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PUBLIC HEALTH ASSESSMENT

NATIONAL ELECTRIC COIL/COOPER INDUSTRIES
DAYHOIT, HARLAN COUNTY, KENTUCKY



FIGURES


Figure 1. General Location Map
of National Electric Coil



Figure 2. Areas of PCB
Concentrations Above 10 PPM



Figure 3. Areas of Total VOC
Concentrations Above 10 PPM



Figure 4. Approximate Location
of Areas with Pb and/or Cr Concentrations
in Soil Above Target Clean Up Levels



Figure 5. Potentiometric Surface Map,
of Shallow-Aquifer Monitoring Well



Figure 6. Bedrock Potentiometric
Surface Map Non-Pumping 12/1/89



Figure 7. Off Site Soil
Sampling Results



Figure 8. Approximate Location
of VOC Plume - July 1993



APPENDIX A - ENVIRONMENTAL CONTAMINATION TABLES

Explanation of Environmental Contamination Tables

Most of the on-site data contained in the environmental contaminant tables have been taken from the October 1991 Removal Action Report by Law Environmental (10). That report included previous assessments from other contractors: Lozier Architects and Engineers, Environmetrics, Environmental Technology Corporation, and International Technology Corporation. Some of the reports have been referenced separately, as indicated in the tables. Some of the 1989 data collected by Lozier Inc. was unusable because the sample identifications could not be deciphered. However, the site is considered to be fully characterized with respect to environmental contaminants because all maximum concentrations have been reported.

Table 1. ON-SITE SOILS (9, 10, 11)
ORGANIC COMPOUNDS

MARCH - AUGUST 1991:
RF=RIVERBANK FILL AREA, 0 - 18 ft
OF=OUTFALL 1 AREA, 0 - 6 ft
ED=EQUIPMENT DRUM & STORAGE AREA, 1 - 8 ft
FL=SOUTH FENCELINE AREA, 0 - 2 ft

CONTAMINANT AREA CONCENTRATION
RANGE
COMPARISON VALUE (CV) FOR INGESTION - PICA CHILD FREQ>CV
(>ND)


ppm ppm Source
Benzene N/A ND - 0.009 24 CREG 0/20*
Chloroform N/A ND - 0.002J 20 EMEG 0/45
Total 1,2-DCE
(dichloroethene)
N/A ND - 7.7 20 LTHA 0/184
Ethylbenzene N/A ND - 168 200 Rfd 0/47
Total PCBs
(Polychlorinated biphenyls)
RF
OF
ED
FL
ND - 610
ND - 49
ND - 9.6
ND - 58
0.09 CREG 57/117
11/18
1/65
9/22
1,1,2,2-
Tetrachloroethane
N/A ND - 0.05 3.5 CREG 0/45
Toluene N/A ND - 4.3 400 Rfd 0/47
TCE
(trichloroethene)
RF
OF
ED
FL
ND - 40**
ND - 480
ND - 19
ND - 9.8
None N/A (75/102)
(30/32)
(51/62)
(2/18)
Vinyl chloride N/A ND 0.04 EMEG 0/45
Different areas have been specified because of the variation in concentrations between areas and their accessibility to public use.

N/A = not applicable

ND = constituent analyzed for but not detected above the instrument detection limit.

J = an estimated value

* The values in the May 1991 data set were not included because of their presence in the blank (possible lab contamination).

** The maximum value for TCE reported in the 1989 Lozier Report is 15,000 ppm.



Table 2. ON-SITE SOIL (10)
INORGANIC COMPOUNDS*

JUNE - AUGUST 1991:

CONTAMINANT CONCENTRATION
RANGE
COMPARISON VALUE (CV) FOR INGESTION - PICA CHILD FREQ >CV

ppm ppm Source
Antimony ND 0.8 Rfd Not
known**
Arsenic ND - 5.6 0.6 Rfd At least
14/27**
Barium 19.8 - 150 140 Rfd 1/27
Beryllium 0.26 - 0.85 0.16 CREG 22/22
Cadmium ND - 2 0.4 EMEG 1/27
Chromium ND - 120 10 EMEG 8/29
Lead 5.3 - 2145 None --- N/A
Manganese 137 - 1260 200 Rfd 20/22
Nickel 5.9 - 220 40 EMEG 3/22
ND = constituent analyzed for but not detected above the instrument detection limit.

* Summary of data from four main areas: riverbank fill, outfall 1, equipment drum and storage, and southern fence line.

** The detection level exceeds the comparison value.



Table 3. ON-SITE SOIL GAS (11)
ORGANIC COMPOUNDS

SEPTEMBER - OCTOBER 1989

CONTAMINANT CONCENTRATION
RANGE
COMPARISON VALUE (CV) FOR INHALATION FREQ >CV
ppm ppm Source
trans 1,2-DCE
(dichloroethene)
ND - 16.5 none --- ---
TCE
(trichloroethene)
ND - 407 0.25 NIOSH TWA/100 13/29
Vinyl chloride ND 0.002 intermediate EMEG Unknown*
ND = constituent analyzed for but not detected above the instrument detection limit.

*The instrument detection limit was above the comparison value.



Table 4. ON-SITE GROUNDWATER, OVERBURDEN (9,10)
ORGANIC COMPOUNDS

JANUARY 1990 - MAY 1991:
BOREHOLES 0-5

CONTAMINANT CONCENTRATION
RANGE
COMPARISON VALUE (CV) FOR INGESTION - REFERENCE ADULT FREQ >CV

ppb ppb Source
Benzene ND - 19,000 5 MCL 4/11
Chloroform ND 5.74 CREG 0/11
cis 1,2 DCE
(dichloroethene)
Not specified 70 LTHA N/A
trans 1,2 DCE
(dichloroethene)
Not specified 100 LTHA N/A
Total 1,2 DCE
(dichloroethene)
ND - 3700 70 LTHA 4/11
Ethylbenzene ND - 3100 1000 Rfd 2/11
Total PCBs
(Polychlorinated biphenyls)
ND 0.004 CREG 0/11
1,1,2,2-Tetra-chloroethane ND - 2J 0.175 CREG 1/11
Toluene ND - 37,000 2000 Rfd 4/11
TCE
(trichloroethene)
ND - 17,000 5 MCL 10/11
Vinyl chloride ND - 77 0.2 EMEG 1/11
ND = constituent analyzed for but not detected above the instrument detection limit.

For evaluation purposes, on-site groundwater was divided into two separate units: wells in the overburden or shallow aquifer and wells in the confined bedrock aquifer.

Methylene chloride was not listed as a contaminant of concern because it was found in the blank(s) and could be attributed to laboratory contamination.



Table 5. ON-SITE GROUNDWATER, OVERBURDEN (9,10)
INORGANIC COMPOUNDS

JANUARY 1990 - APRIL 1991
BOREHOLES 0 - 5

CONTAMINANT CONCENTRATION
RANGE
COMPARISON VALUE (CV) FOR INGESTION FREQ >CV

ppm ppm Source
Antimony ND 0.004 Rfd 0/6
Arsenic ND - 0.004B* 0.003 Rfd N/A*
Barium 0.164 - 1.050 0.7 Rfd 3/6
Beryllium ND - 0.008 8.1 CREG 0/4**
Cadmium ND 0.002 EMEG 0/6
Chromium 0.055 - 0.622 0.05 Rfd 6/6
Lead 0.004 - 0.127 0.005 PMCL 6/6
Manganese 0.293 - 7.31 1.0 Rfd 5/6
Nickel 0.049 - 0.404 0.2 EMEG 2/6
ND = constituent analyzed for but not detected above the instrument detection limit.

* Arsenic was found in the blank (B) as well as in the samples and may have been due to laboratory contamination.

** Beryllium was detected in the blank run for two of the samples; therefore, they were not considered for inclusion.

Zinc concentrations did not exceed the comparison value of 3 ppm in this data set or August 1993 (12).

August 1993 concentrations were lower than those reported here for each metal. Therefore, there are no new maximums to report.



Table 6. ON-SITE GROUNDWATER, BEDROCK AQUIFER (9,10)
ORGANIC COMPOUNDS

MARCH 89 - JULY 1991:
MONITORING WELLS 0,2,10,11

CONTAMINANT CONCENTRATION
RANGE
COMPARISON VALUE (CV) FOR INGESTION - REFERENCE ADULT FREQ >CV

ppb ppb Source
Benzene ND 5 MCL 0/10
Chloroform ND - 20 5.74 CREG 1/6
cis 1,2-DCE
(dichloroethene)
87 70 LTHA 1/1
trans 1,2-DCE
(dichloroethene)
ND - 456 100 LTHA 3/4
Total 1,2-DCE
(dichloroethene)
ND - 3100 70 LTHA 3/6
Ethylbenzene ND 1000 Rfd 0/10
Total PCBs
(Polychlorinated biphenyls)
ND 0.004 CREG 0/4
1,1,2,2-Tetra-chloroethane ND 0.175 CREG 0/10
Toluene ND 2000 Rfd 0/10
TCE
(trichloroethene)
ND - 4800 5 MCL 6/10
Vinyl chloride ND - 103 10 EMEG 3/11
ND = constituent analyzed for but not detected above the instrument detection limit.

Only wells in use at the time of sampling have been included.

Methylene chloride was not listed as a contaminant of concern because it was found in the blank(s) and could be attributed to laboratory contamination.



Table 7. ON-SITE GROUNDWATER, BEDROCK AQUIFER (9,10)
INORGANIC COMPOUNDS

JANUARY 1990 - APRIL 1991
MONITORING WELLS 0,2,10,11

CONTAMINANT CONCENTRATION
RANGE
COMPARISON VALUE (CV) FOR INGESTION FREQ >CV

ppm ppm Source
Antimony ND 0.004 Rfd 0/4
Arsenic ND -0.045B* 0.003 Rfd N/A*
Barium 0.121 - 0.575 0.7 Rfd 0/4
Beryllium ND 0.008 CREG 0/4
Cadmium ND 0.005 EMEG 0/4
Chromium ND - 0.636 0.05 Rfd 1/4
Lead ND - 0.015 0.005 PMCL 1/3**
Manganese 0.028 - 0.187 1.0 Rfd 0/4
Nickel ND - 0.449 0.2 EMEG 1/4
ND = constituent analyzed for but not detected above the instrument detection limit.

* Arsenic was found in the blank as well as in the samples and may have been due to laboratory contamination.

** One of the samples had a blank that showed contamination; therefore, it was not considered for inclusion.

Zinc concentrations did not exceed the comparison value of 3 ppm in this data set or August 1993 (12).

August 1993 concentrations were lower than those reported here for each metal. Therefore, there are no new maximums to report.



Table 8. OFF-SITE SEDIMENT (12)
CUMBERLAND RIVER
Polychlorinated biphenyls (PCBs)

DECEMBER 1993*

CONTAMINANT CONCENTRATION
RANGE
YEAR COMPARISON VALUE (CV) FOR INGESTION - PICA CHILD FREQ >CV

ppm


ppm Source

Upstream of NEC Downstream
of NEC



Upstream of NEC Down-stream
of NEC
Total PCBs: Aroclors ND - 0.038J ND - 0.210J 1993 0.09 CREG 0/2 1/7
J = an estimated value

*Sediments were also sampled for PCBs in December 1989- Estimates of 0.16 ppm (sample CR-D1) and 0.054 ppm (CR-D2) were given for aroclor-1248 in the vicinity of the site.



Table 9. OFF-SITE SOIL GAS (11)
ORGANIC COMPOUNDS

SEPTEMBER - OCTOBER 1989

CONTAMINANT CONCENTRATION
RANGE
COMPARISON VALUE (CV) FOR INHALATION FREQ >CV

ppm ppm Source
trans 1,2-DCE
(dichloroethene)
ND none --- ---
TCE
(trichloroethene)
ND - 5.95 0.25 NIOSH TWA/100 3/85
Vinyl chloride ND 0.002 intermediate
EMEG
Unknown*
ND = constituent analyzed for but not detected above the instrument detection limit.

*The instrument detection limit was above the comparison value.



Table 10. OFF-SITE SOILS (11, 12)
ORGANIC COMPOUNDS

Mobile Home Park
Jan 1990, 0 to 4 feet
August 1993, 0 to 0.5 feet

CONTAMINANT DATE CONCENTRATION
RANGE
COMPARISON VALUE (CV) FOR INGESTION - PICA CHILD FREQ >CV


ppm ppm Source
PCBs-aroclors* 8/93 ND - 0.96 0.09 CREG 5/20
PCBs-aroclors 1254 and 1248 1/90 ND - 1.5 0.09 CREG 9/27
ND = constituent analyzed for but not detected above the instrument detection limit.

PCB = Polychlorinated biphenols

*The total PCBs (aroclors) maximum was 1.053 ppm.

The riverbank adjacent to NEC was considered on site (Tables 1 and 2).



Table 11. OFF-SITE SOIL (12)
INORGANIC COMPOUNDS

AUGUST 1993
SURFACE SOIL (0 to 0.5 feet)

CONTAMINANT CONCENTRATION
RANGE
COMPARISON VALUE (CV) FOR INGESTION - PICA CHILD FREQ >CV

ppm ppm Source
Antimony Not analyzed 0.8 Rfd N/A
Arsenic 1.8N - 4.5 0.6 Rfd Unknown
Barium 28.2 - 102 140 Rfd 0/20
Beryllium ND - 1.0 0.16 CREG At least 16/20
Cadmium 1.1 - 3.1 0.4 EMEG 20/20
Chromium 9 - 18.3 10 RMEG 19/20
Lead* 9.8 - 219N None --- 2/20 > 200 ppm
Manganese 195 - 854 200 Rfd 19/20
Nickel 9.6 - 27.1 40 EMEG 0/20
ND = constituent analyzed for but not detected above the instrument detection limit.

N = spiked sample recovery not within control limits.

* The detection level exceeds the comparison value.

** The metals concentrations are within natural soil composition levels with the exception of lead. Lead maximums are above local background soil and sediment concentrations (11.5 -13.9 ppm) (31).



Table 12. OFF-SITE GROUNDWATER (10)
PRIVATE WELLS - BEDROCK AQUIFER
ORGANIC COMPOUNDS

FEBRUARY 1989 - JAN 1990

CONTAMINANT CONCENTRATION
RANGE
COMPARISON VALUE (CV) FOR INGESTION - REFERENCE ADULT FREQ >CV

ppb ppb Source
Benzene ND 5 MCL 0/15
Chloroform ND 5.74 CREG 0/15
cis 1,2-DCE
(dichloroethene)
ND - 133 70 LTHA 2/100
trans 1,2-DCE
(dichloroethene)
Not Analyzed 100 LTHA N/A
Total 1,2-DCE
(dichloroethene)
ND - 39 70 LTHA 0/15
Ethylbenzene ND - 7JB 1000 Rfd 0/15
Polychlorinated
biphenyls (PCBs)
ND 0.004 CREG 0/2
1,1,2,2-Tetra-chloroethane ND - 120 0.175 CREG 2/15
Toluene ND 2000 Rfd 0/15
TCE
(trichloroethene)
ND - 20J 5 MCL 2/15
Vinyl chloride* ND - 350 0.2 EMEG 19/115
ND = constituent analyzed for but not detected above the instrument detection limit.

B = found in laboratory blank
J = an estimated value

Methylene chloride was not listed because of its presence in blanks (possible lab contamination).

Only those wells in use at the time of sampling were included. Most private wells are deep and lie in the confined aquifer.

* Sampling in July 1991 at the Yo-Yo market, about 1 mile southwest from NEC, found 63.9 ppb vinyl chloride. Two wells tested in the Fresh Meadows area showed non-detect in 1992.



Table 13. FISH TISSUE FILLET SAMPLES -COMPOSITES (12)
CUMBERLAND RIVER
Polychlorinated biphenyls (PCBs)- aroclor-1260

NOVEMBER & AUGUST 1993

CONTAMINANT CONCENTRATIONS FROM COMPOSITES COLLECTED AT TWO LOCATIONS

ppb
Fish: Upstream of NEC Downstream of NEC
Rock Bass 190, 200 140, 160
Golden redhorse ND, 740 440, 690
Channel catfish Not
measured
950
ND = not detected



APPENDIX B - PATHWAYS ANALYSES


TABLE 12. COMPLETED EXPOSURE PATHWAYS
PATHWAY NAME/ENVI-RONMENTAL MEDIA
EXPOSURE PATHWAY ELEMENTS
TIME
SOURCE POINT(S) OF EXPOSURE ROUTE OF EXPOSURE EXPOSED POPULATION
Groundwater Transformers,
Cleaning solvents
NEC,
Holiday Mobile Home Park (HMHP)/
Drive-in theater,
Dayhoit
Ingestion
Inhalation
Skin Contact
Residents, workers, and drive-in goers who drank water from wells within the plume of contamination or used it for bathing. Past
Surface water Drainage lines, surface runoff Cumberland River downstream of NEC (outfall 1).
Areas of HMHP receiving drainage from NEC.
Ingestion
Skin Contact
Swimmers
Children playing in drainage areas.
Past
Food Chain/
Fish
Outfalls, surface runoff, sediment Cumberland River upstream & downstream of NEC including site vicinity Ingestion Cumberland River fish eaters Past
Present
Future
Soil Waste in soil (transformers,
cleaning solvents)
NEC Yard
HMHP near NEC
Ingestion
Inhalation of dusts
Residents of HMHP, on-site trespassers, previous drive-in goers Past
Present
Future
Ambient Air Degreaser pit, Lead pot, burn-out oven, waste materials Inside NEC plant,
outside plant near burning and waste areas.
Inhalation Former workers Past
Waste
Material
Degreaser pit Inside plant Inhalation
Skin contact
Former workers Past


TABLE 13. POTENTIAL EXPOSURE PATHWAYS

PATHWAY NAME/
ENVIRONMENTAL MEDIA
EXPOSURE PATHWAY ELEMENTS
TIME
SOURCE POINT OF EXPOSURE ROUTE OF EXPOSURE EXPOSED POPULATION
Soil Gas/Soil Waste in soil, VOCs from shallow groundwater contamination. On site Inhalation Workers and
trespassers
during soil excavation.
Past
Off site Inhalation Children playing in trenches. Past
Present
Future
Sediment Waste in sediment, outfalls Cumberland River banks near NEC Ingestion Cumberland River users Past
Present
Future
Food Chain/ Vegetables Gardens in the area of NEC Off site in the HMHP and in flooded areas. Ingestion Residents eating vegetables Past
Present
Future
Ambient Air VOCs in waste,
Fuel oils,
air stripper
HMHP, residences north of the site Inhalation Residents near the site Past
Present
Future


TABLE 14 - ESTIMATED POPULATION FOR COMPLETED AND POTENTIAL EXPOSURE PATHWAYS

Exposed Populations and Potentially Exposed Populations Affected by a Completed or Potential Exposure Pathway* For:
Location Minimum No. of Persons Heavy Metals
ex. lead
Chlorinated
Solvents
ex. TCE
BTEX
Compounds
ex. benzene
PCBs
ex. Aroclors
Residents** of Dayhoit: on-site at NEC and off-site exposure in the HMHP &
Cumberland River areas.
350 Surface water,
Groundwater,
Soil

Sediment
Vegetables
Ambient Air

Surface water,
Groundwater,
Soil

Soil gas
Sediment
Ambient Air

Soil gas
Ambient Air

Surface water,
Groundwater,
Soil
Fish

Sediment
Vegetables
Ambient Air

Facility Workers** on-site
exposure
120 Waste materials,
Ambient air,
Groundwater
Waste
materials,
Ambient air,
Groundwater
Waste material Waste material,
Ambient air,
Groundwater

* potential exposure pathways are underlined

** residents who trespassed or workers who also lived near NEC may have a combination of exposures to on- and off-site contaminants.

APPENDIX C - HEALTH CONCERNS

Health Concerns Reported at the Public Availability Meeting

Cancer

liver
gynecologic (cervix, ovary)
musculoskeletal (bone, spine)
breast
hematologic (multiple myeloma, leukemia, Hodgkin's disease)
lung
gastrointestinal (bowel, esophagus, colon)
skin
throat
brain
prostate

Neurologic/Psychiatric Disorders

nervous problems
epilepsy
memory loss
mental stress
headaches
numbness in arms or hands
dizziness
Alzheimer's disease
blacking out
insomnia

Gastrointestinal Disorders

ulcers
gastrointestinal hemorrhaging
digestive problems
stomach problems
constipation
gallbladder problems
sores in mouth and throat
diarrhea
burping blood
cracking and splitting of tongue
nausea
stomach hernia
elevated liver enzymes
hepatitis
circulatory problems

Dermatologic (skin) Disorders

blisters on eyelids, in mouth, and elsewhere
skin rashes
"dead" spots on skin
cysts
eczema
scalp problems
knots
toenails will not grow
hair falling out
boils
plantar warts

Allergy and Immune System Disorders

persistent colds
allergies
immune system problems
enlarged glands

Reproductive Disorders

miscarriage
sterility
birth defects
premature birth

Cardiovascular Disorders

closed artery
heart irregularities
strokes
high cholesterol
arteriosclerosis
heart attack
blood pressure problems
swelling of legs
enlarged heart

Genital/Urinary Disorders

kidney problems, including infection
blood in urine
difficulty urinating
problems controlling bladder
kidney stones

Pulmonary Disorders

lung problems
lung spots
cavities in lungs
shortness of breath
asthma
bronchitis
pneumonia

Vision Disorders

blurred vision
loss of vision
eye problems

Musculoskeletal Disorders

arthritis
fusing of backbone
deteriorating backbone
skin drawing up
pain around ribs
muscle and joint pain

Endocrine Disorders

Graves' disease
thyroid problems
diabetes

Ear/Nose/Throat

earache
ear infection
sinus infection
precancerous throat polyps
nose bleeds

Developmental Disorders

child will not gain weight

Benign Breast Disorders

fibrocystic disease

Gynecologic Disorders

ovarian cysts
female hormone problems

Hematologic Disorders

blood disease requiring transfusions

Dental Disorders

chronic gum disease
teeth requiring being pulled

Miscellaneous

chronic fatigue
PCBs in blood
lead in blood
febrile seizures
surgeries


APPENDIX D - ADDITIONAL DOCUMENTS

Water Consumer Advisory
ATSDR Health Consultation- Groundwater, March 1989
ATSDR Health Consultation- Dioxins/Furans, May 1993

The following section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services
Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333


APPENDIX E - PUBLIC COMMENTS

RESPONSE TO COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD FOR
NATIONAL ELECTRIC COIL
PETITIONED PUBLIC HEALTH ASSESSMENT

The National Electric Coil Public Health Assessment (PHA) was available for public review and comment from December 14, 1992 through January 27, 1993. Copies of the PHA were sent to the Harlan County Library, a repository for the site. A final copy of the PHA will also be sent to the South East Community College Library in Cumberland, Kentucky. Comments were received from EPA, the Commonwealth of Kentucky (Department of Environmental Protection), Cooper Industries, a potentially responsible party, and two Harlan County residents.

Comments and responses on the PHA are summarized below. The comment letters can be requested from ATSDR through the Freedom of Information Act.

COMMENT: Verify off-site contamination levels by PCBs in soil.

RESPONSE: The PCBs levels reported in Table 10 for off-site soils (ND - 1.5 ppm) are correct and were samples taken near the fenceline of the mobile home park with NEC (Map from Lozier report, dated 1990, sheet number 3, reference 11).

COMMENT: References to PCBs in river sediments downstream of NEC at levels of 54 ppm to 720 ppm should be verified because commenters were not aware of data indicative of these levels.

RESPONSE: PCBs in river sediments were inaccurately reported in previous versions of the PHA. PCB concentrations in Cumberland River sediments in the December 1989 data were less than 0.2 ppm. Sampling in 1993 indicated total PCBs in river sediments downstream of NEC as: not detected through an estimate of 0.21 ppm (Reference 12). ATSDR addressed the incorrect PCB concentrations in a flier and discussion with the community when we returned to explain our health assessment in March 1993.

COMMENT: The Kentcuky Department of Environmental Protection measured PCB sediment in the river upstream of the NEC site at 0.028 ppm in 1989.

RESPONSE: Thank you for the information. We have used 1993 data which indicate the maximum upstream level to be 0.038 ppm.

COMMENT: The units are believed to be incorrect for on-site PCB contamination along the NEC and mobile home fence line and should be 0.029 and 0.100 ppm rather than 290 to 9100 ppm. Additionally, the presence of a drainage ditch that flows from the NEC site to the Mobile Home Park is questioned.

RESPONSE: The units are indeed incorrect, however, ATSDR believes that the correction should be 0.29 to 9.1 ppm (NUS sheet number 1, Lozier Inc. 1989, reference 11).

Our editors requested that we change the term swale so we used drainage ditch instead. However, since this term could be misleading (thought to be man-made), we will change it to a low lying area adjoining the two properties.

COMMENT: Please confirm the reference to tetrachloroethane in groundwater. The commenter believes it should be tetrachloroethene.

RESPONSE: The May 1991 Law Environmental Report (Table 4-2) indicates tetrachloroethane is correct. However, we have no longer emphasized it in the discussion since it is not a major contaminant.

COMMENT: Identify source of comparison values for beryllium and manganese.

RESPONSE: The sources have been identified in the environmental contamination tables. ATSDR's Cancer Risk Evaluation Guide (CREG) for 1x10-6 excess cancer risk for beryllium in soil is approximately 0.16 ppm. ATSDR's comparison value for manganese in soil based on EPA's reference dose is 200 ppm. According to information in the March 1994 Remedial Investigation Report (31), these comparison values are lower than background concentrations of these metals in the Dayhoit area. The health assessment was revised to acknowledge these concentrations as background levels. However, they have been retained for consideration of health implications.

COMMENT: Please confirm and verify the number of wells found to be contaminated. It would appear that only 13 wells were contaminated.

RESPONSE: ATSDR's original estimate of fifteen wells excluding the Mobile Home Park included two on-site wells. We have changed the number to 13 in the off-site contamination section.

COMMENT: Based on Cooper's data, wind direction has been found to be primarily northerly, rather than southerly (as stated in the public health assessment). Thus, the air quality in the mobile home park would not have been substantially affected.

RESPONSE: Substantial meteorological data was not provided to ATSDR until the draft Remedial Investigation Report, received in March 1994. ATSDR has updated the final release to reflect this information.

COMMENT: Community members reported the following health effects:

cancer, loss of kidney, fibrocystic disease, cysts, warts, hysterectomy.

RESPONSE: Cancer occurs in one in three people's lifetime. It is very difficult for scientists to determine who will get cancer. Further, if someone gets cancer, scientists and physicians typically cannot know the cause of the person's cancer. We do know, however, that some site-related chemicals are carcinogens. Please refer to the Toxicologic Evaluation section for a discussion of vinyl chloride; asbestos; 1,1,2,2-tetrachloroethane; PCB's; and trichloroethene, which are known or probable human carcinogens. Please refer to the Community Health Concerns Evaluation section for a discussion of cancer in the community.

Fibrocystic disease, warts, cysts, illnesses requiring a hysterectomy, and illnesses requiring the loss of a kidney are all health effects which could be due to a wide variety of underlying causes. In many cases, such as fibrocystic disease and endometriosis (an illness which often requires a hysterectomy), physicians do not know what causes the illness; none of the theories for these effects are based in environmental exposures. Warts are caused by viruses. Information about the underlying condition which required the hysterectomy or the kidney removal would enable us to discuss the possible role, if any, that contamination had in the development of the condition.

A series of comments pertain to particular exposure pathways commenters felt were not acknowledged in the public health assessment. These potential exposures would have occurred in the past. No new exposure pathways or additional exposed segments of the population were identified through these comments. The following 5 comments pertain to exposure pathways.

    COMMENT: There used to be a school downriver from NEC, and children drank the water from the pump right outside the school.

    RESPONSE: The commenter describes an additional route by which children were exposed to groundwater. Without information about contaminant levels, we cannot evaluate the potential health effects of that exposure. It is likely that exposures from that well would have been at similar levels as exposures at other wells in Dayhoit. Because that well is no longer used, we continue to consider exposure to groundwater a past concern.

    COMMENT: In the past, children used to play and collect coal frequently in the river. Baptisms were performed in the river, too.

    RESPONSE: We are aware that people were exposed to contaminants in the river, as discussed in the Completed Exposure Pathways section. We have included participants in baptism rituals in the discussion.

    COMMENT: There is a garden near the discharge pipe from NEC, and many people have worked in the garden and eaten vegetables grown in it. There also used to be a chicken farm in Dayhoit where people bought their eggs.

    RESPONSE: The vegetable garden is discussed in the Food Chain Pathway section of the Environmental Pathways section. With no information about contaminant levels in air during the operation of NEC, and no information about the feed supplied to the chickens, ATSDR cannot evaluate the likelihood of contaminated eggs.

    COMMENT: In the past, air discharges from the facility would be blown into Dayhoit, and that during rainy and foggy times the discharge would be kept right on top of the community.

    RESPONSE: Weather conditions such as inversions affect concentration and residence time of air-borne contaminants; however, as stated in the Environmental Contamination and Other Hazards section, the potential effect air contamination had on public health cannot be evaluated because of the lack of data collection during plant operations.

    COMMENT: Residents used to collect copper in the dump site behind NEC, and the dump site was a continuous smoldering pit.

    RESPONSE: The exposures those people would have sustained from the fumes are acknowledged in the Ambient Air Pathway. People also were exposed to whatever waste material they handled, although we have no information by which to evaluate the health impact of that exposure.

COMMENT: There was a drainage pipe from NEC downriver from the trailer park and therefore soil testing should extend beyond the trailer park.

RESPONSE: The authors were aware of this drainage pipe. The pipe discharged directly to the River and the downstream sediments were characterized. Additionally, further off-site soil testing was not recommended because even the Mobile Home Park contaminant concentrations were low as reported in the Off-site Contamination section.

COMMENT: Death statistics do not always accurately reflect cancer information; for example, if a person has cancer but died of heart failure, heart failure will be listed as the cause of death and cancer will not.

RESPONSE: The commenter is correct to point out that the death statistics do not always accurately reflect cancer information. According to the International Statistical Classification of Diseases and Related Health Problems, tenth revision, mortality is coded to the underlying cause, that is, to the disease or injury which initiated the train of morbid events leading directly to death. For example, the death of a person with cancer who dies in a traffic accident would not be listed as a cancer death statistic. However, if a person dies of heart failure and if cancer were the cause of the heart failure, then the person's death would be considered a cancer death statistic. The physician completing the death certificate determines the underlying cause.

Public health investigations can be designed to identify all people who have cancer (cancer incidence) rather than all people who died of cancer (cancer mortality).

COMMENT: Insufficient documentation is presented to determine if the risk assessments are performed according to standard procedures and calculations.

RESPONSE: ATSDR evaluated the health and environmental information according to standard procedures and calculations as described in the ATSDR Public Health Assessment Guidance Manual. Additional discussion describing how we estimate exposure doses and calculate increased cancer risks has been added to the Public Health Implications section.

COMMENT: How are ATSDR soil levels determined, and what are the chemical-specific soil action levels? Particularly, what about PCB levels?

RESPONSE: As described in the Environmental Contamination and Other Hazards section, ATSDR selects contaminants of concern by comparing the concentration of the contaminant with a comparison value for noncarcinogenic and carcinogenic endpoints. These comparison values are media-specific concentrations used to select environmental contaminants for further evaluation, and are not used as predictors of adverse health effects or for setting clean up or action levels. The EPA determines clean up and action levels. They have set the action level for PCBs at 10 ppm (12).

Non-carcinogenic comparison values (environmental media evaluation guides, EMEGs) are derived from minimal risk levels (MRLs) presented in the ATSDR Toxicological Profiles. An MRL is defined as an estimate of daily human exposure to a chemical that is likely to be without an appreciable risk of deleterious effects over a specified duration of exposure. If no MRL has been developed, the estimated exposure dose is then compared to a comparison value (environmental reference dose evaluation guide, EREG) derived from the EPA's reference dose. Carcinogenic comparison values (cancer risk evaluation guides, CREGs) are based on an excess cancer rate of one in a million persons and are calculated using a cancer slope factor developed by the EPA specifically for each cancer-causing chemical.

When evaluating soil exposures, ATSDR uses the assumptions stated in the Environmental Contamination and Other Hazards section. Using those assumptions and EPA's slope factor for PCBs, we derived a comparison value (CREG) of 0.09 ppm for PCBs.

COMMENT: Will air monitoring take place, even though it is not required by the Kentucky Division for Air Quality?

RESPONSE: Yes, due to the air stripping operation, air monitoring conducted by EPA or their contractors is necessary.

COMMENT: Sampling for chemicals of concern in wells should include trichloroethylene, vinyl chloride and polychlorinated biphenyls as well as 1,2-dichloroethene.

RESPONSE: By recommending that well sampling differentiate between cis- and trans-1,2-dichloroethene, we did not intend to imply that other chemicals need not be sampled for. We have altered the recommendation to eliminate the ambiguity.

COMMENT: Is the USEPA "Guidance Manual for Assessing Human Health Risks from Chemically Contaminated Fish and Shellfish" to be used in assessing the fish tissue data, or are the Food and Drug Administration action levels to be used?

RESPONSE: ATSDR recommends using the USEPA "Guidance Manual for Assessing Human Health Risks from Chemically Contaminated Fish and Shellfish". The EPA and FDA concur with this choice in situations such as the one presented here.

COMMENT: Although Giardia should not be discounted at the site, it is more likely that some other pathogenic bacteria would have caused health symptoms. Many amoeboid pathogens are quite common in Kentucky and may result in health problems in children that spend considerable time in the water.

RESPONSE: We have amended the recommendation to include these pathogens and suggested that this issue be taken up by local health officials and citizens who wish to pursue it.

COMMENT: Since many of the trailers in the Holiday Trailer Park appear to be 10-15 years old, formaldehyde or some other organic may have seeped into homes from trailer insulation. We recommend some of the trailers be monitored for possible contaminants unrelated to the National Electric Coil contamination and the contribution of these indoor air contaminants to health effects be assessed.

RESPONSE: The commenter's request is outside ATSDR's purview. After 10 to 15 years, formaldehyde would have already dispersed from these trailers. Formaldehyde can be a problem for hypersensitive individuals particularly in new trailer homes and cars. Individuals who may be hypersensitive can contact the local or state health departments to learn how to reduce exposure.

COMMENT: The proposed sampling of soil at the Holiday Mobile Home Park is at a screening level and provides insufficient information to perform a risk assessment.

RESPONSE: The off-site soil sampling completed by EPA (date) goes beyond a screening level and provides sufficient information to determine if residents are being exposed to contaminants at levels of health concern.

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