HEALTH CONSULTATION
WINCHESTER TANNERY SITE
WINCHESTER, CHESHIRE COUNTY, NEW HAMPSHIRE
BACKGROUND AND STATEMENT OF ISSUES
This health consultation has been prepared at the request of the U.S. Environmental Protection Agency, Region I (EPA) by the New Hampshire Department of Health and Human Services, Office of Community and Public Health, Bureau of Environmental and Occupational Health (BEOH) through a combined cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). This health consultation reviews environmental sampling data that EPA collected from the area of the former Winchester Tannery, where tannery waste may be present, for the purpose of identifying current public health risk associated with exposure to chemical contaminants on the site.
Site Description and History
The Winchester Tannery was the predecessor of the A.C. Lawrence Tannery. It was located on the east side of North Main Street. The tannery operated from 1831 until it burned down in 1909. During this period of time, the Winchester Tannery site included bark piles, leach pits, a bark mill, splitting, finishing rooms, and a tan yard. When it burned down, it was rebuilt on the opposite side of the river (this is known as the A.C. Lawrence Tannery site).
Part of the Winchester Tannery site is now a residential property. One house was built on the site shortly after the tannery burned down [DES Personal Communication 2002]. In December 2000, New Hampshire Department of Environmental Services (DES) took soil samples from the property; these samples showed elevated levels of lead. The New Hampshire Childhood Lead Poisoning Prevention Program (CLPPP) was also made aware of high levels of lead at the site. Due to the contamination, the Environmental Protection Agency (EPA) conducted a Preliminary Assessment/Site Investigation (PA/SI) of the residential property on the site, to determine the extent of contamination and whether it was the result of the Winchester Tannery.
Upon finalization of the PA/SI in November 2002, DES issued a Certificate of No Further Action for the site. However, this does not equate to a lack of a public health hazard. While DES did note that several soil samples exhibited concentrations of lead, arsenic and polycyclic aromatic hydrocarbons (PAHs) at concentrations exceeding state standards, it did not have data to support that these contaminants were due to releases from the former Winchester Tannery [DES 2002]. Additionally, DES does not have regulatory authority regarding cleanup of contamination resulting from coal and coal ash, or resulting from material such as lead paint applied in a manner consistent with practices used when the material was applied [DES 1998].
Overview of Sampling Data:
Surface soil samples were collected systematically over the entire property, using a grid. This sampling protocol is important since it characterizes the location and the extent of contamination on the entire site. Forty-six soil samples were tested for inorganic compounds (Table 1) and semivolatile (Table 2) compounds.
In preparing this document, BEOH relied on the information provided by outside sources. Only data collected using appropriate sampling and laboratory methods were considered in this analysis. Data with demonstrated QA/QC problems were excluded unless they provided unique and relevant information. Certified laboratories performed all chemical testing. Measurements of chemical concentrations were taken directly from laboratory data sheets to avoid transcription errors.
BEOH evaluated sampling data from the PA/SI to determine if there was any contamination that would present a health risk to residents of the property. BEOH first compared the sampling data to ATSDR's health comparison values (HCVs). An HCV represents the amount (or concentration) of a chemical contaminant in an environmental medium, such as soil, air or water, that is used as a first step in evaluating whether actual exposure may likely result in an adverse health effect. HCVs are screening levels. When the concentration of a contaminant is below the HCV, it is highly unlikely that any kind of harmful effect will result. If a contaminant concentration is greater than the HCV, it doesn't necessarily mean that exposure is going to result in a health problem. It only means that additional evaluation of the circumstances in which humans may be exposed to it and the public health implications of that exposure are needed.
As a conservative measure, BEOH selected chemicals of concern by evaluating the maximum level of each contaminant on the site. If a soil sample contained a chemical above its respective HCV, additional evaluation of that chemical was conducted.
Chemicals of Concern
Lead, arsenic, antimony, iron, vanadium, copper and three PAH compounds (benzo[a]anthracene, benzo[b]fluoranthene and benzo[a]pyrene) were selected as chemicals of concern since at least one soil sample showed each of these chemicals above its comparison value (Tables 1 & 2).
Although the property is on the site of the former Winchester Tannery, it is difficult to ascertain if these contaminants were the result of tannery waste. Tannery waste is often associated with chemicals such as chromium, acids and a variety of organic compounds.
Exposure Pathways
Residents could be exposed to chemicals of concern through dermal (skin) contact and ingestion (swallowing) of contaminated soil.
Public Health Implications of Exposure
Antimony, Copper, Vanadium and Iron
Although the maximum values of antimony, vanadium copper and iron were above their comparison values, the average concentration of these compounds was far below the comparison value and within the range of their respective background levels. No adverse health effects from exposure to current levels of these chemicals are expected.
Lead
Lead is a naturally occurring element in the earth's crust. Most of the high levels found throughout the environment come from human activities. Sources of soil contamination include lead that falls to ground from the air, and chipping of lead-based paint from buildings and other structures. These materials, especially lead-based paint, deteriorate over time and accumulate in soil. Levels of lead may build up in plants where soil is contaminated with lead.
Lead was found in varying concentrations on the property, from below background levels to 1,350 parts per million (ppm). Many of the samples taken near the house, and in the area used for the vegetable garden, showed levels of lead above the HCV of 400 ppm.
The best measure of lead exposure is the concentration of lead in a person's blood, which is known as the Blood Lead Level (BLL). The BLL can be measured directly in the laboratory from a small blood sample. Alternatively, the BLL can be estimated using relationships between BLL and exposure from the scientific literature, which are summarized in Appendix D of ATSDR's Toxicological Profile for Lead [ATSDR 1999]. Since lead is a common and pervasive contaminant, a small amount of lead is present in the blood of all people. For example, the average BLL for the general population was 2.3 micrograms of lead per deciliter of blood (µg/dL) in 1991-1994 [ATSDR 1999]. Therefore, when evaluating lead exposures, the goal is to estimate the increase in a person's BLL as a result of the exposure, and to determine whether the cumulative exposure would be above a level of health concern.
The Centers for Disease Control and Prevention considers blood lead levels higher than 10 µg/dL to be elevated for children, the most sensitive population to lead [CDC 1991]. Assuming a conservative (worst case) scenario, BEOH used the 95% upper confidence limit of 353 ppm as a realistic level of lead that a child living at the residence could be exposed to. This level of lead was used in the Integrated Exposure Uptake Biokinetic Model for Lead in Children (IEUBK), a computer simulation developed by EPA to predict the probability of lead poisoning in children. IEUBK predicted that a child living in an area with 353 ppm of lead in soils would have an 8.4% probability of experiencing blood lead levels higher than 10 ug/dL. In contrast, EPA guidance for evaluating the risks from lead exposures at hazardous waste sites is that a child should not have more than a 5% chance of elevated blood lead levels [EPA 1994; EPA 1998].
According to the sample grid, many samples around the house show levels of lead that are above the 95% upper confidence limit of 353 ppm. Children living in the residence are more likely to play within the vicinity of the house. Therefore, it is likely that the IEUBK model prediction underestimates the probability of lead poisoning in young children.
As stated above, it is difficult to ascertain if the levels of lead in the soil are related to the operations of the former Winchester Tannery. Generally, lead is not associated with tannery waste. Since the house was built shortly after the tannery burned down [DES Personal Communication 2002], it is likely that deteriorated lead paint from the house contributed to the current levels of lead in the soil.
Polycyclic Aromatic Hydrocarbons (PAHs)
PAHs comprise a group of over 100 different chemicals that are formed during the incomplete burning of coal, oil, gas, garbage, and other organic substances such as tobacco or charbroiled meat. PAHs are usually found as a mixture containing two or more of these compounds. Because of the complexity of these mixtures, the most active compound, benzo[a]pyrene, is used as the indicator compound. While not all PAHs are considered carcinogenic (e.g., pyrene), the EPA has determined that benz[a]anthracene, benzo[a]pyrene, benzo[b]fluoranthene, benzo[k]fluoranthene, chrysene, dibenz[a,h]anthracene, and indeno[1,2,3-c,d]pyrene are probable human carcinogens [ATSDR 1995].
From an environmental perspective, PAHs can usually be found at very low concentrations everywhere in the environment. The PAH levels that exist in surface soils throughout the property are lower than the average levels of PAHs that are found in surface soils in urban, nonindustrial areas of New England [Bradley et al. 1994]. From these comparisons, it is possible to conclude that the levels of PAHs in the soil do not pose a hazard to occupants of the property.
Arsenic
Arsenic is another element that is widely distributed in the earth's crust, especially in northern New England. It can be found in drinking water, in most types of soil and in rocks such as granite. EPA classifies arsenic as a known human carcinogen.
Arsenic is present at low levels throughout much of the soils naturally occurring in NH. The average level of arsenic detected in surface soils on the property is within the range of known background levels in the state of New Hampshire [DES 1998]. Exposure to background levels represents only a slight increase risk of cancer over a person's lifetime. Moreover, it is possible to conclude that these levels do not pose a hazard to occupants of the property beyond the risk due to background arsenic levels.
Children are at a greater risk than adults from certain kinds of exposure to hazardous substances emitted from waste sites. They are more likely to be exposed for several reasons (e.g., they play outdoors more often than adults, increasing the likelihood that they will come into contact with chemicals in the environment). Because of their smaller stature, they may 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 certain 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.
With specific regard to contaminants in soil, children are at higher risk of exposure because they are more likely to come in contact with soil than adults. This occurs through playing outdoors, frequent contact with soil, and soil sticking to their exposed skin. Contaminated soil can be spread, resulting in indirect exposures by other children. Levels of lead in the blood can be especially a concern for young children since they are more vulnerable to the effects of lead poisoning.
The purpose of the Public Health Action Plan is to ensure that this document not only identifies any current or potential exposure pathways or related health hazards, but also provides a plan of action to mitigate and prevent adverse human health effects resulting from exposures to hazardous substances in the environment. The first section of the Public Health Action Plan contains a description of completed or ongoing actions to mitigate exposures to environmental contamination. In the second section, there is a list of additional public health actions that will be implemented in the future.
Completed or Ongoing Actions:
Planned Actions:
Todd C. Hudson
Environmental Health Risk Analyst
Bureau of Environmental and Occupational Health
New Hampshire Department of Health and Human Services
Concord, New Hampshire
(603) 271-4664
(603) 271-3991 (fax)
The Health Consultation on the former Winchester Tannery in, Winchester, New Hampshire was prepared by the New Hampshire Department of Health and Human Services under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the Health Consultation was begun.
Gregory V. Ulirsch, M.S.
Technical Project Officer
Superfund Site Assessment Branch (SSAB)
Division of Health Assessment and Consultation (DHAC)
ATSDR
The Division of Health Assessment and Consultation, ATSDR, has reviewed this Health Consultation and concurs with its findings.
Roberta Erlwein
Chief, SSAB, DHAC, ATSDR
Agency for Toxic Substances and Disease Registry (ATSDR). 1999. Toxicological Profile for Lead. Atlanta, Georgia: Agency for Toxic Substances and Disease Registry, U.S. Department of Health and Human Services.
Agency for Toxic Substances and Disease Registry (ATSDR). 1995. Toxicological Profile for Polycyclic Aromatic Hydrocarbons. Atlanta, Georgia: Agency for Toxic Substances and Disease Registry, U.S. Department of Health and Human Services.
Bradley, LJN; Magee, BH; Allen SL. 1994. Background levels of polycyclic aromatic hydrocarbons (PAH) and selected metals in New England Urban Soils. Journal of Soil Contamination, 3(4): 349-361.
Centers for Disease Control and Prevention. 1991. Preventing Lead Poisoning in Young Children. Atlanta, Georgia: Centers for Disease Control, U.S. Department of Health and Human Services.
Department of Environmental Services. 1998. Contaminated Sites Risk Characterization and Management Policy. Concord, New Hampshire.
Department of Environmental Services. 2002. Re: Former Winchester Tannery, Certificate of No Further Action. Concord, New Hampshire.
Environmental Protection Agency. 1994. Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities. OSWER Directive # 9355.4-12. EPA/540/F-94/043. Washington, DC: Office of Solid Waste and Emergency Response, Environmental Protection Agency.
Environmental Protection Agency. 1998. Clarification to the Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities. OSWER Directive # 9200.4-27P. EPA/540/F-98/030. Washington, DC: Office of Solid Waste and Emergency Response, Environmental Protection Agency.
Environmental Protection Agency, Region IV. 2000. Region IV Human Health Risk Assessment
Bulletins; Supplement to Risk Assessment Guidance for Superfund (RAGS). Atlanta, Georgia:
Waste Management Division, Environmental Protection Agency.
http://www.epa.gov/region04/waste/ots/healtbul.htm 
Table 1. Maximum levels of Inorganics.
| Chemical | Max. Conc. (ppm) | Comparison Value | |
| Amount | Source | ||
| Aluminum | 16700 | 100000 | Intermediate EMEG - Child |
| Antimony | 42.8 | 20 | RMEG - Child |
| Arsenic | 41.7 | 0.5 | CREG |
| Barium | 448 | 4000 | RMEG |
| Beryllium | 1.7 | 100 | Chronic EMEG - Child |
| Cadmium | 0.99 | 10 | Chronic EMEG - Child |
| Chromium (VI) | 223 | 230 | Residential RBC |
| Copper | 6640 | 2000 | Intermediate EMEG -Child |
| Iron | 60400 | 23000 | Residential RBC |
| Lead | 1350 | 400 | Residential PRG |
| Manganese | 2450 | 3000 | RMEG - Child |
| Mercury | 0.61 | 23 | Residential PRG |
| Nickel | 20 | 1000 | RMEG - Child |
| Selenium | 2.3 | 300 | Chronic EMEG - Child |
| Silver | 1.1 | 300 | RMEG - Child |
| Thallium | 1.5 | 5.2 | Residential PRG |
| Vanadium | 351 | 200 | Intermediate EMEG - Child |
| Zinc | 40.2 | 20000 | Chronic EMEG - Child |
EMEG – Environmental Media Evaluation Guide, developed by ATSDR
RMEG – Reference Dose Media Evaluation Guide, developed from EPA’s Reference
Dose
CREG – Cancer Risk Evaluation Guide, developed by ATSDR
RBC – Risk-Based Concentration, developed by EPA, Region IV
PRG – Preliminary Remediation Goal, developed by EPA, Region IX
Table 2. Maximum levels of PAHs.
| Chemical | Max. Conc. (ppm) | Comparison Value | |
| Amount | Source | ||
| Fluoranthene | 1.9 | 3100 | RBC Residential |
| Pyrene | 2.3 | 2300 | RBC Residential |
| Benzo[a]Anthracene | 1.4 | 0.87 | RBC Residential |
| Chrysene | 1.4 | 87 | RBC Residential |
| Benzo[b]Fluoranthene | 1.4 | 0.87 | RBC Residential |
| Benzo[k]Fluoranthene | 0.47 | 8.7 | RBC Residential |
| Benzo[a]Pyrene | 0.99 | 0.1 | CREG |
| Indeno[1,2,3-c,d]Perylene | 0.5 | 0.87 | RBC Residential |
CREG – Cancer Risk Evaluation Guide, developed by ATSDR
RBC – Risk-Based Concentration, developed by EPA, Region IV
