected to make people ill. The first section of the public health action plan summarizes completed and ongoing actions at the site. The second section lists additional public health actions that are planned for the future.
1. In response to odor complaints, IDEQ has visited Poles, Inc. multiple times to investigate hazardous waste generation, management and disposal practices. Air modeling was conducted to predict possible off site exposures to penta. BEHS reviewed IDEQ's air modeling results and recommended a thorough investigation be conducted for the site. Additionally, IDEQ sampled surface soil at Poles, Inc. and found elevated levels of penta and PAHs.
2. In response to a citizen's petition and the request from IDEQ and BEHS, the EPA START conducted an IA for the Poles, Inc. site. IDEQ and BEHS were involved in reviewing the IA sampling plan. The IA report was finalized in January 2002 and demonstrated that Poles, Inc. had violations under SPCC and the Resource Conservation and Recovery Act (RCRA).
3. BEHS and CDRI conducted cancer incidence evaluations for the area (Oldtown, Priest River, and Newport) and found an elevated rate of sarcoma cancer.
4. BEHS under its cooperative agreement with ATSDR prepared three health consultations prior to this public health assessment. The first health consultation evaluated IDEQ's air modeling results and the second and third health consultations were technical assistance consults that documents BEHS's suggestions to START IA sampling plan and BEHS's responses to the community questions/issues.
5. BEHS developed and distributed six health education fact sheets to the community. Three of them were chemical informational fact sheets for penta, PAHs, and arsenic. One fact sheet summarized BEHS health consultations. The final two were fact sheets providing updates on site and BEHS's activities to the community members. BEHS also facilitated the activities of the CAG.
6. EPA conducted limited soil sampling for dioxins and furans at the site, at a nearby residence and at Idaho Hill Elementary school.
7. The site owner signed a consent order with IDEQ.
8.2 Ongoing or Planned Actions
1. The EPA START is in the process of determining the HRS score for Poles, Inc.
2. EPA and IDEQ are negotiating with the site owner how to prevent public exposure to the onsite surface soil. Possible actions include site access restriction or installing an asphalt cap. IDEQ and EPA are evaluating the logistics for a soil removal action.
3. IDEQ will request a Tier II operating permit application, emission characterization, fugitive dust control plan, and odor management plan from Poles, Inc. in order to better characterize and control future air emissions and odors.
4. EPA and IDEQ will require Poles, Inc. to perform further investigation of contamination, perform necessary corrective action to mitigate or eliminate potential exposure, and install additional point of compliance, down gradient monitoring well(s) and monitor the well quarterly. A beneficial use survey will be performed to better understand the groundwater usage for the area. BEHS and ATSDR will evaluate the public health implications of any exposures determined from the sampling and survey.
5. EPA and IDEQ will discuss possible plans with the site owner to control current and future contamination of surface and subsurface soil. Remedial action and installation of an asphalt cap are currently being considered. EPA will request a valid SPCC Plan to prevent future contamination. The plan may include an impervious surface, adequate secondary containment, and employee training.
6. CAWG will further investigate the biologically plausible cancer cases from penta for the Oldtown area. A case survey (i.e., questionnaire) inquiring about the medial, family, and personal history of the cases will be administered by CDRI to gather key information on possible exposures to site-related chemicals. CAWG will continue to try to collect information about cancer among the Idaho Hill Elementary school employees.
7. BEHS will provide health education to the community to assist residents in mitigating exposure to the area background soil arsenic.
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Report Authors
Primary: Mingyi W. Trimble, Sc.D., Health Assessor/Toxicologist
Secondary: Elke D. Shaw-Tulloch, M.H.S., Program Manager/ Bureau Chief
Reviewers
Elke D. Shaw-Tulloch, M.H.S., Program Manager/ Bureau Chief
Aaron M. Scheff, M.Ed., Health Educator
Environmental Health Education and Assessment Program
Bureau of Environmental Health and Safety
Division of Health
Idaho Department of Health and Welfare
450 W. State Street, 4th floor
P.O. Box 83720
Boise, Idaho 83720-0036
ATSDR Technical Project Officer
Gregory V. Ulirsch, M.S., Environmental Health Engineer
Division of Health Assessment and Consultation
Superfund Site Assessment Branch
Agency for Toxic Substances and Disease Registry
1600 Clifton Avenue, Mailstop E-32
Atlanta, Georgia 30333
ATSDR Regional Representatives
Karen L. Larson, Ph.D., Regional Representative
Office of Regional Operations, Region X
Agency for Toxic Substances and Disease Registry
1200 Sixth Avenue, Room 1930 (ATS-197)
Seattle, WA 98101
The Idaho Bureau of Environmental Health and Safety prepared this Public Health Assessment under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the Public Health Assessment was initiated.
Gregory V. Ulirsch
Technical Project Officer, SSAB, DHAC
The Superfund Site Assessment Branch (SSAB), Division of Health Assessment and Consultation (DHAC), ATSDR has reviewed this health consultation and concurs with its findings.
Alan W. Yarbrough
for Roberta Erlwein
Chief, SPS, SSAB, DHAC, ATSDR
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