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1. ATSDR > Public Health Assessments & Consultations

PRELIMINARY PUBLIC HEALTH ASSESSMENT

FOOTE MINERAL COMPANY
FRAZER, CHESTER COUNTY, PENNSYLVANIA

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APPENDIX B. Tables

Table 1. Maximum Contaminant Levels in Source Area Borings (Sediment) (N)

CONTAMINANT	MAXIMUM CONC.	LOCATION	COMPARISON VALUE
	PPM		PPM	SOURCE
Lithium	4,390	Drum Wash Area*	NA
Arsenic	1,030	Wet Quarry	0.4	CREG
Chromium	3,490	Lepidolite Ponds	10(P)	RMEG
Antimony	816	Dry Quarry	0.8(P)	RMEG
Benzene	ND		24	CREG
Trichloroethene	ND		64	CREG
Tetrachloroethene	ND		0.036	CREG
Boron	229	Soil Boring #5	180(P)	RMEG

ND - Not Detected
*0-12 Inch Soil Sample
RMEG - Reference Dose Media Evaluation Guide
CREG - Cancer Risk Evaluation Guide
NA - Not Available
P - Pica Child

Table 2. Contaminant Concentrations in On-Site Groundwater (N)

*Assumed total chromium rather than hexavalent chromium.
**1987 U.S.G.S. report - may not be site related.

C - Child
NA - Not Available
CREG - Cancer Risk Evaluation Guide
RMEG - Reference Dose Media Evaluation Guide
1 - PSWC Chester Valley Well (Figures 2 and 5). May not be site related.

Table 4. Completed Exposure Pathways

APPENDIX C - Attachment

Response to Comments on Foote Mineral site
Public Health Assessment

The following comments were received by PADOH in response to the public comment period for the Foote Mineral site Public Health Assessment. The list of comments does not include editorial comments concerning word spellings, sentence syntax, etc. It also does not include comments on the accuracy of stated facts. If the accuracy of a statement in the report was questioned, the statement was verified and corrected as necessary. Comments which requested that information be added to the document without providing documented sources of reference are not addressed here. The following list of comments below were paraphrased by PADOH for brevity or clarity. If the same comments were received from more than one source, only one comment and response is listed. Revisions have been made in this document; therefore, page numbers that are referenced may be different from the current page numbers.

Comment (General):	Because PADOH did not have access to make use of all available information, both the degree of exposure to and the toxicity of the contaminants of concern at the site are not well defined, resulting in an inaccurate assessment and causing the level of risk to be overstated.
Response:	PADOH accessed a variety of toxicologic data bases to determine the potential health effects that may be associated with exposure to chemicals. PADOH has made some revision in the report to show that the level of past exposure was high compared to the current level. PADOH and ATSDR believe that the level of risk is not overstated. The mission of ATSDR and PADOH is to protect the public health.
Comment (General):	These "hazardous chemicals" (lithium and boron) are naturally occurring elements that are widespread in the environment and have been used in applications that involve ingestion or dermal contact.
Response:	The fact that these chemicals are naturally occurring does not necessarily mean they are not toxic. There are several naturally occurring chemicals which are highly toxic (e.g., arsenic, cadmium, radon). Also, the fact that a chemical is used therapeutically, does not mean it is not toxic.
Comment (General):	The unfortunate characterization of the site as a "public health hazard" has led ATSDR's Health Activities Recommendation Panel (HARP) to unnecessarily call for a disease and prevalence study.
Response:	Following a careful review of the data and information pertaining to the site, HARP determined that a disease and symptom prevalence study for people exposed to the contaminants is indicated. The ATSDR Division responsible for conducting such activities has not yet determined if such a study is feasible.
Comment (General):	The conclusion reached independently by four experts was that subtherapeutic levels of lithium presented no risk of adverse health effects.
Response:	It is the opinion of ATSDR and PADOH that a chronic subtherapeutic level of exposure may cause adverse health effects, especially in children and pregnant women. Also, people who are on certain medications may be impacted by lithium exposure. It is known that several groups of drugs interact with lithium, causing increased levels of lithium in the serum. These include diuretics (e.g., hydrodiuril); non-steroidal anti-inflammatory agents (e.g., Motrin); calcium channel blocking agents (e.g., calan) and others. People need to be aware of that in order to discuss exposure with their health care providers.
Comment (General):	The PHA uses numbers and language in a manner that creates a sense of alarm about the site. For instance, contaminants are expressed in micrograms per weight or volume (ppb), while the numbers that might be used to determine safe levels such as therapeutic dosage are expressed in milligram based units. Also, the repeated use of maximum concentrations found on the site, without statistical qualification....
Response:	PADOH and ATSDR have reported the numbers in the same units as reported in the source materials. The report is not written to alarm the people about the site. It is good public health practice to evaluate maximum concentrations for any potential adverse health effects. Therefore, statistical qualification is not an important factor.
Comment:	(1st page of Summary, paragraph 2) In the first sentence, insert "may" in front of "migrate." There is currently only one piece of data that suggests the possibility that volatile compounds are migrating westward.
Response:	PADOH disagrees that the PHA should be changed. The existing geological and monitoring well evidence is sufficient to demonstrate westward migration of VOCs. The monitoring well expansion recommended by PADOH will confirm the status of groundwater west of the site.
Comment:	(1st page of Summary, paragraph 4) CFM takes exception to the conclusion (Summary, para 4, and Conclusions, para 2) that exposures to hazardous chemicals have occurred.... While it is likely that some historical exposure may have occurred, this implies that some local residents are presently or will be consuming groundwater at concentrations of lithium and boron comparable to the maximum concentrations found in off-site groundwater.... As documented previously, maximum exposure concentrations for lithium and boron are about 600 and 200 µg/L, respectively. Thus, there is no current route of human exposure to lithium or boron at levels thought by even the most conservative to produce health effects.
Response:	Revision has been made in the report to reflect past exposure to high levels of lithium and boron through use of contaminated off-site groundwater (private well) that may result in adverse health effects. The current levels of exposure to both lithium and boron through the public water supply and through private wells are not likely to cause adverse health effects. However, the ingestion of maximum levels of lithium presently in the public water supply by children would exceed EPA's provisional RfD of 20 µg/kg/day. Because of the dilution of the water, those levels are not in water that is distributed to the people.
Comment:	(Page 6, paragraph 1) CFM strongly disagrees with the statement, presented as fact, that drums of PCB transformer oils were placed in the wet quarry....
Response:	This claim was made by a former employee and will be further investigated. We will modify or eliminate it from the PHA as necessary for an accurate report.
Comment:	(Page 8 and 9) It is more appropriate that an answer to public health concerns be provided here, instead of elsewhere (pp 18-19 of Public Comment Release) in the PHA.
Response:	ATSDR guidelines require the format used in the PHA.
Comment:	(Page 10, paragraph 2) It is not clear which Weston reports were used. They should be cited here and elsewhere and included in the References section. Add "surface" in front of "soil" in 4th sentence.
Response:	Weston reports are now cited in the report. "Surface" in front of "soil" is not added because the samples do not meet ATSDR's surface soil definition of 0-3" depth.
Comment:	(Page 13, paragraph 2) This paragraph should be moved to the Recommendations section.
Response:	The Recommendations section has been clarified and does reflect the recommendations. However, the data gaps that result in such recommendations are pointed out in other sections of the document.
Comment:	(Page 15, paragraph 1 and 2) a). On page 10 of the PHA, all subsurface soils and quarry fill were classified as "sediments." Since only soil samples (0-12 inches) contained maximum concentrations of contaminants, it is unclear why these soils and fill were called sediments. b). On page 10, the statement was made "in general, sediments (or materials at greater than one foot of depth) contained 2 or 3 orders of magnitude higher concentration than surface soil samples." Therefore, there should be no exposure to workers via inhalation.
Response:	a). The word "sediment" is used because that is the term used in Reference F. b). All surface (and near surface) contamination cannot be assumed to be sufficiently deep so as to prevent exposure through airborne dust. We have modified the report to indicate only the possibility of such exposure.
Comment:	(Page 16, paragraph 4) It is suggested that a sentence be added converting medical dosage of lithium to an equivalent concentration in drinking water, as well as a reference that subtherapeutic levels of lithium produce no adverse effects.
Response:	The report now reflects therapeutic dose of lithium to an equivalent concentration in water. However, PADOH and ATSDR will not make a statement that subtherapeutic levels of lithium produce no adverse effects. We do not have sufficient evidence to make that statement.
Comment:	(Page 16, paragraph 4) The RfD for boron is not being exceeded. Last sentence: Even if water with a concentration of 20,000 µg/L was consumed (and it is not), ingestion would produce a boron dose less than 1 mg/kg/day in adults or children. This dose is one or two orders of magnitude less than the doses reported in the studies of adverse effects.
Response:	It is true that the RfD for boron has not been exceeded for individuals who use water from the public water supply system, and the PHA does not insinuate that to be the case. However, the RfD for boron was exceeded by several fold for people who might have used private well water containing the maximum concentration of 20,000 ppb. EPA's RfD for boron is 90 µg/kg/day. A 70 kg adult, drinking 2 liters/day at this concentration (20,000 ppb) would ingest 571 µg/kg/day of boron, about 6 times the RfD. A 10 kg child, drinking 1 liter/day at this concentration would ingest 2,000 µg/kg/day of boron or about 22 times the RfD. This is an unacceptable level of exposure. Therefore, PADOH and ATSDR will not change the statement that was made in the report that adverse health effects are possible as a result of those particular exposures.
Comment:	(Page 17, paragraph 2) Arsenic was not detected in any of the off-site wells sampled by NUS. The statement exposure to arsenic... has occurred is not factually supported.
Response:	Based on the 1987 U.S.G.S. report, arsenic was detected in the off-site water supply wells. However, the arsenic may or may not be site related. The table has been modified to reflect that.
Comment:	(Page 17, paragraph 3 and 4) While the maximum concentrations of benzene, PCE, and TCE found in on-site wells were correctly cited, the PHA did not explain that these maximum values came from 2 of 29 wells (MW 18 and 22) and that only about 9 of 29 on-site wells exceeded any drinking water standards for VOCs. On-site contamination by VOCs is relatively limited and there is no evidence of off-site migration at any level with the possible exception of MW 23.... Thus, CFM takes exception to the fourth paragraph (page 17) where it is implied that people have been or will be exposed to VOCs originating at the site. Further, it has been at least 20 years since the solvent pit was utilized so that future exposure at high levels is improbable.
Response:	PADOH considers the contamination of the nine on-site monitoring wells to be important, particularly since the maximum contaminant levels are up to 1,000 times the comparison values used to select contaminants of concern. The reason there is no evidence (or little evidence) of off-site migration, to the west, is that there are no wells in that area to verify or dispute migration. The report has neither implied that people have been exposed to VOCs nor will be exposed to VOCs originating at the site. The fact that the solvent pit was used 20 years ago does not mean that future exposure to VOCs is improbable.
Comment:	(Page 21, "Cease/Reduce Exposure Recommendations") Items 1 and 2 have already been accomplished.
Response:	PADOH does not consider the site restricted unless a suitable barrier (fence) is installed. The large, unfenced western part of the property cannot be adequately secured at all times by a guard whose headquarters is at the eastern end of the property. We have modified the second recommendation.
Comment:	(Summary, paragraph 5) What is the distinction, if any, between a "health activity" and "health action"?
Response:	There is no essential difference in the terms.
Comment:	(Page 7, Section C, paragraph 2) On what basis was the discussion of hydrogeology related to the Foote Mineral site extended to include the area north of Philadelphia Memorial Park? Has PADOH reviewed hydrogeologic studies commissioned by PSWC and performed by Leggette, Brashhears and Graham in 1978 and 1992 and by USGS in 1983? What aquifer dewatering in the vicinity of the Foote Mineral site began to increase significantly in 1977? What evidence does PADOH have that wells "near the site" have been replaced by deeper wells since 1977? For the purpose of this report, discussion of land and resource use should have been confined to the area for which there is evidence of affects on or from the Foote Mineral site. Other unrelated speculative discussion is extraneous and irrelevant.
Response:	Basis for the hydrogeology discussion: The flow of groundwater from the site is important to understanding how contamination can leave the site and flow to areas, not only adjacent to, but sometimes far from the site. The site is in close proximity to other NPL sites that may also impact people's drinking water. The discussion is intended to clarify what is happening to the groundwater and what factors are affecting it. Review of studies: PADOH has reviewed all the documents cited by the Philadelphia Suburban Water Company. Aquifer dewatering: Data collected after 1990 indicate a lower water table than existed when the 1984 U.S.G.S. report (referenced in this document) was written. The data indicate a general lowering of water table elevations during the past decade along and near the Chester Valley, from Planebrook northward and eastward toward the quarries. This document has been revised to clarify this issue. U.S.G.S. plans to collect more data in fall 1994 to better evaluate the area water table elevation. Deeper wells: The reference to new and deeper water supply wells refers to the Hillbrook Circle area about one mile north of the site. Land and Resource Use: The discussions on land and natural resource use for the area around the site is appropriate and relevant. No changes are felt warranted.
Comment:	(Page 9, last paragraph) What is the evidence that the petroleum pipeline carries No. 6 fuel? Most petroleum pipelines carry different products at different times....
Response:	The information about the pipeline contents was supplied by a company representative in a telephone conversation.
Comment:	(Page 10, last paragraph) If data exist in published documents confirming the presence of a groundwater divide beneath the site, such data should be referenced.
Response:	A recently published (1993) U.S.G.S. map indicates a groundwater divide through the site. The 1984 U.S.G.S. report previously referenced indicated a groundwater divide just west of the Foote Mineral site.
Comment:	(Page 16, paragraph 1) From what source was the value of 13,000 ppb for lithium obtained, etc.?
Response:	The value was obtained from the 1987 U.S.G.S. report referenced in the public health assessment.
Comment:	(Page 16, paragraph 2) a) EPA's recommended "action level" for boron in drinking water of 630 µg/L corresponding to the oral RfD of 90 µg/kg/day should be given in the report. b) On what data were EPA's risk assessment for boron based? c) Is this assessment challenged elsewhere? d) Has it been revised, withdrawn, or elaborated upon? e) What evidence does PADOH have that the well reporting 20,000 ppb boron is used for drinking? A 1990 survey of 42 wells in the area reported the highest boron level at 333 ppb.
Response:	a) To protect the public health it is appropriate to use the Reference Dose (RfD), which is currently as quoted. The RfD is an estimate of the daily human exposure during a lifetime to a potential hazard that is likely to be without risk of harmful effects. b) EPA used the data obtained from the study where dogs were fed with borax and boric acid in the diet for 2 years. The NOEL was established at 350 ppm of boron equivalents (8.8 mg/kg/day). c) We are not aware of this assessment's being challenged. d) As of October 7, 1993, the RfD still remains the same. e) This value was detected in 1985 from a residential well. Whether or not the well is used "today" is not the issue; furthermore, the PHA makes no such claim. We assume residential wells are (or were) used for drinking and other domestic purposes unless there is documented evidence that such use never occurred. Even if public water became available and well use ceased in the 1980s, there is still a time interval of about 30 years during which some area residents could have been exposed to hazardous chemicals through private well use.
Comment:	(Page 21, last paragraph) a) What precisely is meant by "substance specific technical health consultations are needed for lithium and boron"? b) Who would conduct these consultations and with whom? c) About what possible drug interactions should local health professionals be informed? d) What levels of boron and lithium exposure should local health professionals and the public be told are occurring relative to the Foote Mineral site? e) How does PADOH propose that this information be disseminated? f) Hasn't media coverage of "worst-case" levels and "interim" risk assessments and "guidance levels" over the past four years done enough to inform the public?
Response:	a) ATSDR's Health Activities Recommendation Panel determined that substance-specific research is indicated for this site. This research will be done by ATSDR. The recommendation is one often made when little information is available on substances released into the environment. Most information that is available for lithium involves its use as a medication for a very specific illness. Little information is available about lithium exposure to a healthy population at the levels found at the site. One function of ATSDR is to identify areas where little information is available on toxic substances released to the environment and to provide a mechanism to gather that information when possible. b) The research may involve extensive literature reviews or research that may be developed by ATSDR. ATSDR will determine who will be contacted for information, depending on what type of information is needed. c) The types of drugs that interact with lithium are described in this public health assessment. The information provided to health care professionals would likely elaborate on those interactions. d) The levels of past and current exposure are described in this document. That is the type of information that will be provided to the community and to health care professionals. e) PADOH and ATSDR plan to conduct public availability sessions and, possibly, distribute information or conduct meetings with health care providers. The details on the best way to provide information for this site have not yet been determined. f) Media coverage certainly helps get information to the community. "Interim" risk assessments may not be as readily available to everyone. Neither mechanism provides a means for the people to ask about specific concerns one may have about his or her exposure, and the information available may not be well understood by those who read it. One-on-one public availability sessions will allow individuals to have their specific concerns addressed privately and in less technical terms than most documents can provide.
Comment:	Why was boron not tested for?
Response:	Foote Mineral did test for boron in Phase III sampling, but PADOH did not have the data. We have acquired the data during the comment period and have made appropriate changes in the PHA.
Comment:	Will additional wells be drilled west of the site as recommended?
Response:	PADOH hopes the recommendation will be followed; however, PADOH does not have the authority to force wells to be drilled. PADER or EPA must direct such drilling to be performed should Foote Mineral not agree to do so voluntarily.
Comment:	Can the toluene and xylene be linked to the petroleum pipeline?
Response:	Additional monitoring wells and further groundwater sampling will probably be necessary to say, with a reasonable degree of certainty, that toluene and xylene have come from the pipeline.
Comment:	Should health problems be expected from the public water supply if boron, lithium, and chromium are not removed?
Response:	Considering the dilution that takes place in the PSWC system, the levels of these metals at the tap should not pose a serious health risk. No adverse health effects have been reported in people exposed to those levels over a short period of time. However, long-term, low-level exposures have not been studied. For that reason, further research has been recommended in this document.
Comment:	Can any of the contaminants be found in any of the agricultural products being harvested in the area?
Response:	Yes, both boron and lithium are naturally occurring and are found in plant tissues.
Comment:	What steps will be taken to notify the public of potential exposure?
Response:	Public health education will be conducted by ATSDR and PADOH for local residents.
Comment:	The public water supply contains the metals of concern, etc. How can the supply be safe?
Response:	This comment has been previously addressed. The levels of boron and lithium in the public tap water are not likely to cause adverse health effects. The rest of the comments regarding the public water supply have been previously addressed.
Comment:	Can those drums of PCBs be removed from the quarry?
Response:	The statement about PCBs being placed in the quarry is difficult to verify. If drums are present they may have already leaked. The reference to drums in the body of the PHA has been modified.
Comment:	Can't private wells west of the site be sampled to confirm westward migration of contaminants?
Response:	The wells referenced are not properly located to provide the necessary information.
Comment:	Shouldn't the gathering of pipeline data be a separate study?
Response:	The pipeline information should not be difficult to obtain. Whether or not a "study" is needed will be determined by EPA or PADER.
Comment:	Obtain original maps and copy them for use in the report.
Response:	PADOH has not been able to obtain original maps and figures for reports. The process of copying the PHAs results in poorer quality print with each generation. We have changed two of the figures slightly and tried to make them more readable for future documents.

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