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Public Health Assessment Public Comment Release FRIT INDUSTRIES WALNUT RIDGE, LAWRENCE COUNTY, ARKANSAS EPA FACILITY ID: ARD059636456 Prepared by Arkansas Department of Health MAY 3, 2010 COMMENT PERIOD ENDS: JUNE 11, 2010 Prepared under a Cooperative Agreement with the U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES Agency for Toxic Substances and Disease Registry Division of Health Assessment and Consultation Atlanta, Georgia 30333 THE ATSDR PUBLIC HEALTH ASSESSMENT: A NOTE OF EXPLANATION This Public Health Assessment-Public Comment Release was prepared by ATSDR pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) section 104 (i)(6) (42 U.S.C. 9604 (i)(6), and in accordance with our implementing regulations (42 C.F.R. Part 90). In preparing this document, ATSDR’s Cooperative Agreement Partner has collected relevant health data, environmental data, and community health concerns from the Environmental Protection Agency (EPA), state and local health and environmental agencies, the community, and potentially responsible parties, where appropriate. This document represents the agency’s best efforts, based on currently available information, to fulfill the statutory criteria set out in CERCLA section 104 (i)(6) within a limited time frame. To the extent possible, it presents an assessment of potential risks to human health. Actions authorized by CERCLA section 104 (i)(11), or otherwise authorized by CERCLA, may be undertaken to prevent or mitigate human exposure or risks to human health. In addition, ATSDR’s Cooperative Agreement Partner will utilize this document to determine if follow-up health actions are appropriate at this time. This document has previously been provided to EPA and the affected state in an initial release, as required by CERCLA section 104 (i) (6) (H) for their information and review. Where necessary, it has been revised in response to comments or additional relevant information provided by them to ATSDR’s Cooperative Agreement Partner. This revised document has now been released for a 30-day public comment period. Subsequent to the public comment period, ATSDR’s Cooperative Agreement Partner will address all public comments and revise or append the document as appropriate. The public health assessment will then be reissued. This will conclude the public health assessment process for this site, unless additional information is obtained by ATSDR’s Cooperative Agreement Partner which, in the agency’s opinion, indicates a need to revise or append the conclusions previously issued. Use of trade names is for identification only and does not constitute endorsement by the U.S. Department of Health and Human Services. Please address comments regarding this report to: Agency for Toxic Substances and Disease Registry Attn: Records Center 1600 Clifton Road, N.E., MS F-09 Atlanta, Georgia 30333 You May Contact ATSDR Toll Free at 1-800-CDC-INFO or Visit our Home Page at: http://www.atsdr.cdc.gov Frit Industries Public Comment Release PUBLIC HEALTH ASSESSMENT FRIT INDUSTRIES WALNUT RIDGE, LAWRENCE COUNTY, ARKANSAS EPA FACILITY ID: ARD059636456 Prepared by: Arkansas Department of Health Under a Cooperative Agreement with the U.S. Department of Health and Human Services Agency for Toxic Substances and Disease Registry This information is distributed by the Agency for Toxic Substances and Disease Registry for public comment under applicable information quality guidelines. It does not represent and should not be construed to represent final agency conclusions or recommendations. Public Comment Release Frit Industries – Walnut Ridge, AR Foreword The Agency for Toxic Substances and Disease Registry, ATSDR, was established by Congress in 1980 under the Comprehensive Environmental Response, Compensation, and Liability Act, also known as the Superfund law. This law set up a fund to identify and clean up our country's hazardous waste sites. The Environmental Protection Agency, EPA, and the individual states regulate the investigation and clean up of the sites. Since 1986, ATSDR has been required by law to conduct a public health assessment at each of the sites on the EPA National Priorities List [1]. The aim of these evaluations is to find out if people are being exposed to hazardous substances and, if so, whether that exposure is harmful and should be stopped or reduced. If appropriate, ATSDR also conducts public health assessments when petitioned by concerned individuals. Public health assessments are carried out by environmental and health scientists from ATSDR and from the states with which ATSDR have cooperative agreements. The public health assessment program allows the scientists flexibility in the format or structure of their response to the public health issues at hazardous waste sites. For example, a public health assessment could be one document or it could be a compilation of several health consultations - the structure may vary from site to site. Nevertheless, the public health assessment process is not considered complete until the public health issues at the site are addressed. Exposure: As the first step in the evaluation, ATSDR scientists review environmental data to see how much contamination is at a site, where it is, and how people might come into contact with it. Generally, ATSDR does not collect its own environmental sampling data but reviews information provided by EPA, other government agencies, businesses, and the public. When there is not enough environmental information available, the report will indicate what further sampling data are needed. Health Effects: If the review of the environmental data shows that people have or could come into contact with hazardous substances, ATSDR scientists evaluate whether or not these contacts may result in harmful effects. ATSDR recognizes that children, because of their play activities and their growing bodies, may be more vulnerable to these exposures. As a policy, unless data are available to suggest otherwise, ATSDR considers children to be more sensitive and vulnerable to hazardous substances. Thus, the health impact to the children is considered first when evaluating the health threat to a community. The health impacts to other high risk groups within the community (such as the elderly, chronically ill, and people engaging in high risk practices) also receive special attention during the evaluation. ATSDR uses existing scientific information, which can include the results of medical, toxicologic and epidemiologic studies and the data collected in disease registries, to determine the health effects that may result from exposures. The science of environmental health is still developing, and sometimes scientific information on the health effects of certain substances is not available. When this is so, the report will suggest what further public health actions are needed. Conclusions: The report presents conclusions about the public health threat, if any, posed by a site. When health threats have been determined for high risk groups (such as children, elderly, i Public Comment Release Frit Industries – Walnut Ridge, AR chronically ill, and people engaging in high risk practices), they will be summarized in the conclusion section of the report. Ways to stop or reduce exposure will then be recommended in the public health action plan. ATSDR is primarily an advisory agency, so usually these reports identify what actions are appropriate to be undertaken by EPA, other responsible parties, or the research or education divisions of ATSDR. However, if there is an urgent health threat, ATSDR can issue a public health advisory warning people of the danger. ATSDR can also authorize health education or pilot studies of health effects, full-scale epidemiology studies, disease registries, surveillance studies or research on specific hazardous substances. Community: ATSDR also needs to learn what people in the area know about the site and what concerns they may have about its impact on their health. Consequently, throughout the evaluation process, ATSDR actively gathers information and comments from the people who live or work near a site, including residents of the area, civic leaders, health professionals and community groups. To ensure that the report responds to the community's health concerns, an early version is also distributed to the public for their comments. All the comments received from the public are responded to in the final version of the report. Comments: If, after reading this report, you have questions or comments, we encourage you to send them to us. Letters should be addressed as follows: Attention: Arkansas Department of Health, Environmental Epidemiology, 4815 West Markham Street, Slot 32, Little Rock, Arkansas, 72205 ii Public Comment Release Frit Industries – Walnut Ridge, AR Table of Contents Foreword ............................................................................................................................................. i   Summary ........................................................................................................................................... iv   Purpose and Health Issues ................................................................................................................. 1   Background ........................................................................................................................................ 1   Site History ........................................................................................................................................ 2   Process Description............................................................................................................................ 3   Demographics .................................................................................................................................... 4   Discussion .......................................................................................................................................... 4   Pathways Analysis ......................................................................................................................... 5   Environmental Contamination ........................................................................................................... 6   Surface Water................................................................................................................................. 6   Groundwater Monitoring Wells..................................................................................................... 7   Ambient Air .................................................................................................................................... 8   Soil ................................................................................................................................................. 8   Health Outcome Data ....................................................................................................................... 12   Contaminants of Concern ............................................................................................................ 12   Statistics and Registry Data Review ............................................................................................ 13   Children’s Health Considerations .................................................................................................... 17   Community Health Concerns........................................................................................................... 17   Conclusions...................................................................................................................................... 18   Recommendations............................................................................................................................ 19   Public Health Action Plan................................................................................................................ 19   Authors, Technical Advisors ........................................................................................................... 21   References........................................................................................................................................ 22   Appendix A: Acronyms and Abbreviations.................................................................................... 24   Appendix B: Maps .......................................................................................................................... 25   Appendix C: Groundwater Deed Restriction.................................................................................. 27   Appendix D: Land-use Restriction Clause ..................................................................................... 31   Appendix E: ATSDR “What is Cancer?” Fact Sheet ..................................................................... 33     Appendix F: Glossary of Terms...................................................................................................... 34 Certification ..................................................................................................................................... 49   iii Public Comment Release Frit Industries – Walnut Ridge, AR Summary INTRODUCTION The Frit Industries facility produces micronutrients for the fertilizer industry. This site specializes in granular formulations used as crop additives, as well as horticultural formulations in liquid or powder form. It is located in Walnut Ridge, Lawrence County, Arkansas. The facility is located in the Walnut Ridge Air Base Industrial Park at 156 Frit Road on approximately 30 acres. Frit Industries has been in operation since the 1950’s, and the company is still an active fertilizer manufacturing site today. Frit Industries holds several active permits with the Arkansas Department of Environmental Quality (ADEQ), and has a known history of water and ambient air contamination from its use of chemical waste and hazardous waste materials. A fire in 1979 led to run-off contamination of heavy metals. It was placed on the U.S. Environmental Protection Agency’s (EPA) National Priorities List (NPL) as a Superfund site in 1983, and was removed from this list in 1997. Data evaluated in this Public Health Assessment (PHA) include sampling results for soil, sediment, surface water, groundwater monitoring wells, and air, as well as health outcome data. Based upon the data and information provided by the ADEQ, the contaminants of concern (COCs) that warranted closer evaluation in this PHA were cadmium, chromium, lead, and zinc. CONCLUSION ATSDR reached two conclusions in this PHA for current and past exposures: 1. ADH/ATSDR concludes that current exposure to elevated levels of cadmium and zinc in the on-site soil through skin contact and accidental ingestion at Frit Industries is not expected to harm people’s health. 2. ADH/ATSDR cannot currently conclude whether past exposure to chemicals from Frit Industries could harm people’s health because we do not have sufficient data and information. In response to community concerns, ADH examined health outcome data related to cancer incidence in the general area of Frit Industries, specifically Lawrence County. Rates for cancers which may be linked to the metals contaminants found at Frit Industries were examined. Elevations in the rate of lung/bronchus and other cancers were found for Lawrence County as compared the State of Arkansas. However, due to other risk factors (like smoking) we are unable to determine that the elevated rates of these cancers are related to Frit Industries alone. v Public Comment Release Frit Industries – Walnut Ridge, AR BASIS FOR DECISION 1. Since Frit Industries is still an active facility and is gated and monitored by the company, we do not expect exposures to soil contaminants by unsupervised children. Based on these exposure conditions, our findings indicate that harmful non-cancer health effects are not likely and that the risk of cancer is very low. 2. Data and information in areas where person may have been exposed to siterelated contaminants are not available to evaluate whether harmful effects may have occurred because of these exposures. Individual’s health conditions before and after the 1979 fire and subsequent contaminated off-site run-off were not recorded, making it difficult to discern what part of the surrounding community was potentially exposed. Although we found an elevation in certain cancers in Lawrence County as a whole, there is a major limitation to this analysis in that health outcome data are not readily available at a geographical level (i.e., census tract or census block) to allow it to be highly correlated to residents potentially exposed in the past to contaminants associated with Frit Industries. Moreover, only a few residents would have been likely to have had past exposure to site COCs, which would not account for the increase in county cancer rates. It is likely that the increased rates of lung/bronchus and other cancers may be due to the increased prevalence of smoking in the county compared to state rates. Other limitations of the health outcome data analysis include unknown contributions such as a resident’s years of residency within Lawrence County, and past occupations. Since cancer is a multifaceted condition, each person’s individual exposures, along with lifestyle and genetic components, can contribute to potential adverse health effects and carcinogenic risks. NEXT STEPS At this time, no additional public health actions are needed concerning the environmental media at the Frit Industries site or for people living in the surrounding community. ATSDR/ADH will continue to monitor state and county statistics and cancer registries, as well as provide public health education, as needed. FOR MORE INFORMATION If you have concerns about your health, you should contact your health care provider. You can also call ADH at 1-501-661-2893 and ask for information on the Frit Industries site. v Public Comment Release Frit Industries – Walnut Ridge, AR Purpose and Health Issues This public health assessment (PHA) was prepared to address potential public health exposures as well as address community health concerns from the Frit Industries site in accordance with the Cooperative Agreement between the Agency for Toxic Substances and Disease Registry (ATSDR) and the Arkansas Department of Health (ADH). In preparing this PHA, ADH and ATSDR used sample data previously collected by private contractors and laboratories reporting to the Arkansas Department of Environmental Quality (ADEQ) and made available through public records. Based on data from 1994 to 2009, the primary contaminants of concern (COCs) associated with Frit Industries are the metal compounds: cadmium, chromium, lead, and zinc. This PHA presents conclusions about whether a health threat is present due to the potential exposure to identified COCs, and reports results of the health outcome data evaluated. The information in this PHA is specifically designed to provide information about public health issues, and it is not intended to address liability or other non-health issues. Background The Frit Industries site located in Walnut Ridge, Arkansas, is one company of the national parent-company, Frit Incorporated. The 30-acre Arkansas facility produces micronutrients for the fertilizer industry, specializing in granular formulations used as crop additives, as well as horticultural formulations in liquid or powder form. Frit Industries holds several active permits with the ADEQ, and has a known history of water and ambient air contamination from its use of chemical waste and hazardous waste materials. A fire in 1979 led to run-off contamination of heavy metals [2, 3, 4]. It was placed on the U.S. Environmental Protection Agency’s (EPA) National Priorities List (NPL) as a Superfund site in 1983, and was removed from this list in 1997 [5]. Presently, ADEQ regulates and monitors all the facility’s permitting conditions for hazardous wastes, air, and water [6]. A request was made to personnel at ADEQ by a citizen regarding health concerns due to this site. ADEQ brought it to the attention of ADH and ATSDR. The citizen’s request involved concern of high cancer rates, as well as the number of non-cancerous health problems, around Walnut Ridge in Lawrence County where Frit Industries is located. This citizen expressed concern that the perceptibly higher occurrences of these disorders may be above the averages for the entire state due to the close proximity of the site, and requested information to address these specific concerns. Walnut Ridge is a city which is the county seat of Lawrence County. The health outcome data evaluation in this PHA discusses the review of available cancer data from Lawrence County and the state in regards to the citizen’s interest and initial community request. 1 Public Comment Release Frit Industries – Walnut Ridge, AR Site History Frit Industries is located on what was once a U.S. Army Air Corps training base during World War II, and has been the site of the fertilizer production facility since the early 1950s. It is located in the Walnut Ridge Air Base Industrial Park, along with several other offices, national and local industrial facilities, commercial aircraft services, a fire training center, a restaurant, and an aircraft museum. According to permits held through ADEQ, Frit Industries currently operates 24 hours a day four days per week, producing approximately 500 tons of micronutrient product per week. The Frit Industries site has been historically contaminated with piles of raw material, product, and waste material from the site’s fertilizer micronutrient process, which were – in the past – stored directly on the ground surface without a liner or a cover. This unlined ground storage was documented in a 1989 ATSDR Preliminary Health Assessment; however, it is no longer stored this way as indicated by a 2009 ADEQ inspection report [6]. This site was placed on the EPA’s NPL as a Superfund site in 1983. The most notable contamination that has occurred as a result of the piles is from surface water runoff at the site. The facility is located in an interstream area of the White River watershed, between Coon Creek and Village Creek. Surface runoff from the facility drains directly into an unnamed stream that discharges into Coon Creek; Coon Creek is a tributary of Village Creek, which discharges into the White River. Sampling of the surface water and the sediment has historically shown the ditches and Coon Creek to be contaminated with heavy metals, especially cadmium, chromium, lead, and zinc [7]. Results from surface water and sediment samples taken in 1985 indicated concentrations of cadmium, lead, and zinc to be of public health concern in the surface water; however, there were no heavy metal compounds above levels of public health concern in the sediment [7]. While on EPA’s NPL, several environmental samples were taken to determine the extent of contamination, including those recorded in a Facility Investigation Report (FIR) completed in 1996 [8]. Results of environmental sampling from that time to the present are evaluated in this report. Sediment samples from the various drainage ditches, streams, and creeks around the Frit Industries property were collected in 1994 through 1995 and analyzed for heavy metals for environmental and ecological purposes, and there were no sample concentrations found to exceed public health screening levels in the eight sediment samples taken from on-site and background locations [8]. The EPA announced the deletion of the Frit Industries Superfund site located in Walnut Ridge, Arkansas, from the NPL on October 14, 1997. Therefore, this site no longer fell under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Later, the EPA, in consultation with the ADEQ, determined that the site would be deferred to the 2 Public Comment Release Frit Industries – Walnut Ridge, AR Resource Conservation and Recovery Act (RCRA) and all appropriate response activities conducted and scheduled henceforth would be enforceable and should remain protective of the public health, welfare, and the environment [5]. Since the 1980’s, Frit Industries has been inspected regularly and monitored by ADEQ following federal and state environmental regulations. The FIR summarizes the review or investigation of all environmental media on-site, including soil, sediment, surface water, groundwater, and air sampling. Based on data from the FIR and subsequent groundwater monitoring, a deed restriction for groundwater use was placed on the facility and surrounding area. According to ADEQ, this deed restriction was filed in the city court on May 12, 2009 (see Appendix C). Since state-regulated inspections began, site groundwater monitoring has been actively conducted and is currently ongoing to ensure the effectiveness of the deed restriction [9]. Process Description During the formulation process, all environmental media types (soil, water, air) have the potential to be affected by on-site manufacturing at Frit Industries. According to an ADEQ Air Inspection form from January 2005, a detailed description of the micronutrient production process at Frit Industries is described as follows [10]: “Upon receipt at the granulation plant, raw materials are stored in floor bins, super-sacks, or in piles. In order to be processed, the materials are then fed into feed bins according to the desired product recipe. Raw materials are metered out of the bins and transferred with recycle material by conveyor and elevator to a horizontal rotary granulation drum. Inside the drum, water, sulfuric acid, and calcium lignosulfate are sprayed onto a moving bed of material. The wet granules created in this process exit through a chute leading to a rotary dryer. A natural gas burner at the dryer inlet supplies direct heat to dry the granules. The dried solids are then elevated to two parallel screens to separate the materials into product, undersize grades, and oversize grades. The oversize solids are passed through a hammer mill crusher and then returned back to the screens for sizing. Undersized solids are recycled back to the granulation drum by way of conveyor, elevator, recycle hopper, and the weigh feeder. Product grade solids are transported via conveyor and elevator to a dryer/cooler fluid bed. Ambient air flows through the bed, cooling the product to a level suitable for storage. The cooled product passes through a chute to a rotating, horizontal coating drum where a 0.25% solution of coating material is sprayed on the granules to prevent dusting and caking during storage. The finished product is then transported via conveyors and elevators to product storage for eventual bagging or bulk loadout. Particulate emissions at the facility are controlled and regulated under the State Air Code (Regulation 18) and the State Implementation Plan (Regulation 19).” 3 Public Comment Release Frit Industries – Walnut Ridge, AR Demographics The 2000 United States Census reported the total population for Walnut Ridge as 4,925 and 17,774 for Lawrence County [11, 12]. The Census reported 2,065 people (90.5%) residing in 2,283 housing units within the town of Walnut Ridge [11]. Located within a one-mile radius of the site is Williams Baptist College campus and a residential community that has grown around it, known as College City with a population of 269 [13]. College City has a total of 77 housing units, and 68 of those are occupied [13]. At the time of the 2000 census, 324 children under the age of five and 1,149 women of child-bearing age (15 to 44 years old) resided in Walnut Ridge. The median age in Walnut Ridge is 40.4, and there are approximately 1,128 people over the age of 65 [11]. According to the FIR, Frit Industries is used only for industrial purposes and access to the property is limited to business. The Frit Industries property is fenced and gates are locked at night and on the weekends. Lands adjacent to Frit Industries are agricultural (mainly used as rice fields), commercial, or residential, and access to these land sites varies [8]. Discussion The public health assessment process for NPL and other hazardous waste sites frequently involves the evaluation of multiple data sets. These data include available environmental data, exposure data, health effects data, and community health concerns. Health effects data can include: toxicology, epidemiology, and health outcome or statistical data. As the first step in the evaluation, ATSDR scientists review available environmental data to determine what contaminants are present in the various media to which people may be exposed (e.g., surface water, groundwater, air, and soil) and at what concentrations. ATSDR generally does not collect its own environmental sampling data, but instead, reviews information provided by other federal or state agencies and/or their contractors, by individuals, or by potentially responsible parties (PRPs) [i.e., companies that may have generated the hazardous waste found at an NPL site, shippers that may have delivered hazardous waste to the site, and individuals or corporations that own (or owned) the property on which the site is located]. The presence of hazardous chemical contaminants in the environment does not always mean that people who spend time in the area are likely to experience adverse health effects. Such effects are possible only when people in the area engage in activities that make it possible for a sufficient quantity of the hazardous chemicals to be transported into and absorbed into the body. This transport process is required in order for there to be a true exposure; thus, the assessment of real and potential exposures defines the real and potential health hazards of the site and drives the public health assessment process. As the second step in the health assessment process, ATSDR scientists conduct an evaluation of the various site-specific pathways through which 4 Public Comment Release Frit Industries – Walnut Ridge, AR individuals may become truly exposed to site contaminants and be at risk for adverse health effects. Chemical toxicants can be transported into the body through the lungs, through the gastrointestinal (GI) tract, or directly through the skin by dermal absorption. People can be exposed to site contaminants by breathing air containing volatile or dust-borne contaminants, by eating or drinking food or water that contain contaminants from the site (or through hand-to­ mouth activities with contaminated soil, dust, sediment, water, or sludge present on the hands), or by coming into direct skin-contact with contaminated dust, sediment, water, sludge, or soil resulting in dermal absorption of toxicants. Pathways Analysis To conduct a pathways analysis, ATSDR scientists review available information to determine whether people visiting the site or living nearby have been, currently are, or could be exposed (at some time in the future) to contaminants associated with this site. To determine whether people are exposed to site-related contaminants, investigators evaluate the environmental and human behavioral components leading to human exposure. Exposure to contaminants of concern is determined by examining human exposure pathways through the following criteria: 1. A source of contamination (e.g., hazardous compound(s) in the soil, water, or air), 2. An environmental medium such as water, air, or soil that can hold or move the contamination, 3. A point at which people come in contact with a contaminated medium, 4. An exposure route, such as skin contact or accidental ingestion, and 5. A population who could come in contact with the contaminants. Exposure pathways can be complete, potential, or eliminated. For a person to be exposed to site contaminants, at least one exposure pathway for those contaminants must be complete. A pathway is complete when all five elements in the pathway are present and exposure has occurred, is occurring, or will occur in the future. If one or more of the five elements of a pathway is missing, but could become completed at some point in the future, the pathway is said to be a potential pathway. A pathway is eliminated if one or more of the elements are missing and there is no plausible way of it ever being completed. From a preliminary health assessment prepared by ATSDR in 1989, potential human exposure pathways did exist based on the criteria listed. At or near the Frit Industries site, exposure to the soil could potentially occur (in the past, present, or future) through direct contact, incidental ingestion, or inhalation of fugitive dusts. Exposure to the contaminated surface water on-site or off-site could potentially occur through dermal absorption or incidental ingestion [7]. However, since the implementation of the groundwater monitoring plan and engineering controls, a 5 Public Comment Release Frit Industries – Walnut Ridge, AR potential human exposure pathway from contaminated water sources is unlikely. Along with required testing, there is also a concrete and dirt berm that encircles the perimeter of the facility to contain any untreated storm water runoff and process water [6]. Because the original request was made by residents concerning cancer and disease rates in the area in which they live, statistical analysis was used to evaluate the available percentage of cancer cases in Lawrence County compared to the state of Arkansas and an examination of health outcome data was undertaken. Concurrently, further exposure pathway analysis was performed through a review of more recent environmental data (1994 through 2009) from surface water, groundwater, air, and soil for both child and adult receptors to address all community concerns. The site is fenced. No trespassing is expected to occur and children are supervised when on site, so that exposures to children are expected to be minimal. Environmental Contamination After pathways have been evaluated, ATSDR scientists construct a number of plausible exposure scenarios, depicting a range of exposure possibilities, in order to determine whether people in the community have been (or might be) exposed to hazardous materials from the site at levels that are of potential public health concern. To do this, they must take into consideration the various contaminants, the media that have been contaminated, the site-specific and media-specific pathways through which people may be exposed, and the general accessibility to the site. In some cases, it is possible to determine that exposures have occurred or are likely to have occurred in the past. However, a lack of appropriate historical data often makes it difficult to quantify past exposures. If scientists determine that combined exposures from multiple pathways (or individual exposures from a single pathway) are posing a public health hazard, ATSDR makes recommendations for actions that will eliminate or significantly reduce the exposure(s) causing the threat to public health. The following sections discuss the most recent data collected by contractors preparing a required FIR or groundwater monitoring report for ADEQ during their field activities from 1994 to present [8, 18]. In preparing this report, ADH and ATSDR relied on the data provided by ADEQ as having been collected according to approved Quality Assurance Project Plans. Thus, it is understood that adequate quality assurance/quality control (QA/QC) procedures were followed with regard to data collection, chain of custody, laboratory procedures, and data reporting. Surface Water Historical data shows contamination occurred from surface water run-off after an on-site fire occurred in 1979. Just outside the Frit Industries facility, the area is drained by an unnamed tributary of Coon Creek. This stream is the receiving stream for any surface runoff from the 6 Public Comment Release Frit Industries – Walnut Ridge, AR facility. This stream flows from northeast to southwest, through the Williams Baptist College and College City. Flow rates in the stream are extremely low, and periodically the county has the stream dredged to promote flow [8]. Between March and June 1994, eight samples were collected at five sample locations chosen to characterize the surface water quality. Five on-site samples were taken once a month in March, April, May, and June and analyzed for COC concentrations, and three samples were taken during the same time at different locations to be used as background samples [8]. There were no sample concentrations found to exceed screening levels in the eight surface water samples taken from on-site and background locations. Groundwater Monitoring Wells Frit Industries sampled groundwater during data collection of the FIR in 1994 through 1996, and it is still currently monitoring groundwater and submitting reports under an agreement with ADEQ. From March 1994 to April 2009, there have been approximately 29 separate sampling events from 28 wells located throughout the property [8, 16]. As noted in the FIR, there are several structures around the facility that may potentially influence the groundwater flow, including pipelines, ditches, ponds, and National Pollutant Discharge Elimination System (NPDES) outfalls. The old military airfield the facility now occupies historically obtained water through a network of buried waterlines connected to a nearby well. After closure of the base, the water well was operated by College City. In 1972, College City hooked up to the Walnut Ridge municipal water system, and the well was closed. The well is now inactive [8]. Although zinc concentrations higher than screening levels were detected in four of the groundwater monitoring samples during the most recent sampling event, there were no concentrations of cadmium, chromium, or lead that exceeded screening values. Zinc is not classified as a carcinogen by the Department of Health and Human Services (DHHS), EPA, or the International Agency for Research on Cancer (IARC). Since the groundwater at Frit Industries is not used for drinking water, and no private wells were identified in the area, no further evaluation was done on ingestion of groundwater. When a dermal exposure pathway was evaluated for an agricultural worker scenario exposed to elevated zinc levels in the groundwater, the theoretical calculations were less than ATSDR’s Minimal Risk Level (MRL). The MRL is an estimate of the daily human exposure to a hazardous substance that is likely to be without appreciable risk of adverse noncancer health effects over a specified duration of exposure. The calculations performed for this evaluation were based on an adult exposure time of ten minutes per day for one year with an exposed body surface area of 2,300 square centimeters (approximately equivalent to an adult’s hands and arms 7 Public Comment Release Frit Industries – Walnut Ridge, AR being exposed to the contaminated water). Using a concentration of 32 milligrams per liter (mg/l) of zinc in the groundwater sample, the calculated exposure dose of 0.088 milligrams per kilogram per day (mg/kg/day) is less than the ATSDR MRL for zinc of 0.3 mg/kg/day [15, 16]. Therefore, no further evaluation of a possible agricultural worker’s dermal (skin) exposure to zinc in the groundwater is necessary since the appreciable risk of adverse health effects is unlikely at this site. Ambient Air The Frit Industries site provides little hindrance to wind flow since it is predominantly flat land with few trees or other tall vegetation. Manmade features that could affect the wind patterns include the buildings within the facility used for manufacture or storage purposes. Air sampling was performed at Frit Industries on four separate events from April through July 1994; each event was conducted for four consecutive days. Five separate Wedding and Associates (W&A) PM10 Critical Flow Rate High-Volume Samplers were installed at off-site locations and utilized to sample the air and particulate matter of 10 microns in diameter or less (PM10). No samples indicated that any 24-hour COC average air concentrations were above their perspective threshold limit values (TLVs) for potential on-site worker exposures. For off-site, potential residential exposures, only two of the samples exceeded EPA’s National Ambient Air Quality Standards (NAAQS) PM10 level of 150 micrograms per cubic meter (g/m3) for a 24-hour period during the four months of sampling. The two exceedences occurred at location number 2 (approximately 190 meters from the source) on June 13 – 14 and June 14 – 15, with a total particulate reading of 207 g/m3 and 220 g/m3, respectively [8]. Additionally, in 1996 the Frit Industries facility installed air emission abatement equipment which is designed to further reduce COC concentrations [8]. Due to the singular event of a slightly elevated NAAQS value reading and the installation of new equipment on-site to prevent the majority of contaminated air emissions from leaving Frit Industries, it is unlikely that high concentrations of COCs exists in ambient air which may cause adverse health effects to the surrounding community. Soil Soil in this region of the state is typically sandy clay, and was reported in the FIR as mostly silty sands. During the FIR field activities, 29 soil samples were collected on-site and off-site for the purposes of soil characterization and classification. These samples were taken from 0 to 6 inches, 6 to 12 inches, and 48 to 72 inches of depth. Background samples were also taken approximately one mile southwest of the facility to record the soil chemistry and naturally occurring metal concentrations [8]. Soil samples for COC concentration analysis were as follows: 12 samples from background, 84 on-site samples, and 60 off-site samples. 8 Public Comment Release Frit Industries – Walnut Ridge, AR Of the 156 soil samples, three on-site samples were found to be above screening levels for cadmium, three on-site samples were found to be above screening levels for lead, and one on-site sample was found to be above screening levels for zinc. There were no samples taken from the background site or the off-site location that had concentrations exceeding the screening levels used for public health evaluation. Concentration levels, screening levels, and theoretical cancer and non-cancer analysis for these 7 samples can be found in Table 1. While evaluating potential public health effects due to exposures to the COCs in the soil from the Frit Industries site, ADH used ATSDR Health Comparison Values (CVs) as screening values for soil, where available. CVs are substance concentrations set well below levels that are known or anticipated to result in adverse health effects; so, concentrations at or below the relevant CV may reasonably be considered likely not to harm people’s health. These environmental guidelines are frequently referred to as “screening levels” or “comparison values” since the contaminant concentrations measured at a Superfund or other hazardous waste site are frequently “compared” to their respective environmental guidelines in order to screen for those substances that require a more in-depth evaluation. The CV for cadmium is 10 parts per million (ppm) for a child [14]. This CV is an environmental media evaluation guide (EMEG) level for soil evaluation. There is no listed soil CV for lead. Based on alternate environmental screening sources, the EPA Region 6 Human Health Medium Specific Screening Level (HHMSSL) was used for lead. The HHMSSL screening level of 800 ppm for industrial soil represented an adequate value that was unlikely to cause harm to public health while on the Frit Industries site, because no residents (children or adults) are expected to be on the industrial property. Additionally, the property use on this site will remain industrial in the future due to a land-use restriction clause that limits the site to “Industrial/Commercial” use only (see Appendix D). Evaluation of the soil samples exceeding cadmium and zinc CVs was performed using the ATSDR Toxicological Profile and Health Assessment Toolkit (TopHat). TopHat is a software program that provides the health assessor a means by which one can take site-specific chemical levels and estimate a theoretical excess health risk expressed as the proportion of a population that may be affected by a carcinogen during a lifetime of exposure [15]. TopHat algorithms were used to calculate exposure dose (ED) in units of milligram per kilogram per day (mg/kg/day), which was then used to calculate a potential hazard quotient (HQ) and theoretical lifetime cancer risk (LCR) value for each concentration of cadmium and each exposure pathway and receptor (i.e., child or adult). Exposure pathway scenarios involving dermal (skin) contact or accidental ingestion of soil particulates were used in these measurements. See below for further description and interpretation of the HQ and LCR related to calculations in Table 1. 9 Public Comment Release Frit Industries – Walnut Ridge, AR         Table 1.   On‐Site Soil Samples As Reported In The Frit Industries Facility Investigation Report* Representing Contaminants of Concern for the Public Health Assessment Concentration  in Sample  Sample  Compound  (mg/kg or  ppm)   ID  Theoretical     Hazard  Lifetime  Quotient  Cancer Risk  (HQ) (LCR)  Skin Contact  Exposure Screening Level  Comparison  Concentration    Theoretical    Hazard  Lifetime  Quotient  Cancer Risk  (HQ) (LCR) Accidental Ingestion  Exposure BB‐1  Cadmium  15  ATSDR Soil EMEG‐child  10 ppm 1.4E‐7 child 4.7E‐5 adult 1.3E‐8 child  4.2E‐9 adult  9.4E‐4 child  2.1E‐4 adult 8.5E‐8 child 1.9E‐8 adult BB‐1  Lead  1,242  EPA Region 6 HHMSSL  soil‐industrial 800 ppm N/A N/A  N/A N/A BD‐1  Cadmium  50.4  ATSDR Soil EMEG‐child  10 ppm 4.7E‐4 child 1.6E‐4 adult 4.2E‐8 child  1.4E‐8 adult  3.2E‐3 child  7.2E‐4 adult 2.9E‐7 child 6.5E‐8 adult N/A N/A  N/A N/A BD‐1  Lead  5,058  EPA Region 6 HHMSSL  soil‐industrial 800 ppm BD‐1  Zinc  29,210  ATSDR Soil EMEG‐child  20,000 ppm 9.0E‐4 child 3.1E‐4 adult N/A  6.0E‐3 child  1.4E‐3 adult N/A DC‐2  Cadmium  26.1  ATSDR Soil EMEG‐child  10 ppm 2.4E‐4 child 8.1E‐5 adult 2.2E‐8 child  7.3E‐9 adult  1.6E‐3 child  3.7E‐4 adult 1.4E‐7 child 3.3E‐8 adult EPA Region 6 HHMSSL EC‐1  Lead  1,425  N/A N/A  N/A  soil‐industrial 800 ppm                 mg/kg = milligram per kilogram; ppm = parts per million; N/A = not applicable                 ATSDR = Agency for Toxic Substances and Disease Registry                 EMEG = Environmental Media Evaluation Guide                 EPA Reg. 6 = Environmental Protection Agency Region 6                 HHMSSL = Human Health Medium Specific Screening Level                 NOTE:  Individual samples were calculated and shown, rather than the ranges for each contaminant         to demonstrate the small number of samples that exceeded screening levels.                *Frit Industries Facility Investigation Report data published in 1996.      10 N/A Public Comment Release Frit Industries – Walnut Ridge, AR For the dermal pathway evaluation, the assumptions used in the calculations include: a contaminant concentration based on the laboratory reports; an exposure factor of one hour per day for 14 days per year over a one year period; a conversion factor (unitless); a body weight of 16 kilograms [(kg) or 35 pounds] for a child or 70 kg [154 pounds] for an adult; and a total soil adherence of 1750 milligrams (mg) for a child or 1358 mg for an adult. For the accidental ingestion pathway evaluation, the assumptions used in the calculations include: a contaminant concentration based on the laboratory reports; a model default ingestion rate of one (1.0) mg per day; an exposure factor (unitless); and a body weight of 16 kg for a child or 70 kg for an adult. These factors resulted in a calculated exposure dose (ED) in units of milligram per kilogram per day (mg/kg/day), which was then used to calculate a potential hazard quotient (HQ) and lifetime cancer risk (LCR) value for each concentration of cadmium and each exposure pathway and receptor (i.e., child or adult). Since zinc is not considered a carcinogen, only the HQ for a child or adult was calculated for zinc concentrations. To put the calculated exposure doses into a meaningful context for non-cancer, acute effects [meaning a rapid onset of an illness, or an illness that happens in less than a year (i.e., short duration)] the HQ was calculated for each potentially exposed child or adult. An HQ is the average daily intake divided by a chemical specific reference dose (RfD) set by the EPA. If the HQ for a chemical is equal to or less than one, it is believed that there is no appreciable risk that non-cancer health effects will occur. If the HQ exceeds one, there is some possibility that noncancer effects may occur, although an HQ above one does not indicate an effect will definitely occur. This is because of the margin of safety inherent in the derivation of all RfD values. The larger the HQ value, the more likely it is that an adverse effect may possibly occur. For LCR ranges, potential risks greater than one in 1,000,000 (or 1 x 10-6), which likely represents no risk of cancer, but less than one in 10,000 (or 1 x 10-4) are within the EPA’s target risk range and considered an adequate level of health safety. If the additional lifetime cancer risk is greater than one in 10,000 (or 1 x 10-4), it is generally considered an indicator that further evaluation may be warranted if the source of contamination is not removed. The estimated cancer risks for a child (age 1 – 11) and an adult (age 18 – 70) were calculated for elevated cadmium in soil for the dermal and accidental ingestion pathways. Due to the nature of the citizen’s initial request, a more conservative child scenario along with the adult scenario was calculated. Since Frit Industries is still an active facility and is gated and monitored by the company, children have limited access to the property. It is not expected that unsupervised children will be on site. Adults should practice diligent public health efforts to take precautions if children are on the site. Although there were three on-site soil samples that exceeded the lead screening value of 800 ppm, calculations based on exposure to leadcontaminated soil were not done. Instead of having a RfD to measure exposure, lead evaluation 11 Public Comment Release Frit Industries – Walnut Ridge, AR uses an Integrated Exposure Uptake Biokinetic (IEUBK) model to measure lead exposure in children. The IEUBK model looks at a child’s potential blood-level exposure to lead from all sources, including soil, air, food (including maternal milk), and household dust. ADH/ATSDR does not have access to data on all the external lead sources that could pose a potential exposure source to children in Walnut Ridge. Therefore, values relating to potential exposure to lead in the soil were not calculated. Based on COC concentrations found in the data, all human exposure pathways were eliminated except skin (dermal) contact and accidental ingestion of on-site soil. Surface water and sediment sample concentrations did not indicate public health levels of potentially harmful exposure. The groundwater exposure pathway was eliminated because groundwater is not a source of drinking water for the facility or nearby community. Air samples were reviewed; however, because of the nature of the contaminants of concern, their low volatility and their high affinity for soil particles, this pathway also was eliminated as a plausible pathway of concern. Skin contact and accidental ingestion of on-site soil pathways are the basis for the public health conclusions and recommendations reached in this PHA. Health Outcome Data Contaminants of Concern In this assessment, data from the Arkansas Central Cancer Registry were evaluated to compare general and specific cancers in Lawrence County to the state of Arkansas to address the community’s concerns regarding cancer occurrence in the area. The overall cancer rate was examined, as well as four other specific cancers: (1) lung and bronchus, (2) oral cavity and pharynx, (3) kidney, and (4) stomach. These cancer types were selected based on the target organs typically affected by the COCs connected with this site (according to the 1989 ATSDR Preliminary Health Assessment as well as data collected from 1994 through 2009), namely cadmium, chromium, and lead. Zinc was not considered as part of this cancer incidence analysis because the DHHS and the IARC have not classified zinc for carcinogenicity. Furthermore, based on incomplete information from human and animal studies, the EPA has determined that zinc is not classifiable as to its human carcinogenicity [17]. However, zinc was considered when calculating the HQ values because of the potential for non-cancerous health effects (see Table 1). ATSDR’s Toxicological Profiles for the compounds previously identified at the Frit site were used to classify the health relevance for each COC. The carcinogenic properties and their probable impact on designated target organs for cadmium, chromium, and lead were considered when choosing the specific cancer types to evaluate since these three COCs have shown contamination in the past. Cadmium exposure may occur through ingestion of contaminated food and drinking water, inhalation of particulates from ambient air or tobacco smoke, or ingestion of contaminated soil or 12 Public Comment Release Frit Industries – Walnut Ridge, AR dust. For nonsmokers, food is the major source of cadmium exposure, and inhalation of cigarette smoke is the major source of cadmium exposure for smokers. Cadmium is introduced to the food chain through agricultural soils, which may contain naturally-occurring cadmium or cadmium found in phosphate fertilizer applications. Long-term exposure to low levels of cadmium in air, food, or water leads to a buildup of cadmium in the kidneys and possible kidney disease. Other long-term effects are lung damage and fragile bones. DHHS has determined that cadmium and cadmium compounds are known human carcinogens, and research shows cadmium primarily targets the lungs in term of cancer [18]. Chromium can be found in air, soil, and water after release from the use and disposal of chromium-containing products, and during the manufacturing process. It is also a component of cigarette smoke. Chromium is a naturally occurring element found in rocks, animals, plants, and soil. It can exist in several different forms. DHHS, IARC, and the EPA have determined that chromium (VI) compounds are known human carcinogens. Studies involving chromium have shown evidence of oral, gastrointestinal, and lung cancers in humans and animals [19]. Exposure to lead can happen from breathing workplace air or dust, eating contaminated foods, drinking contaminated water, or exposure to cigarette smoke. The effects of lead are the same whether it enters the body through breathing or swallowing. Lead can affect almost every organ and system in the body, and may cause damage to the nervous system, kidneys, or reproductive system. There is no conclusive proof that lead causes cancer in humans. However, kidney tumors have developed in rats and mice that had been given large doses of certain kinds of lead compounds. DHHS has determined that lead and lead compounds are reasonably anticipated to be human carcinogens, and the EPA has determined that lead is a probable human carcinogen. IARC has determined that inorganic lead is probably carcinogenic to humans and that there is insufficient information to determine whether organic lead compounds will cause cancer in humans [20]. Statistics and Registry Data Review Health outcome data identify certain health conditions that occur in populations. These data can provide information on the general health of communities living near a hazardous waste site. They also can provide information on patterns of specified health conditions. Some examples of health outcome databases are tumor registries and vital records (or statistics). Information from local hospitals and other health care providers also can be used to investigate patterns of disease in a specific population. When a complete exposure pathway or community concern exists, ADH and ATSDR review appropriate and available health outcome data. Using ADH Arkansas Central Cancer Registry data, overall cancer incidence (i.e., morbidity) and cancer incidence for specific primary organ types were calculated from 1997 through 2005 for Lawrence County and statewide. Lawrence County was used as the exposure area because when a more defined area of exposure via the zip code was examined, the case count number 13 Public Comment Release Frit Industries – Walnut Ridge, AR was too low and displayed too much variance. The state of Arkansas was chosen as the reference population to assess possible excess cancer incidence in Lawrence County. A limitation to this analysis is that health outcome data are not readily available at a geographical level (i.e., census tract or census block) to allow it to be highly correlated to residents potentially exposed to contaminants associated with Frit Industries. County level data was the best readily available resource to explore possible elevated cancer risk in the surrounding area. However, the geographic unit (county level) available to evaluate the health outcome data is a limitation in this type of analyses given that the size of the actually exposed population is likely to be much smaller than the county level population. Crude rates were calculated by dividing the number of cancer cases reported to the AR cancer registry by the number of people in the population according to the U.S. 2000 census. Crude rates, however, can only be used to compare populations with similar distributions of age, gender, race, socioeconomic class, geographic distribution, or any other characteristics that might affect the incidence of cancer in a population. Age-standardized rates allow comparisons between populations without the influence of age. As such, a diagnosed-to-expected ratio was calculated by dividing the number of cancers diagnosed in the area by the number of expected cases. This ratio is called a standardized incidence ratio (SIR). The SIR compares the crude rate observed in Lawrence County to an expected rate calculated from age-specific rates for all of Arkansas. An SIR of one indicates that the number of cancer cases diagnosed in Lawrence County is the same as the number of cancer cases expected. If the SIR is greater that one, more cancer cases than expected were diagnosed in Lawrence County. To determine if the number of diagnosed cases is significantly greater than the expected number, a confidence interval (CI) was calculated for each SIR. The CI has a minimum (lower) value and a maximum (higher) value. Analysts commonly use a 95% CI. A 95% CI is the range of estimated SIR values that includes the true SIR value with 95% certainty. If the lower bound of the 95% CI range is greater than one, then number of diagnosed cases in the county significantly exceeded the number of expected cases. However, an excess of cancer cases in Lawrence County relative to the state does not indicate exposure route or exposure duration. Cancer incidence by primary organ type for Lawrence County, as well as statewide, from 1997 to 2005 can be found in Table 2. 14 Public Comment Release Frit Industries – Walnut Ridge, AR Table 2. Case Counts (Observed and Expected) for Lawrence County and Arkansas, 1997-2005 Cancer Type All Cancers 1997-2005 Lung & Bronchus 1997-2005 Oral cavity and Pharynx 1997-2005 Kidney 1997-2005 Stomach 1997-2005 Arkansas Overall Crude Rate (per Cases 100,000) Lawrence County Crude Rate Observed Expected (per Cases Cases 100,000) SIR* CI* 122,902 508.1 1004 768.4 682.1 1.31 (1.23, 1.39) 21,584 89.2 233 142.1 148.9 1.64 (1.53, 1.75) 2,917 12.1 37 18.7 23.4 1.97 (1.33, 2.61) 3,428 14.2 34 22.1 21.5 1.54 (1.01, 2.07) 1,683 7 10 10.6 10.2 0.94 (0.34, 1.54) Source: Arkansas Central Cancer Registry, 2009 * SIR denotes Standardized Incidence Ratio, CI denotes 95% Confidence Intervals Based on the analysis using the data from the Arkansas Central Cancer Registry, potentially elevated risks (values above 1.0, as seen by the SIR) are observed for all cancers combined, as well as cancer of lung and bronchus, cancer of oral cavity and pharynx, and cancer of the kidney in Lawrence County. Stomach cancer, with a SIR below 1.0, does not exceed the number of expected cases for the county. According to the table values, lung cancers account for approximately 38% of the excess cancers seen in Lawrence County. According to the American Cancer Society statistics, one out of three Americans now living may eventually develop cancer. Cancer is the second leading cause of death in the United States following heart disease. Cancers may be caused by a variety of factors acting alone or together, usually over a period of many years. Scientists estimate that most cancers are due to factors related to how we live, or lifestyle factors which increase the risk for cancer including: smoking cigarettes, drinking alcohol heavily, and unhealthy diet (for example, excess calories, high fat, and low fiber). A family history of cancer may also increase a person's chances of developing cancer. 15 Public Comment Release Frit Industries – Walnut Ridge, AR Since cancer, like other chronic diseases, is multi-factorial in origin, research shows there are many factors that may contribute to the development of cancer, such as an individual’s past and current health status, genetic make-up, or lifestyle choices. Considering this, we examined total tobacco use in the area, which increases the risk of cancers of the lung and bronchus, cancers of oral cavity and pharynx, and cancers of the kidney. Figure 1 shows the prevalence of current smokers in Lawrence County and the state overall from 2004 to 2007. While the smoking prevalence for 2007 in Lawrence County is equivalent to all of Arkansas, the data suggests that Lawrence County historically may have had a higher prevalence of smoking than the rest of Arkansas. Although age can be accounted for, information on years of residence and occupation of patients with these cancers in Lawrence County is limited. Of the total cases of cancers (122,902), only ten cases were from patients younger than 30 years of age. This number is too small in the overall data set to make a significant impact to the incidence rate. So, while the age of the patient may be in the accurate range for this site, cancers reported to the cancer registry only list 16 Public Comment Release Frit Industries – Walnut Ridge, AR the patient’s current residence and current occupational information. Since there is a long latency period (i.e., time from initial exposure to development of disease) for most of the cancers, it is important to have all the residential information and occupation history of the patients with cancer. However, as with the smoking history of each individual, this type of information is not currently available. Additionally, information about direct past exposure to the COCs associated with the Frit Industries site for each individual is limited. With the higher prevalence of smoking in Lawrence County, coupled with the small population involved and the lack of historical information relative to each case, ADH/ATSDR currently lacks the adequate data to assess the overall health outcome to determine a potential adverse public health effect within the community due to past contamination from the Frit Industries site. Children’s Health Considerations To protect the health of the nation’s children, ATSDR has implemented an initiative to protect children from exposure to hazardous substances. In communities faced with contamination of the water, soil, or air, ATSDR and ADH recognize that the unique vulnerabilities of infants and children demand special emphasis. Due to their immature and developing organs, infants and children are usually more susceptible to toxi

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