| Pathway
|
Exposure Pathway Elements
|
Time |
| Source
|
Environment
|
Point of
|
Route
|
Exposure
|
| Sediment |
Monarch |
sediment |
Southern &
Northern
drainage
pathways |
ingestion,
inhalation,
dermal |
children |
past,
present,
future |
| Soil |
Monarch |
soil |
On-site,
residences
near plant |
ingestion,
inhalation,
dermal |
workers,
adults,
children |
past,
present,
future |
| Ambient Air |
Monarch |
air |
On-site,
residences
near plant |
inhalation |
workers,
adults,
children |
past |
The following comments were offered by Walston, Stabler, Wells, Anderson & Bains on behalf of Monarch Tile, Inc.:
- Cover sheets; P. iii; P. 1, 1st ¶, 1st line; P. 2, Part A, 1st ¶; P. 15, 3rd ¶; and P. 16, last ¶:
substitute "Rickwood Road/Cox Creek Site: for "Monarch Tile, Inc." where the name of
the CERCLA site which is the subject of the proposed NPL listing is intended. Where the
plant facility is meant, refer specifically to it. Otherwise delete all references to "Monarch
Tile, Inc." (See text of letter below re name change.)
Response: At this time, EPA has not decided on a new name for this site. ATSDR will
track this site by the name of Monarch Tile, Inc.; therefore, we retain the use of "Monarch
Tile, Inc." for this site.
- P. 1, ¶1, 5th line: delete "lead, barium and cadmium." See affidavit of Henry Stamper,
attached as Exhibit 2 to the Comments submitted on July 9, 1993 to the Environmental
Protection Agency Office of Emergency and Remedial Response (hereafter "Comments").
Mr. Stamper stated the "the facility did not use barium, cadmium or lead as a colorant."
An accurate statement would be: "Former operations included the use of glaze materials
containing compounds of zinc, lead, and barium." As Mr. Stamper reported, to his
knowledge the facility did not use cadmium-based compounds in its processes.
Response: As suggested, the statement was changed to read, "Former operations included
the use of glaze materials containing compounds of zinc, lead, and barium." Regardless of
the origin of the compound, cadmium is an environmental contaminant of concern both on
and off site and as such, was evaluated in this report.
- P. 1, ¶1, 8th line: replace the first "1980" with 1976. In 1976, all discharge from the
settling basins was routed to the city sewer pursuant to a State Indirect Discharge permit
issued by the Alabama Department of Environmental Management.
Response: The suggested change was made in the document.
- P. 1, ¶1, 8th line, last sentence: replace "1980" with "1979." See Affidavit of Henry
Stamper, Comments, Exhibit 2. After 1979, use of barium carbonate was discontinued.
After 1979, use of lead compounds stopped.
Response: The suggested change was made in the document.
- P. 2, part A, 3rd ¶;, last line: replace "1989" with "1988."
Response: The suggested change was made in the document.
- P. 2, Part A, last ¶, 6th line: replace "eastern drainage ditch" with "east drainage channel"
to be consistent with Figure 3.
Response: The suggested change was made throughout the document.
- P. 3, Part B, 3rd bullet, 1st line: insert after "ditch," "which was dry and overgrown at the
time of the visit."
Response: The inspection of the area outside the facility property behind Plant 1 was not
sufficiently detailed to justify a determination that the ditch was "dry and overgrown"
along its entire length. Therefore, this change was not made in the document.
- P. 3, Part B, 3rd bullet, 5th line: add "or the creek" to the end of the sentence.
Response: The item denoted by the 3rd bullet refers only to the ditch, not the creek;
therefore, this change was not made in the document.
- P. 4, last line, and P. 5, 1st line: delete "either southwest or northwest" and insert
"southwest." See E&E, p. 2-7 (6).
Response: The suggested change was made in the document.
- P. 5, first full ¶, 1st line: replace "drainage ditch" with "facility."
Response: The suggested change was made in the document.
- P. 5, first full ¶, 4th line: insert "designated as" before "suitable."
Response: The suggested change was made in the document.
- Pp. 6-9, Environmental Contamination and Other Hazards (this comment applies to this
entire section with respect to contaminants of concern, and particularly to the listing of
on-site and off-site contaminants of concern on P. 6). Based on background
concentrations reported in the Background Sampling Analysis Report by ENSR
Consulting and Engineering, August 1994, submitted to EPA Region IV, contaminants of
concern at the site should be limited to barium, lead, nickel and zinc. Based on the Hazard
Ranking System Guidance Manual, any contaminant within three times background
concentration would not be considered as a release. Section 5.1, p. 58. Since cadmium
was never used at the site and since cadmium concentrations measured at the site are
within three times established background, Monarch believes it should not be listed as a
contaminant of concern. Other metals (except lead, nickel, barium, and zinc) were within
background concentrations reported at the site. See Background Sampling Analysis
Report, Tables 6-1 and 6-2. A copy of this report is included.
Response: ATSDR's protocol for PHAs requires evaluation of all contaminants of concern
at a site by comparing them to established comparison values. All available environmental
data are to be included. Any substances present at concentrations above the comparison
values are classified as contaminants of concern.
- P. 8: add available information on "Offsite Surface Water," as follows:
"As reported in ENSR's August 1994 report submitted to EPA, Stormwater Runoff
Sampling Report, metals analyses conducted on runoff samples collected from offsite
ditches during a rain event indicate that metals did not exceed MCLs, with the exception
of two samples which were barely above the MCLs. ENSR conducted stormwater runoff
sampling in both the north and south ditches on May 26, 1994, during a significant rain
event. Samples were analyzed for arsenic, barium, cadmium, chromium, lead, nickel and
zinc. All tested parameters in the north ditch were below drinking water MCLs, with the
exception of one sample which tested at 10 ppb lead (4 ppb above the MCL). That
sample, 5/26-W-1, was collected from the north ditch where it discharges into Cox Creek,
and may reflect other potential contaminant sources. All tested parameters in the south
ditch were below MCLs with the exception of the lead concentration in sample 5/26-W-3,
which was only 2 ppb over the MCL."
A copy of ENSR's August 1994 report is included.
Response: The above information does not substantially change the findings or
conclusions of the document. It reinforces the information reported in Eliminated
Pathways, Public Water Supply and Biota Pathways, p 11. However, the finding of lead
in the surface water runoff strengthens the conclusion that the sediment pathway is a
potential exposure pathway in that lead is migrating off site.
- P. 8, Onsite Groundwater: E&E installed five groundwater monitoring wells in 1987.
Groundwater analysis of samples from the wells in 1987 indicated that metals
concentrations were below MCLs. (6)
Response: Comment noted.
- P. 9, Sediment, ¶ 1: Monarch contends that contaminants of concern should be limited to
barium, lead and zinc on the south ditch, and to barium, lead, nickel and zinc on the north
ditch sediments. Refer to the Background Sampling Analysis Report. Cadmium should
not be included, as discussed above (item 12).
Response: See response to Comment 12.
- P. 11, Biota Pathway: Monarch concurs with the conclusion that sediments are highly
unlikely to migrate in sufficient quantity to pose a health risk, and concurs that sediment
concentrations are unlikely to pose any health threat. ADPH could cite as supporting data
ENSR's recent study of watershed dilution factors, which supports ADPH's conclusion
concerning the migration of sediments from the ditches to the respective creeks. ENSR
calculates that flow in the north ditch is diluted by a factor of over 100 when it reaches
Cox Creek (ratio of north ditch to Cox Creek is 0.009, or 1 to 111.1); similarly, flow in
the south ditch is diluted by a factor of almost seven (ratio of south ditch to Sweetwater
Creek is 0.147, or 1 to 6.8). Engineering Evaluation and Cost Analysis Work Plan,
Appendix A, July 1994, ENSR Consulting and Engineering. A copy of Appendix A is included.
Response: See response to Comment 12.
- P. 12, 1st sentence: Monarch objects to this statement. Substitute: "The monitoring wells
around the settling basins indicate no leaching of the material from the settling basins into
adjacent groundwater." Analytical results of groundwater samples obtained from
upgradient wells were the same or higher than results of downgradient wells in all
sampling events. Therefore, there is no basis to indicate any leaching of material from the
settling basins into groundwater. Furthermore, the electromagnetic conductivity study
conducted by E&E in 1987 indicated there was no leaching of materials from the settling
basins. (6)
Response: The sentence has been changed to read, "The monitoring wells around the
settlement basins indicate very little if any leaching of the material into the adjacent
groundwater."
- P. 12, Section A: The Toxicological Evaluation should only address contaminants of
concern, consistent with item 12 above, which would limit the metals to barium, nickel,
lead and zinc.
Response: See response to Comment 12.
- P. 12, Section A, 2nd ¶: Monarch contends the Comparison Values contained in Appendix
B to the Public Health Assessment are excessively conservative based on the chemical
structures and physical properties of the compounds used at the facility (fritted and
calcined metals). As indicated by the Comments submitted by Monarch on the proposed
NPL listing, metals were used at the site only in a calcined and/or fritted form. Metals in
such forms exhibit far lower bioavailability, and are therefore less toxic, than elemental
metals or metal oxides. Refer to Comments, Section F.1 and throughout, and Exhibit 1 to
the Comments (ENSR Consulting), Comment 15, Comment 18, Comment 21, and
references (including references in the Comments) cited therein. With respect to Minimal
Risk Levels, metals at the site are not found in the forms for which the MRLs were
established. Furthermore, the Comparison Values contained in Appendix B to the Public
Health Assessment are for the elemental forms of the metals listed.
Response: ATSDR's protocol requires the use of these comparison values.
- P. 15, 2nd ¶, 3rd line: In 1973, Monarch did not purchase the facility, but leased it.
Response: The suggested change was made in the document.
- P. 15, 2nd ¶, 4th line: Monarch ceased using such compounds in 1979.
Response: The suggested change was made in the document.
