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PUBLIC HEALTH ASSESSMENT
REYNOLDS METALS COMPANY
TROUTDALE, MULTNOMAH COUNTY, OREGON

APPENDIX A

ENVIRONMENTAL CONTAMINATION

The tables in this section list the contaminants of concern. The contaminants are evaluated in the public health assessment to determine whether exposure to them is significant to public health. Contaminants of health concern are selected using the following information:

  1. concentrations of contaminants in environmental media, such as soil and water;
  2. quality of the samples, the laboratory analyses, and the sampling design;
  3. comparisons of the contaminant concentrations with background concentrations, if available;
  4. comparisons of the contaminant concentrations with comparison values; and
  5. community health concerns.

The inclusion of a contaminant in the list of contaminants of concern does not necessarily indicate that the contaminant will cause adverse health effects. Instead, this list indicates contaminants that will be evaluated further in this public health assessment to determine whether exposure to them is occurring and whether that exposure may be of significance to public health. Also, some substances may be included on the list of contaminants of concern which are not site-related. This may happen when a contaminant is naturally present at high concentrations, or when there is no information about the natural, or background, concentration.

COMPARISON VALUES

ATSDR uses comparison values--contaminant concentrations in specific media that are considered protective of public health--to select contaminants for further evaluation. ATSDR and other agencies have developed the comparison values to provide guidelines for estimating contaminant concentrations below which adverse health effects are not expected to occur. A standard daily ingestion rate and body weight are assumed in deriving these values. The following comparison values are used in this section:

    CREG   Cancer Risk Evaluation Guide: Derived by ATSDR from the EPA cancer slope factor. It represents a concentration in water, soil, or air at which excess cancer risk is not likely to exceed one case of cancer in a million persons exposed over a lifetime.
    EMEG   Environmental Media Evaluation Guide: Derived by ATSDR from ATSDR's minimal risk level. It is the concentration in water, soil, or air at which daily human exposure is unlikely to result in adverse noncancerous effects
    LTHA   Lifetime Health Advisory: Derived by EPA's Office of Water. It is a drinking water concentration at which adverse, noncancerous adverse health effects would not be expected.
    RMEG   Environmental Reference Dose Evaluation Guide: Derived by ATSDR from the EPA oral reference dose. It is the concentration in water or soil at which daily human exposure is unlikely to result in adverse noncancerous effects.

EMEGs and CREGs are the first choices for comparison values. In addition, any contaminant will be a contaminant of concern if it has no CREG but has been designated as a carcinogen or potential carcinogen by the National Toxicology Program in the Department of Health and Human Services, the EPA, or the International Agency for Research on Cancer. If a contaminant is not a carcinogen and has no EMEG, the RMEG will be the comparison value if it is available. If the medium is drinking water, the LTHA will be the comparison value if it is lower than the RMEG.

BACKGROUND CONCENTRATIONS

Table A1:    Background Concentrations in Soils, Sediments, and Deep Groundwater (PRC Environmental Management, 1993).

Contaminant Soils §
(mg/kg)
Sediments
(mg/kg)
Deep Groundwater*
(µg/L)
Aluminum 7,270 4,720 ND
Fluoride 33.8 99.9 0.18
PAHs ND 170 NA
Arsenic 1.3 0.8 ND
Mercury 0.08 NA NA
Chromium 10.3 9.3 NA
Nickel 9.6 7.6 NA
Thallium 0.4 0.18 NA
DDT 24 0.8 NA
DDD NA ND NA
DDE 18 ND NA

ND: not detected
NA: not available

§    Background soil sample was taken from an area to the east of the Troutdale airport.

‡    Background sediment samples are taken from a wetland to the west of the Troutdale airport, and from the Sandy River, 1½ mile upstream of the Reynolds site.

*    Background samples of deep groundwater were taken from a well located one mile south of the Reynolds site.

ON-SITE CONTAMINATION

Table A2: Contaminants of Concern in On-Site Soils (CH2M Hill, 1994, unless specified otherwise).

Contaminant Maximum Concentration
(mg/kg)
# detects/# samples in area Comparison Value
(mg/kg)
North Landfill
Aluminum [PRC, 1993] 11,500 2/2 none
Mercury [PRC, 1993] 0.17 1/2 none
PAHs >1,400 13/15 carcinogens
PCBs 28 9/13 0.09 (CREG)
South Potliner Area
Aluminum [PRC, 1993] 124,000 5/5 none
Arsenic [PRC, 1993] 27 5/5 0.4 (CREG)
Fluoride [PRC, 1993] 137,000 5/5 3000 (EMEG)
PAHs >10,000 18/30 carcinogens
PCBs 1.1 6/26 0.09 (CREG)
Antimony 31 8/17 20 (RMEG)
East Potliner Area
PCBs 0.43 1/8 0.09 (CREG)
Scrap Yard
Aluminum [PRC, 1993] 147,000 4/4 none
Arsenic [PRC, 1993] 28.4 4/4 0.5 (CREG)
Chromium [PRC, 1993] 964 4/4 300 (RMEG)
Mercury [PRC, 1993]
before remediation
after remediation

1780
32.1

not available

none
Nickel [PRC, 1993] 2,220 4/4 1,000 (RMEG)
Fluoride [PRC, 1993] 91,800 4/4 3,000 (RMEG)
PAHs >2,800 9/21 carcinogens
PCBs 16 7/15 0.09 (CREG)
Cryolite Ponds
Aluminum [PRC, 1993] 322,000 2/2 none
Arsenic 174 2/2 0.5 (CREG)
Fluoride 198,000 2/2 3000 (EMEG)
PAHs 61 5/9 carcinogens
South Wetlands
PAHs 19 2/6 carcinogens
PCBs 45 1/2 0.09 (CREG)
Mercury 0.33 1/5 none
Outfall Road
PAHs >500 1/1 carcinogens
Ditch South of BPA Sub-Station
Aluminum 14,000 1/1 none
Monitoring Well Bores
PAHs >110 9/12 carcinogens
PCBs 1.2 3/12 0.09 (CREG)
Aluminum 46,000 11/11 none

Table A3: Contaminants of Concern in On-Site Sediments.

Contaminant Maximum Concentration
(mg/kg)
# detects/# samples in area Comparison Value
(mg/kg)
South Ditch
Aluminum [PRC, 1993] 117,000 5/5 none
Arsenic [PRC, 1993] 64.8 5/5 0.5 (CREG)
Mercury [PRC, 1993] 0.4 5/5 none
Fluoride [PRC, 1993] 127,000 5/5 3000 (RMEG)
PAHs [PRC, 1993] 10,300 5/5 carcinogens
Wetlands
Aluminum [PRC, 1993] 30,300 6/6 none
Arsenic [PRC, 1993] 20.5 6/6 0.5 (CREG)
Mercury [PRC, 1993] 0.23 6/6 none
Fluoride [PRC, 1993] 17,500 6/6 3000 (EMEG)
PAHs [PRC, 1993] 6.6 6/6 carcinogens
DDT [PRC, 1993]
DDD [PRC, 1993]
DDE [PRC, 1993]
0.950
0.200
0.600
6/6 2 (CREG)
3 (CREG)
2 (CREG)
Company Lake
Aluminum [CH2M, 1994] 63,000 7/7 none
Arsenic [CH2M Hill, 1994] 50 7/7 10 (EMEG)
Mercury [CH2M, 1994] 2.2 7/7 none
Fluoride [PRC, 1993] 91,800 5/5 3000 (EMEG)
PAHs [CH2M Hill, 1994] 23,000 7/7 carcinogens
PCBs [CH2M Hill, 1994] 3.5 7/7 0.09 (CREG)
Thallium [CH2M, 1994] 7 5/7 none
Salmon Creek
Aluminum [CH2M, 1994] 17,000 3/3 none
PAHs [CH2M, 1994] 10.6 3/3 carcinogens
PCBs [CH2M, 1994] 0.23 1/4 0.09 (CREG)
East Lake
Aluminum [CH2M, 1994] 20,000 1/1 none
PAHs [CH2M, 1994] 7.4 1/1 carcinogens

Table A4: Contaminants of Concern in On-site Surface Water.

Contaminant Maximum Concentration
(µg/L)
# detects/# samples in area Comparison Value
(µg/L)
Company Lake
Aluminum 600 1/3 none
Fluoride 3000 3/3 500 (EMEG)
East Lake
Lead 4 1/1 none
Fluoride 700 1/1 500 (EMEG)
Salmon Creek
Aluminum 480 2/2 none
South Ditch
Aluminum 1,970 6/6 none
Arsenic 1.1 2/6 0.02 (CREG)
PAHs 17 3/6 carcinogens

Table A5: Contaminants of Concern in On-Site Groundwater (CH2M Hill, 1994, unless specified otherwise).

Contaminant Maximum Concentration
(µg/L)
# detects/# samples in area Comparison Value
(µg/L)
Shallow Groundwater - Monitoring Wells
Fluoride 570,000 11/17 500 (EMEG)
Cyanide 720 9/17 200 (RMEG)
1,1-Dichloroethane 0.260 1/5 carcinogen
1,4-Dichlorobenzene 0.130 1/5 carcinogen
PAHs 0.77 1/14 carcinogens
Aluminum, dissolved
Aluminum, total
65,000
380,000
3/4
14/17
none
Antimony, dissolved
Antimony, total
8
11
2/4
1/17
3 (LTHA)
Arsenic, dissolved
Arsenic, total
83
160
4/4
4/17
3 (EMEG)
Barium, dissolved
Barium, total
900
3,000
3/4
12/17
700 (RMEG)
Chromium, dissolved
Chromium, total
110
410
3/4
5/17
50 (RMEG)
Cobalt, dissolved
Cobalt, total
59
220
1/4
4/17
none
Lead, dissolved
Lead, total
56
100
3/4
5/17
none
Mercury, dissolved 220 1/4 none
Nickel, dissolved
Nickel, total
220
550
1/4
5/17
100 (LTHA)
Vanadium, dissolved
Vanadium, total
510
1,100
3/4
5/17
none
Deep Groundwater - Plant Production Wells
Aluminum 610 2/5 none
Arsenic [PRC, 1993] 2.2 2/5 0.02 (CREG)
Mercury [PRC, 1993] 0.2 1/5 none
Fluoride 680 1/5 500 (EMEG)
OFF-SITE CONTAMINATION

Table A6: Contaminants of Concern in Off-Site Soils (CH2M Hill, 1994).

Contaminant Maximum Concentration
milligrams per kilogram
(mg/kg)
# detects/# samples in area Comparison Value
(mg/kg)
Fairview Farms
PAHs 19 2/2 carcinogens
Aluminum 15,000 2/2 none

Table A7: Contaminants of Concern in Off-Site Sediments (CH2M Hill, 1994).

Contaminant Maximum Concentration
(mg/kg)
# detects/# samples in area Comparison Value
(mg/kg)
Columbia River, Far Upstream
PAHs 1 1/2 carcinogens
Aluminum 6,400 2/2 none
Arsenic 4 2/2 3 (EMEG)
Lead 8.6 1/2 none
Columbia River, 100 Feet Upstream of Outfall
PAHs 0.2 1/1 carcinogens
Aluminum 6,600 1/1 none
Columbia River, 200 Feet Downstream of Outfall
PAHs 0.1 1/1 carcinogens
Aluminum 6,800 1/1 none

Table A8: Contaminants of Concern in Off-Site Surface Water (CH2M Hill, 1994).

Contaminant Maximum Concentration
(mg/L)
# detects/# samples in area Comparison Value
(mg/L)
Columbia River, 100 Feet Upstream of Outfall
Aluminum 740 1/1 none
Columbia River, Far Upstream
Aluminum ND 0/1 none

ND: not detected

Table A9: Contaminants of Concern in Fish from the Columbia River near the Reynolds Metals site.

Contaminant Concentration Range
(µg/kg)
# detects/# samples in area
Lower Columbia River Bi-State Program, 1993
Mercury 20 - 130 8/8
PAHs (naphthalene) ND - 220 1/8
PAHs (2-methyl naphthalene) ND - 230 2/8
PCBs (Aroclor 1254) ND - 120 4/8
Lower Columbia River Bi-State Program, 1994
Mercury 35 - 210 6/6
PAHs (2-methyl naphthalene) ND - 10
PCBs (Aroclor 1254) ND - 170 3/6
PCBs (Aroclor 1260) ND - 55 2/6
Lower Columbia River Bi-State Program, 1995
Mercury 145 - 189 3/3
PAHs ND 0/3
PCBs ND 0/3

ND: not detected

QUALITY ASSURANCE AND QUALITY CONTROL

In preparing this Public Health Assessment, ATSDR relied on the information provided in the referenced documents. The Agency assumes that adequate quality assurance and quality control measures were followed with regard to chain-of-custody, laboratory procedures, and data reporting. The validity of the analysis and conclusions drawn for this health assessment depend on the reliability of the referenced information.

TOXIC RELEASE INVENTORY

The EPA maintains the Toxic Release Inventory (TRI), a database of more than 320 different toxic substances released from facilities into the environment. The TRI was searched for information about releases that may have occurred from 1987 through 1993 in the area surrounding the Reynolds Metals Company. There were no other industries in the area that might have emitted the same contaminants as those found at this site.

APPENDIX B

TOXICOLOGICAL INFORMATION FOR SIGNIFICANT SITE CONTAMINANTS

Aluminum

Exposure to aluminum is usually not harmful. The bloodstream absorbs very little aluminum from the digestive tract, and the kidney rapidly removes most of what the bloodstream does absorb. In addition, less aluminum than normal is absorbed from the digestive tract when fluoride is also present, as occurs at this site. Some studies show that people with Alzheimer's disease have more aluminum in their brains than people who do not have the disease, although It is not known whether this is a cause of the disease or a result of it [ATSDR, 1992].

Fluoride

Fluoride occurs naturally in soils and groundwater. People are often intentionally exposed to fluoride in municipal drinking water supplies; it is added to prevent dental cavities. Concentrations in public drinking water can approach 1,000 µg/L. These small amounts of fluoride have been found to have positive health effects (decreased dental cavities) and no adverse health effects. The positive health effects disappear and adverse effects begin to appear as the level of fluoride exposure increases.

When people are exposed to fluoride by ingesting it, their bones and teeth absorb the fluoride slowly. The absorption process is much slower than the rate at which the body eliminates ingested fluoride. Therefore, a person must ingest large amounts of fluoride over a long period of time before any adverse health effects will occur. Infrequent exposure to fluoride, even in relatively large amounts, should not produce adverse health effects, since the fluoride will be eliminated before the bones and teeth can absorb very much.

Exposure to high levels of fluoride during the development of the teeth in young children can mottle or stain the teeth. Exposure to large amounts of fluoride at any age can also increase the incidence of dental caries, or cavities. When the bones absorb fluoride for several years, decreased amounts of calcium in the bones and a consequent thickening and weakening of the bones can result. This condition is called skeletal fluorosis. It can cause an increased risk for bone fractures. In more severe cases, the spine may become involved, resulting in either a humped or an arched back.

An early study examined 78 workers who were engaged in crushing and refining cryolite, or sodium aluminum fluoride, for up to 40 years. Thirty-nine of these workers showed evidence of skeletal fluorosis of the long bones and cartilage, and a few showed evidence of skeletal fluorosis in the skull. These workers were exposed to much larger amounts of cryolite than would be expected at the Reynolds site.

When fluoride is present with aluminum, as occurs at this site, the aluminum and the fluoride compete for absorption out of the gastrointestinal tract and into the bloodstream. The result of this competition is decreased absorption rates of both aluminum and fluoride when these two elements are ingested together [ATSDR, 1993a].

PAHs

Polycyclic aromatic hydrocarbons, or PAHs, are a product of incomplete burning of fuels and wastes. Most of the PAHs that people are exposed to come from grilled meats. They are also found in cereals. PAHs encompass a wide variety of substances with differing toxic effects. Some PAHs have been shown to cause cancer in laboratory animals. These suspected cancer-causing substances are benzo(a)pyrene, benzo(a)anthracene, and dibenzo(a,h)anthracene. Animals fed these substances showed increases in cancers of the upper gastrointestinal tract, the lung, and the breast and increases in the incidence of leukemia. But the amounts to which the laboratory animals were exposed are much larger than the amounts to which people are likely to be exposed. There is no information on whether PAHs can cause cancer in humans [ATSDR, 1993b].

PCBs

Polychlorinated biphenyls, or PCBs, include a variety of artificial substances that have been used in the cooling liquids for electrical transformers. Although PCBs are no longer made, many older transformers may still contain them. Transformers which were inappropriately disposed of in the past may have allowed PCBs to contaminate the environment.

PCBs are a persistent and stable environmental contaminant. When they are present in soils, they can be washed into nearby rivers, lakes and streams. PCBs can then concentrate in the bodies of fish. Although the concentrations of PCBs are usually much higher in the parts of the fish that aren't eaten, the amounts which are in fish fillets can become large enough to make eating fish a major source of exposure to PCBs.

Laboratory animals that ate PCB-contaminated food for a long time developed many serious effects, including injuries to the liver, stomach, and thyroid gland. These effects have been seen in many different kinds of animals and their offspring. We do not know whether the same effects would happen to people exposed in the same way and to the same amounts.

PCBs are suspected to be carcinogenic, or able to cause cancer. They have caused liver cancers in laboratory animals that ate PCB-contaminated food. However, there is not enough information to determine whether PCBs can cause cancer in humans [ATSDR, 1993c].

Mercury

Mercury is a naturally occurring metal in the environment. Pure mercury occurs as a silver, heavy liquid. It is used in dental fillings, thermometers, manometers, thermostats, and many other common appliances. Because it is so frequently used, it is a frequent environmental contaminant. Most of the mercury found in the environment is in the inorganic state, either as pure mercury or in a compound with other inorganic substances. When mercury is absorbed by plants and animals, it is usually transformed into organic mercury, or methyl mercury. When inorganic or organic mercury contaminate rivers, lakes, and streams, it can be concentrated in the bodies of fish as organic mercury. Therefore, people who eat a lot of fish are likely to have higher exposures to methyl mercury than people who do not eat a lot of fish.

Exposure to high enough levels of any form of mercury can permanently damage the brain, kidneys, and unborn children. The nervous system is very sensitive to mercury's effects. A variety of effects may occur, including personality changes, tremors, changes in vision or hearing, and difficulties with memory. The amounts that have caused these effects in people are much higher than the amounts to which people are usually exposed [ATSDR, 1994].

Arsenic

Arsenic occurs naturally, and is generally found naturally at higher levels in soils in the northwest United States than in other parts of the country. Arsenic is found in the environment in either an inorganic or an organic form. It is used in many pesticides and so is a frequent environmental contaminant. Large doses of inorganic arsenic are deadly to humans. Smaller doses, as can occur at contaminated areas, can cause skin changes. Changes includes a darkening of the skin and the appearance of small corns on the palms, the soles of the feet, and the torso. While these skin changes are not considered to be a health concern in their own right, a small number of the corns may ultimately develop into skin cancer. Swallowing inorganic arsenic may also cause cancer of the liver, bladder, kidney, and lung.

Almost no information is available on the effects of organic arsenic in humans. Studies in animals indicate that organic arsenic is less toxic than inorganic arsenic [ATSDR, 1993d].

ATSDR RESPONSE TO PUBLIC COMMENTS

The Public Comment Period for the Reynolds Metals Company Public Health Assessment was from July 29, 1996 to August 28, 1996.

The comments received and ATSDR's responses to these comments are contained in this section of the Reynolds Metals Company Public Health Assessment.

General Comments

Comment: We found numerous errors in the reported data, including mislabeled units and incorrect values. We advise caution in basing conclusions on the PRC data without a more thorough QA/QC review on the part of the agency.
Response: This data has been reviewed for accuracy. This statement will be added to the Blue Cover document: Reynolds Metals has questioned the validity of PRC information.
Comment: We noted that the comparison values used by ATSDR to evaluate the site are based on long-term residential exposure. Residential scenarios assume a lifetime of almost continuous exposure, with relatively long duration and high exposure to children. Such exposures are not reasonable for this site and its usage.
Response: Comparison values are used by ATSDR for screening contaminants. Concentrations that exceed comparison values are evaluated further using exposure assumptions that are appropriate for the site. Comparison values are not used to evaluate risk.
Comment: Throughout the Public Health Assessment, relative terminology is used that may serve to exaggerate the significance of various issues andperhaps create undue alarm for the public viewing the report.
Response: Terminology was reviewed and some changes will be reflected in the Blue Cover document. For example, the word large has been replaced with significant in relation to amounts of fluoride.

Specific Comments

Comment: Page 1, paragraph 2, under SUMMARY. We suggest changing the sentence "Wastewater is now disposed of into Company Lake, which lies between the plant and the Columbia River, into which the lake discharges" to: "The current wastewater treatment includes pH adjustment, coagulation and flocculation, and solids settling and removal in a clarifier. The treated wastewater is discharged to South Ditch, which lies south of the facility, which then discharges into Company Lake and the outfall ditch, which lie north of the Corps of Engineers dike. Wastewater is pumped from South Ditch into Company Lake and discharges to the Columbia River via the outfall ditch. The treatment and discharge of treated wastewater to the Columbia River is allowed and monitored under Reynolds Metals' NPDES permit".
Response: Change will be added to the Blue Cover document with a short explanation of NPDES.
Comment: Page 1, paragraph 4, under SUMMARY. Access to the northern part of the plant site north of the Corps of Engineers dike is controlled by Reynolds Metals. Visitors wishing to access the area are required to sign in with the plant security guard. The area North of the dike has warning signs at access points to the North Landfill and Company Lake where there would be potential health concern from exposure to contaminants. These warning signs state: "No trespassing, no fishing, no swimming - industrial pollution."
Response: This sentence will be added to the Blue Cover document: The area north of the dike has warning signs at access points to the North Landfill and Company Lake. These warning signs state: "No trespassing, no fishing, no swimming - industrial pollution".
Comment: Page 1, paragraph 6, under SUMMARY. Plant workers are trained in proper occupational health and safety practices. The workers rarely have any reason to work in the source areas, and they have been advised of the constituents present in those areas. As a result of the usage of the areas and proper occupational health and safety practices of the workers, we do not believe that workers are being exposed to "large amounts of fluoride" as is stated.
Response: The following sentence will be added to the Blue Cover document: Reynolds Metals representatives feel that their employees are not being exposed as often as ATSDR estimates.
Comment: Page 2, paragraph 4, under SITE DESCRIPTION AND HISTORY. As noted previously, wastewater that is discharged to Company Lake is treated before discharge and is monitored and discharged under the NPDES permit for the plant.
Response:Comment noted.
Comment: Page 6, first paragraph under ENVIRONMENTAL CONTAMINATION. The background concentrations are listed in Table A1 (the text lists Table A2 for the background concentrations).
Response: Table A1 is the correct table. This change will be reflected in the Blue Cover document.
Comment: Page 7, paragraph 6, under Surface Water. The ditch that discharges into Company Lake is currently referred to as South Ditch. In the surface water section, the data cited as the outfall ditch is actually data for South Ditch, not the outfall ditch that leads from Company Lake to the Columbia River. This confusion stems from the fact that PRC referred to South Ditch as the outfall ditch. We recommend changing the text to reflect the current nomenclature for the various parts of the wastewater treatment system to avoid confusion. Arsenic and PAHs have not been detected in the current outfall ditch.
Response: This change will be reflected in the Blue Cover document.
Comment: Page 8, first paragraph, under Groundwater. Groundwater investigations continue, so there is more data available from those investigations as well as regular monitoring.
Response: Additional data may be considered in a separate document, if necessary.
Comment: Page 8, second paragraph, under Groundwater. Subsequent to the identification of the groundwater depression near PW-15, it was determined that the depression was unrelated to the presence of the former production well. It is therefore not believed that shallow groundwater has been flowing down the casing of PW-15 to deeper groundwater. Regardless, the production well was properly abandoned.
Response: This statement will be added to the Blue Cover document: Since then it was determined that the depression was unrelated to the presence of the former production well.
Comment: Page 8, third paragraph, under em>Groundwater. We recommend that the discussion of values of constituents in the groundwater consider MCLs and background concentrations. Deep groundwater that is used for production has not exceeded MCLs. In addition, the deepest production well is 590 feet, rather than the 280 feet reported.
Response: The depth of the deepest production well will be changed to 590 feet in the Blue Cover document. Comparison values are used by ATSDR for screening contaminants. Concentrations that exceed comparison values are evaluated further using exposure assumptions that are appropriate for the site. Comparison Values are not used to evaluate risk. Maximum Contaminant levels (MCL's) are considered for comparison values when no other information exists.
Comment: Page 9, first paragraph, under Soil. The data cited in this assessment are for drainage soils and are not representative of the overall Fairview Farms site. Additional soil sampling (more than 30 samples) throughout the Fairview Farms area indicated a maximum concentration of 1.1 mg/L; PAHs in most samples were below detection limit. See the Current Situation Summary for these additional soil data.
Response: This change will be made in the Blue Cover document: "samples were taken from a field" will be changed to "samples were taken from drainage soils". Additional samples will be reviewed and evaluated in a separate document, if necessary.
Comment: Page 9, third paragraph, under Surface Water. Company Lake is a permitted NPDES discharge and is allowed a 164 foot mixing zone extending both upstream and downstream of the outfall point. The mixing zone allows for dilution of the wastewater within a specified area of the Columbia River. The sample collected upstream lies within the permitted mixing zone radius.
Response: This will be added to the last sentence in the Blue Cover document: "within the NPDES permitted mixing zone".
Comment: Page 11, second paragraph, under People Who Eat Fish From the Columbia River. The elevated aluminum concentration referred to was within the permitted NPDES mixing zone. The other sample collected near the outfall was outside of the mixing zone and aluminum was not detected in surface waters. The presence of aluminum within the mixing zone should not be used as evidence that widespread constituent migration is occurring to surface water because aluminum discharge is regulated under NPDES.
Response: It is understand that aluminum concentrations are within the NPDES permit limits, but there is evidence that aluminum concentrations are elevated near the outfall.
Comment: Page 11, fourth paragraph, under Workers at the Reynolds Facility. Employees at the facility are not likely to be exposed to sediments at work. Plant operations do not require employees to access Company Lake. Additionally, signs have been posted around the lake to warn employees of exposure.

It is stated that employees are also likely to be exposed to contamination on-site through on-site production wells. It should be noted that bottled water is provided to the plant workers for drinking water. This has been the practice for some time because the local water is foul-tasting because of the naturally occurring manganese that is present in the water.

Response: The last sentence in paragraph four will be changed to: Employees at the facility are not likely to be exposed to contamination in on site production wells, because of bottled drinking water.
Comment: Page 11, fourth paragraph, under Workers at the Reynolds Facility. Workers at the Troutdale facility are trained in proper occupational safety and hygiene practices for the constituents present in the workplace, such as fluoride. These are the same constituents found in source areas at the site. The occupational safety program trains the workers in the use of appropriate safety equipment and appropriate hygiene practices.
Response: Comment noted.
Comment: Page 11, fifth paragraph, under Workers at the Reynolds Facility. Reynolds Metals hopes to resume operations in the future at the Troutdale facility, but cannot speculate as to when economic conditions will make this possible.
Response: Comment noted.
Comment: Page 12, fourth paragraph, under Food Chain. As noted previously, berries analyzed from the Fairview Farms area did not contain detectable quantities of fluoride or PAHs. In addition it is suggested that the berries are present in areas with high concentrations of PAHs and fluoride in the soil. This is not really the case, since the berries are not growing on the areas that have been identified as source areas, such as the North Landfill. There are abundant berries near East Lake, but some sampling has shown that constituents at the lake are relatively low and it is not considered by EPA to be a source area.
Response: Blackberries were observed growing in areas near Company Lake. Determinations about biouptake can not be made without knowing what soil concentrations were.
Comment: Page 13, fourth paragraph, under Recreational Users. It is suggested that recreational users visit the area monthly and wade in Company Lake and its outfall ditch on three of those visits each year. This is not a reasonable assumption, as is noted previously. The lake and outfall are part of the permitted industrial waste treatment and discharge system for the plant, and have signs indicating thus. Access to much of the lake and the outfall ditch is difficult, and the area does not represent a desirable recreation area.
Response: The site is accessible, so we have assumed a reasonable, but conservative exposure scenario.
Comment: Page 15, first paragraph, under Workers at the Reynolds Facility and page 16, third paragraph under HEALTH OUTCOME DATA. See comments made previously on worker exposure.
Response: See previous Responses to comments on worker exposure.
Comment: Page 17, fourth paragraph under CONCLUSIONS. It is noted that there is evidence that plants could absorb PAHs and fluoride. As noted previously, sampling done at Fairview Farms did not show that to be the case. Data used to make this statement should be provided.
Response: Data will be provided in the Blue Cover document.
Comment: Page 17, fifth paragraph, under CONCLUSIONS. Workers at the site are not necessarily exposed to contaminated soils, sediments, and groundwater. It would be more appropriate to say that they "may" be exposed. In addition it has not been demonstrated that fluoride is expected to cause health effects. We recommend that the sentence saying that "Fluoride is the only site contaminants (sic) expected to cause adverse health effects to workers" be deleted.
Response: This sentence will be changed in the Blue Cover document to: Fluoride is the only site contaminant which may cause adverse health effects to workers.
Comment: Page 18, RECOMMENDATIONS. It should be noted that all the recommendations proposed by ATSDR have been or are in the process of being implemented as part of the plant standard operating practices or as a result of the CERCLA investigations.
Response: Comment noted.

FOOTNOTES

1. National Pollutant Discharge Elimination System (NPDES) - A provision of the Clean Water Act which prohibits discharge of pollutants into waters of the United States unless a special permit is issued by EPA, a state, or (where delegated) a tribal government on an Indian reservation.

2. Comparison values are concentrations of hazardous substances in soil, air, or water, below which no adverse health effects are expected to occur. Please see Appendix A for more information.

3. An unconfined aquifer is a groundwater unit that has no confining layer of clay or stone above it, so that rainwater can percolate directly down through soil, sand, or sediments to fill the aquifer.

4. A monitoring well is a well which has been constructed only for the purpose of studying the flow and quality of groundwater.

5. The proper abandonment of a well involves plugging the entire length of the well hole with a substance that water cannot flow through, such as clay. Depending upon state regulations, the well casing, or piping, may also be removed.

6. Since the shallow and deeper groundwater are not physically separated, the contamination may flow freely between them. Pumping water from the deeper groundwater may promote the movement of the contamination from the shallow to the deep groundwater.

7. Evidence that plants could absorb PAH's and Fluoride is provided in the Toxicological Profiles for PAH's and Fluoride under the section Potential for Human Exposure.

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