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PETITIONED PUBLIC HEALTH ASSESSMENT

SITES IN
BLUEFIELD, WEST VIRGINIA; BLUEFIELD, VIRGINIA; AND VICINITY


APPENDIX A: SAMPLING DATA

Table 1A Summary of Soil, Waste, and Chemical Contaminants withComparison Values

Table 1B Summary of Water Contaminants with Comparison Values

Table 2 Acken Sign Service Monitoring Data

Table 3 Appalachian Power Company Service Center Monitoring Data

Table 4 Bernard Neal Property Monitoring Data

Table 5 Bull Tail Hollow Data

Table 6 Joy Manufacturing Monitoring Data

Table 7 Lin-Electric Co., Inc. Monitoring Data

Table 8 Mercer County Landfill Monitoring Data

Table 9 Sam Neal Property Monitoring Data

Table 10 Bluefield WV Public Water Supply Monitoring Data



TABLE 1A

Human Health Effects at Various Hydrogen Sulfide Concentrations in Air
COMPOUND MAXIMUM
SOILS
(ppm)
CONCENTRATIONS
WASTES/CHEMICALS
(ppm)
COMPARISON
VALUE
(ppm)
SOURCE
PCBs 22,000 13,000 0.09 CREG
2,3,7,8-TCDD 0.012* 0.048* 0.00005 EMEG
Dibenzofuran 0.0095** 0.00053 none none
TCE 20 34,000 60 CREG
2,4-D no data 48,000*** 500 RfDG
2,4,5-T no data 48,000*** 500 RfDG
Picloram no data 8,900*** 4,000 RfDG
MAM no data 22,000*** none none

==================  

* - includes all PCDDs
** - includes all PCDFs
*** - estimated concentration in liquid when sprayed
ppm - parts per million
PCDDs - polychlorinated dibenzodioxins
PCDFs - polychlorinated dibenzofurans
PCBs - polychlorinated biphenyls
2,3,7,8-TCDD - tetrachlorodibenzo-p-dioxin
TCE - trichloroethylene
2,4,-D - 2,4-dichlorophenoxyacetic acid
2,4,5-T - 2,4,5-trichlorophenoxyacetic acid
MAM - monosodium acid methanearsonate
EMEG - ATSDR Environmental Media Evaluation Guide
RfDG - US EPA Reference Dose-based Guide
CREG - ATSDR Cancer Risk Evaluation Guide

 

TABLE 1B

SUMMARY OF WATER CONTAMINANTS WITH COMPARISON VALUES
COMPOUND
MAXIMUM
CONCENTRATIONS
(ppm)
COMPARISON
VALUE
(ppm)
SOURCE
PCBs ND or NI ---- ----
2,3,7,8-TCDD ND or NI ---- ----
Dibenzofuran NI ---- ----
TCE 1.9* 0.003 CREG
2,4-D NI ---- ----
2,4,5-T NI ---- ----
Picloram NI ---- ----

MAM

NI ---- ----

==================

* - cleanup rinse water
ND - not detected
NI - no information
PCBs - polychlorinated biphenyls
2,3,7,8-TCDD - tetrachlorodibenzo-p-dioxin
TCE - trichloroethylene
2,4,-D - 2,4-dichlorophenoxyacetic acid
 2,4,5-T - 2,4,5-trichlorophenoxyacetic acid
 MAM - monosodium acid methanearsonate
CREG - ATSDR Cancer Risk Evaluation Guide


Table 2.

ACKEN SIGN SERVICE MONITORING DATA
BEFORE CLEANUP--ON SITE:  

PCBs inside building:

 

surfaces (wipe samples)
concrete chips
dust collected from surfaces
wood fragments
sediment in drain
paint
resinous material on floor
air

79 ug/100 cm2 (maximum value)
940 ppm (maximum value)
150 ppm (maximum value)
36 ppm (maximum value)
<1 ppm (one test)
8 ppm (one test)
11 ppm (one test)
<0.01 ug/liter

PCBs outside building:

 

sludge in drain
pavement surface (wipe sample)
soil under graveled area

3 ppm (one test)
<1.1 ug/100 cm2 (one test)
<1 ppm (maximum value)

AFTER CLEANUP--ON SITE:

 

PCBs inside building:

 

surfaces (wipe samples)

6.2 ug/100 cm2 (maximum value)

ug - microgram
cm - centimeter
ppm - parts per million
PCBs - polychlorinated biphenyls

 

Sources: (3,10,11)

 

   


SOILS

Table 3.

APPALACHIAN POWER COMPANY SERVICE CENTER MONITORING DATA
ON SITE:  

PCBs, by east property line
PCBs, by north property line

60 ppm (maximum value)
3 ppm (maximum value)
OFF SITE:  

PCBs, downslope of northeast area of site
PCBs, beyond northcentral area of site
PCBs, beyond northwest area of site

62 ppm (maximum value)
<1 ppm (maximum value)
0.084 ppm (maximum value)

ppm - parts per million
PCBs - polychlorinated biphenyls

 

Source: (6,12,13)

 

 


SOILS

Table 4.

BERNARD NEAL PROPERTY MONITORING DATA
ON SITE:

 

February 1986

 

PCBs

1,600 ppm (maximum value)

April 1986

 

PCBs (Aroclor 1248, 1254)
PCDDs (total)
PCDFs (total)

360 ppm (maximum value)
0.002 ppm (maximum value)
0.0095 ppm (maximum value)

December 1986

 

PCBs (1248, 1254)

690 ppm (maximum value)

June 1993

 

PCBs (total)
PCDDs, PCDFs*

687 ppm (maximum value)
0.004 ppm (maximum value)


ug - microgram
cm - centimeter
ppm - parts per million
PCBs - polychlorinated biphenyls
PCDDs - polychlorinated dibenzodioxins
PCDFs - polychlorinated dibenzofurans
* - as 2,3,7,8-tetrachlorodibenzodioxin equivalents

Sources: (14,15,16)

Table 5.

BULL TAIL HOLLOW ATSDR CALCULATED SPRAYING DATA *
  Calculated Values *
Principal Compounds

Calculated
Concentrations
in Spray
(maximum values)

Calculated
Distribution
on Ground
(maximum values)

2,4-D

48,000 mg/L (4.8 percent) 63 mg/sqft

2,4,5-T

48,000 mg/L (4.8 percent) 63 mg/sqft
TCDD ** 0.048 mg/L (4.8E-6 percent) 0.00006 mg/sqft
Additional Compounds    

Picloram

8,900 mg/L (0.89 percent) 15 mg/sqft

Monosodium Acid

   

Methanearsonate

22,000 mg/L (2.2 percent) 46 mg/sqft


* - Monitoring data are not available for any media.
ATSDR used information provided by the power company to calculate 1) contaminant concentrations in the liquids sprayed and 2) estimated amounts of sprayed contaminants on the ground (soil, vegetation, etc.,).
** - calculated values based on ATSDR assuming 1 ppm TCDD
concentration in 2,4,5-T
ppm - parts per million
mg/L - milligrams per liter
mg/sqft - milligrams per square foot
2,4-D - dichlorophenoxyacetic acid
2,4,5-T - trichlorophenoxyacetic acid
TCDD - 2,3,7,8-tetrachlorodibenzo-p-dioxin

Source: (18)


Table 6.

(Page 1 of 7) JOY MANUFACTURING MONITORING DATA BEFORE CLEANUP
ON SITE:  
PCBs in soils 220,000 ppm (maximum value)
PCDDs, PCDFs in soils  0.00259 ppm * (maximum value)
PCBs inside building:  
paint chips 17,100 ppm (maximum value)
wood 300 ppm (maximum value)
concrete chips 1,300 ppm (maximum value)
oil in storage drum 3 ppm (one test)
surfaces (wipe samples) 430,000 ug/100 cm2 (maximum value)
surfaces (wipe samples) 290,000 ug/m2 (maximum value)
PCDDs, PCDFs inside building:  
paint chips 0.066 ppm * (maximum value)
wood 0.013 ppm * (maximum value)
   
OFF SITE:  
PCBs in soils in swale/swamp ** 58,200 ppm (maximum value)
PCBs in soils in swale, **
downgradient from swamp
15 ppm (maximum value)
PCBs in soils, in ditch by site
fence along Washington Street
560 ppm (maximum value)
PCBs in soils, east of Washington
Street, near residences
<1 ppm (maximum value)
 PCDDs in soils by perimeter fence 0.0012 ppm * (one test)
PCDDs, PCDFs in soils
in swale/swamp **
0.00095 ppm * (one test)


ug - microgram
cm - centimeter
m - meter
ppm - parts per million
PCBs - polychlorinated biphenyls
PCDDs - polychlorinated dibenzodioxins
PCDFs - polychlorinated dibenzofurans
* - as 2,3,7,8-tetrachlorodibenzodioxin equivalents
** - on or near Galliat property

Sources: (5,6,19,20,21,22,23)


Table 6.

(Page 2 of 7) JOY MANUFACTURING DURING CLEANUP
ON SITE:  

PCBs in surface soils
PCBs in soils, subsequently covered
with concrete
PCBs in concrete, subsequently covered
with concrete slab
PCBs in stair tread (wipe sample), tread
subsequently removed

8 ppm (maximum value)
2,400 ppm (maximum value)

680 ppm (maximum value)

13,000 ug/100 cm2 (one test)


OFF SITE:
 

PCBs in surface soils *
PCBs in soils, in excavated ditch by site
fence along Washington Street, prior to
backfilling with clean soil

<1 ppm (maximum value)
24 ppm (maximum value)
PCBs in concrete 2 ppm (one test)


ug - microgram
cm - centimeter
ppm - parts per million
PCBs - polychlorinated biphenyls
* - on remediated and other portions of Galliat property

Sources: (24,25,26,27)


AFTER CLEANUP
(ASSESSMENT A)

Table 6.

(Page 3 of 7) JOY MANUFACTURING
ON SITE:  

PCBs in black material at edge of concrete
pad near east property line
PCBs in black material taken from under concrete slabs
PCBs in wood chips from stairway
PCBs in wood slivers from roof member
PCBs in concrete wall (wipe sample)

13,000 ppm (one test)

3,410 (maximum value)
624 ppm (one test)
102 ppm (one test)
53 ug/100 cm2
(one test)


ug - microgram
cm - centimeter
ppm - parts per million
PCBs - polychlorinated biphenyls

Source: (28)


Table 6.

(Page 4 of 7) JOY MANUFACTURING AFTER CLEANUP (ASSESSMENT B)
ON SITE:  

PCBs in interior walls and
floors (wipe samples)
PCBs in asphalt taken from a trench
PCBs in black material at edge
of concrete pad near east property line
PCBs in surface soils outside building
PCBs in soils beneath concrete
outside building
PCBs in soils in pit in building
PCDDs and PCDFs in black material
at edge of concrete pad near
east property line
PCDDs and PCDFs in sample of asphalt

8 ug/100 cm2 (maximum
value)
2,100 ppm (one test)
1,000 ppm (one test)

28 ppm (maximum value)
1,100 ppm (maximum value)

0.33 ppm (maximum value)
0.00053 ppm * (one test)


<0.001 ppm * (one test)
OFF SITE:  

PCBs in soils, in ditch by site fence
along Washington Street
PCBs in soils across street south
of site (background sample)
PCDDs and PCDFs in soils across street
south of site (background sample)

0.18 ppm (maximum value)

<0.025 ppm (one test)

<0.001* ppm (one test)


ug - microgram
cm - centimeter
PCBs - polychlorinated biphenyls
PCDDs - polychlorinated dibenzodioxins
PCDFs - polychlorinated dibenzofurans
* - as 2,3,7,8-tetrachlorodibenzodioxin equivalents

Source: (29)


Table 6.

(Page 5 of 7) JOY MANUFACTURING AFTER CLEANUP (ASSESSMENT C)
ON SITE:  

PCBs in surface soils
PCBs in soils/black material
beneath concrete slabs
PCBs in concrete dust from borehole
PCBs on hard surface (wipe sample)
PCBs in paint chips swept from floor
PCBs in chips from cinder blocks

25 ppm (maximum value)
5,700 ppm (maximum value)

1,400 ppm (maximum value)
87 ug/100 cm2 (one test)
743 ppm (one test)
305 ppm (maximum value)


ug - microgram
cm - centimeter
ppm - parts per million
PCBs - polychlorinated biphenyls

Source: (30)


Table 6.

(Page 6 of 7) JOY MANUFACTURING AFTER CLEANUP (ASSESSMENT D)
ON SITE:  

PCBs in surface soils
PCBs in site runoff water
PCBs in air

3.2 ppm (maximum value)
ND
ND
OFF SITE:  

PCBs in surface soils
(on Galliat property)
PCBs in pond sediment
(on Galliat property)
PCBs in site runoff water

1.8 ppm (maximum value)

0.03 ppm (one sample)

ND


ppm - parts per million
PCBs - polychlorinated biphenyls
ND - not detected

Source: (31)


Table 6.

(Page 7 of 7) JOY MANUFACTURING AFTER CLEANUP
OFF SITE:  

PCBs in surface soils at
residences and businesses
PCBs in surface soils at eastern
part of swale
PCBs in surface soils at western
part of swale, toward high school

1.3 ppm (maximum value)

ND

0.19 ppm (maximum value)


ppm - parts per million
PCBs - polychlorinated biphenyls
ND - not detected

 

Source: (13)

Table 7.

LIN-ELECTRIC CO., INC. MONITORING DATA BUILDING/GROUNDS DECONTAMINATION BEFORE CLEANUP
ON SITE:  

PCBs in floor residue
PCBs in residues on hard surfaces
PCBs in sludges
PCBs in waste oil
TCE in soil
TCE in sludges
TCE in solids
TCE in tank residue
TCE in wastes or residues

36 ppm (one test)
0.015 mg/wipe (maximum value)
<1 ppm (maximum value)
5 ppm (one test)
20 ppm (one test)
8,400 ppm (maximum value)
34,000 ppm (maximum value)
1,500 ppm (one test)
660 ppm (maximum value)
 
DURING/AFTER CLEANUP
ON SITE:  

PCBs in rinse water or drain water
cleanup areas
PCBs in residues on hard surfaces
TCE in rinse water or drain water

32 ppm (maximum value)

0.015 mg/swab (maximum value)
1.9 ppm (maximum value)


mg

- milligram

ppm - parts per million
PCBs

- polychlorinated biphenyls

TCE - trichloroethylene

Source: (8)

Table 8.

MERCER COUNTY LANDFILL MONITORING DATA RUNOFF POND SEDIMENT AND LEACHATE-STAINED SOIL *
ON SITE:  

PCBs
PCDDs and PCDFs

ND
0.00075 * ppm (maximum value)


ppm - parts per million
ND - not detected
PCBs - polychlorinated biphenyls
PCDDs - polychlorinated dibenzodioxins
PCDFs - polychlorinated dibenzofurans
* - as 2,3,7,8-tetrachlorodibenzodioxin equivalents,
calculated by ATSDR using laboratory data presented
in source document.

Source: (32)

SOILS

Table 9.

SAM NEAL PROPERTY MONITORING DATA
ON SITE:  
February 1986  

PCBs
PCDDs

340 ppm (maximum value)
0.0039 ppm (maximum value) *
March 1987  

PCB, Aroclor 1254
PCB, Aroclor 1242
PCDD and PCDF

250 ppm ** (maximum value)
92J ppm ** (maximum value)
less than 0.001 ppm * (maximum value)
October 1987  

PCBs, Aroclors 1248, 1254
PCBs (in background sample)

33 ppm (maximum value)
ND
June 1993  
PCBs Aroclor 1254
PCBs (total; may be affected by burn ash)
PCBs (in unoccupied house basement)
PCDD and PCDF (in unoccupied
house basement)
PCDD and PCDF (may be affected
by burn ash)
0.82 ppm (maximum value)
55 ppm (maximum value)
3.59 ppm (maximum value)
0.0016 ppm * (maximum value)

0.094 ppm * (maximum value)


J - estimated value
ppm - parts per million
PCBs - polychlorinated biphenyls
PCDDs - polychlorinated dibenzodioxins
PCDFs - polychlorinated dibenzofurans
* - as 2,3,7,8-tetrachlorodibenzodioxin equivalents
** - data judged to be of questionable reliability by EPA
and additional sampling conducted in October 1987.

Sources: (16,33,34,12)

Table 10.

BLUEFIELD WV PUBLIC WATER SUPPLY MONITORING DATA RAW WATER AND TREATED WATER
PCBs
PCDDs
PCDFs
Trichloroethylene
ND (0.001 ppm)
ND (0.01 ppm)
ND
ND (0.001 ppm)


PCBs - polychlorinated biphenyls
PCDDs - polychlorinated dibenzodioxin
PCDFs - polychlorinated dibenzofurans
ND - not detected
(0.001 ppm) - test quantitation limit

 

Sources: (13,35,36)


Appendix B summarizes the comments received on the Public Comment Release edition of the public health assessment and ATSDR's response to those comments. Page and paragraph numbers noted in the following discussion refer to the Public Comment Release edition. This document has been revised, where noted, in response to comment issues.

APPENDIX B: RESPONSE TO COMMENTS

Comment 1: Page 58--A commenter reports that three sites have been recommended for inclusion on CERCLIS; two sites (Blacor Steel and the Old Bluefield, Virginia, Landfill) were accepted and are now on CERCLIS. Placement on CERCLIS indicates that a Preliminary Assessment will be performed within a year.
Response: The document has been revised.
Comment 2: A commenter says information about civil litigation involving the Joy facility and former workers should be addressed in the document.
Response: The document has been revised.
Comment 3: A commenter says that two owners of land adjacent to the Galliat property filed lawsuits against Joy, claiming that their property was contaminated with PCBs. Those cases were dismissed because neither owner could produce any evidence of contamination.
Response: The document has been revised.
Comment 4: Page 1; Joy Facility--A comment about the former Joy facility and its use of trichloroethylene was was subsequently recinded.
Response: Document was not changed.
Comment 5:

Page 1--A commenter proposes that "potential" be inserted in front of "exposure(s)" in three places on this page.

Response: The exposures referred to were either deleted or characterized as "likely".
Comment 6: Page 1; APCO and Sam Neal Property--A commenter requests clarification: does the phrase "...a small increased risk for cancer for those working or living at those locations..." refer to traditional, conservative, 70-year exposure calculation of assessing carcinogenic risks for lifetime exposure?
Response: Yes, this statement does refer to a traditional, conservative 70-year calculation. For more information, see the Toxicological Evaluation section.
Comment 7: Page 1--A commenter proposes that the text "...more deaths than expected..." be revised to "...more deaths than expected due to this disease..."
Response: The document has been revised.
Comment 8:

Page 2--A commenter proposes that the text "Petitioners...reported that they have been exposed...." should be amended to "Petitioners...reported that they have potentially been exposed...."

Response: The document accurately reflects the manner in which those parties expressed their exposure concerns. The document has not been changed.
Comment 9: Page 3; Joy Facility--A comment about TCE was subsequently recinded. Commenter also mentioned steam cleaning and described the low levels of TCE in soils. Commenter also says that the available soil and concrete PCB testing indicate that solvents had not been extensively applied to the floors within the building.
Response: ATSDR has modified the document relative to steam cleaning. ATSDR is not convinced that the PCB levels in concrete--nor the levels of TCE (a volatile compound) in soils--are a reasonable measure of solvent quantities applied to floors at the Joy facility. Thus the document has not been changed for that issue.
Comment 10: Page 3; Joy Facility--A commenter suggests that the phrase "...and other such activities released...." should be revised to "...and other such activities potentially released...."
Response: The statement describes general release information and is not intended to single out a specific location. There are ample sampling data that shows many releases occurred--those were actual releases, not potential releases. The document was not revised.
Comment 11: Page 8; Joy Facility--A commenter reports that Aroclor 1254 was not known to have been at the Joy Facility.
Response: The document has been revised.
Comment 12:

Page 8; Joy Facility--A commenter identifies the phrase "Motors were degreased and baked in ovens..." and reports that motors were degreased via steam cleaning; after dismanteling, parts were degreased with solvents, including some limited use of TCE.

Response: The document has been clarified.
Comment 13: Page 8; Joy Facility--Concerning the phrase "...and some waste coolants were poured onto the ground and into building drains."; a commenter says that building drains were not discovered during facility cleanup.
Response: The document has been amended to include that information.
Comment 14: Page 8; Joy Facility--Concerning the phrase "In the mid-1980's, under EPA oversight..."; a commenter proposes that it be made more specific as follows: "Beginning in 1986, until 1988, under EPA oversight..."
Response: The document has been revised.
Comment 15: Bottom of Page 8, continuing onto Page 9; Joy Facility--A commenter proposed several refinements to that text intended to clarify discussion of cleanup actions.
Response: ATSDR considers that the commenter's intent has been achieved by ending that discussion with a statement provided by the commenter: "All areas known to be contaminated with PCBs were cleaned under EPA oversight to achieve the required cleanup criteria."
Comment 16: Page 13; Joy Facility--A commenter suggests that the phrase "...because EPA remediation was insufficient..." should be changed.
Response: The document has been revised: "because remediation (under EPA oversight) was insufficient..."
Comment 17: Page 16; Acken Sign--A commenter suggests a minor word change concerning PCBs in building concrete and dust at the Acken Sign site. Commenter also says those materials were subsequently decontaminated or cleaned up.
Response: These issues are addressed more comprehensively under other comments presented later in this section.
Comment 18. Page 16; APCO and Joy Facility--Under APCO depot: a commenter reports concerns about the following sentence: "However, it is not clear whether any of the westerly samples were taken where the highest concentrations conceivable might occur, such as in the runoff flow line or at the embankment by the high school where ponding is likely to occur." Specific issues are:

 

1) Commenter says that samples were taken in the "APCO Drainage Ditch" that extends down to the marshy area.

2)

Commenter says sampling extended laterally until consecutive sample locations towards the high school indicated nondetectible results for PCBs.

3)

Commenter believes that the embankment at the school is uphill from the marshy area near Joy.

4)

Commenter says it is unlikely that PCBs could be located at the high school due to runoff.
Response:

With respect to 1) & 2) above: ATSDR is aware of the samples in the "APCO Drainage Ditch" and the swale soil sampling toward the high school. Based on results of additional sampling conducted in 1993 that show PCB concentrations, where detected, in the western swale are low; the entire sentence quoted by the commenter has been deleted.

Concerning 3) & 4) above: ATSDR personnel walked the swale. Although there is a depression in the swale flow line at the marshy area near the Joy facility, the overall flow gradient in the swale is clearly toward the embankment. Ponding water-marks were observed on the embankment slope. During "heavy" runoff, ATSDR was told, water overflows the depression at the marshy area, and there is substantial westward flow. That flow could have resulted in deposition westward, beyond the marshy area, along the swale flow line and at the embankment. Such deposition might have been the source of the low levels of PCBs detected in the western swale in 1993. The document has not been revised with respect to these issues.

Comment 19: Page 21--A commenter requests that "PCBs...a limited extent..." be changed to "PCBs...a very limited extent..."
Response: The document has been changed.
Comment 20: Page 25; APCO and Joy Facility--A commenter disagrees with information in Paragraph 2; "However, sampling may not have been sufficiently extensive.....by the high school."
Response: That information has been substantively revised and relocated to the Joy Manufacturing section.
Comment 21: Page 25; APCO and Joy Facility--A commenter disagrees with "A broad shallow depression...could be a surface expression of a sink hole.
Response: In ATSDR's judgement, the evaluations performed and the reported absence of groundwater within borings do not convincingly show that the depression is not associated with a sinkhole. The document has not been changed.
Comment 22: Page 32; Joy Facility--A commenter disagrees with "...however, if a business reactivates the property or the property is developed for residences without additional cleanup, substantial exposure to contaminants of concern is likely to occur..." The commenter asserts that the sampling results indicate that the majority of elevated PCB concentrations are contained within materials that are not accessible for contact. Commenter also says that those samples, apparently, were purposely located to find "worst-case" residual concentrations.
Response: The document does say that substantial exposure is not likely if the site remains fenced, inactive and intact. At present, the majority of the substantively elevated residual PCB concentrations appear to be contained within materials that are not readily accessible for exposure. However, reuse of the site by industry or for residences would result in activities (the most severe might include demolition, remodeling, and construction) that would make those contaminated materials more accessible. Also, post-cleanup surface soil data show residual levels of PCBs as high as 28 ppm. Thus, ATSDR believes its characterization of exposure is appropriate for the circumstances described. The document has not been revised.
Comment 23: Page 32; APCO and Joy Facility--A commenter takes issue with "...sampling data may not be sufficient...to confirm whether contaminants are present..." in the westerly swale area "at concentrations for which infrequent exposure would pose a health concern."
Response: The issue has been substantively revised to reflect the results of the 1993 sampling in that area.
Comment 24: Page 32; APCO and Joy Facility--A commenter takes issue with: "Groundwater sampling data have not been developed to determine whether groundwater resources have been contaminated in the vicinity of..." Commenter says four borings were installed (some to 70 feet) and groundwater was not encountered. Also, PCB contamination of soils was limited to surface and near surface soils. Therefore, it is highly unlikely that PCBs migrated to depths upwards of 70 feet. Also, analyses indicates that the facility may be located in an area where there is no continuous aquifer.
Response:

Elsewhere in the document, especially Page 25, ATSDR identified its belief that sampling data and site-specific geologic data are not sufficient to confirm either groundwater contamination or migration mechanisms.

 

ATSDR believes that groundwater does occur in the area. The commenter confirms that groundwater was not encountered within their boring depths and hence, no samples could be taken to determine whether contamination is present in the underlying groundwater system.

In ATSDR's opinion, the available information does not reasonably eliminate the possibility of a sinkhole in the swale depression. A sinkhole, if it exists, could have provided (prior to remediation of the depression) a relatively rapid migration route to the groundwater system at considerable depth. That migration would be independent of what might migrate elsewhere from contaminated soils.

The document has been changed to reflect that several borings did not encounter groundwater; and, thus, no data have been developed to determine whether groundwater is contaminated.

Comment 25: Page 50--A commenter takes issue with "There have been exposures of workers..." Commenter requests a change to "There have been potential exposures of workers..."
Response: For the type of work activities conducted, ATSDR considers worker exposure was likely. The document has been modified.
Comment 26: Page 51--Commenter takes issue with all statements under General Recommendations Nos. 1, 2, 3, and 4, saying they do not appear to be necessary based upon commenter's analyses of the data in the report. These appear to be research-oriented, "nice to have" and/or "make work" items.
Response: ATSDR considers these to be appropriate for evaluation of public health issues. None have been eliminated from the document.
Comment 27: Page 54; Joy Facility--Commenter takes issue with "Also maintain the pavements and concrete slabs that cover contaminated soils." The change requested; "Also...that cover potentially contaminated soils."
Response: The data indicate that some contaminated soils remain beneath pavements and slabs. That represents actual--not potential--contamination. The document has not been changed.
Comment 28: Page 55; Joy Facility--Commenter asks that Recommendations 3 and 4 be deleted.
Response:

ATSDR considers the recommended sampling to be warranted in the event those properties are used/developed. The recommendations have not been deleted.

Comment 29: Page 62; Reference No. 35--A commenter suggests that the date should be 1993, rather than 1933.
Response: The document has been changed.
Comment 30: Page 77; Joy Facility--A commenter indicates the phrases "PCBs in soils, subsequently covered with concrete" and "PCBs in concrete, subsequently covered with concrete slab" may be misleading. Commenter reports that extensive EPA oversight was performed during cleanup and all cleanup criteria were achieved as required by EPA's order.
Response: ATSDR reported on Page 8 that the clean-up activities were conducted under EPA oversight. Rather than restate that issue on this and other tables, it is more appropriate to restate it on Page 18 of the contamination section, where site cleanup is discussed. Thus, the text--not the table--has been changed.
Comment 31: Page 1; Acken Sign Services--A commenter refers to "Ongoing human exposure...may be occurring for workers at Acken Sign Services..." Commenter requests ATSDR to review information submitted concerning remediation at the facility.
Response: Based on the data received, reference to Acken Sign was deleted.
Comment 32: Page 1; Acken Sign Services--A commenter refers to: "Because of insufficient environmental data, it is impossible to determine the health consequences of workers exposure or other possible exposures to PCBs at Acken Sign Services." Commenter mentions investigations before and after remediation, wonders why the site is singled out as having insufficient data, and wonders whether the 1990 remediation report was not considered.
Response: Based on the data received, this sentence was deleted.
Comment 33: Page 5; Acken Sign Services--A commenter asserts the 1990 remediation effort and results should be described here.
Response: The 1990 remediation activities have been added to that discussion.
Comment 34: Pages 15 & 16; Acken Sign Services--A commenter requests that those sections be updated to reflect decontamination.
Response: Discussion on Pages 15 & 16 has been modified to reflect decontamination.
Comment 35: Pages 23 & 24; Acken Sign Services--A commenter objects to using unverified, uncollaborated statements as fact and making assumptions based on that information. Commenter also objects to assumptions about facility operation. Commenter says those do not fulfill the scientific objectives of this health assessment.
Response: ATSDR frequently receives unverified information about facility activities from facility owners, workers, and community members. Unverified information frequently is an important resource for fulfilling the overall objectives of the public health assessment process. ATSDR tries diligently to use such information appropriately. The specific issues raised by the commenter are addressed in subsequent comment/response items.
Comment 35A: Page 23; Acken Sign Services--Commenter is concerned about resident's statement: "in earlier years..workers did not use protective equipment and came into contact with..." Commenter said they cannot verify that resident's statement. (Commenter did not provide information about workers' practices during those years).
Response:

ATSDR's policy is to identify and evaluate actual and potential exposures that may affect public health. The resident's statement is consistent with information ATSDR frequently hears for worker practices prior to the advent of concern for chemicals. Inadequate worker protection and work habits and resultant exposure are much more likely to have occurred then than for workers to have been fully protected and to have experienced no exposure. Therefore, ATSDR considers exposure was likely to have occurred. Except for minor word changes, the document has not been changed.

Comment 35B: Page 23; Acken Sign Services--Commenter is concerned about a statement concerning a (former) PCB pathway from transformer oils to a vented oven to ambient air.
Response: ATSDR's statement did not specify PCBs, it specified contaminants of concern, which include solvents and PCBs. In the absence of clear information to the contrary, ATSDR believes it is appropriate to consider that motor or transformer parts placed in the oven had some solvents or PCBs on their surfaces and to consider that the oven was vented to ambient air. Thus, the document has not been changed.
Comment 35C: Page 23 and 24; Acken Sign Services--Commenter is concerned about the (current) worker exposure scenarios described and suggests that ATSDR review a 1990 report that describes 1986 and 1988 precleanup sampling data and 1990 cleanup procedures and postcleanup sampling data. Commenter focuses on precleanup dust and the interior air sampling information.
Response: ATSDR had considered the 1986 and 1988 precleanup sampling data but was unaware of the 1990 cleanup information. The discussion has been extensively changed to place the current worker exposure scenario in a more appropriate perspective that takes into account the 1986 air data and the 1990 cleanup.
Comment 35D Page 24; Acken Sign Services--Commenter is concerned about 1) an unverified statement by a resident to the effect that waste oils were disposed of in building drains, and 2) transport from site by rain runoff.
Response:

1) The 1986 data shows a low level of PCBs in a sample of "soil/sludge" taken from the steam-clean area storm drain. Although there is no evidence that those PCBs resulted from waste oil disposal, it does support ATSDR's contention that contaminants entered at least a part of the drain system. The document has been changed to place a clearer perspective on this issue.

2) ATSDR agrees that there are no data to support transport by runoff. Former facility operations may have resulted in contamination beyond the building, but three samples outside the building seem too few to conclude whether contamination exists. The discussion perspective has been modified.

Comment 36: Page 38; Acken Sign Services--Commenter mentions the interior air sample taken in 1986 and HNU readings taken in 1990 (no readings above background).
Response: Based on the data provided, it is unlikely that there are ongoing exposures at Acken Sign Services. Therefore, discussion of current/future exposure for Acken Sign in the Toxicological Evaluation section has been deleted.
Comment 37: Page 40; Acken Sign Services--Commenter requests section be modified to reflect air sampling results.
Response: Based on the data provided, it is unlikely that there are ongoing exposures at Acken Sign Services. Therefore, discussion of current/future exposure in the Toxicological Evaluation section has been deleted.
Comment: 38:

Page 50; Acken Sign Services--Commenter asserts:

1) the conclusions section should be modified to note that there are no ongoing exposures to humans from PCB contamination in light of completion of the 1990 remediation.

2) the comment suggesting that the environmental data are insufficient is not appropriate, given the information provided by the 1990 remedial project.

Response: Based on the data provided, the statement about current exposure has been deleted.
Comment 39:

Page 51; Acken Sign Services--Commenter asserts:

1) Re: recommendation for reduction of worker exposure.

The remedial project was completed in 1990.

2) Re: recommendation for soil sampling.

There were no indications that any industrial activity associated with PCB containing compounds were ever conducted in other than inside areas of the plant; and a single resident's unsubstantiated comment that waste oil was discharged outside the building area should not be cause to warrant a sampling survey of outside areas.

3) Re: recommendation for private well survey and sampling.  Note the EPA contractor's report comment regarding area water wells. Also note EPA's "Potential Hazardous Waste Site Preliminary Assessment (1991)" states that little potential for groundwater contamination exists.

Response:

1) The recommendation for reduction of worker exposure has been removed.

2) ATSDR believes that potential public health issues cannot be fully considered without conducting sampling to confirm whether soil contamination exists around the plant. The document has not been changed, except to clarify sample location(s).

3) ATSDR agrees that there may be little potential for groundwater contamination. Available information indicates that the closest residences are connected to the public water supply, but private wells are in use in the area. An EPA report describes what is in the public record concerning private well locations--EPA also says a well survey was not conducted. ATSDR believes that potential public health issues cannot be fully considered without conducting at least a limited well survey and any pertinent well sampling. The document has not been changed, except to suggest that a limited well survey might suffice.

Comment 40:

Recommendations--USEPA reports sampling has been initiated for:

1) the Bluefield, Virginia and West Virginia water supplies and the Bull Tail Hollow Reservoir,

2) the swale,

3) a sample of street/road material, trying to duplicate an earlier sample from which there was some indication of positive results, and

4) the Bernard Neal and Sam Neal properties.

USEPA previously agreed to visit the Joy facility every 6 to 9 months to observe conditions. USEPA will conduct any further actions/studies indicated by the data to be received, and will share the data with ATSDR and the interested public.

Response: ATSDR has modified information in the Public Health Action Plan.
Comment 41: Page 2; re: APCO Facilities--commenter takes exception to citizens' allegations of improper use and disposal at APCO facilities and requests that the Summary and Conclusions be modified with respect to that issue.
Response: Portions of the Summary and Conclusions have been modified.
Comment 42: Page 5; APCO Service Center--Commenter reports that transformers containing PCB fluids (as defined at 40 CFR 761.3(a)(2) cannot be serviced and are only stored at the site for a very limited time and under strict control measures. Capacitors containing PCB fluids are stored in leak-free containers in a special area and are disposed of off site in accordance with time constraints. Equipment meeting select criteria are retrofilled with clean mineral oil and reclassified as nonPCB after satisfying EPA requirements for this process. All handling and procedures are conducted in accord with EPA requirements and guidelines.
Response: The document has been modified.
Comment 43: Page 6; APCO Glen Lyn--The commenter wants text amended to show that the burning of transformer oil is authorized by 40 CFR 761.3 and that the EPA notification required has been properly made.
Response: The document has been modified.
Comment 44: Page 7; Bull Tail Hollow--A commenter responds to the assertion on Page 7 that homes and springs have been sprayed: Buffer zones of no spray have been and continue to be observed around residences, known springs, streams, crops, etc,. Herbicides are applied in accord with laws and regulations, label directions, and company guidelines. Materials are applied under the direct supervision of certified pesticide applicators. The commenter submits that there is no evidence that there was ever any improper or unusual applications of herbicides in the Bull Tail Hollow by Appalachian Power Company and requests that be made clear in the report.
Response: The document has been modified.
Comment 45: Page 12; re APCO Glen Lyn Plant--A commenter reports that the Bluestone River enters the New River approximately 28 miles downstream from Glen Lyn.
Response: The document has been changed.
Comment 46: Page 13; re APCO Glen Lyn Plant--A commenter believes the phrase "...receives non-contact cooling water..." is extraneous information.
Response: The document has been modified.
Comment 47: Page 13; re APCO Service Center--A commenter addresses Item 2. under "Community Health Concerns". Commenter is unaware of any allegation that there was contaminated runoff of any sort issuing from the Service Center. Commenter requests that the power company be able to examine any allegation and accompanying documentation presented to ATSDR concerning that issue. Commenter requests the item be deleted or modified in such a manner that it is clear that the existence of contaminated runoff is in dispute.
Response:

Item 2. says "The petitioner Committee wonders whether PCB contamination from the Joy and APCO Service Center sites spreads..." ATSDR interpreted that to be the Committee's question--not an allegation.

 

The question expressed was interpreted by ATSDR from information received in a letter and in subsequent discussions. The letter can be obtained through the Freedom of Information Act.

The item is a petitioner concern and cannot be deleted; and, based on ATSDR's review, should not be modified--nor should the commenter's dispute with the issue be identified at this place in the document. The disputed release/runoff issue is addressed, in part, in modifications elsewhere in the document.

Comment 48: Page 14 and Table 5; re: Bull Tail Hollow Spraying--Commenter points out that most of the spray material does not reach the ground. Most of the solution falls on vegetation, where it is absorbed into the plant. Therefore risk of exposure to man and the environment is greatly minimized.
Response: Page 17 of the document has been modified to reflect this information.
Comment 49:

Page 16; APCO Service Center--A commenter says:

This section presents the data upon which the report bases its conclusion that the facility is a source of off-site PCB contamination and that employees are being subjected to an increased risk of cancer.

The report assumes that because PCB materials have been handled at the facility any contamination found must be the result of the company's activities.

The sampling effort was undertaken by the company because of its concern for the potential for runoff from the Joy site. EPA concluded that the power company had no liability for cleanup at the adjoining facility. Fifteen soil samples were taken in the vicinity of the company's eastern fence line adjacent to the Joy property and along the northern fence line near the swale. PCB concentrations were detected in eight samples; highest levels were 60, 51, and 12 ppm; the remainder were less than 10 ppm. The sample with the concentration of 60 ppm was obtained in a drainage ditch directly beneath the discharge of a pipe coming from an unknown location in the direction of the Joy facility. The other high concentration was taken in the same ditch immediately down slope from the first. All other samples showing positive results were taken immediately adjacent to the Joy facility fence line. The samples that contained no detectable PCB were located along the northern fence line upslope from the swale and down slope from the higher samples. The company does not have any sampling data in its files that exactly correspond to the results reported in the ATSDR report.

In light of this, the proper conclusion for the ATSDR report to state is that any PCB contamination at the Service Center is extremely localized and most likely the result of contamination from off-site operations not associated with the company.

As a result, the conclusion of the report suggesting that an increased cancer risk may exist at the Service Center and the strongly inferred assertion that the facility is the source of contamination that is migrating off its property are both unsupported. The commenter recommends that all conclusions, assertions, etc. that are based on the sampling data cited be deleted.

Response:

The document has been changed in several respects. ATSDR's review of reference information, together with the above information provided by the commenter, shows that soils data for the Service Center were not presented clearly--leading ATSDR to interpret sample numbers to be additional concentration values. Thus, it is now clear that surface soil sampling on the east (by the Joy facility) and north (by the swale) property lines show: 1) PCBs were reported up to 60 ppm close to the Joy facility, and 2) PCBs were reported (3 ppm) at only one of the seven locations sampled to the west, along the north property line. That data, together with information about the pipe and topography, suggests that the PCBs encountered at the soil sampling locations may result from off-site activities not associated with Service Center operations. Thus, the company may not be a source of soil-related contaminants that might migrate from that area. Since the on-site sampling locations do not extend substantively toward the interior from the east property line, the data may not show the extent of the affected area. ATSDR said on Page 50, that the then-perceived exposure would not likely place any worker at risk. However, the document has been revised at appropriate places to further clarify that issue; the sample data table also has been revised.

Comment 50: Page 17; Bull Tail Hollow--A commenter reports that "Agent Orange" was never used by the power company. The herbicides 2,4-D and 2,4,5-T, the active ingredients in Agent Orange, were used twice: in 1969 and 1974--at concentrations that were much lower than used in Agent Orange. The company uses only those herbicides registered for use in rights-of ways. Therefore, use of 2,4,5-T was discontinued by the company in 1979 when the USEPA modified its registration to allow continued use of 2,4,5-T only on rangeland and rice crops.
Response: The document was modified to address the central theme of the comment.
Comment 51:

Page 24; APCO Service Center--A commenter refers to potential exposure at the depot as expressed (1st paragraph) by "Past workers who serviced capacitors and transformers...were potentially exposed...to substantive levels of contaminants of concern. Some workers could also transported contaminants home...potentially exposing family members." This statement is unwarranted and is unsupported by any factual evidence. The implication is that operations were in some manner substandard or improper. PCB handling procedures in place at the facility are now, and have always been, in accordance with or in excess of industry-wide practices and all regulations promulgated subsequent to the advent of concern with these materials. To single out this facility, especially in light of practices discussed for other facilities considered in the report is misleading, unfairly critical, and places the company in a position where it could be subject to undeserved assertions of liability. The assertion regarding liability is in the form of conjecture in this section. However in the conclusions section, the same assertion regarding worker exposure is presented as if it were an established fact. This unsupported conclusion should be deleted.

The second paragraph continues conjecture concerning the potential for worker exposure to PCB, which is apparently not based on any observation of handling practices or interviews, but merely on the fact that the company handles an occasional PCB capacitor or mineral oil containing small amounts of PCB and the company does clean up spills when such an incident occurs. Any work in the field of electrical distribution involves potential contact with some PCB material. This fact is known to all workers whose job responsibilities may involve such contact and procedures are in place to keep this contact and the chance of exposure to an acceptable fact. To discuss this in a published report is somewhat unnecessary; it is a well-known fact. To make such a fact one of the conclusions of a report based on the authority given in CERCLA, an act normally associated with the investigation of improper or environmentally harmful activities, places company operations in an undeserved position of criticism.

Unsupported allegations should be deleted or all references to company activities should have appended a statement to the effect that no evidence exists that operations places any worker into an exposure situation that is uncommon in the industry.

Response:

Persons, especially community members, expressed concern that certain chemicals (including PCBs) have been improperly used or disposed of in the Bluefield area and expressed concern for exposure and health consequences. To respond to those broad issues, ATSDR uses available factual information it finds about contaminants and exposure and augments that with contaminant and exposure conditions for which experience shows has a substantive potential to occur. ATSDR's policy is to consider potential exposure issues. It is ATSDR's judgement that such discussion is needed to be responsive, from a public health perspective, to the concerns expressed to us. This would include potential exposures that would likely have occurred before the current level of awareness and concern for chemical practices and concerns were put in place.

Ahead of paragraph 1, ATSDR has added information provided by the commenter that reflects past and current practices and helps clarify information presented in paragraphs 1 and 2.

In paragraph 1, ATSDR described the likelihood for substantive exposure in the past--which includes the period that precedes the presently recognized threat posed by PCBs. ATSDR's experience is that prior to a chemical threat being recognized some workers are/were not appropriately careful in activities associated with them. Thus, ATSDR believes that at least some of the APCO workers in the past were likely to have been exposed to substantive concentrations because 1) knowledge of PCB threat was more limited, and 2) in the past, the facility handled PCBs at higher concentrations than at present. ATSDR does not have "proof" of that exposure or its frequency or magnitude. ATSDR's policy is to describe such exposures and qualify them. Paragraph 1 has been changed slightly to 1) clarify exposure as "likely", 2) delete "substantive" in the third sentence, and 3) clarify that these exposures were most likely at a time that preceded special concern for PCBs.

For paragraph 2, ATSDR added information that reflects current practices.

The conclusions section has been modified.

Comment 52:

Page 25; APCO Service Center--A commenter identifies several issues:

1) The statement: "Liquids from building floor drains and surface runoff...discharge off site, to the north, into the wide drainage swale..." The company has checked plans and interviewed personnel there and find no evidence that any building floor drains are allowed to introduce liquids to this swale. All drains are connected to the Bluefield sanitary sewer system and, to the company's knowledge, have been connected to this system since this facility was constructed. Uncontaminated runoff from facility outdoor areas does drain to the swale as would be common at such a facility.

2) A commenter identifies the statement: "Drain effluent and runoff are likely to have deposited some of the contaminants of concern on the swale soils..." This statement is irresponsible and unfounded and should be removed.

3) A commenter identifies the last paragraph on the page and says that an assertion that discharge of materials of concern from the Service Center as an established fact should be deleted.

4) A commenter identifies a part of the last paragraph on the page: "...an underground pipe may extend from the APCO Service Center building toward the embankment and discharge into a cavity." There is no evidence of such an outlet. There is, however, a pipe from the Service Center yard that carries storm water runoff to a well-defined sinkhole on the southwest side of the property. That sinkhole also receives runoff from the U.S. Government property and the highway. The sinkhole receiving that runoff is not the same area that collects water from the swale.

Response: The document has been changed to delete or place these issues in a more appropriate perspective. Also, discussion in the last paragraph of Page 25 and all of Page 26 has been relocated, with appropriate revisions, to the Joy Manufacturing section.
Comment 53:

Page 27; APCO Glen Lyn--A commenter asserts that discussion of potential contamination and worker exposure to PCBs at the Glen Lyn plant are merely conjecture and that no evidence exists that company activities are such that contamination or exposure is likely.

Response:

ATSDR's policy is to consider potential issues in its public health assessments. However, the document has been further clarified.

Comment 54: Page 31; Bull Tail Hollow--A commenter asserts that a statement relating to the non-persistent nature of the herbicides should be used to emphasize that the herbicides were/are not an important source of exposure to the residents.
Response: The document has been changed.
Comment 55: Page 37; Public Health Implications, Re: APCO--A commenter mentions the first paragraph which asserts that on going PCB exposure may be occurring at the APCO Service Center and that "There were likely exposures to PCBs in the past..." Commenter contends that such statements are unfounded and asks that they be deleted or modified.
Response: Based on the new information that the commenter provided, this statement was deleted.
Comment 56:

Page 38; Public Health Implications, Section A: Toxicological Evaluation, Exposed Doses for Polychlorinated Biphenyls, Re: APCO--

1) A commenter asks the section be modified in accordance with suggestions contained in the preceding comment.

2) A commenter mentions that PCB contamination varied from less than one ppm to 60 ppm (not 62 ppm). The document seems to convey the impression that the data presented is in some way representative of the entire property, an idea that has no supporting evidence. This assertion is then used in subsequent areas of the report to support the possibility of an increased cancer risk to company employees. This statement should be revised to reflect that the higher concentration soil samples represent a de minimis area in a remote corner of the property and can not be used for any further risk analysis.

Response: Based on the information the commenter provided, the detailed evaluation of APCO Service Center in the Toxicological Evaluation section has been deleted.
Comment 57: Page 39; Public Health Implications, Section A: Toxicological Evaluation, Exposed Doses for Polychlorinated Biphenyls, Re: APCO--A commenter asserts that the calculations for worker exposure that assume all workers could be exposed to soil contaminated by PCB to a level of 62 ppm are inappropriate. That all workers could be exposed to soil contaminated by PCB to a level of 62 ppm is so remote as to not even fit the criteria for determining a worst case scenario. As there is no evidence that any more than perhaps a few square feet show any contamination and that this small area is located in a remote corner of a property comprising more than 170,000 square feet, the use of 62 ppm to do a risk assessment is unjustified. Notably, the report seems to conclude that even if the 62 ppm data point were valid, it would still be unlikely for anyone to actually experience an exposure that could lead to an increased cancer risk. In light of the invalidity of this data point for this type of use, the only proper conclusion for the report to reach is that there is no evidence suggesting any increase in the potential cancer rate due to worker exposure at this facility.
Response: Based on the information the commenter provided, the detailed evaluation of APCO Service Center in the Toxicological Evaluation section has been deleted.
Comment 58:

Page 50; Conclusions, Re: APCO Service Center--A commenter identified the following concerns:

1) That there has been worker exposure to PCBs in the past at the APCO Service Center.

2) Ongoing exposure to PCBs may be occurring at the APCO Service Center.

3) There is an increased risk of cancer to workers due to PCB exposure at the APCO Service Center.

The commenter asserts the report does not contain any credible evidence supporting these conclusions and that the statement of these conclusions unfairly exposes the company to allegations of improper practices. These conclusions should either be deleted or extensively rewritten to more accurately reflect actual conditions.

Response: As discussed in the Pathways Analyses section, ATSDR stands by its conclusion that past workers were likely to have been exposed to PCBs at APCO. The other two conclusions about APCO have been deleted.
Comment 59:

Page 52; Recommendations, Site Specific Recommendations, Re: APCO Service Center--A commenter raised several issues:

1) For Recommendation 1.--The company's PCB activity is no different than for similar service centers. No federal or state agency that has regulatory responsibility has seen a need to require such a program. Pending evidence that the Service Center does present a worker hazard that is different for like facilities, the commenter submits that no further study is required. The commenter is unable to understand the reference to TCE in this recommendation. At no place in the report is there any discussion of TCE use at the Service Center. This recommendation is, therefore, unsupported.

2) For Recommendation 2.--There is no evidence of any contaminated liquids being discharged; hence, there is no reason to pursue any such sampling program.

3) For Recommendation 3.--There is no pipe at the facility that meets that description.

4) For Recommendation 4.--The commenter acknowledges that some PCB contamination may be present in the swale area but denies there is any evidence that such contamination could be from company operations. Therefore, any such sampling program would be the responsibility of parties other than the company.

5) For Recommendation 5.--The commenter considers sampling in the undeveloped area north of the Service Center to be good advise for anyone who purchases property adjacent to a Superfund site but feels that this advisory is misplaced in the report when included under the heading "APCO Service Center".

6) For Recommendation 6.--The commenter asserts this recommendation should not be associated with the APCO Service Center.

Response:

1) ATSDR understands that the PCB activity is similar to the activity being carried out at any electrical distribution center. ATSDR's public health assessment is in response to concerns expressed about exposure in the Bluefield area to the contaminants of concern, and the depot was identified for ATSDR to consider. Some information that would be important to show whether substantive exposure might be occurring at the depot is not available. Hence, the document has not been changed, except to delete TCE.

2) The recommendation has been deleted.

3) The recommendation has been deleted.

4), 5), 6) Those recommendations have been deleted here and included, more appropriately, under recommendations for Joy Manufacturing.

Comment 60:

Pages 52, 53; Recommendations, Site Specific Recommendations, Re: Glen Lyn Plant--A commenter raised several issues:

1), 2) Recommendations 1. and 2.--The use of this oil as a supplementary fuel is in accordance with EPA regulations. In promulgating those regulations, EPA concluded that the practice would not have an adverse effect on human health or the environment. The commenter knows of no case where such a sampling effort has been required. The requests for surface and private well sampling are unwarranted and would generate unnecessary concern for the public. ATSDR has not presented any evidence that such a study is needed other than the fact that the supplementary fuel burning exists.

3) Recommendation 3.--The company's PCB activity is no different than for other supplemental fuel users. No federal or state agency that has regulatory responsibility has seen a need to require such a program. Pending evidence that the plant does present a worker hazard that is different from like facilities, the commenter submits that no further study is required.

Response: 1), 2) 3); ATSDR understands that the PCB activity is similar to the activity being carried out at any supplemental fuel user. ATSDR's public health assessment is in response to concerns expressed about exposure in the Bluefield area to the contaminants of concern, and the plant was identified for ATSDR to consider. Information that would be important to show whether substantive exposure might be occurring there is not available. ATSDR's policy is to consider potential exposures. Hence, the document has not been changed except to indicate that the sampling might be initiated on a small scale and expanded only if the initial data indicate more is needed.
Comment 61: Page 54; Bull Tail Hollow--A commenter says that for any contaminants, if found, it would be difficult to determine the source contamination. For example, identifying the source of 2,4-D would be difficult because it is widely used and generally available to the public.
Response:

ATSDR concurs but identifies no public health related issue that warrants a change in the document. Thus, the document has not been changed.

1. The National Toxicology Program in its Annual Report on Carcinogens classifies a chemical as a "known human carcinogen" based on sufficient human data. Its classification of a chemical as being "reasonably anticipated to be a carcinogen" is based on limited human or sufficient animal data.

2. IARC defines a class 1 carcinogen as a substance whichstudies in humans indicate a causal relationship between theagent and human cancer. Class 2 carcinogens are those reasonablyanticipated to be carcinogens. For a 2A classification, there islimited evidence of carcinogenicity from human studies whichindicate that a causal interpretation is credible, but notconclusive. A classification of 2B indicates that there issufficient evidence of carcinogenicity from studies inexperimental animals.

3. In EPA's classification scheme, a chemical is considered aclass A or human carcinogen based on sufficient evidence fromstudies of humans. A substance is considered class B1 if thereis limited evidence from human studies. B2 is used when evidencefor carcinogenicity is inadequate or non-existent based on humanstudies, but sufficient based on animal studies.



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