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PUBLIC HEALTH ASSESSMENT

ATLANTIC WOOD INDUSTRIES INCORPORATED
PORTSMOUTH, PORTSMOUTH COUNTY, VIRGINIA


CONCLUSIONS

From the information reviewed, VDH concludes the Atlantic Wood Industries site to be anindeterminate public health hazard. The limited data available indicate that people working at thesite may be or have been exposed to levels of contamination that could cause adverse health effects ifexposure occurs over a long period of time to maximum levels of contaminants detected in surfacesoil. However, those conclusions are based on worse-case conditions, and no information isavailable to indicate that anyone has been exposed to contaminants under those conditions. Also,information is not available for all environmental media to which humans may be exposed.

Sources of releases of contaminants in the air have been identified. One air monitoring samplinground did not identify the presence of any contaminants of concern, although one sample showedslightly elevated naphthalene levels. No information is available on particulates that may bemigrating to nearby facilities.

Contaminants identified in shellfish, as well as the poor water quality of the area, has resulted in aban on shellfish collection. No information is available on fin fish collection, consumption, orquality. Physical evidence indicates fin fish may also contain contaminants.

Groundwater in the area is used as industrial process water. No information is available on thequality of that water and whether or not workers come into contact with the water.

No adverse health outcomes have been reported by the community, and no data are available toindicate that the site has had an adverse impact on human health.

Community health concerns do not address the AWI site specifically, but citizens are generallyopposed to the use of incineration of wastes as a clean up method. The community is interested inimproving the water quality of the Elizabeth River and the Chesapeake Bay.


RECOMMENDATIONS

VDH and ATSDR recommend the following actions:

  1. Determine the extent of surface soil migration from the site, especially to adjacent areas where people are working.

  2. Confirm if contaminants are migrating from the site through the air.

  3. Determine if the ban on collecting shellfish is effective. Determine if the ban should include fin fish.

  4. Further characterize surface water and sediment quality as it relates to site contaminants.

  5. Determine if workers come into contact with groundwater at facilities in the area where wellwater is used for process water. If workers do come into contact with the water, determine if the facilities monitor the quality of the water.

  6. Continue the use of proper protective equipment for on-site workers during operations and for remediation.

  7. Continue to guard against trespassers.

The Comprehensive Environmental Response, Compensation, and Liability Act of 1980(CERCLA), as amended, requires ATSDR to perform public health actions needed at hazardouswaste sites. To determine if public health actions are needed, ATSDR's Health ActivitiesRecommendation Panel (HARP) evaluated the data and information developed in the Atlantic WoodIndustries Public Health Assessment. No follow-up health actions are indicated at this time,because, although there is a possibility, no evidence indicates that people have been exposed tocontaminants at levels that will cause adverse health effects. If information becomes availableindicating exposure at levels of concern are occurring or have occurred, ATSDR will evaluate that information to determine what actions, if any, are necessary.


PUBLIC HEALTH ACTIONS

After review of the HARP determinations, VDH has developed the following public health actionsto ensure that public health is protected:

As new information becomes available, ATSDR will evaluate that information to determine whatactions, if any, are necessary.

ATSDR will coordinate with EPA and state agencies to discuss the feasibility of implementing recommendations made in this public health assessment.


PREPARERS OF THE REPORT

Bureau of Toxic Substances
Virginia Department of Health

Peter C. Sherertz, Ph.D.
Toxicologist

Connie K. Webb, M.P.H.
Toxic Substances Information Specialist

Sanjay Thirunagari, M.S.
Geologist

Vickie L. O'Dell
Toxic Substances Information Specialist

Graziella M. Wilson
Toxic Substances Biologist


ATSDR Regional Representative

Charles J. Walters
Regional Services
Office of The Assistant Administrator, ATSDR


ATSDR Technical Project Officer

Gail D. Godfrey
Environmental Health Scientist
Division of Health Assessment and Consultation
Remedial Programs Branch


CERTIFICATION

The Atlantic Wood Industries, Inc., Site Public Health Assessment has been prepared by theVirginia Department of Health under a cooperative agreement with the Agency for ToxicSubstances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the public health assessment was initiated.

Gail D. Godfrey
Technical Project Officer, SPS, RPB, DHAC


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

Director, DHAC, ATSDR


REFERENCES

  1. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Arsenic. March 1989. 125 pp.

  2. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Benzene. May 1989. 173 pp.

  3. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Polycyclic Aromatic Hydrocarbons. October 1990. 231 pp.

  4. Agency for Toxic Substances and Disease Registry. Toxicological Profile forPentachlorophenol. December 1989. 135 pp.

  5. Callahan, M.A., Slimak, M.W., Gable, N.W., et al. Water-related Environmental Fate of 129 Priority Pollutants. 1979. EPA 440/4-70-029. 1160 pp.

  6. Huggett, R.J., Bender, M.E., and Unger, M.A. "Polynuclear Aromatic Hydrocarbons in theElizabeth River, Virginia." In: Dickson, K.L., Maki, A.W., and Brungs, W.A. (eds.). Fateand Effects of Sediment-Bound Chemicals in Aquatic Systems. Soc. Environ. Toxicol.Chem., Spe. Pub. Ser. pp. 327-341.

  7. National Oceanic and Atmospheric Administration. Preliminary Natural Reserve Survey. January 1990. VAD990710410.

  8. Norfolk Naval Shipyard. Remedial Investigation Interim Report. August 1989. Project No. 303047.

  9. Shacklette, H.T. and Boerngen, J.G. Elemental Concentrations in Soils and OtherSurficial Materials of the Conterminous United States. U.S. Geological Survey,Professional Paper 1270. U.S. Department of the Interior. 1984.

  10. Goodman, L.S. and Gilman, A.G. The Pharmacological Basis of Therapeutics. Seventh Edition. 1985. McMillan, New York.

  11. Keystone Environmental Resources. Atlantic Wood Industries, Inc., RemedialInvestigation. Sept. 1991.

APPENDIX A: GLOSSARY

Aquifer: A permeable body of rock capable of yielding quantities of ground water to wells andsprings.

Bioaccumulation: The accumulation of a chemical by organisms of a single species from waterdirectly or through consumption of food containing the chemical.

Biomagnification: Efficient transfer of chemical from food to consumer, through two or moretrophic levels, results in a systematic increase in tissue residue concentrations from one trophic levelto another.

Biotransformation: the transformation of chemical compounds within a living system.

Cancer Risk Evaluation Guide (CREG): Guides used to select contaminants of concern that arecalculated from EPA's cancer slope factors for 1 x 10-6 excess cancer risk.

Cancer Slope Factors (CSF): factors (for inhalation and ingestion) that define the relationshipbetween exposure doses and the likelihood of an increased risk of developing cancer compared withnon-exposed controls. Usually derived from animal or occupational studies, cancer slope factors areused to calculate the exposure dose likely to result in one excess cancer case per one million personsexposed over a lifetime (70 years).

Class A human carcinogen: EPA classification based on sufficient evidence of carcinogenicity inhumans and in animals.

Class B2 carcinogen: EPA classification based on sufficient evidence in animals and inadequatedata in humans.

Environmental Media Evaluation Guides (EMEGs): Media specific comparison values,calculated from ATSDR's Minimal Risk Levels, used to select chemical contaminants of potentialhealth concern at hazardous waste sites. The values consider non-carcinogenic health effects only.

Hydrolysis: Decomposition or alteration of chemical substances by water.

Maximum Contaminant Level (MCL): Enforceable standards for public drinking water suppliesunder the Safe Drinking Water Act. Also referred to as drinking water standards.

Minimal Risk Level (MRL): An estimate of daily human exposure to a chemical likely to bewithout appreciable risk of harmful effects (non cancerous) over a specified duration of exposure. MRLs are based on human and animal studies and are reported for acute (less than or equal to 14days), intermediate (15-364 days), and chronic (greater than or equal to 365 days) exposures. If anindividual's daily exposure is below the MRL, adverse health effects are not expected.

National Priorities List (NPL): EPA's list of top-priority hazardous waste sites that are eligible toreceive Federal funds for investigation and cleanup under the Superfund program.

National Pollutant Discharge Elimination System (NPDES): A nationwide program requiringindustrial, municipal, and other point source dischargers to obtain permits setting forth specificlimitations on the discharge of pollutants into navigable U.S. waters.

Photolysis: Chemical changes produced by use of radiant energy.

Quality Assurance/Quality Control (QA/QC): A system of procedures, checks, audits, andcorrective actions used to ensure that field work and laboratory analysis during the investigation andcleanup of Superfund sites meet established standards.

Record of Decision (ROD): A public document that explains which cleanup alternative(s) will beused at National Priorities List Superfund sites. The record of decision is based on information andtechnical analysis generated during the Remedial Investigation/Feasibility Study and involves theconsideration of public comments and community concerns.

Reference Concentration (RfC): EPA's estimate for the human population, including sensitivesubpopulations, of the daily exposure by the inhalation route likely to be without appreciable risk ofharmful noncancerous effects during a lifetime.

Reference Dose (RfD): An estimate of the daily exposure of the human population to a potentialhazard that is likely to be without risk of deleterious effects during a lifetime. RfDs are notapplicable to nonthreshold effects such as cancer.

Reference Dose Medium Evaluation Guide (RMEG): Media specific comparison values,calculated from EPA's RfD, used to select chemical contaminants of potential health concern athazardous waste sites. The values consider non-carcinogenic health effects only.

Remedial Investigation/Feasibility Study (RI/FS): Investigative and analytical studies usuallyperformed at the same time in an interactive, iterative process, and together referred to as the"RI/FS." They are intended to gather the data necessary to determine the type and extent ofcontamination at a Superfund site; establish criteria for cleaning up the site; identify and screencleanup alternatives for remedial action; and analyze, in detail, the technology and costs of theremedial alternatives.

Resource Conservation and Recovery Act (RCRA): EPA's comprehensive regulations for themanagement of hazardous waste.

Toxic Chemical Release Inventory (TRI): EPA database containing information on the annual industry-estimated releases of toxic chemicals to the environment.


APPENDIX B: FIGURES

Site Map
Figure 1. Site Map

Site Features and Surface Water Sampling Locations
Figure 2. Site Features and Surface Water Sampling Locations


APPENDIX C: PUBLIC COMMENTS

PUBLIC COMMENT PERIOD

The initial draft of this document was released for public comment from October 15, 1992, throughNovember 16, 1992. Copies of the initial draft were available to the public at the PortsmouthPublic Library, 601 Court Street; the Portsmouth Health Department, 800 Crawford Parkway; andat the Portsmouth City Hall, 801 Crawford Street. No comments were received from any member ofthe public except the potentially responsible party, Atlantic Wood Industries, Inc. One commentwas received from the Virginia Department of Waste Management. Those comments that reflectdata we did not have access to during initial preparation were used to revise this document.

All comments received, and the response to those comments, follow.
COMMENT: Page 1 indicates that the ROD was expected to be signed in the Spring of 1992. It should be noted that the ROD has not yet been signed.
RESPONSE: The change has been made to reflect that fact.
COMMENT: On page 7 the first paragraph [note that page numbers have likely changed because of revisions made in this document] is a little confusing. It seems to be saying that the air samples were questionable because standard quality control procedures were not followed. If this is the meaning, I don't think it would be clear to a member of the general public reviewing this document.
RESPONSE: Changes have been made to reflect that only one sampling was done and that analyses for all contaminants that could be a problem were not performed. Hopefully, the document is clearer now.
COMMENT: The meaning of the column "Concentrations from RfD" used in Tables 1-4 is not clear and has not been explained adequately in the text. It appears that the concentrations needed to cause adverse health effects were calculated from the RfDs. Since most of the chemicals of concern were carcinogens these values were not applicable. Why were similar concentrations not calculated for the carcinogens based on their slope factors?
RESPONSE: We agree that the document did not adequately clarify the different kinds of comparison values used. Changes have been made to the document to reflect that a wide variety of comparison values are considered. However, if one comparison value is exceeded, we do not list all others that may be exceeded, too. If one value is exceeded, the contaminant is further evaluated for possible cancer and non-cancer health effects if exposure to that contaminant has occurred.
COMMENT: It is also not clear why these values were identical for soils and sediments since presumably there would be different exposure factors involved with these two different media.
RESPONSE: Currently, comparison values have been developed for soil concentrations and those values are used for sediment concentrations, also. The values are used only to select contaminants for further evaluation. When the toxicological implications are evaluated, the specific conditions of the exposure, which include the differences in how people are exposed to contaminants in soil versus contaminants in sediment occur, are considered when determining whether or not adverse health effects may result. Hopefully, changes in this document have helped clarify that.
COMMENT: Throughout the document, pH is represented as Ph.
RESPONSE: Thank you. The changes have been made.
COMMENT: The term MCL used on page 22 should be in bold print, since it is defined in the glossary rather than the text. Previously in the document, Virginia water quality standards were referred to. Perhaps it should be explained how these two values are related. Also, page 22 refers to benzene greatly exceeding the MCL at this site. However, the section on groundwater on page 18 implies that the benzene level in groundwater at the site is equal to the MCL. I understand that the levels referred to on page 18 are only from the aquifer that is actually in use but it is a little confusing when compared to the statement on page 22. It is also not clear why the MCL for benzene is referenced in this section but a similar reference is not made for arsenic.
RESPONSE: The sections have been extensively revised to clarify the issues reflected in your comments.
COMMENT: Several recommendations are made at the end of the document but it is not specified who is responsible for implementing these recommendations. Will the additional sampling recommendations be incorporated into the Public Health Action Plan with agencies specified as responsible for implementation? The public health action section of the document says that any new information will be evaluated but does not indicate how the new information would be generated.
RESPONSE:

VDH and ATSDR make recommendations that are felt appropriate for protection of public health. Currently, ATSDR does not have the capability of conducting follow-up environmental sampling and characterization. Those activities are negotiated with EPA or state environmental agencies. EPA or the state environmental agencies determine which recommendations can be implemented. ATSDR works with EPA and the states to determine who will carry out the recommendations. At this time, ATSDR is hopeful that the recommendations will be addressed in any ROD that is issued for the site. If HARP determines that health actions, such as a health study or health education, is needed, ATSDR conducts those actions. No actions of those types were determined to be necessary at this time.

Other information that may become available include data from additional studies that may be conducted by EPA or state agencies in conjunction with a ROD or routine monitoring, a report or inquiry from citizens that adverse health effects have occurred, or a request from EPA or another agency or group to consider data that may not have been available when this document was developed.

COMMENT: Atlantic Wood Industries, Inc. (AWII) ceased wood treatment operations at the Portsmouth site on August 6, 1991. The only activities currently conducted at the site are the storage and distribution of wood products treated at other AWII facilities. Wood treatment began at the AWI site in 1926 not 1929.
RESPONSE: The document has been corrected.
COMMENT: A statement is made that the Elizabeth River is used extensively for water recreation. This is incorrect. The area surrounding the AWII site both upstream and downstream is highly industrialized. The "extensive recreation" near the AWII site is limited to transient boat traffic utilizing the intracoastal waterway and some commercial crabbing. Water skiing, jet skiing, and swimming activities are limited to waters south of the I-64 bridge (4 miles upstream). A letter from the Virginia Department of Health dated July 20, 1990, is enclosed a Attachment 1 to confirm that the river adjacent to the site is not primary contact recreational waters.
RESPONSE: Clarifications have been made in this document.
COMMENT: Also, it should be noted that prohibition to the taking of bivalve mollusks from the Elizabeth River was not in response to the AWII site or PAH contamination. This action was taken due to heavy metal contamination as stated on page 5, fourth paragraph of the draft Public Health Assessment.
RESPONSE: Changes made in the document clarify the circumstances of the shellfish advisory.
COMMENT: AWII conducted the Phase I Removal Sampling Investigation during July and August 1988 to characterize the nature and extent of soil contamination along the existing storm sewer. The results of this investigation were submitted to EPA on August 11, 1989. The Remedial Investigation (RI) for the site was conducted during 1992. On May 28, 1992, AWII received permission from EPA to incorporate the Focused Feasibility Study (FFS). AWII has not removed any portion of the storm sewer as is stated in this paragraph. AWII submitted the draft FFS report to EPA on May 29, 1992.
RESPONSE: That information has been incorporated into the document.
COMMENT: It should be noted that the Norfolk Veneer Mill was formerly the Wycoff Company as described on page 4, third paragraph of the draft Public Health Assessment.
RESPONSE: The addition was made.
COMMENT: Over the years, AWII has changed corporate names several times, not ownership. AWII changed ownership once on January 1, 1986, when the employees of AWII purchased the operating assets of the corporation under an Employee Stock Ownership Plan (ESOP).
RESPONSE: The correction has been made.
COMMENT: Pentachlorophenol was used at the site from 1972-1985 and for a short period (approximately 5 months) in 1991. Again, all wood treatment activities at the site were discontinued on August 6, 1991.
RESPONSE: Corrections have been made.
COMMENT: The wood treatment retorts are "closed cylinders" not "tanks." These cylinders are large horizontal pressure vessels in which wood products are placed prior to the pressure treatment process. They are not used as a storage vessel for liquids.
RESPONSE: Corrections have been made.
COMMENT: It is inaccurate to say that waste preservative was stored in the southwest corner of the facility. The term "waste preservative" in the first sentence should be changed to "waste" since many different materials were deposited in the southwest corner of the site. The type of waste materials are described in detail later on in the paragraph.
RESPONSE: Changes have been made to clarify those issues.
COMMENT: Clarify what is meant by "other wastes include contaminated sediments in the Southern Branch of the Elizabeth River." This implies that contamination from the site has migrated an extremely long distance from the site. Also, there is no specific evidence indicating that the sediments in the "Southern Branch of the Elizabeth River" were impacted solely by AWI, rather than other upstream facilities and sources.
RESPONSE: Changes have been made in several sections of this document to clarify those issues.
COMMENT: The RCRA interim status permit for the site was not revoked but withdrawn at AWII's request. The notice of termination of interim status was signed by the Commonwealth of Virginia on January 16, 1985, and is included as Attachment 2.
RESPONSE: The correction has been made.
COMMENT: AWII has a NPDES permit to discharge storm water run off only. It is more accurate to refer to the discharge as storm water runoff instead of surface water.
RESPONSE: Clarifications have been made. However, the monitoring of the storm water runoff is considered as "surface water" monitoring for public health assessment purposes.
COMMENT: The presence of zinc at the AWII site cannot be attributed to the treatment process. Neither AWII nor EPA have been able to determine the source of the zinc contamination at the site.
RESPONSE: Zinc is not identified as a contaminant of concern in any environmental media sampled on the site. Shellfish contain heavy metals, including zinc. No insinuation is made that the zinc is a result of site contaminants. Some changes made in this document may make that point clearer.
COMMENT: The use of the work "strong" to describe the creosote odor is very subjective. Creosote is a complex mixture of aromatic hydrocarbons. Many of these compounds can be detected by the human olfactory organs at parts per billion concentrations thus making it very difficult to quantify creosote odor.
RESPONSE: Description of the odor is subjective; however, to the people conducting the site visit, the odor was "strong." The word is used as a qualitative assessment of conditions for the average person who does not work with the material everyday. Use of the word is not intended to represent a quantitative value.
COMMENT: The three run off ditches are for storm water from the site. These ditches are dry except during precipitation events and should not be considered surface water ditches.
RESPONSE: Clarification has been made to indicate the ditches are for storm water runoff; however, the water, when present in the ditches, constitutes surface water as opposed to groundwater.
COMMENT: ATSDR should update this paragraph using the most recent 1990 census data. Currently nine people work at the AWI site and four over the road truck drivers operate out of the site.
RESPONSE: The updated information has been added.
COMMENT: AWII believes the use of the word "high" to describe concentration levels of contaminants is subjective. As an alternative, the word "elevated" could be used or present a range of concentrations found at the site to quantify contaminate levels. Using a range of contamination concentrations would accurately reflect site conditions.
RESPONSE: The word "high" is appropriate in that it conveys the qualitative interpretation that levels are much greater than comparison values. Note that health implications are based entirely on actual concentrations and whether or not exposure has actually occurred. By using the "worst case" conditions (maximum levels) to evaluate possible health impact, no sensitive population is overlooked.
COMMENT: Since the off-site migration of naphthalene that occurred on July 19, 1985, was as stated in the draft Public Health Assessment "an anomaly and of dubious merit," this discussion should be removed from the report. Including this text only confuses the reader and provides no valuable information.
RESPONSE: Contaminated air is a potential, and probably, a completed exposure pathway. The data collected were not sufficient to conclude what kinds and how much contamination people may be exposed to at the site and off site. The responsibility of the health assessor is to discuss what data are available and the value of that data. The discussion is appropriate.
COMMENT: PAHs and PCP were detected in surface and subsurface soils in the nine areas of the site that were investigated, not in "all" areas of the site.
RESPONSE: Clarifications have been made in the document.
COMMENT: More explanation is required for the "concentrations calculated from RfDs." The text should state that these are not promulgated standards. The methodology and assumptions used to calculate the RfD concentrations should be given either in the main text or an appendix to the report. Furthermore, why are carcinogenic PAHs for which there are no RfDs included in the tables and noncarcinogenic PAHs which have RfDs are excluded.
RESPONSE: A definition of an RMEG, a medium-specific comparison value calculated from EPA's RfD, has been added to the Glossary. RMEGs, as with EMEGs, are used to determine if a contaminant is present in the environment at levels, that upon human exposure, could possibly result in adverse health effects under certain conditions (which are discussed in the Public Health Implications section). Those values do not consider carcinogenic properties. CREGs, which are defined in the Glossary, are comparison values used to select possible carcinogenic contaminants of concern. If a CREG cannot be calculated (if there is no Cancer Slope Factor), the contaminant is automatically listed because no one knows how much exposure to a possible carcinogen may result in a person's increased risk of developing cancer. If contaminants were not listed, the levels present in the environment did not exceed any of the comparison values used to select contaminants of concern. Those contaminants are not believed to be present at levels that may cause adverse health effects, cancer or non-cancer, upon exposure.
COMMENT: Also, because the site and surrounding areas are industrial and it is extremely unlikely for a child to visit the site, the child and pica child scenarios are not relevant. It is inappropriate to be comparing site soils to health based levels developed for children and pica children when these exposures are extremely unlikely to occur. If discussions regarding pica are retained in this document, pica should be clearly defined.
RESPONSE: We reevaluated accessibility of the site to children and agree that children are not likely to play on the site. Changes have been made to the document to consider that.
COMMENT: A range of constituent concentrations should be presented in this section instead of only maximum constituent concentrations. The sole use of maximum concentrations in most of the discussion presents an inaccurate description of site conditions.
RESPONSE: We agree that using a range of concentrations gives a better over-all perspective of conditions of the site. However, by using the maximum contaminant values detected, the worst-case conditions are evaluated and measures can be taken to prevent exposure to contaminants where high levels may be present. The purpose of the public health assessment is to identify what exposures may cause health effects and to make recommendations to protect people who may come into contact with those contaminants.
COMMENT: [Under Groundwater, in the first paragraph, last sentence], the statement is incorrect. A number of monitoring wells at the site showed contaminant levels to be at background or below detection levels. Figures depicting groundwater quality at the site for contaminants of concern are included as Attachment 3. These figures are from the EPA approved RI Report dated March 1992.
RESPONSE: Some modification was made to the statement to better define contamination that is present.
COMMENT: The inlet associated with outfall 002 does not receive any "industrial discharge." Outfall 002 is for stormwater runoff only.
RESPONSE: The correction has been made.
COMMENT: The draft Public Health Assessment states that surface water samples were not analyzed for all site-related constituents of concern. This is incorrect. Since 1986....
RESPONSE: The correction has been made.
COMMENT: A statement is made that sediment samples collected at on-site locations showed higher levels of contamination than off site sampling locations. Analytical data presented in Table 3 indicate that only pentachlorophenol and arsenic in on-site sediments exceeded off site sediment concentrations. All.... We also suggest that on-site and off site sampling locations be identified on a map. This would provide the reader a visual awareness of where each sampling station is in relation to the AWII site.
RESPONSE: The text has been clarified. A good map that copied well and was easy to read of sampling locations was not available.
COMMENT: [Table 4] should be updated with the most recent data provided in Attachment 4.
RESPONSE: The Attachment was not provided to ATSDR. Therefore, we will have to evaluate the information when the site is reevaluated, which usually occurs as remedial activities are underway or concluded. The data that were available provides enough information to indicate what types of contaminants and their levels were present when more activity was occurring at the site.
COMMENT: The statement, "All other contaminants of concern, except benzene and PCP, were estimated to be present in the DNAPL" requires clarification. Benzo(a)pyrene was detected in the DNAPL at 1900 mg/L. Please explain that the remaining contaminants in questions were flagged with a J data qualifier, and provide some explanation of the qualifier as shown in Table 4-249 of the EPA approved RI Report (March 1992).
RESPONSE: The statement has been modified.
COMMENT: Change "also, four additional wood treatment facilities" to also, this may be due to four additional wood treatment facilities."
RESPONSE: The sentence is clear as stated. No changes are felt to be necessary.
COMMENT:

Due to high concentration of PAHs in sediments throughout the Southern Branch of the Elizabeth River, the multiple sources of PAHs, and the tidal action of the river, it is difficult to form any definite conclusions from the Huggett report which would link any discharge from the AWI site directly to PAH levels in oysters.

The correlation between PAH contamination in sediments and the increased prevalence of gross abnormalities in fish as reported by Huggett is also questionable. ... given that most fish exhibit movement over a large range, the text should include a discussion of non site related sources of contamination which could elicit the observed abnormalities.

RESPONSE: The document discusses the other sources of contamination of the Elizabeth River. The discussion in the section of the document related to this comment is to convey to the reader only what was found in the study. There is no need to repeat the discussions about other sources in that section.
COMMENT: The text on the fate and transport of constituents in air, soil, groundwater, and surface water should state that the discussion is theoretical...it gives the impression the physical and chemical processes described are currently occurring at the site.
RESPONSE: The section has been modified to convey what exposure pathways are complete and which are considered potential. The discussions now reflect what is or is potentially occurring.
COMMENT: The groundwater discharge rate of 0.48 liters per second converts to 1465 cubic feet per day not 720 cubic feet per day.
RESPONSE: This statement is part of the section that has been rewritten to more clearly define completed and potential exposure pathways.
COMMENT: Remove the words "a significant amount of" from this sentence or replace them with the groundwater discharge number from page 17 of the draft Public Health Assessment.
RESPONSE: Again, this comment involves the section of the document that has been rewritten to reflect how people have been or may be exposed to contaminants.
COMMENT: Change the second sentence [Toxicological Evaluation section] to "As discussed in the Pathways Analyses section, the potential human exposure pathways for this site are ingestion, dermal contact, and inhalation of contaminated soils for on-site workers, and ingestion of contaminated fish and shellfish by off-site residents."
RESPONSE: Revisions have been made in the wording of the section to clarify the information. However, your suggestion was not used because ingestion, dermal contact, and inhalation are routes of human exposure that are only one element of an exposure pathway.
COMMENT: The draft Public Health Assessment indicates that "arsenic may enter the body by ingestion of contaminated food or water." This statement addresses the concept of exposure in terms too general for a Public Health Assessment. The EPA approved Remedial Investigation Report, containing a Public Health and Environmental Assessment (risk assessment), specifically identifies potential exposure scenarios and receptors for the Atlantic Wood site...subjective statement[s] should be replaced with facts from the EPA approved RI Report [risk assessment].
RESPONSE: Use of risk assessments as interchangeable documents for public health assessments is inappropriate. The goal of the risk assessment is, among other things, to establish acceptable clean-up levels for the site. Those levels should be at or below levels that may cause adverse effects on people or the environment. To do this, scenarios are developed about possible exposures. One goal of the public health assessment, on the other hand, is to identify actual completed exposure pathways and potential exposure pathways and to provide the exposed people with information about their specific exposure. People who have been exposed to contaminants are not usually interested in what chance in 10,000 or in 1,000,000 they have of developing cancer or other health effects. They usually want to know in simple terms how they are exposed to the contaminants and if that exposure is going to make them sick. The use of qualitative terms (moderate, high, slight) relates on a more personal basis what chances the exposure to a contaminant will make the person sick. We feel the document accurately imparts that information to the exposed people.
COMMENT: As explained in the EPA approved RI report, potential risks associated with exposure to benzene at the AWI site are negligible relative to the potential risks associated with exposure to other constituents. Although benzene is present, it poses little significance with regard to impact to human health...Arsenic, pentachlorophenol, and polycyclic aromatic hydrocarbons are more important constituents with regard to public health impact at the site.
RESPONSE: In the revised public health assessment, discussions are limited only to contaminants of concern in completed exposure pathways. When new information becomes available about potential exposure pathways, further evaluations may be necessary.
COMMENT: [In the toxicological evaluation of pentachlorophenol], the formal definition of "Class B2 carcinogen" should be provided...Instead of presenting the maximum concentration, a discussion of the range of concentrations would provide a more representative description of the site...specific risks associated with exposure to pentachlorophenol are available in the risk assessment...The MCLG and MCL for PCP are 0 and 1.0 µg/L, respectively....
RESPONSE: Further information has been provided about B2 carcinogens. The questions about use of maximum levels of contaminants and the inappropriateness of using risk assessment information in public health assessments have already been addressed. References to MCLGs and MCLs have been removed from the discussion because those are not appropriate health comparison values for toxicological evaluations.
COMMENT: PAHs are ubiquitous in the environment and their presence due to anthropogenic and naturally occurring sources should be discussed.
RESPONSE: A discussion of that nature has been added to the toxicological evaluation of PAHs.
COMMENT: The Elizabeth River receives permitted discharges from numerous industrial and municipal outfalls...Therefore, the use of biota sampling to determine potential impacts from the AWI site does not appear to be an appropriate means for quantifying site related effects.
RESPONSE: ATSDR's obligation is to identify how people are or may be exposed to contaminants in the environment that may cause adverse health effects upon exposure. Sometimes information is found during the public health assessment process that indicates a mechanism for exposure that may not be site related, or entirely attributable to the site. ATSDR still has an obligation to the people who may be exposed to inform them of the contamination and to make recommendations to gather information that may help further evaluate the exposure pathway. EPA must decide whether or not to implement the recommendations and how the information will be gathered.
COMMENT: [In recommendation 5], the statement is incorrect. Please refer to the comments regarding NPDES sampling requirements...The statement that site related contaminants are found in the Elizabeth River should be changed to "contaminants similar to those found at the AWI site are also found in the Elizabeth River"...The draft Public Health Assessment also recommends that surface water samples should be collected from off-site locations. This does not appear to be necessary....
RESPONSE: The recommendation for additional on-site surface water sampling at NPDES stations has been deleted. Some changes in wording for other recommendations have been changed to clarify what specific information is needed. However, the recommendation for further surface water (Elizabeth River) and sediment characterization is appropriate.
COMMENT: A marked up copy of Figures 1 and 2 are included as Attachment 5 to correct inaccuracies and to provide additional information regarding site features.
RESPONSE: ATSDR was not provided the Attachment. VDH is believed to have verified the figures and made changes they felt appropriate.
COMMENT: The EPA approved Remedial Investigation Report (March 1992) prepared by Keystone Environmental Resources, Inc. on AWII's behalf should be added to the References section.
RESPONSE: Only the draft document dated September 1991 was provided for this public health assessment and that reference has been added.



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