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PUBLIC HEALTH ASSESSMENT

NORTH BRONSON INDUSTRIAL AREA
BRONSON, BRANCH COUNTY, MICHIGAN


Table 9. Concentrations of contaminants of concern in surface water from the western lagoons on the North Bronson Industrial Area site.

Chemical Date Maximum Concentration
(ppb)
Comparison Value
(ppb)
acetone 1988 5.J 1,000R
1991 ND (22)
arsenic 1988 18.1 3E, 0.02C
1991 9.1
barium 1988 78.1 700R
1991 24.7
benzene 1988 ND 1C
1991 1.J
gamma-BHC 1988 ND 0.4Ei, carcinogen
1991 0.011J
bis(2-ethylhexyl)phthalate 1988 3.J 200R, 3C
1991 54
cadmium 1988 544 7E, carcinogen
1991 206

chromium (total)


                  (hexavalent)

1988 2,080 10,000R (III)
50R, 3C (VI)
1991 725
1988 ND
1991 21
cobalt 1988 19.5 NA
1991 ND
copper 1988 766 1,300MG
1991 290
cyanide 1988 65.9 200R
1991 ND
1,2-dichloroethylene (total) 1988 ND 70A (cis)
100A (trans)
1991 5.J
lead 1988 72.2 15PL, carcinogen
1991 29.1
manganese 1988 415 50R
1991 202
mercury 1988 ND 2A
1991 0.68
methyl ethyl ketone 1988 3.J 6,000R
1991 ND (10)
methylene chloride 1988 8.J 600E, 5C
1991 ND (10)
4-methylphenol 1988 16 carcinogen
1991 ND
nickel 1988 3,420 200R, carcinogen
1991 1,120
trichloroethylene 1988 ND 3C
1991 4.J
vanadium 1988 8.3 6Ei
1991 6.3
zinc 1988 2,220 3,000R
1991 629

Reference: 1

Shaded chemicals exceed comparison values

Contaminants of concern that are not listed were not detected

ND -- Not Detected
(III) -- For chromium(III)
(VI) -- For chromium(VI)

NA -- None Available
carcinogen -- Carcinogen (proven, probable, or possible) but no CREG available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
Ei -- ATSDR Environmental Media Evaluation Guides (EMEGs), intermediate-duration exposure
R -- ATSDR Reference Dose Media Evaluation Guides (RMEGs), calculated from EPA Reference Dose, assuming child ingestion
C -- ATSDR Cancer Risk Evaluation Guides (CREGs), for 1 x 10-6 estimated excess cancer risk (a significant additional risk of developing cancer is taken to be one additional case of cancer in a population of 1 million people experiencing the exposure)
A -- U.S. EPA Drinking Water Lifetime Health Advisory
PL -- U.S. EPA Proposed Action Level for Lead in Drinking Water


Table 10. Concentrations of contaminants of concern in sludge samples collected from the lagoons on the North Bronson Industrial Area site.

Chemical Date Lagoons Maximum Concentration
(ppm)

Comparison Value
(ppm)

acenaphthylene 1988 eastern

0.11J

NA
1989 western

ND

acetone 1988 eastern

0.24J

200R
1989 western

0.01J

antimony 1988 eastern

2,280

0.8R
1989 western

185

arsenic 1988 eastern

32.J

0.6E, 0.5C
1989 western

46.4J

barium 1988 eastern

5,920

100R
1989 western

150

benzene 1988 eastern

0.003J

20C
1989 western

ND

benzo(a)anthracene 1988 eastern

1.1J

carcinogen
1989 western

ND

benzo(b)fluoranthene 1988 eastern

1.1J

carcinogen
1989 western

ND

benzo(k)fluoranthene 1988 eastern

0.68J

carcinogen
1989 western

ND

beryllium 1988 eastern

ND

10R, 0.2C
1989 western

0.34J

bis(2-ethylhexyl)phthalate 1988 eastern

25.J

40R, 50C
1989 western

0.38J

cadmium 1988 eastern

9,280.J

1E, carcinogen
1989 western

2,200.J

chromium (total) 1988 eastern

97,800.J

2,000R (III)
10R, 60C (VI)
1989 western

15,700.J

chrysene 1988 eastern

1.1J

carcinogen
1989 western

ND

1,2-dichloroethylene (total) 1988 eastern

ND

40R (trans)
NA (cis)
1989 western

0.26

di-n-octylphthalate 1988 eastern

0.17J

NA
1989 western

ND

lead 1988 eastern

2,150

carcinogen
1989 western

574

manganese 1988 eastern

554.J

300R
1989 western

348

methyl ethyl ketone 1988 eastern

0.023J

1,000R
1989 western

0.037

methylene chloride 1988 eastern

ND

100E, 90C
1989 western

0.213

nickel 1988 eastern

16,100

40R, carcinogen
1989 western

3,900.J

PCBs 1988 eastern

1.2J

0.04E, 0.09C
1989 western

ND

trichloroethylene 1988 eastern

ND

4Ei, 60C
1989 western

5.9

vanadium 1988 eastern

39.J

6Ei
1989 western

14.J

vinyl chloride 1988 eastern

ND

0.04E, carcinogen
1989 western

0.029J

zinc 1988 eastern

11,700

600R
1989 western

2,470

Reference: 1

Shaded chemicals exceed comparison values

Contaminants of concern that are not listed were not detected

ND -- Not Detected
J -- Estimated Value
NA -- None Available

(III) -- For chromium(III)
(VI) -- For chromium(VI)

carcinogen -- Carcinogen (proven, probable, or possible) but no CREG available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
Ei -- ATSDR Environmental Media Evaluation Guides (EMEGs), intermediate-duration exposure
R -- ATSDR Reference Dose Media Evaluation Guides (RMEGs), calculated from EPA Reference Dose, assuming child ingestion
C -- ATSDR Cancer Risk Evaluation Guides (CREGs), for 1 x 10-6 estimated excess cancer risk (a significant additional risk of developing cancer is taken to be one additional case of cancer in a population of 1 million people experiencing the exposure)


Table 11. Concentrations of contaminants of concern found in water from residential wells near the North Bronson Industrial Area site study area.

Chemical Date Maximum Concentration
(ppb)
References Comparison Value
(ppb)
arsenic 10/84 ND 6 3E, 0.02C
1988 6 1
1989 8.3 1
1995 9 8
barium 10/84 ND 6 700R
1988 ND 1
1989 ND 1
1995 260 8
beryllium 10/84 ND 6 50R, 0.008C
1988 ND 1
1989 2.1 1
1995 ND 8
lead 10/84 ND 6 15PL, carcinogen
1988 ND 1
1989 ND 1
1995 5 8
manganese 10/84 ND 6 50R
1988 113 1
1989 122 1
1995 ND 8
zinc 10/84 ND 6 3,000R
1988 595 1
1989 69.1 1
1995 ND 8

Shaded chemicals exceed comparison values

Contaminants of concern that are not listed were not detected

ND -- Not Detected

carcinogen -- Carcinogen (proven, probable, or possible) but no CREG available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
R -- ATSDR Reference Dose Media Evaluation Guides (RMEGs), calculated from EPA Reference Dose, assuming child ingestion
C -- ATSDR Cancer Risk Evaluation Guides (CREGs), for 1 x 10-6 estimated excess cancer risk (a significant additional risk of developing cancer is taken to be one additional case of cancer in a population of 1 million people experiencing the exposure)
PL -- EPA Proposed Action Level for Lead in Drinking Water


Table 12. Concentrations of contaminants of concern in water from monitoring wells near the North Bronson Industrial Area site.

Chemical Date Maximum Concentration
(ppb)
Comparison Value
(ppb)
arsenic 1989 8.2 3E, 0.02C
1991 ND
manganese 1989 912 50R
1991 111
mercury 1989 ND 2A
1991 0.59

Reference: 1

Shaded chemicals exceed comparison values

Contaminants of concern that are not listed were not detected

ND -- Not Detected

carcinogen -- Carcinogen (proven, probable, or possible) but no CREG available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
R -- ATSDR Reference Dose Media Evaluation Guides (RMEGs), calculated from EPA Reference Dose, assuming child ingestion
C -- ATSDR Cancer Risk Evaluation Guides (CREGs), for 1 x 10-6 estimated excess cancer risk (a significant additional risk of developing cancer is taken to be one additional case of cancer in a population of 1 million people experiencing the exposure)
A -- U.S. EPA Drinking Water Lifetime Health Advisory


Table 13. Concentrations of contaminants of concern in surface soil samples collected near the North Bronson Industrial Area site in 1991.

Chemical Maximum Concentration
(ppm)
Comparison Value
(ppm)
antimony 6.6J 0.8R
arsenic 6.7 0.6E, 0.5C
barium 72.6 100R
beryllium 0.4 10R, 0.2C
chromium (total) 20.1 2,000R (III)
10R, 60C (VI)
cobalt 5.7J NA
copper 18.6J NA
cyanide 0.19 40R
lead 32.8J carcinogen
manganese 613 300R
mercury 0.14 NA
nickel 9.9 40R, carcinogen
vanadium 32 6Ei
zinc 60.4 600R

Reference: 1

Shaded chemicals exceed comparison values
Contaminants of concern that are not listed were not detected

J -- Estimated Value

NA -- None Available

(III) -- For chromium(III)
(VI) -- For chromium(VI)

carcinogen -- Carcinogen (proven, probable, or possible) but no CREG available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
Ei -- ATSDR Environmental Media Evaluation Guides (EMEGs), intermediate-duration exposure
R -- ATSDR Reference Dose Media Evaluation Guides (RMEGs), calculated from EPA Reference Dose, assuming child ingestion
C -- ATSDR Cancer Risk Evaluation Guides (CREGs), for 1 x 10-6 estimated excess cancer risk (a significant additional risk of developing cancer is taken to be one additional case of cancer in a population of 1 million people experiencing the exposure)


Table 14. Concentrations of contaminants of concern (metals only) in subsurface soil samples collected from monitoring well borings near the North Bronson Industrial Area site in 1991.

Chemical Maximum Concentration
(ppm)
Comparison Value
(ppm)
arsenic 5.8J 0.6E, 0.5C
barium 8.3 100R
chromium (total) 9.7 2,000R (III)
10R, 60C (VI)
cobalt 1.2 NA
copper 12.3J NA
lead 3.9J carcinogen
manganese 145.J 300R
nickel 11.5 40R, carcinogen
vanadium 6 6Ei
zinc 18.6 600R

Reference: 1

Shaded chemicals exceed comparison values

Contaminants of concern that are not listed were not detected

J -- Estimated Value

NA -- None Available

(III) -- For chromium(III)
(VI) -- For chromium(VI)

carcinogen -- Carcinogen (proven, probable, or possible) but no CREG available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
Ei -- ATSDR Environmental Media Evaluation Guides (EMEGs), intermediate-duration exposure
R -- ATSDR Reference Dose Media Evaluation Guides (RMEGs), calculated from U.S. EPA Reference Dose, assuming child ingestion
C -- ATSDR Cancer Risk Evaluation Guides (CREGs), for 1 x 10-6 estimated excess cancer risk (a significant additional risk of developing cancer is taken to be one additional case of cancer in a population of 1 million people experiencing the exposure)


Table 15. Concentrations of contaminants of concern in sediment from County Drain # 30 at and near the North Bronson Industrial Area site.

Chemical Date Maximum Concentration
(ppm)
Comparison Value
(ppm)
upstream at the site downstream
acenaphthylene 1988 ND 0.28 ND NA
1991 ND ND ND
acetone 1988 0.038 0.12J ND 200R
1991 0.017 0.019J ND
antimony 1988 ND ND ND 0.8R
1991 ND 6.2J 6.4
arsenic 1988 7 27.6 4.2 0.6E, 0.5C
1991 1.3 31.4 9
barium 1988 42.8 260 16.9 100R
1991 10.4 219 46.2
benzo(a)anthracene 1988 ND 3.2J ND carcinogen
1991 ND 5.3J 0.27J
benzo(b)fluoranthene 1988 ND 7.4 ND carcinogen
1991 ND 12.X 0.78X
benzo(k)fluoranthene 1988 ND 1.6J ND carcinogen
1991 ND 12.X 0.78X
benzo(g,h,i)perylene 1988 ND ND ND NA
1991 ND 3.3J 0.16J
benzo(a)pyrene 1988 ND 3 ND 0.1C
1991 ND 4.2J 0.33J
beryllium 1988 ND ND ND 10R, 0.2C
1991 ND 0.48 ND
gamma-BHC 1988 ND ND ND 0.08Ei, carcinogen
1991 ND 0.00017J ND
delta-BHC 1988 ND ND ND NA
1991 ND 0.011J ND
butylbenzylphthalate 1988 ND ND ND 400R, carcinogen
1991 ND 0.82J 0.15J
cadmium 1988 6.6 231 ND 1E, carcinogen
1991 ND 38.4 13.7
carbazole 1988 ND ND ND NA
1991 ND 0.091 ND
chromium (total) 1988 1,090 2,220 25.1 2,000R (III)
10R, 60C (VI)
1991 3.7 1,300 163
chrysene 1988 ND 2.8 ND carcinogen
1991 ND 5.8 0.37J
dibenzo(a,h)anthracene 1988 ND ND ND carcinogen
1991 ND 1.2J ND
1,2-dichloroethylene (total) 1988 ND ND ND 40R (trans)
NA (cis)
1991 ND 0.005 ND
di-n-octylphthalate 1988 ND 2.2 ND NA
1991 ND 0.72J ND
indeno(1,2,3-cd)pyrene 1988 ND ND ND carcinogen
1991 ND 3.7J 0.15J
lead 1988 64.7 601 7.5J carcinogen
1991 5.5J 690 58.6
manganese 1988 72.5 605 235 300R
1991 96.5 457 146
methyl ethyl ketone 1988 ND ND ND 1,000R
1991 ND 0.002J ND
methylene chloride 1988 0.006J ND ND 100E, 90C
1991 ND ND ND
2-methylnaphthalene 1988 ND 0.17 ND NA
1991 ND ND ND
naphthalene 1988 ND 0.67 ND NA
1991 ND ND ND
nickel 1988 233 1,310 19.3 40R, carcinogen
1991 4 856 63.7
4-nitrophenol 1988 ND ND ND NA
1991 ND 0.26J ND
PCBs 1988 ND 0.52J 0.51 0.04E, 0.09C
1991 ND 0.97J 3.J
phenanthrene 1988 ND 2.6 ND NA
1991 ND 4.8J 0.22J
vanadium 1988 16.2 37.2 8.4 6Ei
1991 5.4 36.1 12
zinc 1988 109 1,440 31.4 600R
1991 14.1 693 165

Reference: 1
Shaded chemicals exceed comparison values
Contaminants of concern that are not listed were not detected
ND -- Not Detected
J -- Estimated Value
X -- Total benzo(b)fluoranthene and benzo(k)fluoranthene
NA -- None Available
(III) -- For chromium(III)
(VI) -- For chromium(VI)
carcinogen -- Carcinogen (proven, probable, or possible) but no CREG available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
Ei -- ATSDR Environmental Media Evaluation Guides (EMEGs), intermediate-duration exposure
R -- ATSDR Reference Dose Media Evaluation Guides (RMEGs), calculated from EPA Reference Dose, assuming child ingestion
C -- ATSDR Cancer Risk Evaluation Guides (CREGs), for 1 x 10-6 estimated excess cancer risk (a significant additional risk of developing cancer is taken to be one additional case of cancer in a population of 1 million people experiencing the exposure)


Table 16. Concentrations of contaminants of concern in surface water from County Drain #30 near the North Bronson Industrial Area site and from outfalls to the creek from the site.

Chemical Date Maximum Concentration
(ppb)
Comparison Value
(ppb)
upstream at site downstream outfalls
acenaphthylene 1988 ND ND ND -- NA
1991 ND ND ND 3.J
arsenic 1988 3.3 3.4 3.1 -- 3E, 0.02C
1991 6.7 7.9 4.1 5.6
barium 1988 96.3 100 95.8 -- 700
1991 246 265 62.5 87.2
benzene 1988 ND ND ND -- 1C
1991 ND 1.J ND ND
benzo(b)fluoranthene 1988 ND ND ND -- carcinogen
1991 ND ND ND 2.X
benzo(k)fluoranthene 1988 ND ND ND -- carcinogen
1991 ND ND ND 2.X
benzo(a)pyrene 1988 ND ND ND -- 0.005C
1991 ND ND ND 1.J
benzyl alcohol 1988 5.J 19 ND -- NA
1991 ND ND ND ND
gamma-BHC 1988 ND ND ND -- 0.4Ei, carcinogen
1991 ND ND 0.009J 0.029J
bis(2-ethylhexyl)phthalate 1988 ND 6.J ND -- 200R, 3C
1991 ND ND ND ND
cadmium 1988 ND 13.3 ND -- 7E, carcinogen
1991 ND ND ND ND
4-chloro-3-methylphenol 1988 ND 7.J ND -- NA
1991 ND ND ND ND

chromium (total)


                     (hexavalent)

1988 606 111 ND -- 10,000R (III)
50R, 3C (VI)
1991 25.2 55.4 12.3 65.9
1988 ND ND ND --
1991 ND ND ND ND
cyanide 1988 ND 93.8 ND -- 200R
1991 16 21.1 ND ND
1,2-dichloroethylene (total) 1988 ND 19 ND -- 70A (cis)
100A (trans)
1991 ND 12 6.J 370
heptachlor epoxide 1988 ND ND ND -- 0.1R, 0.004C
1991 ND ND 0.006J ND
lead 1988 ND 33.3 ND -- 15PL, carcinogen
1991 21 28 ND ND
manganese 1988 169 156 171 -- 50R
1991 721 1,090 165 122
mercury 1988 ND ND ND -- 2A
1991 ND ND ND 0.27J
methyl ethyl ketone 1988 ND ND ND -- 6,000R
1991 2.J 2.J ND ND
2-methylnaphthalene 1988 ND ND ND -- NA
1991 ND ND ND 8.J
naphthalene 1988 ND 1.J ND -- 20A
1991 ND ND ND 25
nickel 1988 382 287 18.2 -- 200R, carcinogen
1991 21.3 54.8 17.7 35.4
phenanthrene 1988 ND ND ND -- NA
1991 ND ND ND 3.J
trichloroethylene 1988 ND 4 ND -- 3C
1991 ND 3.J ND 72
vanadium 1988 ND 21.2 ND -- 6Ei
1991 41.9 63 ND 5
vinyl chloride 1988 ND ND ND -- 0.2E, carcinogen
1991 ND 3.J ND 34
zinc 1988 156 42.2 10.8 -- 3,000R
1991 130 156 ND ND

Reference: 1

Shaded chemicals exceed comparison values

Contaminants of concern that are not listed were not detected

ND -- Not Detected
X -- Total benzo(b)fluoranthene and benzo(k)fluoranthene
(III) -- For chromium(III)
(VI) -- For chromium(VI)

NA -- None Available
carcinogen -- Carcinogen (proven, probable, or possible) but no CREG available

Comparison Value Bases:

E -- ATSDR Environmental Media Evaluation Guides (EMEGs)
Ei -- ATSDR Environmental Media Evaluation Guides (EMEGs), intermediate-duration exposure
R -- ATSDR Reference Dose Media Evaluation Guides (RMEGs), calculated from EPA Reference Dose, assuming child ingestion
C -- ATSDR Cancer Risk Evaluation Guides (CREGs), for 1 x 10-6 estimated excess cancer risk (a significant additional risk of developing cancer is taken to be one additional case of cancer in a population of 1 million people experiencing the exposure)
A -- EPA Drinking Water Lifetime Health Advisory
PL -- EPA Proposed Action Level for Lead in Drinking Water


RESPONSIVENESS SUMMARY

The Michigan Department of Community Health (MDCH) released a draft of this document for public comment on November 6, 1996. The comment period lasted until December 6, 1996. The MDCH received comments from the city manager of the city of Bronson. His comments and MDCH responses to them follow. Page and paragraph references are to the draft that was released and may differ from those in this draft.

  1. First of all, a good share of the warning in the draft was in relation to the cyanide destruction facility located in a residential block. The fallen structure was removed and the area fenced in May of this year (1996).

    Response: Thank you for reminding us of this. The events referred to occurred while ATSDR was reviewing and approving the draft assessment for this preliminary release. The state of the site study area has been brought up to date in the final draft.

  2. Construction of the lagoons did begin in 1939. While there may have been five separate lagoons by the year 1949, initially only two were constructed.

    Response: Thank you for the information. The text has been revised to clarify the situation.

  3. You also make reference to five lagoons at the Bronson Plating site. I don't recall ever seeing any data to substantiate any more than four lagoons.

    Response: A contractor for MDNR said there were five lagoons (Reference 2). We have reviewed the available information to improve the history of the site.

  4. My records also show Bronson Plating acquiring the property on May 12, 1969, not 1970.

    Response: Thank you for the information. The text has been revised.

  5. In July of 1995, Brad Stempel of the Environmental Protection Agency's (EPA's) Emergency Response Division did indeed remove 50-60 55-gallon barrels from the site. The barrels were, however, all empty. Mr. Stempel told me personally that the barrels were innocuous, but they looked bad stacked in a former plating area and that he would remove them more for a cosmetic reason than that of any hazard they may represent.

    Response: Thank you for the information. The text has been revised.

  6. On page four of the document under "Site Visit" Michigan Department of Health (MDPH) officials claim they were unable to obtain access to the west lagoons. Those lagoons are on city property. We have never refused access to the site to any official. The area is unfenced along the County Drain and could have been accessed even if no one was present at the waste water treatment facility.

    Response: At that time, the MDPH personnel made only a cursory attempt to reach the lagoons, and turned away at the closed gate to the wastewater treatment facility. No other methods of access were tried. We regret the unfortunate implication of our original phrasing, which has been revised. On a later occasion, documented in new text, MDPH personnel did obtain access to the lagoons, while MDNR personnel were there.

  7. The 1990 Census for the City of Bronson is 2342, not 2332.

    Response: Thank you for the information, and the correct value is in the text.

  8. The subsurface soil section on page 10 references that duplicate samples taken for the RI in 1991 showed much lower concentrations of some metals and substantially different concentrations of other metals. What are we to assume here? The area is cleaning itself up? The first set of samples was erroneous? The second set of samples was erroneous?

    Response: This issue is addressed in the "Quality Assurance and Quality Control" section of the draft assessment (page 13 of the public comment draft, page 12 in the current document):

      "[The order of magnitude difference between the concentrations in duplicate samples] suggests that there may have been some interference with the analysis, and the results for all soil samples analyzed at the same time may be questionable."

    The duplicate samples were collected at the same time, so it is not a question of the site situation changing. MDCH can not draw any further conclusions as to which set of results is accurate. MDNR's contractor presented these results in the RI report without further comment.

  9. I believe, though I am not certain, the well use survey is complete. The document states that it was scheduled for completion in mid-1996.

    Response: The well-use survey was completed while ATSDR was reviewing and approving the draft assessment before the public comment release. The results of the complete survey have been included in this revision.

  10. Again, overall I felt the document to be easy to read and useful.

    Response: Thank you for the compliment.


1. On October 1, 1995, the environmental evaluation, regulatory, and enforcement functions of the Michigan Department of Natural Resources (MDNR) were transferred to the newly formed Michigan Department of Environmental Quality (MDEQ).

2. Comparison values: Acetone -- ATSDR reference dose media evaluation guide (RMEG) 1,000 ppb; methyl ethyl ketone -- RMEG 6,000 ppb.

3. On April 1, 1996, the Michigan Department of Public Health (MDPH) Division of Health Risk Assessment (DHRA) was absorbed into the newly formed Michigan Department of Community Health (MDCH). The site history and background section of this document uses the departmental identifiers in effect at the time of the events.

4. Pica behavior is an abnormal consumption of nonfood materials, such as soil, most often seen in children between 2 and 5 years of age.

5. Comparison values: Acetone -- ATSDR reference dose media evaluation guide (RMEG) 1,000 ppb; methyl ethyl ketone -- RMEG 6,000 ppb.

6. On April 1, 1996, the Water Supply Division of the Michigan Department of Public Health (MDPH) was transferred to the Michigan Department of Environmental Quality (MDEQ), Division of Drinking Water and Radiological Protection. The organizational identifiers used in this document are those in effect when the actions described occurred.

7. Comparison values (in ppb): trichloroethylene -- 3 (CREG); cis-1,2-dichloroethylene -- 70 (LTHA); trans-1,2-dichloroethylene -- 100 (LTHA); vinyl chloride -- 0.2 (EMEG), no CREG; 1,1-dichloroethylene -- 90 (EMEG), 0.06 (CREG).

8. Comparison value: 1,1,1-trichloroethane -- 200 ppb (LTHA).

9. The estimated carbon disulfide exposure dose is given as 3.6 x 10-2 mg/kg/day, and the reference dose as 1.0 x 10-1 mg/kg/day. However, the hazard quotient, the exposure dose divided by the reference dose, is given as 3.6, when it should be 0.36. The sum of the hazard quotients, the hazard index, is given as 3.8, when it should be 0.5. Since the risk of non-cancer adverse health effects is considered significant if the hazard index exceeds 1.0, this error raises a nonsignificant risk to a significant one.

10. Pica behavior is an abnormal urge to consume nonfood substances, such as soil, that most commonly occurs between ages 2 and 5.


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