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PETITIONED PUBLIC HEALTH ASSESSMENT

SITES IN
BLUEFIELD, WEST VIRGINIA; BLUEFIELD, VIRGINIA; AND VICINITY



CONCLUSIONS

Additional information is needed to more fully evaluate releases, migration, and resulting contaminant levels at points of potential human exposure, as well as to more fully evaluate associated potential health concerns. Because necessary data are limited, ATSDR considers the Bluefield area to be an indeterminate public health hazard.

Environmental sampling shows one or more of the chemicals are present at some of the locations. However, for several of the identified sites, data are too limited (or are absent) to conclude whether improper use or disposal of the contaminants of concern has occurred--ATSDR considers those locations to include at least:

o Appalachian Power Company Service Center
o Appalachian Power Company Glen Lyn Plant
o Blacor Steel
o Bluefield Armature
o Bluefield City Park
o Bull Tail Hollow
o Old Bluefield, VA, landfill on High Street

Ongoing exposure of humans to PCBs in the Bluefield area may be occurring for children and adults at the Sam Neal Property. Children and adults may have been exposed to dioxin at the Sam Neal Property. Worker exposure to PCBs has likely occurred in the past at Acken Sign, APCO Service Center, Joy Manufacturing, and Linn Electric. There were no relevant sampling data for the APCO Glen Lyn Plant, Blacor Steel, Bluefield Armature, the streets of Bluefield, Bull Tail Hollow, and the Old Bluefield Landfill in Virginia.

Exposures to PCBs and dioxin at the Sam Neal property do not appear to be great enough to result in noncarcinogenic health effects. Exposure to PCBs at the Sam Neal property represents a small increase of risk for cancer for those working or living there for many years. However, it appears unlikely that anyone has worked or lived there long enough to be at risk.

Evaluation of age-adjusted mortality data for Tazewell and Mercer Counties revealed no excess rates of death and total cancer. The age-adjusted mortality data for 1979-1988 indicate that the rate of stomach cancer for Tazewell County, Virginia was greater than the rate for Virginia, but less than that for the United States. For lung cancer, the age-adjusted mortality rate for Tazwell County for 1979-1988 was greater than the rates for Virginia and the United States. However, rates for the entire county may not reflect the occurrence of these health outcomes in the Bluefield area. The significance of the county-wide results needs further evaluation.


RECOMMENDATIONS

ATSDR usually finds that public health issues cannot be evaluated as thoroughly as seems appropriate because contamination and exposure information or other data are not fully available. Recommendations for information that would allow ATSDR to better evaluate those issues are provided in this section.

Site Characterization and Cease/Reduce Exposure Recommendations

General Recommendations

  1. Future sampling activities should include analyses for all contaminants of concern--PCBs, PCDDs, PCDFs, and TCE--unless investigators are confident one or more of those compounds will not be present. For Bull Tail Hollow, include 2,4-D and 2,4,5-T.

  2. Periodic analyses should be conducted for the contaminants of concern for the public water supply for Bluefield, VA, and Bluefield, WV, and for GVGPSD's system that uses Bull Tail Hollow Reservoir to check whether any contaminants arise at concentrations that pose a potential public health concern.

  3. Analyses should be conducted of edible portions of game fish taken from productive fishing areas in the Bluestone River downstream of Bluefield, VA, to determine whether any of the contaminants of concern are present at concentrations that pose a potential public health concern.

  4. Laboratory tests should be conducted using protocols that provide detection limits that are commensurate with the low concentrations at which some of the contaminants of concern potentially pose adverse health effects.

Site-Specific Recommendations

Acken Sign Services

  1. Conduct analysis of additional surficial soil samples obtained on site and--if those results warrant--also off-site areas to determine whether any of the contaminants of concern are present at levels that pose a potential public health concern.

  2. Conduct at least a limited survey of private wells in the site vicinity, and conduct sampling, as appropriate, to determine whether any of the contaminants of concern are present in well water at concentrations that pose a potential public health concern.

APCO Service Center

  1. Conduct analyses in areas where PCB liquids are handled to determine whether any contaminants of concern are present at concentrations that pose a potential public health concern to the workforce. If excessive contaminant concentrations are found, implement measures that reduce the contaminant source levels or that protect workers from undue exposure.

APCO Glen Lyn Plant

  1. Conduct sampling of surface soils at several residences at varying distances in the predominant downwind direction to determine whether contaminants have been deposited at concentrations that could pose a public health concern. The sampling might be initiated in a limited area and expanded if warranted by the initial results.

  2. Conduct groundwater sampling at some of the private and public wells in the plant vicinity to determine whether any of the contaminants of concern are present at levels that pose a public health concern. The sampling might be initiated in a limited area and expanded if warranted by the initial results.

  3. Assess areas where PCB liquids are handled to determine whether any contaminants are present at levels that pose a potential health concern to the workforce. The sampling might be initiated on a small scale and expanded if warranted by the initial results. If excessive contaminant concentrations are found, implement measures that either reduce the contaminant source levels or that protect workers from exposure.

Bernard Neal Property

  1. Conduct a survey of private wells in the site vicinity. If wells are present, conduct sampling to determine whether any of the contaminants of concern are present in well water at concentrations that pose a potential public health concern.

  2. If the site remains undeveloped, minimize the potential for incidental human exposure to contaminants--consider fencing the area or placing a layer of cover soil. If the property is developed for habitation, consider more substantial measures for protecting public health.

Blacor Steel

  1. To determine whether any of the contaminants of concern are present at concentrations that pose a public health concern, conduct sampling and analyses of surface soils on site in areas where salvage operations have been done.

  2. If soil sampling indicates that contaminants of concern are present, a survey should be conducted of private wells in the site vicinity, and water sampling should be initiated at representative wells to determine whether any of the contaminants are present at concentrations that pose a potential public health concern.

  3. If soil sampling indicates that contaminants of concern are present at levels that pose a public health concern to workers, institute measures that would reduce the source levels or protect workers.

Bluefield Armature

  1. Attempt to confirm whether PCB-laden fluids or TCE have been handled or disposed of at the facility. If that is not possible to confirm, conduct sampling in the building and in surface soils behind the building to determine whether the contaminants of concern are present at levels that pose a potential public health concern to the workforce. If excessive contaminant concentrations are found, institute measures that either reduce concentrations or that protect workers from exposure.

Bluefield Area Streets and Alleys, City Park, Playgrounds, and High School Track

  1. Initiate sampling and analyses of surface soils at a statistically significant number of locations selected from the roads and other areas that were possibly sprayed to determine whether contaminants of concern are present at concentrations that pose a public health concern. Evaluate the results of that initial program to decide whether, or where, additional sampling and analyses are needed to complete the evaluation. Results of soil sampling conducted in 1993 at the high school track suggest that additional analyses are unwarranted at that location.

  2. If the results of the sampling program identify locations where exposures are a public health concern, initiate remediation designed to reduce either the source contamination or the exposure to levels that are acceptable from a public health perspective.

  3. If concentrations at levels of concern are detected in soils, conduct a survey of private wells near such location(s), and sample well water to determine whether any of the contaminants of concern are present at levels that could adversely affect public health.

Bull Tail Hollow

  1. Initiate at least a nominal soil sampling program for the road and power distribution lines and also the private water well to determine whether contaminants of concern are present at concentrations that pose a public health concern. Evaluate the results from the initial program to decide whether, or where, additional sampling and analyses are needed to complete the evaluation.

  2. If the results of the sampling program identify locations where exposures are a public health concern, initiate remediation designed to reduce either the source contamination or the exposure to levels that are acceptable from a public health perspective.

Joy Manufacturing

  1. Periodically inspect and maintain the perimeter fence system to minimize the potential for intruder access.

  2. Periodically inspect and maintain the layer of fill soils that have been placed over contaminated soils on and off site. Also maintain the pavements and concrete slabs that cover contaminated soils, and maintain building components that are necessary for structural integrity or for preventing rain water from entering.

  3. If the buildings or site are used again for industry or residences, supplemental sampling and assessment should be made of residual contamination within the building and perimeter to clarify whether the intended use would expose workers or other users to contaminants in building components or soil at concentrations that would pose a public health concern.

  4. If the swale area is ever developed, conduct supplemental sampling for contaminants of concern to determine whether any are present at levels for which anticipated exposures that might be associated with development would pose a public health concern.

  5. EPA reports a search of well logs at county offices did not identify any private wells in that area. ATSDR recommends augmenting that search by touring area streets with the water company meter reader who could readily identify any residences or businesses that do not have a water meter. If wells are present, conduct sampling to determine whether any of the contaminants of concern are present in well water at concentrations that pose a potential public health concern.

Lin-Electric Company

  1. Clarify available clean-up documents in a manner that clearly outlines the areas sampled, the criteria for cleanup, the limits of areas remediated, and levels of contaminants of concern that remain in media through which workers might be exposed--and/or conduct additional sampling and documentation that demonstrates that the cleanup resulted in an environment that is compatible with worker health.

  2. Conduct a survey of private wells in the site vicinity. If wells are present, conduct sampling to determine whether any of the contaminants of concern are present in well water at levels that pose a potential public health concern.

Mercer County Landfill

  1. Conduct sampling of surficial soils on the landfill and on several representative adjacent properties, including the youth detention center, to determine whether any contaminants of concern are present at concentrations that pose a public health concern.

  2. Conduct a survey of private wells in the site vicinity. If wells are present, conduct sampling to determine whether any of the contaminants of concern are present in well water at concentrations that pose a potential public health concern.

  3. If the collection ponds are dredged to increase storage capacity, take at least nominal precautions when handling and covering dredged materials.

Old Bluefield, VA, Landfill

  1. Conduct sampling of surficial soils or wastes on or immediately around the landfill to determine whether contaminants of concern are present at concentrations that pose a public health concern to current trespassers or future users of the property.

  2. Conduct sampling of sediments in the downgradient drainage channel where it passes through the community of Hales Bottom to determine whether children who might play in the channel could be exposed to contaminants at concentrations that pose a public health concern.

  3. Conduct a survey of private wells in Hales Bottom, sample groundwater at the nearest private well downgradient and several others to determine whether residents are being exposed to contaminants at concentrations that pose a public health concern.

Sam Neal Property

  1. Conduct soil sampling on the immediately adjacent residential property.

  2. Using the foregoing sampling data, assess public health implications, and decide whether any remedial or other protective measures are needed to reduce adverse exposure.

  3. Conduct a survey of private wells in the site vicinity. If wells are present, conduct sampling to determine whether any of the contaminants of concern are present in well water at concentrations that pose a potential public health concern.

Health Activities Recommendation Panel (HARP) Recommendations

The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended, requires ATSDR to perform public health actions needed at hazardous waste sites or toxic substance releases. To determine if public health actions are needed, ATSDR's Health Activities Recommendation Panel (HARP) has evaluated the data and information developed in the Bluefield Public Health Assessment.

Data are very limited. Most exposures are believed to be past and current worker exposures, and a referral is needed to appropriate occupational health agencies.

HARP determined that residents who live on the Sam Neal property where soil is contaminated should have their blood tested for polychlorinated biphenyls.

HARP determined that a health statistics review is needed of the occurrence of cancer and diabetes in the Bluefield area, if appropriate databases can be found.

In addition, HARP determined that community and health professionals education is indicated. Community health education should be focused at the residents of the Sam Neal Property and should include information on how to minimize exposures via soil. The health professions education should focus on the effects of PCBs, 2,3,7,8 tetrachlorodibenzo-p-dioxin, and trichloroethylene.


PUBLIC HEALTH ACTIONS

ATSDR has asked the Virginia Department of Health to evaluate the feasibility of a health statistics review of lung and stomach cancer for the Bluefield, Virginia area--and, should such a study prove feasible, to consider conducting it prior to the end of 1994. ATSDR will conduct community health and health professional education as resources permit. ATSDR has determined a biological indicator of exposure study is not needed.

EPA reports they revisit former Joy Manufacturing property, the swale, and associated areas at 6- to 9-month intervals to review conditions and determine if any worsening conditions exist. In 1993, in response to recommendations, EPA initiated sampling at the swale, high school track, Sam Neal and Bernard Neal sites, Bluefield, WV, and Bluefield, VA, water supplies, and Bull Tail Hollow reservoir. A sample of road/street materials also was taken; an effort was made to duplicate a road sample taken previously. EPA reports they will conduct any further actions or studies indicated by the data being developed. The remaining sites will be referred to the agency's Site Assessment Program for assessment as potential Superfund sites but may be re-referred to other operating programs in EPA; timing of referral actions is uncertain (40). EPA reports they anticipate a removal action for the Sam Neal and Bernard Neal sites, with a goal of starting the removal in April, 1994 (71).

A commenter reports that the Virginia Department of Environmental Quality recommended three of the four sites in that state for inclusion on CERCLIS (Comprehensive Environmental Response, Compensation, and Liability Information System). Two sites, Blacor Steel and the Old Bluefield Landfill were accepted. Inclusion on CERCLIS indicates that a Preliminary Investigation will be performed within a year.


PREPARERS OF REPORT

Preparers of Report:
 

Don Gibeaut
Environmental Health Engineer
Environmental Science Section
Remedial Program Branch
Division of Health Assessment
and Consultation

John Crellin, Ph.D.
Environmental Health Scientist
Health Science Section
Remedial Program Branch
Division of Health Assessment
and Consultation

Regional Representative:

 
Charles Walters
Public Health Advisor
Region III
Office of Assistant Administrator



REFERENCES

  1. Petitioner for Bluefield Site. Petition letter to ATSDR. Undated.

  2. Petitioner for Bluefield Site. Petition letter to ATSDR. May 5, 1989.

  3. REMCOR, INC. Final Comprehensive Report on Sampling and Analysis Program and Remediation of Polychlorinated Biphenyls, Acken Signs Company. November 8, 1990.

  4. Deposition. US District Court, Beckley West Virginia. July 29, 1987.

  5. Remedial Corporation. Remedial Investigation/Feasibility Study, On-Site Areas, Route 52 Site, Bluefield, West Virginia. July 1986.

  6. Remedial Corporation. Remedial Investigation/Feasibility Study, Off-Site Areas, Route 52 Site, Bluefield, West Virginia. July 1986.

  7. U.S. Court of Appeals for the Fourth Circuit. Rodney D. Ball, Sr., et al, versus Joy Technologies, Inc., etc. August 5, 1991. Amended February 12, 1992.

  8. ERT Inc. Closure Certification Report. April 1988.

  9. U.S. Environmental Protection Agency. Site Inspection Report, Sam Neal Property. Undated.

  10. Remedial Corporation. Letter to Baker Mine Service. August 21, 1986.

  11. Remedial Corporation. Letter to Baker Mine Service. May 4, 1988

  12. U.S. Environmental Protection Agency. Memorandum and data. Bluefield PCB sites. November 15, 1993.

  13. Weston. Memorandum and data to EPA Region III. Subject: Transmittal memo of December 16, 1993 and request for Route 52 sampling map and Bluefield water quality data. December 21, 1993.

  14. West Virginia Department of Natural Resources, Division of Waste Management. Site Investigation Report, Bernard Neal Site. December 20, 1988.

  15. NUS Corp. Field Trip Report, Bernard Neal Site. September 16, 1986.

  16. WESTON. Memorandum, Bernard Neal and Former Sam Neal Properties. December 6, 1993.

  17. Vanderbilt University, Center for Health Services. Letter to petitioner. July 6, 1987.

  18. Appalachian Power Company. Letter to ATSDR. February 6, 1991.

  19. Joy Manufacturing. Letter to U.S. Environmental Protection Agency. October 25, 1985.

  20. Comprehensive Safety Compliance Inc. Letter to Joy Manufacturing. December 27, 1985.

  21. U.S. Environmental Protection Agency, Region III. Environmental News Circular. June 1986.

  22. American Water Works Service County. Letter to U.S. Environmental Protection Agency. July 21, 1986.

  23. Remedial Corporation. Revised Building Decontamination Work Plan, for Joy Manufacturing Company. July 18, 1986.

  24. Remedial Corporation. Letter to U.S. Environmental Protection Agency. July 16, 1987.

  25. Remedial Corporation. Letter to U.S. Environmental Protection Agency. September 17, 1987.

  26. Remedial Corporation. Building Work Activities. January 1988.

  27. Remedial Corporation. Final Report, Soil Removal Activities. February 8, 1988.

  28. Bruck, Hartman & Esposito, Inc. Letter to Mr. Elwin Aliff. July 14, 1989.

  29. U.S. Environmental Protection Agency. Memorandum, PCB Sampling Assessment. November 14, 1989.

  30. Bruck, Hartman, & Esposito, Inc. Summary of Findings, PCB Contamination at Aliff Property. November 17, 1989.

  31. Weston. Memorandum to EPA: Joy Manufacturing Site Assessment. January 19, 1993.

  32. NUS Corp. Field Trip Report, Mercer County Landfill. September 2, 1986.

  33. West Virginia Department of Natural Resources, Division of Waste Management. Site Investigation Report, Sam Neal Site. June 15, 1989.

  34. U.S. Environmental Protection Agency. Closeout Memo, Sam Neal Site. October 26, 1988.

  35. West Virginia American Water Company. Laboratory Data Report, Ada Treatment Plant. July 8, 1988.

  36. West Virginia American Water Company. Letter to U.S. Environmental Protection Agency. June 17, 1986.

  37. Agency for Toxic Substances and Disease Registry. Record of telephone communication with Virginia Water Control, Abingdon, Virginia. March 7, 1990.

  38. Virginia Department of Health. Laboratory Data Sheets. 1989.

  39. West Virginia Bureau of Public Health. Laboratory Data Sheets. 1991.

  40. U.S. Environmental Protection Agency. Memorandum to ATSDR. March 17, 1993.

  41. Agency for Toxic Substances and Disease Registry. Toxicological profile for selected PCBs. Atlanta: ATSDR, October 1991.

  42. Agency for Toxic Substances and Disease Registry. HAZDAT 1.0 (A Hazardous Substance Database). Atlanta, GA: Agency for Toxic Substances and Disease Registry. March 1992.

  43. U.S. Environmental Protection Agency. Integrated Risk Information System (computer database). Washington, D.C.: U.S. Environmental Protection Agency, 1992.

  44. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Selected PCBs (Aroclor -1260, -1254, -1248, -1242, -1232, -1221, and -1016) Atlanta, GA: Agency for Toxic Substances and Disease Registry (ATSDR), DHHS (PHS) TP-88-21. June 1989.

  45. Fein GG, Jacobson JL, Jacobson SW, Schwartz PM, Dowler JK. Prenatal exposure to polychlorinated biphenyls: effects on birth size and gestational age. J Pediatrics 105: 315-320. 1984.

  46. Jacobson SW, Fein GG, Jacobson JL, Schwartz PM, Dowler JK. The effect of intrauterine PCB exposure on visual recognition memory. Child Dev 56: 853-860. 1985.

  47. Jacobson JL, Jacobson SW, Humphrey HEB. Effects of in utero exposure to polychlorinated biphenyls and related contaminants on cognitive functioning in young children. J Pediatrics 116: 38-45. 1990.

  48. Jacobson JL, Jacobson SW, Humphrey HEB. Effects of exposure to PCBs and related compounds on growth and activity in children. Neuro Terato 12: 319-326. 1990.

  49. Rogan WJ, Gladen BC, McKinney JD, Carreras N, Hardy P, Thullen J, Tinglestad J, Tully M. Neonatal effects of transplacental exposure to PCBs and DDE. J Pediatrics 109: 335-341. 1986.

  50. Barsotti DA, Van Miller JP. Accumulation of a commercial polychlorinated biphenyl mixture (Aroclor 1016) in adult rhesus monkeys and their nursing infants. Toxicology 30: 31-44. 1984.

  51. Levin ED, Schantz SL, Bowman RE. Delayed spatial alternation deficits resulting from perinatal PCB exposure in monkeys. Arch Toxicol 62: 267-273. 1988.

  52. Schantz SL, Levin ED, Bowman RE, et al. Effects of perinatal PCB exposure on discrimination-reversal learning in monkeys. Neurotoxicol Teratol 11: 243-250.

  53. Thomas JA. Toxic responses of the reproductive system. in (Amdur MO, J Doull, and CD Klaassen, eds) Casarett and Doull's Toxicology. The Basic Science of Poisons. Fourth Edition. New York: Pergamon Press. 1991.

  54. Hill RN. Current EPA perspectives on animal selection and extrapolation. in (Roloff MV et al, eds) Human Risk Assessment. The Role of Animal Selection and Extrapolation. London: Taylor and Francis. 1987.

  55. Stallones RA. Epidemiology and Environmental Hazards. in (Gordis L and Libauer CH, eds) Epidemiology and Human Risk Assessment. Oxford: Oxford University Press. 1988.

  56. Paustenbach DJ. A survey of health risk assessment. in (Paustenbach DJ, ed) The Risk Assessment of Environmental Hazards. A Textbook of Case Studies. New York: John Wiley and Sons. 1989.

  57. Evans RG, Webb KB, Knutsen AP, Roodman ST, Roberts DW, Bagby JR, Garrett WA, Andrews JS. A medical follow-up of the health effects of long-term exposure to 2,3,7,8-tetrachlorodibenzo-p-dioxin. Arch Envir Hlth 43: 273-278.

  58. Webb KB, Evans RG, Knutsen AP, Roodman ST, Roberts DW, Schramm WA, Gibson BB, Andrews JS, Needham LL, Patterson DG. Medical evaluation of subjects with known body levels of 2,3,7,8-tetrachlorodibenzo-p-dioxin. J Tox Env Hlth 28: 183-193. 1989.

  59. Kimbrough RD, Falk H, Stehr P, Fries G. Health implications of 2,3,7,8-tetrachlorodibenzodioxin (TCDD) contamination of residential soil. J Tox Env Hlth 14: 47-93. 1984.

  60. La Goy PK. Estimated soil ingestion rates for use in risk assessment. Risk Analysis 7: 355-359. 1987.

  61. Agency for Toxic Substances and Disease Registry. Public Health Assessment Guidance Manual. Atlanta: Agency for Toxic Substances and Disease Registry, March 1992.

  62. Centers for Disease Control. Diabetes in the United States: A Strategy for Prevention. A Report to the Technical-Advisory Committee for Diabetes Translation and Community Control Programs. Centers for Disease Control (CDC), DHHS (PHS). May 1991.

  63. Bennett PH. Epidemiology of diabetes mellitus. in (Rifkin H, Porte D, eds) Ellenberg and Rifkin's Diabetes Mellitus. Theory and Practice. 4th Edition. New York: Elsevier. 1990.

  64. Macdonald JS, Steele G, Gunderson LL. Cancer of the stomach. in (Devita VT, Hellman S, Rosenberg SA, eds) Cancer Principles and Practice of Oncology. 3rd Edition., Vol. 1. Philadelphia: J.B. Lippincott Company. 1989.

  65. Minna JD, Pass H, Glatstein E, Ihde D. Cancer of the lung. in (Devita VT, Hellman S, Rosenberg SA, eds) Cancer Principles and Practice of Oncology. 3rd Edition., Vol. 1. Philadelphia: J.B. Lippincott Company. 1989.

  66. NLM. Hazardous Substance Database (HSDB) file on Toxicology Data Network (TOXNET). Bethesda, MD: National Library of Medicine (NLM). December 1991.

  67. Agency for Toxic Substances and Disease Registry. Toxicological Profile for 2,3,7,8 Tetrachloro-dibenzo-p-dioxin. Atlanta, GA: Agency for Toxic Substances and Disease Registry (ATSDR), DHHS (PHS) TP-88-23. June 1989.

  68. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Trichloroethylene. Atlanta, GA: Agency for Toxic Substances and Disease Registry (ATSDR), DHHS (PHS) TP-88-24. October 1989.

  69. Scheufler E, Rozman K. Industrial and environmental chemicals. in (Rozman K, Hanninen O, eds) Gastrointestinal Toxicology. Amsterdam: Elsevier. 1986.

  70. Gordon T, Amdur MO. Toxic responses of the reproductive system. in (Amdur MO, J Doull, and CD Klaassen, eds) Casarett and Doull's Toxicology. The Basic Science of Poisons. Fourth Edition. New York: Pergamon Press. 1991.

  71. U.S. Environmental Protection Agency. Memorandum. Bluefield investigations continued. December 10, 1993.

SELECTED BIBLIOGRAPHY

REFERENCES REVIEWED BUT NOT CITED

General

Resident. Letter to ATSDR concerning Bluefield area. April 16, 1986.

Resident. Letter to EPA concerning Bluefield area. March 31, 1987.

Resident. Letter to the Centers for Disease Control concerning Bluefield area. May 5, 1989.

Appalachian Power Company Glen Lyn Plant

Appalachian Power Company. Letter to ATSDR concerning PCB content of oils burned. May 22, 1990.

Bernard Neal Site

West Virginia Division of Water Resources. Preliminary Assessment. February 28, 1986.

Bluefield Area Roads, City Park, Playgrounds and high school track

Resident. Deposition concerning spraying oil on streets and alleys. July 29, 1987.

Joy Manufacturing (and Galliat) Site

Agency for Toxic Substances and Disease Registry. Memorandum to Charles Walters concerning site. January 29, 1986.

Agency for Toxic Substances and Disease Registry. Record of communication regarding the National Institute of Occupational Safety and Health and worker exposure assessments. April 8, 1986.

Agency for Toxic Substances and Disease Registry. Record of site visit. September 19, 1989.

American Water Works Company. Letter to EPA providing soil PCB data. June 17, 1986.

Bruck, Hartman & Esposito, Inc. Letter to EPA concerning site. March 7, 1990.

Bruck, Hartman & Esposito, Inc. Letter to Whom it May Concern regarding site. June 11, 1990.

Resident. Letter to Whom it May Concern about author's employment at Joy Manufacturing and illnesses. March 8, 1986.

Resident. Letter to EPA concerning site. April 16, 1986.

Resident. Letter to EPA concerning site cleanup. March 19, 1988.

Resident. Affidavit concerning waste oil at site. Undated.

DECON Environmental Services. Final Draft, Review of Remedial Work Activities and Verification Sampling. August 15, 1988.

Jackson, Kelly, and others. Letter to West Virginia Department of Natural Resources providing soil PCB data. January 9, 1986.

Joy Manufacturing Company. Letter to EPA concerning PCB contamination. October 25, 1985.

M. Pat Esposito. Affidavit concerning Joy Manufacturing Site. March 16, 1992.

National Institute of Occupational Safety and Health. Letter to Mr. Elwin Aliff concerning occupational health evaluation issues. January 7, 1987.

Remedial Corporation. Letter to EPA concerning PCB levels. August 7, 1987.

Remedial Corporation. Soil Removal Report. February 1988.

Remedial Corporation. Final report to EPA concerning cleanup. February 1988.

Remedial Corporation. Revised Decontamination Work Plan. July 18, 1988.

Sidney Gilreath. Letter concerning Bruck, Hartman, and Esposito conclusions. July 15, 1989.

Sunday Gazette-Mail. Two articles concerning reported waste handling, waste disposal, and worker and resident exposures. September 28, 1986.

Technical Testing. PCB data for soils beneath concrete. October 19, 1988.

U.S. Environmental Protection Agency. CERCLA 106 (a) Order concerning removal. February 20, 1986.

U.S. Environmental Protection Agency. Public Information Release concerning dioxin test results. June 19, 1986.

U.S. Environmental Protection Agency. Letter to Elwin Aliff concerning cleanup issues. March 1988.

U.S. Environmental Protection Agency. Letter to Mr. Elwin Aliff concerning cleanup issues. March 11, 1988.

U.S. Environmental Protection Agency. Letter to Mr. Elwin Aliff concerning cleanup issues. February 26, 1990.

U.S. Environmental Protection Agency. Letter to Mr. Elwin Aliff concerning cleanup issues. September 6, 1990.

Versar. Oversight Report. June 2, 1987.

Versar. Addendum to Oversight Report. March 1988.

Weston. Memorandum to EPA concerning PCB sampling. November 14, 1989.

West Virginia State Health Department. Memorandum concerning site. January 29, 1986.

Lin-Electric Site

Geological Consulting Services, Inc. Final Evaluation of Closure Plan on the Coopers Industries Building. May 1988.

Sam Neal Site

NUS Corporation. Field Trip Report. September 16, 1986

Weston. Site Assessment and Data. Undated.

Weston. Analytical Data and Options. Undated.

West Virginia Department of Natural Resources. Preliminary Assessment. February 23, 1988.

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