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HEALTH CONSULTATION

Public Health Evaluation of the (Proposed) Air Monitoring Plan of the Preliminary Design Report for the Ciba-Geigy Superfund Site
(Operable Unit 2)

CIBA-GEIGY CORPORATION
TOMS RIVER, OCEAN COUNTY, NEW JERSEY


CONCLUSIONS

The NJDHSS and the ATSDR have reviewed the proposed the Plan for monitoring of on-site ambient air during remedial activities that include excavating soils, bio-remediation, and drum removal. ATSDR's and NJDHSS' evaluation is a culmination of a review of various drafts of Ciba's air monitoring plan and numerous discussions with EPA regarding the proposed air action levels and other aspects of the air monitoring plan. During the course of these reviews and discussions, several recommendations were put forth by ATSDR and the NJDHSS that have been addressed by EPA and incorporated into the Plan. Moreover, ATSDR and NJDHSS provided a draft copy of this health consultation to the CACCCC, the Toxic Environment Affect Children's Health (TEACH) group, the Ocean County Health Department, and Manchester Township. Comments received from these entities and ATSDR's and NJDHSS' response to these comments are provided in this Health Consultation.

Overall, the proposed plan and other actions that will be taken by EPA should be protective of public health provided that certain additional measures are taken (see Recommendations below). Based on the review of available information and the proposed plan, ATSDR and NJDHSS conclude that:

  1. Establishment of three zones of action, i.e., work, near field, and perimeter, should be able to characterize airborne contaminants that may be emitted during remedial activities. Therefore, the proposed monitoring of COCs in these areas should adequately protect the health of workers and the public. No long-term action levels (LTALs) are necessary for the work or near field zones;


  2. Monitoring for nine site-wide and five source area-specific COCs should provide sufficient data to characterize the type and concentrations of potential airborne emissions;


  3. Installation and operation of six stationary monitoring stations (and one mobile station) along the perimeter should be sufficient to determine the potential exposure to, and thereby protect the health of, the public near the CGC property. Even though the perimeter monitoring stations will be located on CGC property (to help protect them from vandalism), they are considered to be exposure point monitors. Consequently, the continuous monitoring data that will be gathered from the stationary and mobile stations should provide sufficient information to characterize the potential exposure to the nearest off-site populations;


  4. After evaluating the action levels that are proposed in the Plan, NJDHSS and ATSDR concur that it is appropriate to utilize TVOC concentrations as the trigger levels to initiate contaminant-specific monitoring and , as necessary, response actions. Use of TVOC measurements will allow for quicker reaction and initiation of protective response actions, since identification and determination of the concentration of an individual COC requires a longer period of time than does a TVOC measurement. The use of TVOC as a trigger helps to expedite the response actions because the TVOC instruments can provide immediate readings;


  5. The Plan calls for contaminant-specific monitoring to be implemented when the TVOC trigger level is exceeded. However, in practice, contaminant-specific monitoring will be initiated before the TVOC trigger level is exceeded. Determining the identities of the individual VOCs before the TVOC trigger level is exceeded will provide an extra measure of protection for the workers and the community;


  6. NJDHSS and ATSDR have evaluated the proposed work zone and near-field action levels, and concur that they should be protective of on-site workers. These action levels should also be sufficient to determine the need to stop work and take appropriate measures to reduce the potential for COCs to exceed action levels at the perimeter;


  7. NJDHSS and ATSDR have reviewed the assumptions that were made in deriving the action levels. Most of these assumptions should be protective of public health. However, off-gassing of COCs could occur (1) during periods when excavation is not occurring, but has not been completed in a particular area, and (2) from soils brought outside for final bio-remediation. In addition, based on the proposed schedule for remediation, activities are likely to take place during essentially every available work day for two years. Therefore, the assumption of the frequency of exposure (i.e., number of days exposed) used to derive the actions levels may be exceeded;


  8. NJDHSS and ATSDR concur with the Plan that periodic confirmatory monitoring for lead and mercury will be necessary to confirm that particulate matter action levels are protective for exposure to these metals. Moreover, NJDHSS and ATSDR believe that confirmatory monitoring for lead and mercury should be conducted if any of the particulate matter action levels are exceeded. That is, confirmatory monitoring is needed to ensure that concentrations of mercury and lead do not exceed their individual action levels. If appropriate confirmatory monitoring is performed, then the proposed action levels for particulate matter should be protective of public health;


  9. While site data indicate that lead and mercury are the most likely particle-bound air contaminants, NJDHSS and ATSDR believe that it is a prudent public health measure to perform additional particle analysis for the full spectrum of potential particle-bound contaminants; and,


  10. An odor may be the first indication to nearby residents that COC's or other compounds from the source areas are in the ambient air. However, it is important to note that the presence of an odor does not necessarily indicate that there is a public health concern.

RECOMMENDATIONS

To adequately address community health concerns and to protect the public health during remedial activities at the on-site source areas, NJDHSS and ATSDR recommend the following:

  1. The perimeter LTALs should be re-evaluated periodically when soil excavation, bio-remediation and drum removal has begun, to determine if any of the exposure assumptions used in their development have been exceeded. If any of the assumptions are exceeded, then the LTALs should be reconsidered and lowered if warranted;


  2. If any of the action levels for particulates are exceeded while excavating the Backfill Lagoon and Filtercake Disposal Areas, particle analyses should be conducted for airborne lead and mercury, respectively;


  3. Additional analysis for the full spectrum of potential particle-bound air contaminants should be conducted. Moreover, these analyses should be conducted especially on days when the nearest receptor population is downwind of an area being excavated (e.g., analyze particles from monitors along Cardinal Drive when excavating the Filtercake Disposal Area).


  4. The Plan, and its associated response actions, should be exercised on-site, prior to the initiation of remedial activities, under different scenarios, e.g., during work and non-work hours, prior to the initiation of remedial activities to properly train monitoring and response personnel;


  5. A method for providing up-to-date information and status regarding excavation activities, as well as procedures to address inquiries from the public, should be established;


  6. Additional on-site security measures should be taken during remediation to reduce the potential for trespassers to be exposed to the on-site excavation areas and emissions and to help protect the integrity of the air monitoring equipment; and,


  7. ATSDR should evaluate the Health and Safety Plan when it becomes available.

The EPA will implement the above ATSDR and NJDHSS recommendations 1-6. The ATSDR will follow-up on recommendation number 7.


CERTIFICATION

This Health Consultation was prepared by the New Jersey Department of Health and Senior Services (NJDHSS) under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It has been produced in accordance with approved methodology and procedures existing at the time the Health Consultation was begun.

Gregory V. Ulirsch
Technical Project Officer
Superfund Site Assessment Branch (SSAB)
Division of Health Assessment and Consultation (DHAC)
ATSDR


The Division of Health Assessment and Consultation, ATSDR, has reviewed this Health Consultation and concurs with its findings.

Richard Gillig
Chief, Superfund Site Assessment Branch (SSAB), DHAC
ATSDR


PREPARERS OF REPORT

Preparers of Report:

Bruce E. Wilcomb, Ph.D.
Health Assessment Project
Hazardous Site Health Evaluation Program
Consumer and Environmental Health Services
New Jersey Department of Health and Senior Services

and

Gregory V. Ulirsch, MS
Superfund Site Assessment Branch (SSAB)
Division of Health Assessment and Consultation (DHAC)

ATSDR Contributors/Reviewers:

Lynn Wilder, MS, CIH
Exposure Investigation and Consultation Branch (EICB)
Division of Health Assessment and Consultation (DHAC)

Allan Robison, Ph.D.
Superfund Site Assessment Branch (SSAB)
Division of Health Assessment and Consultation (DHAC)

ATSDR Regional Representative:

Arthur Block
Regional Representative, Region II
Regional Operations
Office of the Assistant Administrator

ATSDR Technical Project Officer:

Gregory V. Ulirsch
Technical Project Officer
Superfund Site Assessment Branch (SSAB)
Division of Health Assessment and Consultation (DHAC)

Any questions concerning this document should be directed to:

Health Assessment Project Manager
Consumer and Environmental Health Services
New Jersey Department of Health and Senior Services
3635 Quakerbridge Road
PO Box 369
Trenton, NJ 08625-0369


REFERENCES

ACGIH, 2002. Threshold Limit Values for Chemical Substances and Physical Agents, ACGIH, Cincinnati, OH, 2002

AIHA, 1995. Odor Thresholds for Chemicals with Established Occupational Health Standards, AIHA, Fairfax, VA, 1995

ATSDR, 1988. Public Health Assessment - Ciba-Geigy National Priorities List Site, U.S. Agency for Toxic Substances and Disease Registry, Atlanta, Ga., October 26, 1988.

ATSDR, 2000. Health Consultation - Evaluation of Proposed Remedial Alternative for Soils (OU2), Ciba-Geigy Corporation Site, Agency for Toxic Substances and Disease Registry, Atlanta, GA, 2000

ATSDR, 2002. ATSDR ToxProfiles 2002, ATSDR, 2002. (CD-ROM)

CDM, 1993. Source Control Remedial Investigation Report - Ciba-Geigy Site (Revised Draft), CDM Federal Programs, July 2, 1993.

CDM, 1994. Revised Toxicity Assessment Tables Tentatively Identified Compounds (Surface Soil Borings Only) , Ciba-Geigy Corporation, PTRL Environmental Services, Inc., September, 1994.

Ciba, 1999. Feasibility Study Report (Draft), Ciba-Geigy Superfund Site, Operable Unit 2, August 31, 1999 (CD-ROM).

Ciba, 2002a. Air Monitoring Plan, Appendix A of the Preliminary Design Report, Ciba-Geigy Superfund Site, Toms River, New Jersey, April 2002

Ciba, 2002b. Emergency Management Plan, Appendix C of the Preliminary Design Report, Ciba-Geigy Superfund Site, Toms River, New Jersey, May 2002

DS, 1997. Tentatively Identified Compounds at Ciba-Geigy Site, Toms River, NJ, Disposal Safety Report No. 44, May 28, 1997 (includes: Dye Compounds in Ciba-Geigy Source Areas, Disposal Safety Inc., December 6, 1993).

EPA, 1989. Record of Decision - Ciba-Geigy Corporation Operable Unit 1, USEPA Region 2, April 24, 1989.

EPA, 1993. Explanation of Significant Differences, USEPA Region 2, September 1993.

EPA, 2000. Record of Decision - Ciba-Geigy Corporation Site Operable Unit 2, USEPA Region 2, September 29, 2000

NIOSH, 1997. NIOSH Pocket Guide to Chemical Hazards, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, June 1997.

NJDOH and ATSDR, 1996. Public Health Response Plan, Dover Township Childhood Cancer Investigation, New Jersey Department of Health, and Agency for Toxic Substances and Disease Registry, June 24, 1996.

NJDHSS and ATSDR, 2001a. Public Health Assessment - Ciba-Geigy Corporation, February 22, 2001.

NJDHSS and ATSDR, 2001b. Public Health Consultation - An Exposure Investigation Conducted in Support of Public Health Assessments for Ciba-Geigy Corporation, Reich Farm, and Dover Township Municipal Landfill, NJDHSS and ATSDR, May 7, 2001.

NJDHSS and ATSDR, 2001c. Public Health Consultation - A Summary of Monitoring Well Sampling Conducted in Support of Public Health Assessments for Ciba-Geigy Corporation, Reich Farm, and Dover Township Municipal Landfill, NJDHSS and ATSDR, May 7, 2001.

NUS, 1988. Remedial Investigation for the Ciba-Geigy Site, NUS, January 22, 1988 Rev 3.


TABLES

Table 1. Summary of Chemicals of Concern and Source Areas (Ciba, 1999)

Source Area Site-wide COCs Source Area- Specific Contaminants Excavation Volume
(cu. yds.)
Drum Disposal Area (DDA) TCB, DCB, CB, NAP, NB, PCE, TCE TOL, MEK, MIBK 63,900 plus 32,000 drums
Filtercake Disposal Area (FCD) TCB, DCB, CB Mercury 24,900
East and West Equalization Basins (EB) TCB,DCB, 2CT, CB, NB NONE 21,500
Backfilled Lagoon Area (BLA) Northern and Southern Drying Lagoons TCB, 2CT, NAP, TCP Lead 25,000
Former South Dye Area (SDA) TCB, DCB, 2CT, TCP NONE 10,900
Former Building 108 Underground Storage Tank Area (FB108) TCB NONE 400
Borrow Compactor Area (BCA) TCB,DCB,CB,NAP,TCE NONE 800

COC - Chemical of Concern
CB - Chlorobenzene
2CT - 2-Chlorotoluene
DCB, 1,2-Dichlorobenzene
NAP - Naphthalene
NB - Nitrobenzene
PCE - Perchloroethylene
TCB - 1,2,4-Trichlorobenzene
TCE - Trichloroethylene
TCP - 1,2,3-Trichloropropane
MEK - Methyl ethyl ketone
MIBK - Methyl isobutyl ketone
TOL - Toluene


Table 2. Summary of Proposed Monitoring Instruments (Ciba, 2002)

Zone of Action (distance) Instrument Response Time MDL
Work Zone VOCs
ppbRae (TVOC)
SRI Instruments GC (VOC specific)

Particulates
Casella (TSP)


Continuous
Up to 30 min


Continuous


1 ppb
20-100 ppb


1µg/m3

Near field
(100 yds)
VOCs
ppbRae (TVOC)
SRI Instruments GC (VOC specific)

Particulates
Casella (TSP)


Continuous
Up to 30 min


Continuous


1 ppb
20-100 ppb


1µg/m3

Perimeter
(Minimum 300 yds)
VOCs
ppbRae (TVOC)
SRI Instruments GC (VOC specific)
SUMMA canister (mobile)(VOC specific)

Particulates
Casella (TSP)
Mie Dataram (TSP, PM10)
TEOM (TSP, PM10, PM2.5, metals)


Continuous
Up to 30 min
8 hr sample


Continuous
5 min avg
1 hr avg


1 ppb
20-100 ppb
0.2-1µg/m3


1µg/m3
0.1µg/m3
-----------

GC - Gas Chromatograph
VOC - Volatile Organic Compound
TVOC - Total Volatile Organic Compounds
MDL - Minimum Detection Level
TSP - Total Suspended Particulates
PM10 - Particulate matter less than 10 micrometers in diameter
PM2.5 - Particulate matter less than 2.5 micrometers in diameter
--- Not indicated


Table 3. Proposed Immediate and Short Term Trigger Levels for Total Volatile Organic Chemicals (TVOCs) and Action Levels for Specific Volatile Organic Chemicals of Concern (COCs), in parts per million (ppm). (Ciba, 2002a)

Contaminant Work and Near Field Zones Site Perimeter Zone
  Immediate
(ppm)
Short Term
(ppm)
Immediate
(ppm)
Short Term
(ppm)
Total VOCs NE 1 NE 0.1
Chlorobenzene 500 10 100 1
2-Chlorotoluene NE 50 NE 5
1,2-Dichlorobenzene 25 25 5 2.5
1,2,4-Trichlorobenzene 2.5 NE 0.5 NE
Nitrobenzene 100 1 20 0.1
Naphthalene 15 10 7.5 1
Tetrachloroethylene 75 25 15 2.5
Trichloroethylene 100 50 50 5
1,2,3-Trichloropropane 50 10 10 1
Toluene 150 50 30 5
Methyl Ethyl Ketone 300 200 150 20
Methyl Isobutyl Ketone 75 50 37 5

NE = Not established


Table 4. Proposed Long Term Action Levels (LTALs) for Specific Volatile Organic Chemicals of Concern (COCs), in micrograms per cubic meter (µg/m3) and in parts per million (ppm). (Ciba, 2002a)

Contaminant EPA Carcinogenicity Category EPA Reference Concentration (RfC), (µg/m3) Site Perimeter Zone
      Long Term
(µg/m3)
Long term
(ppm)**
Chlorobenzene D 60 365 0.08
2-Chlorotoluene NE 70 426 0.08
1,2-Dichlorobenzene D 200 1,217 0.2
1,2,4-Trichlorobenzene D 4 24 0.003
Nitrobenzene D 2 3 0.0006
Naphthalene C 3 37 0.007
Tetrachloroethylene UR 490 47* 0.007
Trichloroethylene UR 21 71* 0.01
1,2,3-Trichloropropane NE 5 2* 0.0003
Toluene D 400 649 0.17
Methyl Ethyl Ketone D 1,000 1,622 0.55
Methyl Isobutyl Ketone NE 80 130 0.03

EPA Carcinogenicity Categories: C = Possible human carcinogen; D = Not classifiable; NE = Not established

* LTAL based on potential cancer effects

** LTALs also given in ppm for comparison to immediate and short term action levels (Table 3).

Conversion between (µg/m3) and (ppm), at room temperature, is as follows, where MW = molecular weight:

µg/m3 = (ppm x MW/24.45) x 1,000


Table 5. Odor Thresholds for Volatile Organic Chemicals of Concern (COCs), in micrograms per cubic meter (µg/m3) and in parts per million (ppm). (AIHA, 1995)

Contaminant Molecular Weight Odor Threshold
    In µg/m3 In ppm
Chlorobenzene 112.56 6,000 1.3
2-Chlorotoluene 126.60 210 0.04
1,2-Dichlorobenzene 147.00 720 0.12
1,2,4-Trichlorobenzene 181.45 Unknown Unknown
Nitrobenzene 123.11 1,900 0.37
Naphthalene 128.16 200 0.038
Tetrachloroethylene 165.83 319,000 - 481,000 47 - 71
Trichloroethylene 131.39 440,000 - 591,000 82 - 110
1,2,3-Trichloropropane 147.43 Unknown Unknown
Toluene 92.14 6,000 - 41,000 1.6 - 11
Methyl Ethyl Ketone 72.11 47,000 - 50,000 16 - 17
Methyl Isobutyl Ketone 100.16 400 - 33,000 0.1 - 8

Conversion between (µg/m3) and (ppm), at room temperature, is as follows, where MW = molecular weight:

µg/m3 = (ppm x MW/24.45) x 1,000


Table 6. Proposed Short Term and Long Term Action Levels for Particulate Matter, in micrograms per cubic meter (µg/m3). (Ciba, 2002a)

Action Level Measurement Term Work Zone Near Field Zone Site Perimeter Zone
Short Term (µg/m3) 5,000 4,000 400
Long Term (µg/m3) No LTAL No LTAL 150 (24 hour average)
50 (annual average)

LTAL = Long Term Action Level

Short Term Action Levels are based on a five minute exposure.

The OSHA Permissible Exposure Limit for nuisance dust is 15,000 µg/m3 (total) or 5,000 µg/m3 (respirable fraction (NIOSH, 1997). The ACGIH Threshold Limit Value for nuisance dust is 10,000 µg/m3 (inhalable) and 3,000 µg/m3 (respirable) (ACGIH, 2002).

The National Ambient Air Quality Standard for particulates (PM10) is 50 µg/m3 (annual average) and 150 µg/m3 (24 hour average).


FIGURES

Ciba-Geigy Corporation Superfund Site Location
Figure 1. Ciba-Geigy Corporation Superfund Site Location

Ciba-Geigy Source Areas
Figure 2. Ciba-Geigy Source Areas

Source Areas to be Excavated
Figure 3. Source Areas to be Excavated

Ciba-Geigy Fixed Air Monitoring Locations
Figure 4. Ciba-Geigy Fixed Air Monitoring Locations


APPENDIX A: ATSDR AND NJDHSS RESPONSE TO COMMENTS PROVIDED BY THE CITIZEN'S ACTION COMMITTEE ON CHILDHOOD CANCER CLUSTER (CACCCC), THE TOXIC ENVIRONMENT AFFECT CHILDREN'S HEALTH (TEACH) GROUP, THE OCEAN COUNTY HEALTH DEPARTMENT, OR MANCHESTER TOWNSHIP

Comment 1: After reviewing this Public Health Evaluation I find it very vague and incomplete.

Response: Please see responses to individual comments below which will, hopefully, address this general comment.

Comment 2: Why wasn't all information reviewed? "Based on the review of available information and the proposed Plan, ATSDR and NJDHSS conclude"… What types of information wasn't reviewed and does this affect the completeness of this report?

Response: The only information pertinent to making conclusions and recommendation regarding the overall protectiveness of the air monitoring plan, which was not reviewed for this health consultation, was the Health and Safety Plan. ATSDR has committed to review this plan when available. ATSDR will revisit the conclusions and recommendations of this health consultation in light of any new information contained in the Health and Safety Plan.

Comment 3: The vagueness of this report is up to interpretation as to whether the recommendations have to be followed or not. Example "…using TVOC trigger levels established for each zone and, as necessary, response actions.", etc…throughout this report.

Response: ATSDR's and NJDHSS' role in evaluating the overall air monitoring plan and the action levels was to provide our opinion on the overall protectiveness of the plan. ATSDR and NJDHSS are not regulatory agencies and therefore our recommendations are not enforceable. The EPA has enforcement authority and is responsible for managing the risk related to the clean-up of the Ciba-Geigy site. The EPA does concur with our conclusions and they plan on implementing the recommendations in this health consultation. The health consultation will be changed to reflect that EPA has agreed to implement our recommendations.

Comment 4: "Installation and operation of six stationary monitoring stations (and one mobile station) along the perimeter should be sufficient to determine the potential exposure to, and thereby protect the health of, the public near the CGC property." I have asked, and the community has asked for off site monitoring as an assurance that we know what the public has been exposed to from this remediation. The EPA failed this community when they failed to monitor off-site air emissions at Reich farm.

Response: As indicated in the health consultation, the placement of the monitors at the fence line, especially adjacent to residences along Cardinal Drive and the West Dover School, is, for all intent and purposes, at the nearest exposure points. That is, the levels of contaminants in the air detected on the Ciba-Geigy side of the fence will be very similar the levels on the community side of the fence (in the backyards of the residents along Cardinal Drive and in the playground of the West Dover School). Moreover, it is important to note, that the main goal of the overall air monitoring plan is to prevent harmful exposures to the community. From this standpoint, the monitors that are located at the excavation site and between the excavation site and the fence line are critical to achieving this goal. Again, ATSDR and NJDHSS conclude that the overall air monitoring plan is protective as long as our recommendations set forth in this health consultation are implemented.

Comment 5: Please reference the source document that has been established where the EPA Region II Remedial Program Manager has committed to: "contaminant-specific monitoring will be initiated before the TVOC trigger level is exceeded."

Response: The text will be changed to indicate that reference for this statement is the Air Monitoring Plan, Appendix A, Preliminary Design Report.

Comment 6: Less emphasis should be place on the word "should" and replaced with "shall" in the appropriate sections.

Response: Please see response to comment 3 above.

Comment 7: I want all assumptions to be protective of public health, please re-evaluate. "Most of these assumptions appear to be protective of public health." Also please state what assumptions did not appear to be protective of public health.

Response: It states in the Action Levels for VOCs at the Site Perimeter section of the health consultation that "NJDHSS and ATSDR have reviewed these assumptions and believe that they are protective of public health. However, the assumption of frequency of exposure (i.e., number of days potentially exposed), a major factor in determining the long-term action levels (LTALs), has the potential to be violated. Therefore, the NJDHSS and ATSDR believe that the perimeter LTALs should be re-evaluated periodically once the excavations, bio-remediation and drum removal have begun, to determine if the frequency of exposure assumption, or any of the exposure assumptions used in the development of these LTALs, should be reconsidered, and if lowering the current LTALs is warranted." The use of the word "appear" is appropriate in this context in that the assumptions as stated are conservative and ATSDR and NJDHSS believe that they are protective of public health. However, these are assumptions and we feel it important that all assumption that have gone into the development of the action levels, especially the frequency of exposure assumptions, should be verified once remediation begins.

Comment 8: In the following paragraph please change "may be necessary" and "should be" to "will be necessary" and "shall be":

"NJDHSS and ATSDR concur with the Plan that periodic confirmatory monitoring for lead and mercury may be necessary to determine if the particulate matter action levels are protective for exposure to these metals. Moreover, NJDHSS and ATSDR believe that confirmatory monitoring for lead and mercury should be conducted if any of the particulate matter action levels are exceeded. That is, confirmatory monitoring is needed to ensure that concentrations of mercury and lead do not exceed their individual action levels. If appropriate confirmatory monitoring is performed, then the proposed action levels for particulate matter should be protective of public health; and,"

Response: ATSDR will change the language to indicate that periodic confirmatory monitoring for lead and mercury will be necessary to confirm that the particulate matter action levels are protective for exposures to these metals. As indicated above in response to comment 3, EPA will be performing this confirmatory monitoring.

Comment 9: Please remove the word "low" in the following paragraph. You may be implying an odor is only conducive indication of low concentrations.

"An odor may be the first indication to nearby residents that low concentrations of source area COCs or other compounds are in the ambient air. However, it is important to note that the presence of an odor does not necessarily indicate that there is a public health concern."

Response: We agree with this comment and will revise the text.

Comment 10: Page 3 items 1-3 contain the word "should," please change to shall.

Response: Please see response to comment 2 above.

Comment 11: "A method for providing up-to-date information and status regarding excavation activities, as well as procedures to address inquiries from the public, should be established;"….

The EPA has already decided not to provide up to date information or real time information. Again I have requested real time data for the public to view especially on air monitoring via the Internet. Again the public is not being informed adequately especially for families that have a child with cancer and want to protect them from any exposure. Beside the above, delaying for 24 hours the data release, there are no guarantees the data may be accurate.

Response: ATSDR and NJDHSS were asked to determine if the air monitoring plan was protective of public health. As stated in the health consultation, we believe that the plan is protective as long as certain actions are taken, as outlined in our recommendations to EPA. We thought it important that some method for providing up-to-date information to the community be established by the EPA and they concur with the recommendation. As previously, mentioned, EPA has enforcement authority and is responsible for managing the risk relating to the clean-up of the Ciba-Geigy site. What method EPA chooses does not effect ATSDR's and NJDHSS' overall conclusion regarding the protectiveness of the air monitoring plan.

Comment 12: Are we sure the below statement to be true? I do not recall a fence line on the northern area of the site. "The entire CGC site is fenced, with a controlled entrance from Oak Ridge Parkway on the eastern side of the site."

Response: The northern area of the site is fenced. As noted in the health consultation, during the site visit on May 22, 2002, ATSDR and NJDHSS staff noted the breeches in the fence on the northern side of the site. However, after further inquiry with EPA, it does appear that there is not a fence along Ciba-Geigy property adjacent to the Toms River. The text of the health consultation will be revised.

Comment 13: "Consequently, the continuous monitoring data that will be gathered from the stationary and mobile stations that are adjacent to the nearby residential areas should provide sufficient information to characterize the potential exposure to these off-site populations." Vague statement, I want to be assured that these six monitors provide proper protection to this community.

Response: ATSDR and NJDHSS believe that the placement of the monitors in the work zone, near-field zone, and the perimeter is protective of public health. The text will be revised to make this clear.

Comment 14: "Based on EPA guidance, the Plan provides a rationale that indicates that if the action levels for inhalable particles are not exceeded, then the individual action levels for lead and mercury will also not be exceeded." Please explain in detail the EPA guidance and the rationale behind this.

Response: EPA's rationale is explained in Attachment C of the Air Monitoring Plan, which is available in the repositories.

Comment 14: "The Plan indicates that airborne emissions will be monitored in the three zones of action for three different potential exposure durations (see Table 2). NJDHSS and ATSDR concur that the proposed monitoring of the three zones of action for "immediate", "short-term", and "long-term" exposure will likely be sufficient to characterize the potential exposure to workers and the community due to emissions from the source areas."

If the standards being used are not conservative enough, then please re-evaluate. The public needs to be assured it is protected, not "will likely be sufficient", either it is or isn't. Please explain why we can assure the public is being protected?

Response: ATSDR and NJDHSS believe that the planned monitoring in the three zones of action for three different potential exposures durations to be protective of public health--the text of the health consultation will be revised to make this clear.

Comment 15: "The excavations will be conducted in conjunction with about 225 drum removal events per year (a total of about 32,000 drums) that will be conducted at the DDA over a period of two years (a total of about 450 excavation days)."

Is the drum excavation day, a 24-hour period? If so, is the removal of three drums per hour (over a 24 hr period) realistic? Are the drums being sampled? And is it safe to remove drums around the clock?

Response: The details of how EPA plans on excavating and removing drums is provided in the Drum Handling Plan which is available for review in the repositories.

Comment 16: However, in practice, contaminant-specific monitoring will be initiated before the TVOC action level is exceeded (Personal Communication, EPA Remedial Project Officer, August 2002).

"In practice", where is the source document for this practice? And is there any penalties or fines associated with failing to follow or initiate any protective actions?

Response: Please see response to comment 5 above.

Comment 17: "Even though the perimeter monitoring stations will be located on CGC property (to help protect them from vandalism), they are considered to be exposure point monitors. Consequently, the continuous monitoring data that will be gathered from the stationary and mobile stations should provide sufficient information to characterize the potential exposure to the nearest off-site populations;"

I do not agree with this conclusion. We have asked for offsite air monitoring to know what the public is receiving. Some equipment on the Ciba site has already been stolen, so the conclusion for having it on site to protect it from vandalism is not valid. I want to be assured the public is being protected.

Response: Please see response to comment 4 above.

Comment 18: Under references, why are we referencing a "draft report"?

Response: It is our understanding that the final version of the Source Control Remedial Investigation Report did not change appreciably from the draft report (CDM, 1993). Therefore, relying on the draft version of this report does not effect the overall conclusions and recommendations of this health consultation.

Comment 19: Table 3, will a value be established for total VOCs in the "Work and Near Field Zones" for the "Immediate" action level.

Response: No, the more conservative short-term TVOC number of 1 ppm will be used as the trigger for contaminant-specific monitoring and other actions. As shown in Table 3 of the health consultation, the 1 ppm level was chosen because it was less than or equal to any of the immediate or short-term chemical-specific action levels. The nearest immediate action level for the work or near-field zones is 2.5 ppm for 1,2,4-trichloro-benzene.

Comment 20: Since prevailing winds are Westerly, the fixed locations of the monitoring devices appear to need additional units on the Northeast side of the site. DRAFT Report included Fig.4 shows only one fixed location on the Northeast bordering the Toms River. I would suggest additional permanent monitoring stations between the Backfilled Lagoon location and the first of two located on the Eastern fence-line along Cardinal Drive.

Response: The reason there is not a monitor located in this area is because the placement of the fixed monitoring devices are biased towards evaluating the contaminant levels in air leaving the site in areas adjacent to populated areas off-site. However, as stated in the air monitoring plan, a mobile station will be placed at the site perimeter in a position downwind of the disposal area being excavated on any given day.

Comment 21: While TVOCs and (limited as this list is) COC identification appear to be adequately addressed in the plan, contaminant bound particulates appear inadequately addressed for the following reasons:

Inadequate number and/or location placement of fixed stations.

COCs are limited by both number and class of contaminants.

Coal was the original fuel used on this site as an energy source possibly leaving PAHs bound to soil particles still on site.

Although lead and mercury are addressed as possible particulate concerns when the excavation occurs for the FCD area and the BFL area, what about any other contaminants that may be bound to soils disturbed during excavation or movement to treatment indoors for bio-treatment and back outdoors for additional treatment before returning "clean" soils to the excavated site?

The public has repeatedly requested tenting of excavation locations due to particulate threat of travel from excavation sites to surrounding community neighborhoods.

Older mapping of previous investigations have shown the LSD to be called the Arsenic Pit, which may well have been a geographic nickname to the site workers at the time, designed to differentiate between one area from another.

Are there no other specific contaminants or classes of contaminants to be analyzed at all areas of soil excavation when TVOCs are exceeded, other than heavy metals lead and mercury in the BFL and FCD?

And finally, Page 7, Par. 4, lines 3,4&5, (CDM, 1994) (DS, 1997) note hundreds of organic dyes, resins, TICs, etc. in surface and subsurface soils.

Response: While site data indicate that lead and mercury are the most likely particle-bound air contaminants, additional particle analyses for the full spectrum of contaminants is a prudent public health action. ATSDR and NJDHSS have discussed this with EPA and they have agreed to conduct these analyses. ATSDR and NJDHSS recommend that these analyses should be conducted especially on days when the nearest receptor population is downwind of an area being excavated (e.g., analyze filter samples from monitors along Cardinal Drive when excavating the Filtercake Disposal Area. The health consultation will be updated to include the above conclusion and recommendation.

Comment 22: How will "clean" soils be determined to be clean? Will the results of all contaminant testing be documented, unlike the Reich Farm site that just listed how much soil was excavated and thermally treated, but lacked any information about the contaminants and concentrations?

Response: Details of the soil clean-up levels can be found in the 2000 EPA Record of Decision which can be found in the repository.

Comment 23: Do you know when the Health and Safety Plan will be available for public review?

Response: It is ATSDR and NJDHSS' understanding the Health and Safety Plan will be available for review once a contractor is chosen to perform the work; however, we do not know a specific timeframe for when the plan will be available for public comment. The EPA will provide ATSDR and NJDHSS with a draft copy of the plan for review.

Comment 24: I concur with your evaluation that off-gassing is possible at any point in the excavation, movement and storage of contaminated soils, since it is noted that there is an ambient 15ppb, without the planned remedial activities in operation.

Response: ATSDR and NJDHSS thank you for your comment.

Comment 25: Suggesting exercising the plan and associated response actions, under different scenarios prior to the on-site remedial activities is an excellent recommendation.

Response: ATSDR and NJDHSS thank you for your comment.

Comment 26: I agree with the recommendations of the NJDHSS and ATSDR.

Response: ATSDR and NJDHSS thank you for your comment.

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