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PETITIONED PUBLIC HEALTH ASSESSMENT

CAROLINA SOLITE CORPORATION
(a/k/a CAROLINA SOLITE CORPORATION/AQUADALE)
AQUADALE, NORWOOD COUNTY, NORTH CAROLINA


APPENDIX E: RESIDENTIAL SOIL AND SEDIMENT SAMPLING DATA

Year 2000 Soil Sampling Locations
Figure 1. Year 2000 Soil Sampling Locations

Table 1.

EPA soil testing results for Carolina Solite vicinity and background levels, 2000
Contaminants exceeding health based guideline screening levels for soils (ppm)*
Contaminant Range of Detection Number of samples positively identified Health based guidelines Contaminant of Concern?
Aluminum 6500-28,000 16 of 16 samples ATSDR Intermediate EMEG (ppm):
4000 pica child; 100,000 ppm child; 1,000,000 ppm adult
No
Antimony ND-2.4 1 of 16 samples ATSDR RMEG (ppm):
0.8 ppm pica child; 20 ppm child; 300 ppm adult
No
Arsenic 3.3-24 16 of 16 samples ATSDR RMEG and chronic EMEG (ppm):
0.6 ppm pica child; 20 ppm child; 200 ppm adult
CREG= .5 ppm
Yes
Barium 30-150 16 of 16 samples ATSDR RMEG (ppm)
100 ppm pica child; 4000 ppm child; 50,000 ppm adult
No
Cadmium ND-1.8 5 of 16 samples ATSDR Chronic EMEG
0.4 ppm pica child; 10 ppm child; 100 ppm adult
Yes
Iron 12,000-75,000 16 of 16 samples EPA Risk Based Concentration, 23,000 ppm No
Manganese 77-770 16 of 16 samples EPA Risk Based Concentration, 3200 ppm
ATSDR RMEG: 100 ppm pica child; 3000 ppm child; 40,000 ppm adult
No
Vanadium 19-84 16 of 16 samples EPA Risk Based Concentration, 5500 ppm
ATSDR Intermediate EMEG: 6 ppm pica child, 200 ppm child, 2000 ppm adult
No
* ppm= parts of contaminant per million parts soil


Table 2.

Dioxin/Furan concentrations, EPA 2000
Dioxin/Furan Concentrations in Residential and Background Soils (ng/kg)*

Analyte Residential Soil Medium EPC Background Medium EPC TEF Residential Soil TEQ (ng/kg) Background Soil TEQ (ng/kg) Comparison Value
1,2,3,4,6,7,8-Heptachlorodibenzodioxin 170 65 0.01 1.7 0.65 N/A
1,2,3,4,6,7,8-Heptachlorodibenzofuran 66 26 0.01 0.66 0.26 N/A
1,2,3,4,7,8,9-Heptachlorodibenzofuran -- -- 0.01 -- -- N/A
1,2,3,4,7,8-Hexachlorodibenzodioxin 1.5 -- 0.01 0.15 -- ATSDR CREG 0.1 ng/kg
EPA RBC HxCDD, 78 ng/kg
1,2,3,4,7,8-Hexachlorodibenzofuran 8.5 -- 0.1 0.85 -- N/A
1,2,3,6,7,8-Hexachlorodibenzodioxin 5.6 2 0.1 0.56 0.20 EPA RBC HxCDD, 78 ng/kg
1,2,3,6,7,8-Hexachlorodibenzofuran 4 -- 0.1 0.4 -- N/A
1,2,3,7,8,9-Hexachlorodibenzodioxin 3.4 3 0.1 0.34 0.26 EPA RBC HxCDD, 78 ng/kg
1,2,3,7,8,9-Hexachlorodibenzofuran 3.5 -- 0.1 0.35 -- N/A
1,2,3,7,8-Pentachlorodibenzodioxin 0.89 -- 0.5 0.445 -- N/A
1,2,3,7,8-Pentachlorodibenzofuran 2.2 -- 0.05 0.11 -- N/A
2,3,4,6,7,8-Hexachlorodibenzofuran 4.2 -- 0.1 0.42 -- N/A
2,3,4,7,8-Pentachlorodibenzofuran 5.6 -- 0.5 2.8 -- ATSDR Intermediate EMEG: 60 ppt pica child; 2000 ppt child; 20,000 ppt adult
2,3,7,8-Tetrachlorodibenzodioxin -- -- 1 -- -- ATSDR Chronic EMEG: 2 ppt pica child; 50 ppt child; 700 ppt adults
ATSDR Intermediate EMEG: 40 ppt pica child; 1000 ppt child; 10,000 ppt adults
EPA RBC 3.9 ppt
2,3,7,8-Tetrachlorodibenzofuran -- -- 0.1 -- -- N/A
Octachlorodibenzodioxin 10,000 4400 0.001 10 4.40 N/A
Octachlorodibenzofuran 40 -- 0.001 0.04 -- N/A
TCDD Mixture Concentration       18.83 5.77

3.9 ng/kg

*ng/kg= nanogram per kilogram


Table 3.

USGS reference soil locations
USGS background soils for the conterminous United States, North Carolina, 1965
metal county level detected (ppm)-1965 range of EPA soil results, 2000 distance from Stanly county site CVs
arsenic Stanly 18 3.3-24 0 ATSDR RMEG and chronic EMEG (ppm):0.6 ppm pica child; 20 ppm child; 200 ppm adult, CREG= .5 ppm
  Randolph 4.1   17 miles  
  Mecklenburg 4.6   40 miles  
  Davie 4.2   40 miles  
  Chatham (#1) 7.6   40 miles  
  Chatham (#2) 5.6   60 miles  
  Hoke 1.2   60 miles  
  Surry 1.5330   65 miles  
  Burke 6.5   70 miles  
aluminum Stanly 50,000 6500-28,000 0 ATSDR Intermediate EMEG (ppm):
4000 pica child; 100,000 ppm child; 1,000,000 ppm adult
  Randolph 50,000   17 miles  
  Mecklenburg 100,000   40 miles  
  Davie 70,000   40 miles  
  Chatham (#1) 70,000   40 miles  
  Chatham (#2) 100,000   60 miles  
  Hoke N/A   60 miles  
  Surry 100,000   65 miles  
  Burke 70,000   70 miles  
antimony Stanly N/A ND-2.4 0 miles ATSDR RMEG (ppm):
0.8 ppm pica child; 20 ppm child; 300 ppm adult
  Randolph N/A   17 miles  
  Mecklenburg 1   40 miles  
  Davie N/A   40 miles  
  Chatham (#1) N/A   40 miles  
  Chatham (#2) N/A   60 miles  
  Hoke N/A   60 miles  
  Surry 1   65 miles  
  Burke N/A   70 miles  
barium Stanly 200 30-150   ATSDR RMEG (ppm)
100 ppm pica child; 4000 ppm child; 50,000 ppm adult
  Randolph 300      
  Mecklenburg 300      
  Davie 100      
  Chatham (#1) 300      
  Chatham (#2) 700      
  Hoke N/A      
  Surry 700      
  Burke 500      
cadmium   NOT SAMPLED ND-1.8    
iron Stanly 70,000 12,000-75,000   EPA Risk Based Concentration, 23,000 ppm
  Randolph 20,000      
  Mecklenburg 70,000      
  Davie 50,000      
  Chatham (#1) 70,000      
  Chatham (#2) 30,000      
  Hoke N/A      
  Surry 70,000      
  Burke 30,000      
manganese Stanly 2000 77-770   EPA Risk Based Concentration, 3200 ppm
ATSDR RMEG: 100 ppm pica child; 3000 ppm child; 40,000 ppm adult
  Randolph 200      
  Mecklenburg 300      
  Davie 5000      
  Chatham (#1) 3000      
  Chatham (#2) 300      
  Hoke N/A      
  Surry 700      
  Burke 150      
vanadium Stanly 300 19-84   EPA Risk Based Concentration, 5500 ppm
ATSDR Intermediate EMEG: 6 ppm pica child, 200 ppm child, 2000 ppm adult
  Randolph 70      
  Mecklenburg 150      
  Davie 150      
  Chatham (#1) 150      
  Chatham (#2) 150      
  Hoke N/A      
  Surry 150      
  Burke 100      


Table 5.

Sediment testing results for Carolina Solite vicinity and background levels, EPA, 2000
Contaminants exceeding health based guideline screening levels, Sediment (ppm)*

Contaminant Range of Detection Frequency of detection Health based guidelines
Aluminum 2300-16,000 5 of 5 samples ATSDR Intermediate EMEG (ppm):
4000 pica child; 100,000 ppm child; 1,000,000 ppm adult
Arsenic 2-70 5 of 5 samples ATSDR RMEG and chronic EMEG (ppm)
.6 ppm pica child; 20 ppm child; 200 ppm adult
CREG= .5 ppm
Cadmium ND-1.4 3 of 5 samples ATSDR Chronic EMEG
0.4 ppm pica child; 10 ppm child; 100 ppm adult
Iron 20,000-94,000 5 of 5 samples EPA Risk Based Concentration, 23,000 ppm
Lead 11-1100 5 of 5 samples EPA Risk Based Concentration, 400 ppm
Manganese 280-5300 5 of 5 samples EPA Risk Based Concentration, 3200 ppm
ATSDR RMEG: 100 ppm pica child; 3000 ppm child; 40,000 ppm adult
Vanadium 13-68 5 of 5 samples EPA Risk Based Concentration, 5500 ppm
ATSDR Intermediate EMEG: 6 ppm pica child, 200 ppm child, 2000 ppm adult

 

* ppm=contaminants reported in parts per million

Year 2000 Sediment Sampling Locations
Figure 2. Year 2000 Sediment Sampling Locations


APPENDIX F: PUBLIC COMMENTS

The Agency for Toxic Substances and Disease Registry (ATSDR) issued the public health assessmentdraft of this document for a 30-day public comment period ending October 31, 2001. A summary of thecomments received and ATSDR responses on the Public Comment Petitioned Health Assessment for theCarolina Solite Corporation, dated September 24, 2001 are summarized below:

  1. Comment: Page 1

"Unfortunately, the ATSDR continues to provide misinformation to the public by stating that it is"unable to assess health implications of past exposures." The reason given is that there are nomonitoring data available. However, there are other means of evaluating the impact of past exposures,e.g., via epidemiological studies and evaluating cancer incidents. As was emphasized in previouscomments, such studies have been conducted for the Carolina Solite facility. In fact, we believe that twopublications reporting the findings of those studies were forwarded to the ATSDR with the last round ofcomments. A third report recently has been published by S-W. Hu, M. Hazucha, and C.M. Shy in theAugust 2001 issue of the Journal of Air and Waste Management Association; a copy is enclosed. Theresults remain the same- no statistically significant association between pulmonary function andemissions the then hazardous waste incinerator. As noted at the end of the 2001 publication, the ATSDRsupported the Hazucha et. al. study. Additionally, in the last released public health assessment, theAgency evaluated cancer incidence for residents of Stanly County and found that there were nosignificant differences when compared with state and national data. The facility has been operatingsince the early 1950s, a sufficiently long period to account for latency of cancer development. TheAgency should be strongly urged to recognize the respiratory health studies and its own cancer analysis.The results provide evidence that past exposures have not caused any increased health risks to residents in Stanly County."

ATSDR Response:

The issue of historical emissions was addressed in the final version of the first PHA released for this site.Please refer to pages I-2 and I-3 in reference to the studies mentioned above. Repeated below are twoATSDR responses regarding these studies and whether or not they are accurate representations ofcommunity respiratory illness (see page I-2 of ATSDR's Public Health Assessment for Carolina Solite, released September 13, 2001):

"D) The data are not conclusive for the residents of the hazardous waste incinerator (HWI)community. One study states that "Although the slight but significantly higher odds of havingchronic respiratory symptoms among residents of the HWI community disappeared when wepooled the hazardous waste comparison population with the other two comparison populations,the result from the pooled analysis is not necessarily the correct one." In other words, the levelsof respiratory symptoms were significantly higher in the residents in the HWI community thanthe control community for the HWI community. Both of these were rural communities. However,when compared to the other two communities used as controls, these differences lost theirsignificance. Because the other two communities were urban or suburban communities, ATSDRfails to recognize them as appropriate for direct comparison with the rural affected community.Urban and suburban communities are more likely to be exposed to respiratory stressors than ruralcommunities, therefore rural communities should only be compared to rural communities. In thiscase, when the control and study population for HWIs were compared, a significant result wasobserved.

E) Assuming this is the Abermarle facility, the data have limitations. The most important is thatthe air quality study was conducted for 35 successive days of the year, and "to the extent that thisperiod of time is not representative of longer-term air quality in these communities, [theresearchers] may not be detecting differences that actually exist." Also, the HWI was not usingHWDF in the first year of the study, thus "[the researchers'] first-year results are not applicableto measuring acute respiratory effects from the burning of liquid hazardous wastes..." Theselimitations may affect the usefulness of the data in evaluating adverse health effects fromexposure to HWDF. Additionally, the time frame of the study for the study years were notcollected for a significant duration to account for seasonal variation in wind direction, wind speed, etc."

The residents living in close proximity of the facility are the most likely of Stanly County residents to beimpacted by emissions. However, cancer data are not specific to these residents. That, and the lack ofhistorical emissions, is the reason ATSDR labeled available information as "inconclusive".

  1. Comment: Page 5
  1. The Agency presents the result of its analysis and correctly finds that the levels detected inambient air do not pose a health risk to the residents of Stanly County. However, there is a glaring omission in discussing these data. The report states on Page 5:

    The background site was located in an area believed to be unimpacted by the Solite facility and the population exposure site was placed in an area believed to be a maximum impact area.

    In Table 1 of Appendix D, Frog Pond site is marked as the location for background data. Thereis no information provided with which one can identify the "population exposure site". The othersites listed in Table 1 are all located near the facility and therefore, one might assume that these are the "population location sites" to which the report infers.

ATSDR Response:

Initially, the Frog Pond site was designated as a "background site" for this investigation. Chapel Roadwas designated the "population exposure site" based on the concentration of residents and the airmodeling of maximum impacted areas. ATSDR has made the distinction for Chapel Road in Appendix D as a "population exposure site".

  1. The most interesting fact revealed by these data is not even mentioned within the text of thereport, i.e., the highest average and media concentration as well as the largest upper value in therange of detection reported for arsenic are found at the Frog Pond site, the background location.One exception is that the maximum value detected at Intersection is 10.7 nanograms per cubicmeter (ng/m3) compared with the 10.2 ng/m3 at Frog Pond. Without a statistical analysis, there isno reason to believe that these two values are statistically different. Therefore, this findingstrongly suggests that the source of arsenic in the ambient air at all monitoring locations is notthe Solite facility. Such an important finding must be presented in this report, particularly asarsenic has been a major concern for the residents of Stanly County.

ATSDR Response:

Please note that ATSDR assisted NC DHHS in the evaluation of data in this community to determinewhether or not adverse health effects would likely occur from residential exposure to heavy metals in air.It is not ATSDR's obligation to implicate or resolve the Carolina Solite facility of responsibility foremissions in the area. Based on our evaluation, residents are not expected to experience health effects based on the data we were provided for review.

  1. The Agency reports that there were significant differences between the 1999 and 2000 data.(This incorrectly implies that the highest average, median, and range of detection for arsenic inthe 1999 data also occurred at the background location.) A statistical analysis should beconducted between the two sets of data. Since this analysis is not presented the use of the word 'significant' is inappropriate.

ATSDR Response:

The reviewer misunderstood ATSDR's discussion on page 5. In the second paragraph on page 5,sentence 4 reads, "ATSDR did not find significant differences in trends in air concentrations of metals,nor was there significant differences in the concentrations of metals in air between 1999 and 2000results."

Significant in this context was used as it is defined in Webster's English dictionary, as "important ineffect or meaning", as a synonym for "important", "meaningful", "notable", or "of import". ATSDRdifferentiates mathematical significance from "important in effect or meaning" by discussing "statisticalsignificance", and not "significant (or notable) differences" in concentrations.

To ease the confusion of the reviewer, ATSDR will replace the word "significant" with the word "notable" on page 5.

  1. It should also be brought to the Agency's attention that the common practice when reportingdata, and that required by most state and federal regulatory agencies, is to present generally 2significant figures, or at a minimum no more than the number of significant figures used in thecomparison. The data in Appendix D reported in Appendix D have 3 to 4 significant figures.However, the comparison values used by ATSDR only have two significant figures. The 1999 and 2000 data presented in Tables 1 and 2 in Appendix D should be corrected accordingly.

ATSDR Response:

ATSDR represented air data in the manner in which it was formatted by NC DENR, with 4 significant figures. NC DENR provided concerned residents with the same data sets, presented in 4 significant figures. ATSDR presented the data in the same format so that residents would recognize the data which they were provided by NC DENR in Appendix D. ATSDR is aware of general rules of data presentation, however in this case it was deemed prudent to represent data to residents in a familiar format. Also, some concentrations would drop out completely if ATSDR rounded the concentrations to the nearest hundredth decimal. It is ATSDR's assumption that residents would prefer to have data sets on the public record that are identical to those reported by NC DENR.

  1. Finally, the report misrepresents the data in Table 2 of Appendix D. The title reads: Comparisonof concentrations of metals in air, Carolina Solite facility vicinity, 1999-2000 (Emphasis added).
  2. Yet, the 2000 data presented for all of the metals in columns marked average and medianconcentration range include the data collected at the background location of Frog Pond.Presumably, the same misleading reporting occurs for the 1999 data. Frog Pond is not locatedin the Carolina Solite facility vicinity and was not viewed by North Carolina as a "populationexposure location". Thus, the table should only report the range of those sites located in the"population exposure" areas, i.e. Medlin, Medlin Precision, Intersection, Hill Site, HillPrecision, and Chapel Road.

ATSDR Response:

Vicinity in this context is defined as "a surrounding or nearby region", which is suitable for the discussion and the data tables presented in Appendix D.

  1. Table 3 is also misleading. The footnote indicates that the highlighted values represent thehigher average. Yet, for arsenic the higher average is found at the background location.Therefore, highlighting population exposure locations when these reported concentration areless than the background is misleading. We are aware of the availability of a statistical analysisto determine whether there is any significant difference between high values detected atpopulation locations and that detected at a background location. Without a statistical analysis, Table 3 is scientifically meaningless.

ATSDR Response:

Table 3 is intended to give an overall comparison of the 5 monitors located in this area to characterize air quality and identify contaminants of concern (COCs) between 1999 and 2000 data. It was not intended to identify the source of metals in air, but to screen the trends of COCs in the area. Overall, it appears that the trends are relatively stable, but that slight increases occurred in 2000 for cadmium and chromium.

  1. The Agency includes a discussion of particulates in air, but does not present the data anywhere in the appendix. For consistency, these data should be presented in Appendix D.

ATSDR Response:

ATSDR agrees and has added a fourth table to Appendix D which presents TSP data for 2000.

  1. Comment: Page 6
  1. In discussing the soil sampling protocol, the report states that the location were selected forbeing "maximum impact areas". Additionally, the sediment samples included "upstream" and"downstream" samples. The report should note that no background location was selected for thesoil monitoring. A review of the map presented in Appendix E indicated that sample locationSOLO1 might represent a background location. It is in the general vicinity of the Frog Pondlocation used as background for the air monitoring. The reader would benefit greatly knowing whether and where a soil background area might have been located.
  2. The report notes that soil and sediment samples were analyzed for metals, extractable organiccompounds, pesticides, PCBs and dioxins. However, only metals and dioxin data are addressed in Appendix E. Please correct this discrepancy.

ATSDR Response:

Soil samples 01A-SF, 01B-SF, and 01C-SF were collected near the background ambient air location. Inits investigation of soil and sediment, EPA did not label these sites "background locations", howeverthey were a greater distance from the facility than the other samples collected. ATSDR has added thisinformation to the text.

ATSDR generally presents data table only for contaminants of concern, or those contaminants whichhave exceeded health based guidelines. In this case, heavy metals and dioxins/furans were the onlycontaminants which exceeded ATSDR or EPA health based guidelines, and thus are the onlycontaminants presented in the Appendix E tables.

  1. All method data presented in Table 1 of Appendix E is difficult for the reader to follow. Allsamples are presented together for a single metal. The data would be better presented followingthe format used in Appendix D, i.e., indicating a concentration for each sample location and foreach independent sample within a location duplicates were used. If that format had been used,the reader could determine whether the samples in assumed "maximum impact areas" differedfrom the background location. Such a comparison would be particularly helpful for arsenic as that is a metal of great concern for the Stanly County residents.

ATSDR Response:

ATSDR copied the original table from EPA's Soil/Sediment Investigation Report into Appendix E. The other tables will remain as a summary of pertinent information.

  1. The residential soil median and background median are reported for the dioxin/furans in Table 2of Appendix E. However the report fails to include soil median and background data for themetals. The report states that all soil samples were analyzed for metals, organics, PCBs, anddioxin/furan. Therefore, if a background concentration can be reported for dioxin, there must bea background sample value for all of the other analytes. If not available then a valid explanation should be provided.

ATSDR Response:

EPA did not make a distinction when presenting soil samples between background or non backgroundsamples. ATSDR reproduced the dioxin tables based on those presented in an EPA human'contaminants of potential concern' screening assessment written in January 2001. This report, while notthe official report, stated that "...the context in which 'background is used in this report refers to thesampling activities either upgradient or significantly downgradient from the site." Namely, thosesamples considered background are soil samples SOLSF-01A, 01B, and 01C, and sediment samplesSOLSD-01 and 05. ATSDR has included this information by including a reproduction from the original data package for this information in Table 4, Appendix E.

  1. Comment: Page 7
  1. The report discusses the fact that the maximum concentration for arsenic slightly exceeded theEMEG and RMEG values for children. In the table of soil results presented on page 7 and Table1 of Appendix E, the range of arsenic given is 3.3 ppm to 24 ppm. It would be helpful to thereader to have an opportunity to view the full data set to obtain a better understanding of thelocation of the maximum concentration. A map is provided in Appendix E indicating thelocations of the samples, but there is no information given about the results associated with any of the locations selected be "maximum impact areas". The map should address:
  • the location of the 24 ppm result
  • the distance from the facility where the maximum concentration occurred
  • explain if it was detected near farmland

ATSDR Response:

ATSDR clarified this information by adding that Samples 3a and 3b exceeded child EMEG and RMEGlevels at 24 and 21 ppm, respectively. Also, it was added that the samples were taken 50 feet north of theSolite property, and that the samples were collected in a wooded area, not on farmland.

  1. It would be helpful to the reader if the "background" data from the USGS could be presented ona map, particularly for the nine that were "within 70 miles of the 1965 Stanly County sample". Questions that need to be answered in order to determine the relevance of this comparison include:
  • Where was the 1965 Stanly County sample located?
  • Where were the nine USGS samples within 70 miles of the Stanly County sample actually located?
  • Were any of these sites near the locations of 2000 sample location SOLO1?

ATSDR Response:

The USGS regional comparison data were used as a simple screening tool for comparing the 2000 soil data to existing regional data to determine 'normal' ranges. The 2000 samples, when compared USGS data were not determined to be outside a normal range for regional data. If the samples had multiple results which exceeded these 'normal ranges' mapping may be useful to determine hot spot locations. This is not the case, and therefore, ATSDR has decided that mapping is unnecessary. However, a data table with USGS sample locations has been added to Appendix E. If the reviewer wishes to obtain specific latitude and longitude of these sample, he/she may visit www.usgs.gov, and click on "mineral spatial data", and review sampling data from North Carolina.

  1. On page 7, the report also provides a table comparing 1965 soil samples with the 2000 data. Further explanation of the table entries would be helpful to the reader. For example:
  2. Please address the difference between the columns titles "1965 contaminant mean (ppm)" and "1965 Stanly County level".

    While the report notes that arsenic and iron maximum values for the 2000 data exceed themaximum values obtained in 1965, it fails to mention that the 2000 contaminant mean reported in ppm is lower than the values reported for 1965 Stanly County level.

ATSDR Response:

ATSDR has modified this section in consideration of the comment above.

  1. Comment: Page 8
  1. The sediment sample locations represent both up and downstream locations from the facility. Itwould be helpful to the reader if the Agency provided an indication of the upstream anddownstream locations.

ATSDR Response:

ATSDR has added further clarification to the discussion by adding "Sediment samples 2, 3, and 4 werecollected downstream of the facility. Sample 2D was a duplicate of downstream sample 2. Two 'control'samples were collected upstream from the facility and it's effluent discharges."

  1. For consistency and to ensure the reader's better understanding of the data, results should bepresented by sample location for each metal as was done for the ambient air data. Because thesample SOLO1 has the appearance of being upstream, a more detailed presentation of the databy location would permit an evaluation of changes over area, a more valuable piece ofinformation than simply reporting a large range and number of samples of a total in which a metal was detected.

ATSDR Response:

ATSDR has added an additional table which organizes data results by sampling location (Table 4, Appendix E). Other data tables that have the purpose of presenting summary data of metal concentrations remain.

  1. The report notes that the maximum value reported for arsenic, cadmium, iron, and manganeseexceeded the 1976 data for maximum values. It would be helpful in evaluating these data if thereport provided the sediment results via location, particularly distinguishing between upstreamand downstream locations. The report should delineate exactly which sample location wheremaximum concentrations were detected, at SOLO1, SOLO2, SOLO3, or SOLO4? Please correctthe error on the Appendix F map. In order for a reader to determine the validity of the Agency'scomparison of the 1976 and 2000 data, it is necessary to indicate the location of these 1976 data on a map.

ATSDR Response:

ATSDR could not locate the first statement of comment 5c on page 8 in either the Initial Releasedocument of the Public Comment Release document. ATSDR did make the following statement "Of themetals sampled in sediment, arsenic, aluminum, cadmium, manganese, and vanadium exceeded ATSDREMEG and RMEG levels for children exhibiting pica behavior."

If this comment was made in regard to the table on page 8, ATSDR has addressed how data may beskewed by a single peak concentration, as often the case in 2000, on page 9. Also, page 9 states "...theconcentration ranges and mean levels are more reliable for the 1976 samples than the 2000 samplesbecause they are based on 45 samples, whereas the 2000 sample data are based on 6 samples...."

The comparison data were used as a simple screening tool for comparing the 2000 soil data to existingregional data to determine 'normal' ranges. The 2000 samples, when compared to NURE and NorthCarolina Geologic Survey data were not determined to be outside a normal range for Stanly County orNorth Carolina data. If the samples had multiple results which exceeded these 'normal ranges' mappingmay be useful to determine hot spot locations. This is not the case, and therefore, ATSDR has decided that mapping is unnecessary.

  1. Comment: Page 9
  1. The report states that "the concentration ranges of arsenic, iron, and lead exceed those of the1976 samples". Yet the table on page 8 lists the 1976 range for lead as 10-2,587 and the 2000 range as 11-1,100.

ATSDR Response:

This statement should read "the average concentration ranges of arsenic, iron , and lead...", which leadsin to the discussion about how a single peak concentration (2587 ppm in this case) can skew averages. ATSDR has added "average" to the text on page 9.

  1. In discussing the potential for a single high concentration skewing the analysis of the results, thereport notes that arsenic, iron, and lead each had a single sample that "far exceeded othersample concentrations for the same metals". It then provides examples for iron and lead. Why isthere not an example for arsenic, particularly as that is a metal of high concern for the public?

ATSDR Response:

See the sentence "The highest arsenic concentration measured in 2000 was 70 ppm, but the rest of thesamples were measured at 34, 12, 11, 10, and 2 ppm." ATSDR has added "detected in sediment sample 3", to clarify the location of the elevated sample.

  1. The Agency reports that the highest iron concentration was detected at location 1, whichappears to be upstream of the facility The lower concentration mentioned for iron is downstreamand located in the proximity of the facility. The lead discussion fails to provide a samplelocation. Consistency among the different metal discussions would benefit the reader'sunderstanding. The point of a single sample skewing the results strongly supports a need for data presented in Appendix F to be reported by individual sampling locations.

ATSDR Response:

ATSDR will add "170 ppm in sediment sample 3" to clarify the location of the next highestconcentration of lead in sediment samples.

  1. Comment: Page 11

In discussing the various sources of cadmium in food, it would be helpful to the reader to provide some sample concentrations. The food concentrations would help put the Stanly County air, soil, and sediment levels in context.

ATSDR Response:

ATSDR will add the following information:

Milk, dairy products, eggs, beef, and fish usually contain <0.01 mg/kg (ppm) cadmium, while higherconcentrations, 0.01-0.10 mg/kg are typically found in vegetables, fruits, and grains.

Potatoes (average concentration of 0.0421) and leafy vegetables (av. 0.0328) have the highestconcentrations (Source Gartrell, et al. 1986. Pesticides, selected elements, and other chemicals in adulttotal diet samples, October 1980- March 1982. J Assoc Off Anal Chem 69:146-161).

  1. Comment: Page 13

The section titled, Other contaminants exceeding ATSDR CVs, redundantly discusses arsenic. Arsenic has already been fully discussed on pages 10 and 11.

ATSDR Response:

Arsenic was not discussed in this section, but was mentioned in error in the first sentence. The word'arsenic' as well as 'cadmium' has been removed from that sentence, as they were previously discussed.

  1. Comment: Page 14

The following statement could benefit from additional text:

Iron was detected at its highest concentration (94,000 ppm) at the background site, which is upstream ofthe facility as well as upstream of the facility effluent discharges.

The text might also state..."Therefore, the Solite facility is an unlikely source of iron found in the StanlyCounty area." Also, this statement adds strength to the above suggestion that the soil and sediment datashould be presented in a manner consistent with the ambient air data, i.e., by sample location for each metal.

ATSDR Response:

ATSDR does not deem it necessary to clarify the statement in the suggested manner. The commentsalready included make the point that most likely the iron elevations in this area are naturally occurring.The report states "...iron,... an essential nutrient...", and "... many of these minerals, including iron, arenaturally occurring in this area, and are common, even essential, components of a normal diet....".

  1. Comment: Page 16

The following statement made in the report at the start of the Conclusion is misleading to the reader:

Data collected in 1999 and 2000 do not indicate the existence of a health hazard at this time for theresidents living in the vicinity of the Carolina Solite facility.

Nowhere in this report has the Agency determined that the presence of metals in the environment ofStanly County is due to activities of the Carolina Solite facility. Such a determination would require astatistical analysis of the potential difference between background and "exposure" locations. Yet, thelimited data presented that distinguishes between a background location and the rest of the sampleareas, appears to suggest that the source of these metals in air, soil, and sediment is not the Carolina Solite facility. For example:

  • Arsenic ambient air concentrations were highest at the background location of Frog Pond

  • There were no statistical analysis to determine whether ambient air concentrations of other metals were significantly higher at the population exposure locations when compared to the Frog Pond results.

  • Lead sediment concentrations suggest that the facility is not the source (see the discussion on page 14); again there is no statistical analysis with which one can determine whether significant differences exist between background results and downstream locations.

  • The highest iron concentrations in soil occurred at the background site. Without a statistical analysis, there is no evidence that significant differences exist between background concentrations for other metals and the maximum impact area results.

The conclusions reached by ATSDR would be more accurate and not misleading if it stated:

Data collected in 1999 and 2000 do not indicate the existence of a health hazard for residents living inStanly County. No conclusive evidence currently exists that would support a view that the CarolinaSolite facility is a contributor, or even a major contributor, to the range of analytes evaluated in air,soil, or sediment detected in the Stanly County environment.

ATSDR Response:

As mentioned previously, it should be noted that ATSDR assisted NC DHHS in the evaluation of data inthis community to determine whether or not adverse health effects would be likely to occur fromresidential exposure to heavy metals in air. It is not ATSDR's obligation to implicate or resolve theCarolina Solite facility of responsibility for emissions in the area. Based on our evaluation, residentsare not expected to experience health effects based on the data we were provided for review. If a healthhazard had been identified by ATSDR's investigation, the aid of regulatory agencies may have beenenlisted to determine the source of harmful emissions, and then to decrease or cease the exposure ofresidents to harmful exposures by undertaking regulatory action.

  1. Comment:

EPA Facility ID Number

The EPA facility ID number shown on the cover of the report and the subsequent cover page isincorrect. The correct EPA facility ID number for the facility is NC003152642.

ATSDR Response:

The Carolina Solite record in ATSDR's Hazardous Substance Release and Health Effects Database(HAZDAT) is a Comprehensive Environmental Response, Compensation, and Liability InformationSystem (CERCLIS) record; Superfund number 0403022, and CERCLIS facility identification numberNCD980557730. The official facility location in CERCLIS is "CAROLINA SOLITECORP/AQUADALE, RTE 2, NORWOOD, NC 28128". Several years ago years ago, the Superfundprogram archived (i.e., NFRAP=No Further Remedial Action Planned) the site. The NFRAP record canbe found online via the Superfund Site Information site. See www.epa.gov/superfund/sites/arcsites. TheID number ATSDR uses is correct based on CERCLIS information.

The number NCD003152642 is the RCRA "Handler ID" number and the RCRA site location is listed as"SOLITE CORPORATION GIANT RESOURCE RECOVERY INCORPORATED, 12423 OLDAQUADALE RD., NORWOOD, NC 28128" (as found in Envirofacts).

Because ATSDR is a Superfund agency, we are obliged to keep our data synchronized with EPA's Superfund data. The ID number remains because of these reasons.



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