PUBLIC HEALTH ASSESSMENT

NAVAL AIR FACILITY, ADAK
(a/k/a ADAK NAVAL AIR STATION)
ADAK, ALEUTIAN ISLANDS CENSUS, ALASKA

CHEMICAL MIXTURES

In general, humans are continuously exposed to low levels of chemical mixtures by a variety of routes and for varying lengths of time. Interactions may occur among chemicals in the mixture that alter their toxicity. Possible effects that are greater than, less than, or equal to the sum of the effects of the individual components of the mixture can theoretically occur. ATSDR evaluated the likelihood of combined effects of the chemicals on the exposures people would experience at Adak. Again, we used the maximum contaminant concentration values and totaled the estimated exposure doses for each exposed group of people. Scientific literature has documented that adverse effects are unlikely to occur when the individual components in the mixture are present at levels well below their respective thresholds. Therefore, the combined effects of the chemicals that are present on Adak were evaluated. ATSDR determined that subsistence fish consumers are at greatest risk for adverse health effects from the chemical contaminants present in fish.

ATSDR CHILD HEALTH INITIATIVE

ATSDR's Child Health Initiative recognizes that the unique vulnerabilities of infants and children demand special emphasis in communities faced with contamination of their water, soil, air, or food. Children are at greater risk than adults from certain kinds of exposures to hazardous substances emitted from waste sites and emergency events. They are more likely to be exposed because they play outdoors and they often bring food into contaminated areas. They are shorter than adults, which means they breathe dust, soil, and heavy vapors close to the ground. Children are also smaller, resulting in higher doses of chemical exposure per body weight. The developing body systems of children can sustain permanent damage if toxic exposures occur during critical growth stages. Most importantly, children depend completely on adults for risk identification and management decisions, housing decisions, and access to medical care.

ATSDR evaluated the likelihood for children living in the downtown area on Adak to be exposed to contaminants at levels that pose a health hazard. ATSDR identified several situations in which children are or could in the future be exposed to physical or chemical contaminants likely to result in adverse health effects. Those include: (1) ingesting lead in tap water in Sandy Cove and Eagle Bay homes, (2) breathing JP-5 fuel related contaminants in indoor air in Sandy Cove homes, (3) contact with physical hazards throughout the downtown and remote areas, (4) contact with potentially contaminated sediments in Helmet Creek, and (5) subsistence consumption of seafood from Clam Lagoon, Andrew Lake, Andrew Bay, and Finger Bay. Each scenario is evaluated in detail in the body of this document.

HEALTH OUTCOME DATA

ATSDR conducts a review of existing health outcome data (e.g., birth and death certificates, birth defects registries, cancer registries, etc.), when available, if people have been exposed to site contaminants at levels likely to cause adverse health effects or if the community has concerns related to specific health outcomes. ATSDR did not evaluate health outcome databases in conjunction with the Naval Air Facility Adak Public Health Assessment because no one is being exposed to contaminants at levels likely to result in adverse health effects.

COMMUNITY HEALTH CONCERNS

1. Community members have expressed concern about possible radioactive areas of Adak.

The Radiological Affairs Support Office (RASO) conducted a radiological survey of Adak in 1997 to identify undocumented radioactive material that may have been disposed of on the island. The survey included the disposal of medical and instrument waste as well as wastes associated with military operations. The survey did not find any radiological contamination. (BRAC Cleanup Plan 11/97).

2. Community members have expressed concern that the Chemical Warfare Material disposed in an off-shore area of Adak may wash ashore.

Adak was used as a major staging area for bombing against the Japanese on the islands of Attu and Kiska during WWII. At the end of the war, remaining munitions and chemical warfare materials were disposed of by burning, detonation, burial, and open ocean dumping. Several hundred one-ton containers of chemical warfare material (i.e., Lewisite) were disposed 10 miles north of Adak Island at a depth of greater than 1000 meters (US AAF 1945). It is most likely that the containers imploded and released their contents more than 50 years ago on the ocean floor, although there is no official confirmation of this.

3. Residents and community members have reported fuel odors from areas at or near 160-D in Sandy Cove housing area.

In 1996, people staying in or adjacent to Sandy Cove unit 160-D reported fuel-type odors. The unit was made off-limits. The Navy has reported that they have conducted a survey of the unit and discovered a heating oil fuel leak; and removed the heating oil tank. The Navy also states that in 2000, additional work was done to cleanup the spill. The piping lines from the tank containing more than 50 gallons of heating oil were cleaned out. Additionally, the Navy removed soil adjacent to the piping and beneath the house down two feet deep and replaced the contaminated soil with clean soil. The Navy reports that home should be reopened in the near future.

Other Concerns

ATSDR has addressed many of the community concerns in the body of this report. Here are concerns citizens expressed to ATSDR which are included in earlier sections.

• The community has expressed concern to ATSDR regarding the physical hazards such Rommel stakes and explosives that will remain on the island.



• The community has expressed concerns about asbestos in the high school tile floor.



• The community has expressed concerns about the safety of people who must access NORPAC Hill.



• The community has expressed concerns about the safety of fish caught from Sweeper Cove.



• The community has expressed concerns about the safety of Sandy Cove housing area playgrounds.

If anyone has additional health concerns they would like to relay to ATSDR, they should direct them to:

Program Evaluation, Records, and Information Services Branch
RE: Adak Naval Air Facility
ATSDR, Division of Health Assessment and Consultation
1600 Clifton Road, MS E-56
Atlanta, GA 30333
1-888-42-ATSDR

BASE REDEVELOPMENT AND PUBLIC HEALTH

The Naval Air Facility, Adak was closed in 1995 as mandated by the Defense Base Closure and Realignment Commission under the Defense Base Closure and Realignment Act of 1990. The preferred alternative for reuse of the base property is an aviation-mixed use scenario that includes a civilian airport, seaport, light industrial, commercial, recreational and residential development.

ATSDR has evaluated potential future public health issues on Adak Island by integrating the land uses described in the preferred alternative for redevelopment with information on the types and concentrations of hazardous substances, explosive and physical hazards that will be left in the soils, sediments, groundwater, and surface waters. Our evaluation places emphasis on areas proposed for residential or public/recreational reuse activities that are more likely to bring people into contact with waste materials.

There is uncertainty associated with this evaluation. ATSDR has assumed that while the details of the specific type of activity on a parcel of land may vary, the basic land use category will remain stable. However, future changes in the preferred redevelopment plan may result from economic realities, the success of marketing efforts, and other factors. These changes cannot be predicted. Therefore, ATSDR recommends that changes in the base redevelopment plan trigger re-evaluation of potential public health issues. Specifically, the Navy, EPA, Alaska State Department of Environmental Conservation, and the Aleut Corporation should carefully evaluate any significant changes in the redevelopment plan that would result in new areas being used for (1) residential or public recreational activities that could bring people into contact with environmental contamination, explosive and physical hazards, or (2) utilization of the shallow groundwater resources which are contaminated in several areas of Adak.

PREPARER OF THIS REPORT

Carole Hossom
Environmental Health Scientist
Federal Facilities Assessment Branch
Division of Health Assessment and Consultation

Reviewer:

Diane Jackson
Chief, Defense Facilities Assessment Section B
Federal Facilities Assessment Branch
Division of Health Assessment and Consultation

LITERATURE CITED AND DOCUMENTS REVIEWED

Adios (TM) 1.1 June 1999 Database. Fuel Oil No. 1 (JP-8).

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ATSDR. 1998a. Toxicological Profile for Jet Fuels (JP-5 and JP-8). U.S. Department of Health & Human Services. Atlanta, Georgia.

ATSDR. 1998b. Record of Communication, telephone discussion with Lynn Johnston, Alaska Department of Conservation. July 8.

ATSDR. 1998c. Adak Island Site Visit Summary Report. July 10.

ATSDR. 1999a. Toxicological Profile for Total Petroleum Hydrocarbons (TPH). U.S. Department of Health & Human Services. Atlanta, Georgia.

ATSDR. 1999b. Record of Communication, telephone discussion with David Hertzog former Environmental Manager of NAS Adak. February 1.

ATSDR. 1999c. Record of Communication, telephone discussion with Richard Stoll, NFA-NW project manager. October 25.

ATSDR. 1999d. Record of Communication, telephone discussion with Bruce J. Bauman , American Petroleum Institute, Washington DC. December.

ATSDR 1999e. Record of Communication, telephone discussion with John Swanson, Air Toxics LTD. Environmental Analytical Laboratory. Folsom, California. August 18.

ATSDR. 1999f. Record of Communication, telephone discussion with David Hertzog former Environmental Manager of NAS Adak. December 1.

ATSDR. 1999a. Toxicological Profile for Mercury. U.S. Department of Health & Human Services. Atlanta, Georgia.

ATSDR. 2000a. Record of Communication, telephone discussion with Langston Walker, NFA-NW. September 12.

ATSDR 2000b. Toxicological Profile for Polychlorinated Biphenyls (PCBs) (update). Atlanta: U.S. Department of Health and Human Services; 2000 April.

ATSDR 2001. Toxicological Profile for Asbestos (update). Atlanta: U.S. Department of Health and Human Services; 2001 September.

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BP Oil Company 1999. Material Safety Data Sheet for JP-5. Cleveland, Ohio. June 9..

Bristol Environmental and Engineering Services Corporation. 2000. Completion Report Shoreline Restoration and Partial Cap Installation, Metals Landfill. Naval Air Facility Adak Island, Alaska. June 30.

Carpenter A. 1997. To: Mike Allen. Interoffice Memorandum. Subject: BTEX in Floating Product: Exposure by Inhalation Pathway. March 10.

Carpenter A. 1997. To: Scott Myers. Interoffice Memorandum. Subject: Analysis of BTEX Results from Soil Vapor Sampling Near Housing Units Overlying Free-Product (Adak). September.

Carpenter A. 1998. To: Thom Booth, URS Greiner. Technical Memorandum. Subject: Analysis of BTEX Results from Soil Vapor Sampling Near Eagle Bay and Sandy Cove Housing Area Units Overlying Free-Product (Adak Island). January 29.

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NFA NW. 1997. Executive Partnering Session Briefing Papers. April 7-8.

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NFA NW. 1999. Agreement Concerning Transfer of Lands at Adak Naval Complex Emailed to ATSDR August 5.

NFA NW. 2000. Agreement Concerning Transfer of Lands at Adak Naval Complex Emailed to ATSDR September 6.

NFA NW. 2001. Final Institutional Control Management Plan, Adak Island, Alaska. December.

EPA 1991. U.S. Environmental Protection Agency. Drinking water regulations maximum contaminant level goals and national primary drinking water regulations for lead and copper. Federal Register 1991 Jun 7;56:26560.

Exploration Technologies, Inc., Geochemical Services, TX. 1998 http://www.eti-geochemistry.com/anaerobic/#biogenic Accessed 8/5/02

IDM Consulting. 1997. Establishing Alaska Subsistence Exposure Scenarios ASPS #97-0165. Submitted to the Alaska Department of Environmental Conservation. September 1.

Integrated Risk Information System. 1999. U.S. Environmental Protection Agency Computer printout for THALLIUM. Washington, DC. January.

Foster Wheeler Environmental Corporation. 1997 Intrusive Investigation of UXO in the Priority I and II Areas, Conduct Archive Search Reports, Geophysical Surveys, and Intrusive Sampling. Naval Air Facility Adak Alaska. Draft. October 24.

Foster Wheeler Environmental Corporation. 1998a. Intrusive Sampling Work Plans: Site-Specific Work Plan, Site-Specific Health and Safety Plan, Environmental Protection Plan/Environmental Conditions Report, Addendum to Contractor Quality Control Plan Dated July 1994. Unexploded Ordnance Investigation of Priority III Area, Naval Air Facility, Adak Alaska. March 2.

Foster Wheeler Environmental Corporation 1998b. Archival Search Summary Report. Naval Air Facility Adak Island, Alaska, October 2.

Foster Wheeler Environmental Corporation. 1998c. Unexploded Ordnance investigation Summary Report, Unexploded Ordnance Investigation of the Priority III Area. Naval Air Facility Adak Island, Alaska, October 16.

Foster Wheeler Environmental Corporation. 1998d. Limited Action Work Plan, Minefield Investigations, Naval Air Facility, Adak Alaska, August 6.

Foster Wheeler Environmental Corporation. 1998e. Ordnance Awareness Training Plan for Adak Island Residents and Visitors. December.

Foster Wheeler Environmental Corporation. 1999. Minefield Investigation Summary Report 1998 Field Season, Unexploded Ordnance Investigation Naval Air Facility Adak Island, Alaska, January 29.

Foster Wheeler Environmental Corporation. 2000. Draft Site Investigation Report Selected Areas of Potential Concern in Operable Unit B. February 7.

Foster Wheeler Environmental Corporation. 2000. Draft Final Preliminary Assessment report Selected Areas of Concern Operable Unit B, Former Naval Air Facility Adak Island, Alaska. September 29.

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IARC (International Agency for Research on Cancer). 1987. IARC monographs on the evaluation of carcinogenic risks to humans. Vol. 1-42. Suppl. 7. Lyon, France.

IARC. 1989. IARC monographs on the evaluation of carcinogenic risks to humans. Vol. 45. Occupational exposures in petroleum refining: Crude oil and major petroleum fuels. Lyon, France. World Health Organization.

Less Than Fair Market Interim Lease Between the U.S. and the Adak Reuse Corporation Date Unknown.

Linderman-Reese and Stacey Lynne. 1998. Levels of Organochlorine Contamination in Blue Mussels, Mytilus Trossulus from the Aleutian Archipelago. University of California, Santa Cruz. March.

Maes, et al. The Contribution of Lead in Drinking Water to Levels of Blood Lead. (Submitted for Publication).

Marcus AH. 1989a. Relationship between childhood blood lead and lead in water or liquid diet. Report from Battelle Columbus Division to Office of Toxic Substances, USEPA. Contract No. 68-02-4294. February 14.

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Preliminary Review Draft Comprehensive Monitoring Plan, Operable Unit A, Former Naval Base, Adak Island, Alaska, May 5, 1999.

Sechena R, C. Nakano, S. Liao, N. Polissar, R. Lorenzana, S. Truoun, and R. Fenske. 1999. Asian and Pacific Islander Seafood Consumption Study in King County, Washington. U.S. Environmental Protection Agency Region 10, Seattle Washington.

Space Mark. Not Dated. Notice to all Sandy Cove and Eagle Bay Residents. Regarding Lead in Taps.

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GLOSSARY

Action Levels:

Regulatory levels recommended by EPA to warrant action or trigger a response under Superfund.

Acute:

Occurring over a short time, usually a few minutes or hours. An acute exposure (0-14 days) can result in short-term or long-term health effects.

Adverse Health Effect:

Adverse health effects are deleterious consequences in a biological system. Adverse health effects can range in severity from no apparent result to obvious frank illness. Adverse health effects can include some enzyme changes in the body which may not be noticeable even to the individual, to acute illness such as vomiting, or long-term illnesses such as cancer.

Ambient:

Surrounding. For example, ambient air is usually outdoor air (as opposed to indoor air).

Background Level:

A typical or average level of a chemical in the environment. Background often refers to naturally occurring or uncontaminated levels but can include contaminants so widespread in the environment that no specific source is apparent.

Cancer Risk:

The theoretical based assumptions from a linear multi-stage model used to calculate a theoretical risk of developing cancer over a lifetime (70 years) of daily exposure. True risk is usually much lower and may even be zero.

Carcinogen:

Any substance that may produce cancer.

Comparison Values:

Estimated contaminant concentrations in specific media that are not likely to cause adverse health effects, given a standard daily assumptions i.e., ingestion rate and standard body weight. Comparison values are calculated from the scientific literature available on exposure and health effects.

Concentration:

The amount of one substance dissolved or contained in a given amount of another. For example, sea water contains a higher concentration of salt than fresh water.

Contaminant:

Any substance or material that enters a system (e.g., the environment, human body, food, etc.) where it is not normally found.

Database:

A collection of various data stored in an electronic format.

Dermal contact:

Contact with the skin. Refers to absorption through the skin as a route of exposure.

Dose:

The amount of substance to which a person is exposed. Dose often takes body weight into account.

Downgradient:

Refers to a location toward which groundwater will flow.

Environmental Media:

Groundwater, surface water, air, soil, sediment, and biota.

Environmental Transport:

Movement of contaminants from the source to points where human exposure can occur.

Epidemiology:

The study of the occurrence and causes of health effects in human populations. An epidemiological study often compares two groups of people who are alike except for one factor, such as exposure to a chemical or the presence of a health effect. Investigators try to determine if any factor is associated with the health effect.

Exposure:

Contact with a chemical by swallowing, breathing, or direct contact (such as through the skin or eyes). Exposure may be short term (acute) or long term (chronic).

Exposure Investigation:

The collection and analysis of site-specific information to determine if human populations have been exposed to hazardous substances. The site-specific information may include environmental sampling, exposure-dose reconstruction, biologic (i.e., urine, blood) or biomedical testing and evaluation of medical information.

Exposure Pathway:

An exposure pathway is the process by which an individual is exposed to contaminants that originate from some source of contamination. It consists of five elements: 1) Source of Contamination, 2) Environmental Media/Transport, 3) Point of Exposure, 4) Route of Exposure and 5) Receptor Population.

Feasibility Study:

A study that must be completed before any remedial cleanup can begin. It evaluates different methods of handling the issue and selects a method that will effectively protect public health and the environment.

Groundwater:

Water contained in the spaces between soil and rock below the water table. This water can be in shallow (overburden) aquifers or deep bedrock aquifers.

Health Consultation:

A response to a specific question or request for information pertaining to a hazardous substance, facility, or one exposure. It often contains a time-critical element that necessitates a rapid response; therefore, it is a more limited response than a public health assessment.

Ingestion:

Swallowing (such as eating or drinking). Chemicals can get into or on food, drink, utensils, cigarettes, or hands where they can then be ingested. After ingestion, chemicals can be absorbed into the blood and distributed throughout the body.

Inhalation:

Part of the breathing process. Exposure can occur by inhaling contaminants which can then be deposited in the lungs, taken into the blood, or both.

Inorganic Chemicals:

Inorganic chemical consist of minerals without a carbon basis. Inorganic chemicals include manganese, salts (i.e., sodium chloride), and metals (i.e., iron, lead).

Lowest Observed Adverse Effect Level (LOAEL):

The LOAEL is the lowest dose at which an adverse health effect is seen in a particular study. The LOAEL is often used to derive RfDs.

Maximum Contaminant Level (MCL):

The MCL is a regulatory limit set by the Environmental Protection Agency (EPA) for contaminants in drinking water. If an MCL is exceeded, regulatory action is required under the Safe Drinking Water Act. MCLs are not always strictly health based, but can consider technological or economic feasibility.

Media:

Soil, sediment, water, air, plants, animals, or any other parts of the environment that can contain contaminants.

Medical Monitoring:

The periodic medical testing to screen people at significant increased threat of disease.

Minimal Risk Level (MRL):

Minimal Risk Levels (MRLs) are levels of chemical exposure below which non-cancer effects are not expected. MRLs are derived by the Agency for Toxic Substances and Disease Registry. An MRL is derived by dividing a LOAEL or NOAEL by "safety factors" to account for uncertainty and provide added health protection.

National Priorities List (NPL):

The Environmental Protection Agency's (EPA) listing of sites that have undergone preliminary assessment and site inspection to determine which locations pose an immediate threat to persons living or working near the hazardous chemical release. These sites are most in need of cleanup.

National Toxicology Program (NTP):

NTP conducts toxicological testing on those substances most frequently found at sites on the National Priorities List, and which also have the greatest potential for human exposure.

National Exposure Registry:

A listing of persons exposed to hazardous substances. This listing consists of chemical-specific subregistries. The primary purpose of the registry program is to create a large database of similarly exposed persons. This database is to be used to facilitate epidemiology research in ascertaining adverse health effects of persons exposed to low levels of chemicals over long periods of time.

No Apparent Public Health Hazard:

An ATSDR hazard category used when human exposure to contaminated media is occurring or has occurred in the past, but the exposure is below levels likely to result in adverse health effects.

No Observed Adverse Effect Level (NOAEL):

The NOAEL is the highest dose from a study that did not find any adverse health effects. The NOAEL is often used to derive MRL and RfDs.

No Public Health Hazard:

An ATSDR hazard category used when data indicate that no current, past and potential for future exposure exists and, therefore, no health hazard exists.

Oral Reference Dose (RfDo):

Oral Reference Doses (RfD) are levels of chemical exposure, derived by the Environmental Protection Agency, below which non-cancer effects are not expected. An RfD is derived by dividing a LOAEL or NOAEL by "safety factors" to account for uncertainty and provide added health protection.

Point of Exposure:

A location of potential or actual human contact with a contaminated medium (e.g., drinking water well, residential yard, playground, etc.)

Potential/Indeterminate Public Health Hazard:

An ATSDR hazard category used when no conclusions about public health hazard can be made because environmental and/or toxicological data are lacking.

Public Availability Session:

An informal, drop-by meeting at which community members can meet one-on-one with ATSDR staff members to discuss health and site-related concerns.

Public Health Assessment:

The evaluation of data and information on the release of hazardous substances into the environment in order to assess any current or future impact on public health, develop health advisories or other recommendations, and identify studies or actions needed to evaluate and mitigate or prevent human health effects; also, the document resulting from that evaluation.

Public Health Hazard:

An ATSDR hazard category used when human exposure to contaminated media is occurring or has occurred in the past, at levels likely to cause adverse health effects as the result of long-term exposures to hazardous substances.

Receptor Population:

Persons who are exposed or potentially exposed to the contaminants of concern at a point of exposure.

Record of Decision (ROD):

A public document approved by the participating parties of the federal facilities agreement: Navy, EPA, and Alaska Department of Environmental Conservation (in this case). The ROD outlines the cleanup method that will be used at a superfund site. It includes the responses to public comments on the Feasibility Study and the Proposed Plan.

Risk:

In risk assessment, the theoretical probability that something will cause injury, combined with the potential severity of that injury. Actual risk may be as little as zero.

Route of Exposure:

The way in which a person may contact a chemical substance. For example, drinking (ingestion) and bathing (skin contact) are two different routes of exposure to contaminants that may be found in water.

Semi-Volatile Organic Compounds (SVOCs):

SVOCs are compounds similar in composition to VOCs. However, SVOCs are less volatile than VOCs and have less potential to move in the environment. SVOCs have boiling points from 240-400ºC. They include coal tar components such as PAHs.

Soil Gas:

Gaseous compounds that occur in the small spaces between particles of the earth and soil. Such gases can move through or leave the soil or rock, depending on changes in pressure.

Source (Environmental):

Origin of a contaminant release into the environment, or, if the source is unknown, the environmental media through which contaminants are presented at a point of exposure.

Source (Reference):

Research studies, health studies, epidemiological studies, occupational studies, animal studies, exposure investigations, health evaluations, computer models, exposure models, etc. which provide reference for previous work and knowledge.

Superfund:

Another name for the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), which created ATSDR.

Volatile Organic Compounds (VOCs):

Substances that easily become vapors or gases (boiling points from 50-260ºC) and contain carbon and different proportions of other elements such as hydrogen, oxygen, fluorine, chlorine, bromine, sulfur, or nitrogen. Many VOCs are commonly used as solvents (paint thinners, lacquer thinner, degreasers, and dry cleaning fluids).

RESPONSE TO PUBLIC COMMENTS

General Comments:

NAVY: The report does not include all of the available data and studies that were conducted.

ATSDR: While a summary document of all the available data and studies that were conducted would be nice, it would be impractical for a public health assessment to contain the numerous volumes of documents the Navy, ADEC, and EPA maintain. ATSDR includes data and study information relevant to contaminants to which people are exposed. During the public health assessment process, additional data collection and studies have been conducted. Although we have tried to include the most current information available, the public health assessment represents only a snapshot in time. Clean up activities and environmental investigation continue on Adak Island. All the data and information regarding cleanup efforts may not have been included in this report at the time of printing.

In this report, we make public health recommendations based on information we have been able to obtain. If we make recommendations to protect people from contaminants in an area that is being cleaned of contaminants, then our recommendations represent prudent public health practice; we err on the side of protecting public health. We follow up our recommendations to determine if they are carried out.

A. EXPOSURES FROM UNAVOIDABLE DAILY ACTIVITIES

A1. Residents Exposed to Lead in Tap Water in Sandy Cove and Eagle Bay Homes - Current and Future Exposure - Public Health Hazard

NAVY: The Navy agrees that lead concentrations in tap water may be a health concern, but requests that the information in the PHA report be changed to accurately reflect past sampling efforts and future plans. Specifically, these issues need to be addressed: flushing and stagnant times recommended in the text are not consistent with U.S. Environmental Protection Agency (EPA) and State regulations; the report does not include all of the available data and studies that were conducted; the list presented in the report of completed and on-going actions to reduce exposure to lead is incomplete; and the planned actions listed in the report are incomplete. The flushing and stagnant times recommended in the text are not consistent with EPA and State regulation. According to State and Federal requirements (18 AAC 80.540 and 40 CFR 141.85), the flushing times are 15 to 30 seconds.

USEPA: EPA has reviewed the comments submitted by the Navy to ATSDR for the Adak Island PHA on April 18, 2002. EPA fully supports the Navy's comments, technical analyses, conclusions and recommendations. EPA encourages ATSDR to undertake a critical re-evaluation of the PHA that includes a thorough technical analysis of the data and conclusions.

ATSDR: According to state and federal requirements (18 AAC 80.540 and 40 CFR 141.85), the flushing times that are recommended are 15 to 30 seconds, but both guidelines also state that flushing times may need to be longer to reduce the lead level in taps where water has been standing in pipes (unused) for six hours. ATSDR's recommendation for 2 to 3 minutes of flushing is based on the past sampling results and results of lead present at levels of health concern even after flushing for 30 seconds. According to additional samples collected at Sandy Cove, 3-minute flushing times greatly reduced lead levels. Therefore, ATSDR's recommendations are clearly consistent with state and federal requirements.

Alaska Community Action on Toxics: ATSDR should recommend that an alternative water source be used in Sandy Cove and Eagle Bay homes.

ATSDR: The drinking water comes from Lake Bonnie Rose. Although Lake Bonnie Rose water is free from contaminants, the water is somewhat corrosive. When allowed to sit in pipes containing lead solder or brass components, the water causes the lead (and copper) to leach from the plumbing material into the water. The longer the water is allowed to remain in the pipes, the greater the likelihood lead levels will increase. So it is not the drinking water itself that is the problem, but the pipes. The Navy is considering alternative piping and will be following up on this situation.

A2. Residents Possibly Exposed to Jet Propellant -5 (JP-5) in Sandy Cove Homes - Current and Future Potential Exposure - Indeterminate Public Health Hazard

NAVY: The highest concentration of the most toxic volatile constituents (BTEX), with vapor pressures significantly above other JP-5 fuel constituents, were not found to exceed one part per million in the soil. It is anticipated that the levels of VOCs attributable to JP-5 in the breathing zone of building occupants would be nondetectable.

ATSDR: Bacteria that attack hydrocarbons generate carbon dioxide under aerobic conditions and methane under anaerobic conditions (Wiedemeier et al., 1995; Newell et al., 1995). These biogenic gases (methane and carbon dioxide) can occur at dangerous levels especially in confined spaces. New or modified building characteristics can contribute to the groundwater off-gassing into the buildings. ATSDR is unaware of a groundwater concentration at which anaerobic degradation reduces the potential biogenic gases to migrate indoors. Because many factors influence the travel path for contaminants (e.g., gasses can diffuse directly though foundations through cracks, gaps, footers, foundation floors and walls below grade level, poor seals around utility entry points), each situation should be evaluated individually. Not only do bacterial activities occur, but percent levels of carbon dioxide and methane are often generated. Biogenic methane and carbon dioxide data, generally can be used for mapping the distribution of contaminated soils; even when the contamination is very old and the lighter hydrocarbon volatiles are nearly absent (ETI 1998). Therefore, ATSDR continues to recommend that indoor air in homes in Sandy Cove be tested.

Alaska Community Action on Toxics: ATSDR should consider the potential health effects of JP-5 additives such as biocides and other chemicals. ATSDR should recommend removal of fuel spills and other sources of contamination that affect people in their homes.

ATSDR: ATSDR reviewed the information regarding additives to JP-5. Although the exact additives and their concentrations are considered proprietary information, we did contact several JP-5 manufacturers to get a general list of the various chemical additives and a concentration range that may be present in the JP-5 that was released through spills and pipeline leaks. Additionally, we reviewed the laboratory sampling methods used to analyze the various media to determine if the laboratory methods could possibly detect various additives.

Typical additives to jet fuels include antioxidants, metal deactivators, static dissipator, corrosion inhibitors, fuel system icing inhibitors, octane enhancers, ignition controllers, and detergents/dispersants. These additives are used only in specified amounts, as governed by the military and which may include 2,6-di-tert-butyl-4-methylphenol and tert-butyl-2,4-dimethylphenol among other chemical additives. These additives typically would move through and disperse in groundwater very rapidly and would not likely be detectable 10 years after release.

Other Comments

Alaska Community Action on Toxics: Although ATSDR cites the Radiological Affairs Support Office's (RASO) 1997 radiological survey, the assessment does not properly evaluate the limitations of the survey. The RASO survey was grossly deficient. It is irresponsible for ATSDR to conclude that no radiological contamination exists. ATSDR should recommend that an independent and comprehensive radiological study be conducted on the island and surrounding marine waters to assess radiological hazards from nuclear submarine operations, nuclear weapons transport and storage, and other operations.

ATSDR: ATSDR reviewed the RASO report as well as numerous declassified archived information including memos, letters, and reports dating back to 1943 to determine the locations and types of radioactive material that has been used on Adak Island. We evaluated the ways in which people could come in contact with areas where radioactive material was used, stored, and disposed. The medical facility is the only current area where people can come in contact with radioactive material which is strictly regulated by the National Radiation Commission and the Medical Waste Tracking Act. ATSDR did not identify any other areas where people could come in contact with media at areas previously used to store, dispose, or use radioactive material.

Alaska Community Action on Toxics: ATSDR should generate independent environmental and public health data and not simply review the limited and biased Navy contractor data for this analysis. The document does not discuss the implications of recent peer-reviewed scientific articles that demonstrate that people living in the vicinity of landfills have a greater risk of health problems than people living in more distant locations.

ATSDR: ATSDR does not routinely conduct environmental data instead, we rely on data generated by the military under scrutiny by EPA and state agencies. In rare cases, when data gaps are identified that require immediate sampling not conducted by other agencies, ATSDR can step in to perform that sampling. At Adak, ATSDR did not identified the need to step in to conduct sampling. We make recommendations for sampling modifications to the Navy's plans.

ATSDR has reviewed the information presented in several articles regarding the health problems in people who live near landfills. The studies reviewed, are ecological studies that use disease data bases and overlay census tract information about the people living nearby. These studies do not evaluate whether people living near landfills come in contact with contaminants at the landfill or migrating from the landfill. In most studies, there are limitations or confounders that are sometimes not factored into the evaluation. Confounders often include socio-economic status and access to medical care, or individual risk factors such as smoking or hazardous occupations.

In this report, ATSDR has evaluated whether people are actually coming in contact with contaminants migrating from the landfill on island and determined that people are not likely to experience sickness from living near the Adak landfills.

Table 3. Kuluk Bay Resident Fish and Shellfish Exposure Estimates

Biota Type

Biota Portion

Contaminant

Location

Maximum Contaminant Value

Units

Fish RBC (mg/kg)

Effect

EPAs Reference Dose (mg/kd/d)

Estimated Noncancer Dose (mg/kg/day)

ATSDR Conclusion for Noncancerous Health Effects

Estimated Cancer Dose (mg/kg/day)

Cancer Slope Factor

Cancer Risk Estimate

ATSDR Conclusion for Cancer Risk

Lowest Observed Adverse Effect Level (mg/kg/day)

SOLE

ALL, WET

ALUMINUM

13/612

235

ppm

1353.000000

N

1.0E+00

4.056E-01

No Hazard

SOLE

WHOLE, WET

ALUMINUM

13/612

235

ppm

1353.000000

N

1.0E+00

4.056E-01

No Hazard

SOLE

FILLET, WET

ALUMINUM

13/612

38.3

ppm

1353.000000

N

1.0E+00

6.611E-02

No Hazard

MUSSEL

ALL, WET

AROCLOR 1254

11/103

0.004

ppm

0.001600

C

2.0E-05

2.082E-06

No Hazard

8.924E-07

2

1.785E-06

No Hazard

MUSSEL

ALL, WET

AROCLOR 1254

13/609

0.018

ppm

0.001600

C

2.0E-05

9.370E-06

No Hazard

4.016E-06

2

8.031E-06

No Hazard

MUSSEL

ALL, WET

AROCLOR 1254

13/610

0.02

ppm

0.001600

C

2.0E-05

1.041E-05

No Hazard

4.462E-06

2

8.924E-06

No Hazard

MUSSEL

ALL, WET

AROCLOR 1254

13/611

0.024

ppm

0.001600

C

2.0E-05

1.249E-05

No Hazard

5.354E-06

2

1.071E-05

No Hazard

SOLE

ALL, WET

AROCLOR 1254

13/612

0.35

ppm

0.001600

C

2.0E-05

6.041E-04

EXCEEDS

2.589E-04

2

5.178E-04

EXCEEDS

No Adverse Effect

SOLE

WHOLE, WET

AROCLOR 1254

13/612

0.35

ppm

0.001600

C

2.0E-05

6.041E-04

EXCEEDS

2.589E-04

2

5.178E-04

EXCEEDS

No Adverse Effect

SOLE

FILLET, WET

AROCLOR 1254

13/612

0.011

ppm

0.001600

C

2.0E-05

1.899E-05

No Hazard

8.137E-06

2

1.627E-05

No Hazard

SOLE

ALL, WET

AROCLOR 1260

13/612

0.014

ppm

0.001600

C

2.0E-05

2.416E-05

EXCEEDS

1.036E-05

2

2.071E-05

No Hazard

SOLE

FILLET, WET

AROCLOR 1260

13/612

0.014

ppm

0.001600

C

2.0E-05

2.416E-05

EXCEEDS

1.036E-05

2

2.071E-05

No Hazard

MUSSEL

ALL, WET

ARSENIC

11/103

1.8

ppm

0.002103

C

3.0E-04

9.370E-04

EXCEEDS

4.016E-04

1.5

6.023E-04

EXCEEDS

No Adverse Effect

MUSSEL

ALL, WET

ARSENIC

11/104

1.6

ppm

0.002103

C

3.0E-04

8.329E-04

EXCEEDS

3.569E-04

1.5

5.354E-04

EXCEEDS

No Adverse Effect

MUSSEL

ALL, WET

ARSENIC

13/609

1

ppm

0.002103

C

3.0E-04

5.205E-04

EXCEEDS

2.231E-04

1.5

3.346E-04

EXCEEDS

No Adverse Effect

MUSSEL

ALL, WET

ARSENIC

13/610

1.6

ppm

0.002103

C

3.0E-04

8.329E-04

EXCEEDS

3.569E-04

1.5

5.354E-04

EXCEEDS

No Adverse Effect

MUSSEL

ALL, WET

ARSENIC

13/611

1.8

ppm

0.002103

C

3.0E-04

9.370E-04

EXCEEDS

4.016E-04

1.5

6.023E-04

EXCEEDS

No Adverse Effect

SOLE

ALL, WET

ARSENIC

13/612

3.4

ppm

0.002103

C

3.0E-04

5.868E-03

EXCEEDS

2.515E-03

1.5

3.773E-03

EXCEEDS

No Adverse Effect

SOLE

FILLET, WET

ARSENIC

13/612

3.4

ppm

0.002103

C

3.0E-04

5.868E-03

EXCEEDS

2.515E-03

1.5

3.773E-03

EXCEEDS

No Adverse Effect

SOLE

WHOLE, WET

ARSENIC

13/612

1.7

ppm

0.002103

C

3.0E-04

2.934E-03

EXCEEDS

1.258E-03

1.5

1.886E-03

EXCEEDS

No Adverse Effect

MUSSEL

ALL, WET

CADMIUM

11/103

0.636

ppm

1.351851

N

1.0E-03

3.311E-04

No Hazard

1.419E-04

MUSSEL

ALL, WET

CADMIUM

11/104

0.621

ppm

1.351851

N

1.0E-03

3.233E-04

No Hazard

1.385E-04

MUSSEL

ALL, WET

CADMIUM

13/609

0.617

ppm

1.351851

N

1.0E-03

3.212E-04

No Hazard

1.376E-04

MUSSEL

ALL, WET

CADMIUM

13/610

0.819

ppm

1.351851

N

1.0E-03

4.263E-04

No Hazard

1.827E-04

MUSSEL

ALL, WET

CADMIUM

13/611

0.988

ppm

1.351851

N

1.0E-03

5.143E-04

No Hazard

2.204E-04

MUSSEL

ALL, WET

CHROMIUM

11/103

0.92

ppm

2000.000000

N

1.5E+00

4.789E-04

No Hazard

2.052E-04

MUSSEL

ALL, WET

CHROMIUM

11/104

0.76

ppm

2000.000000

N

1.5E+00

3.956E-04

No Hazard

1.695E-04

MUSSEL

ALL, WET

CHROMIUM

13/609

1.6

ppm

2000.000000

N

1.5E+00

8.329E-04

No Hazard

3.569E-04

MUSSEL

ALL, WET

CHROMIUM

13/610

4.25

ppm

2000.000000

N

1.5E+00

2.212E-03

No Hazard

9.481E-04

MUSSEL

ALL, WET

CHROMIUM

13/611

1.79

ppm

2000.000000

N

1.5E+00

9.318E-04

No Hazard

3.993E-04

SOLE

ALL, WET

CHROMIUM

13/612

1.06

ppm

2000.000000

N

1.5E+00

1.830E-03

No Hazard

7.841E-04

SOLE

WHOLE, WET

CHROMIUM

13/612

1.06

ppm

2000.000000

N

1.5E+00

1.830E-03

No Hazard

7.841E-04

SOLE

FILLET, WET

CHROMIUM

13/612

0.63

ppm

2000.000000

N

1.5E+00

1.087E-03

No Hazard

4.660E-04

MUSSEL

ALL, WET

DIELDRIN

13/610

0.0007

ppm

0.000200

C

5.0E-05

3.644E-07

No Hazard

1.526E-07

16

2.499E-06

No Hazard

MUSSEL

ALL, WET

DIELDRIN

13/611

0.0006

ppm

0.000200

C

5.0E-05

3.123E-07

No Hazard

1.339E-07

16

2.142E-06

No Hazard

SOLE

ALL, WET

DIELDRIN

13/612

0.001

ppm

0.000200

C

5.0E-05

1.726E-06

No Hazard

7.397E-07

16

1.184E-05

No Hazard

SOLE

WHOLE, WET

DIELDRIN

13/612

0.001

ppm

0.000200

C

5.0E-05

1.726E-06

No Hazard

7.397E-07

16

1.184E-05

No Hazard

MUSSEL

ALL, WET

LEAD

11/103

0.304

ppm

8.9E-04

1.582E-04

No Hazard

6.782E-05

MUSSEL

ALL, WET

LEAD

11/104

0.209

ppm

8.9E-04

1.088E-04

No Hazard

4.663E-05

MUSSEL

ALL, WET

LEAD

13/609

0.367

ppm

8.9E-04

1.910E-04

No Hazard

8.187E-05

MUSSEL

ALL, WET

LEAD

13/610

0.325

ppm

8.9E-04

1.692E-04

No Hazard

7.250E-05

MUSSEL

ALL, WET

LEAD

13/611

1.68

ppm

8.9E-04

8.745E-04

No Hazard

3.748E-04

SOLE

ALL, WET

LEAD

13/612

0.165

ppm

8.9E-04

2.848E-04

No Hazard

1.221E-04

SOLE

WHOLE, WET

LEAD

13/612

0.165

ppm

8.9E-04

2.848E-04

No Hazard

1.221E-04

SOLE

FILLET, WET

LEAD

13/612

0.077

ppm

8.9E-04

1.329E-04

No Hazard

5.696E-05

MUSSEL

ALL, WET

PCBs

11/103

0.004

ppm

0.001600

C

2.0E-05

2.082E-06

No Hazard

8.924E-07

2

1.785E-06

No Hazard

MUSSEL

ALL, WET

PCBs

13/609

0.018

ppm

0.001600

C

2.0E-05

9.370E-06

No Hazard

4.016E-06

2

8.031E-06

No Hazard

MUSSEL

ALL, WET

PCBs

13/610

0.02

ppm

0.001600

C

2.0E-05

1.041E-05

No Hazard

4.462E-06

2

8.924E-06

No Hazard

MUSSEL

ALL, WET

PCBs

13/611

0.024

ppm

0.001600

C

2.0E-05

1.249E-05

No Hazard

5.354E-06

2

1.071E-05

No Hazard

SOLE

ALL, WET

PCBs

13/612

0.35

ppm

0.001600

C

2.0E-05

6.041E-04

EXCEEDS

2.589E-04

2

5.178E-04

EXCEEDS

No Adverse Effect

SOLE

WHOLE, WET

PCBs

13/612

0.35

ppm

0.001600

C

2.0E-05

6.041E-04

EXCEEDS

2.589E-04

2

5.178E-04

EXCEEDS

No Adverse Effect

SOLE

FILLET, WET

PCBs

13/612

0.025

ppm

0.001600

C

2.0E-05

4.315E-05

EXCEEDS

1.849E-05

2

3.699E-05

No Hazard

ATSDR selected contaminants for this table based on it relative hazard and ability to bioaccumulate or bioconcentrate. This is not the complete data set.
ATSDR used the Alaska Department of Environmental Conservation, IDM Consulting 1997, Establishing Alaska Specific Exposure Scenarios for Ingestion of marine (nonsalmon) fish at 126 g/day and shellfish at 38 g/day shellfish
ATSDR used EPA Reference Dose for all chemicals excluding lead. For lead ATSDR used a calculated reference dose specific to this document based on scientific literature and EPA's IEUBK model for lead uptake.
LOAEL for PCBs (total Arochlors) 0.001 mg/kd/day
LOAEL for Arsenic is 0.005 mg/kd/day

This table does not include the 1999 and 2000 annual monitoring data for PCB analysis because only summary data was provided to ATSDR. PCB data from 1999 and 2000 showed lower levels than those presented here.

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