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PUBLIC HEALTH ASSESSMENT

FIRST PIEDMONT ROCK QUARRY
BEAVER PARK, VIRGINIA


APPENDICES

APPENDIX A

GLOSSARY

Action level: Concentration of a contaminant that indicates a need for remediation, treatment, orprotection.

Cancer Risk Evaluation Guide (CREG): A comparison value for an environmental mediumdeveloped from EPA's Cancer Slope Factor for 1 x 10-6 excess cancer risk should human exposureoccur at that level.

Cancer Slope Factor: A value developed from studies, usually animal studies, to estimate the 1x 10-6 cancer risk for a specific chemical should human exposure occur.

Class A Human Carcinogen: EPA classification based on sufficient evidence of carcinogenicityin humans and in animals.

Class B Carcinogen: EPA classification based on insufficient evidence of carcinogenicity inhumans and sufficient evidence of carcinogenicity in animals.

Comparison Values: Existing guidelines or standards of exposure to specific contaminants. Examples of comparison values include EMEGs, RfCs, MCLs, Drinking Water Health Advisories,and Ambient Water Quality Criteria.

Drinking Water Health Advisory: The level of a contaminant in drinking water at which adversenoncarcinogenic health effects would not be anticipated with a margin of safety.

Environmental Media Evaluation Guides (EMEGs): Media specific screening values used toselect chemical contaminants of potential health concern at hazardous waste sites.

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): ATSDR's estimate of daily exposure of a human being to a chemical(in mg/kg/day) that is likely to be without an appreciable risk of deleterious effects(noncarcinogenic) over a specified duration of exposure. MRLs are based on human and animalstudies.

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

Potentially Responsible Parties (PRP): Past or present owners or operators of a hazardous wastefacility, anyone who arranged for disposal or treatment of hazardous substances at that facility, andanyone who both transported such substances to the disposal or treatment facility and selected it forthat purpose.

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 Dose Media Evaluation Guide (RMEG): A contaminant concentration in a particularmedium that is likely to be without appreciable risk of harmful effects during a lifetime exposure. The RMEG is calculated from an EPA-established reference dose.

Reference Dose (RfD): An estimate of the daily exposure of the human population to a potentialhazard that is likely to be without risk of harmful effects during a lifetime. RfDs are not applicableto nonthreshold effects such as cancer.

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.

Secondary Maximum Contaminant Level (SMCL): Guidelines established under the CleanWater Act to control drinking water contaminants that affect the aesthetic qualities of the water andare related to public acceptance of the water.

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


APPENDIX B

FIGURES


Figure 1. Regional Site Location


Figure 2. Topographic Map


Figure 3. Site Layout


Figure 4. Sampling Locations



APPENDIX C

RESPONSE TO PUBLIC COMMENTS

The initial draft of this document was released for public comment from March 1 through March31, 1993. Copies of the initial draft were available to the public at the Pittsylvania County PublicLibrary, 24 Military Drive, Chatham, VA; Danville City Health Department, 326 Taylor Drive,Danville, VA; and with the Pittsylvania County Administrator, 21 North Main Street, Chatham, VA. Comments that point out typographical errors are not included in this section. Also, wherecomments were duplicated, the comments were not repeated.

COMMENT:
I would like for it to be included in the recommendations for the First Piedmont Rock Quarry Superfund Site that a water line be installed for the residents in a one mile radius of this Superfund Site to ensure that the residents will always have a safe source of water. I would like this in addition to the existing remedial action plan, since the Environmental Protection Agency cannot give the residents surrounding the FPRQS a 100% assurance that our wells will never be contaminated by the toxic waste buried at this Superfund Site.

RESPONSE:
ATSDR has reviewed all the information available. At this point in time no information suggests that groundwater flow would result in contamination of private wells from site-related contaminants. Therefore, ATSDR cannot recommend an alternate water supply for residents at this time. EPA has arranged for continued monitoring of groundwater at the site to make sure conditions do not change. Also, as remediation is implemented, groundwater contaminant levels should decrease over time. Should the on-going monitoring reveal a change in groundwater flow patterns, ATSDR will reevaluate the need for an alternate water supply.

The concern about the your water supply is understandable. Data gathered from the October 1993 sampling round of private wells indicates that no contaminants are present at levels of health concern. Iron was present in one well at levels above environmental comparison values; however, the iron is not likely coming from the site and is not likely to result in adverse health effects upon ingestion. The sampling results do indicate a need for continued monitoring of the wells and, as recommended in this document, a need to identify the source for contaminants found periodically in the wells.

COMMENT:
No down gradient wells were tested. Local Health Department has not met with area citizens or tested wells.

RESPONSE:
No downgradient wells have been found to test. All private wells in the area are upgradient of the site. The local Health Department released sampling results of 15 randomly-selected private wells in the area in June 1985. The meeting conducted with citizens is described in the COMMUNITY HEALTH CONCERNS section of this document. In addition, EPA has conducted private well sampling in the area since that time. Wells were tested in October 1993. Results of the sampling are discussed in the OFF-SITE CONTAMINATION section.

COMMENT:
No health ed[ucation] is being offered, no well testing presently occurring or planned to my knowledge.

RESPONSE:
Health education coordination efforts have been slowed because of the length of time needed to release this document in final form. The document, along with other pertinent information, may be used as part of the community education program. Well testing information was addressed in the previous comment.

COMMENT:
EPA adm[inistrative] record shows old disposal area to be a contaminant source yet it's potential risks are not accessed.

RESPONSE:
This public health assessment is for the First Piedmont Rock Quarry site. The Old Disposal site is not defined as part of the site; however, clarifications are made in this document to acknowledge that the area is a possible contaminant source area.

COMMENT:
Observation #5, not all drums are fenced.

RESPONSE:
Clarifications are made in this document. However, at this time, the site is fenced and drums that contained waste from the Remedial Investigation have been removed.

COMMENT:
Why was site-specific health data unavailable?

RESPONSE:
No health studies have been conducted in the area. State health outcome data that are available do not address possible health effects that could result from exposure to contaminants at the site. Furthermore, no exposure to contaminants at the site has been confirmed. Only potential exposure pathways have been identified. Before a contaminant can make someone sick, that person has to come into contact with the contaminant at a high enough level and for a long enough period of time for effects to be seen.

COMMENT:
Was source of lead contamination in the private well identified and remedied?

RESPONSE:
A common source of lead contamination in drinking water comes from lead solder in home water supply lines. ATSDR is not aware if the contamination was definitely identified as coming from the home plumbing. However, in recent sampling, lead was not found in any of the private wells at levels above comparison values. A recommendation to identify the source(s) of contamination in private wells is incorporated into this document.

COMMENT:
Lack of waste characterization is of great concern. Risks cannot be assessed without this vital information.

RESPONSE:
As previously stated, people have to come into contact with contaminants before the contaminants can make them sick. Additionally, people have to come into contact with enough of the contaminant and for a long enough period of time to get sick. Site access is now restricted so that people cannot come into contact with the waste material. People who may have trespassed on the site prior to access restriction may have come into contact with the waste material. Although the levels of contaminants in the environment may be high, nothing is known about the duration of exposures. Those possible exposures cannot be evaluated, but the likelihood that someone trespassed on site and came in contact with waste material for long periods of time is doubtful.

On the other hand, to determine clean-up levels that should be established for the site, EPA needs enough information about the waste material to make remediation decisions. When making these decisions, EPA assumes that some type of exposure is possible and establishes a risk value for the contamination. A Record of Decision has been signed for the site, and the preferred alternatives appear to be protective of public health once implemented. If information gathered during the Remedial Design phase indicates a need for further characterization, that information will be gathered.

COMMENT:
Need to address data gap in the analytical results for cadmium.

RESPONSE:
Although the information would be needed if human exposure to the cadmium is identified, the data indicate that, if anything, the actual levels are less than reported because the contaminant was also found in the field blank. The remedial alternatives described in the Record of Decision provide for protection of the environment and human health from all contaminants found, including cadmium.

COMMENT:
At least one box of samples was mishandled with regard to [QC/QA]. Should we suspect others?

RESPONSE:
No. Laboratories identify questionable analyses with qualifiers so that the data can be appropriately evaluated. Mishandling of some samples is not uncommon.

COMMENT:
Should air be tested to determine health risks?

RESPONSE:
Air data may have been useful when wastes were disposed at the site to determine if nearby residents were exposed to contaminants at that time. However, the contaminants presently identified at the site as contaminants of concern are not likely to migrate through the air to nearby neighborhoods. Therefore, air data are not needed at this time. Air samples should be collected for particulates and volatiles during any excavation activities that occur during remediation to ensure that contaminants are not leaving the site through the air.

COMMENT:
Recommendations should include [installation of] a waterline to service a one mile radius surrounding the FPRQSS due to the fact that amounts, types and locations of wastes are unknown.

RESPONSE:
There is no health basis for that type of recommendation. ATSDR will continue to evaluate information as it becomes available to determine if there is a change in conditions.

COMMENT:
Trespassing will continue until the site is appropriately fenced.

RESPONSE:
ATSDR and EPA agreed. The site is now fenced.

COMMENT:
The Danville Health Department is not providing health education to Superfund community.

RESPONSE:
The details of such community health education need to be worked out.

COMMENT:
To my knowledge Danville Health Department is not and has not monitor[ed] residential wells. It is essential that the community be canvassed and surveyed to truly assess the affects this superfund site has had and continues to have on residents surrounding, not just upgradient of, this contaminated area.

RESPONSE:
Actions that have been taken by Danville Health Department and other agencies are described in this public health assessment. No private wells have been identified in the area except those that are upgradient of the site. Your comment indicates that you are very concerned about your health and the health of your neighbors because of the presence of the waste site in your community. Your health is our first concern. Hopefully, this public health assessment has been clarified to better explain what conditions must exist for the site to have impact on your health. ATSDR and EPA will continue to monitor conditions at the site to determine if changes occur that could impact your health. If you feel that we have missed something, please share that information with us. If you have sampling data to share with us, please include the laboratory's quality control/quality assurance information to help us evaluate the data.

COMMENT:
Recently, community concern has increased. A public workshop was held on March 11, 1993, where approximately 60 people attended. Citizens requested that water lines be installed. However, no significant evidence of contamination attributable to the site has been found in private wells, and this request has not been granted.

RESPONSE:
Changes have been made in the Community Health Concerns and Community Health Concerns Evaluation sections to incorporate that information.

COMMENT:
Under Surface Water in the Environmental Contamination and Other Hazards section: For better readability: Soil staining was observed during our site visit, which indicates that during high flow periods, some surface water drains from the seepage area southwestward to the Southern Drainage.

RESPONSE:
Some clarifications were made to the Site Visit section as well as to the section in question.

COMMENT:
If applicable, it may be helpful to explain if and how a rainfall might affect sampling. The sentence (Off-Site Contamination, Surface Water section) implies that rainfall may be important.

RESPONSE:
Some clarification has been added.

COMMENT:
What might a lack of data for waste characterization mean? How does it affect this assessment.

RESPONSE:
ATSDR agrees that the comments were confusing. The data available were adequate for assessing exposure pathways.

COMMENT:
[In the lead discussion, 4th paragraph, 1st sentence, the sentence] may read better as: ...health are the blood, nervous system, health and blood vessel systems....

RESPONSE:
We agree, and the change has been made.

COMMENT:
Second paragraph under Manganese: Is there a more understandable way to demonstrate .33 liters-in parentheses?

RESPONSE:
Considerable changes have been made to this section. Hopefully the clarifications are helpful.

COMMENT:
[In Community Health Concerns Evaluation], also asked was, "How do we know it never will?" Maybe also include here a sentence or two about the residents' request for water lines, and the lack of supporting evidence for it.

RESPONSE:
Considerable changes have been made to that section to include the information you offer.

COMMENT:
[In the Summary], second paragraph states that occasional use of the site is suspected. There is no information in the body of the report to verify this statement. The type of use suspected should be discussed in the Demographics, Land Use, and Natural Resource Use section.

RESPONSE:
Some clarifications have been made in several sections of the document.

COMMENT:
...The provisions of the ROD should also be discussed.

RESPONSE:
The information has been added.

COMMENT:
During the site visit in August 1990, evidence of runoff erosion was observed on the southwest side of the landfill. Does this erosion occur only within the landfill or in other areas of the site as well? Does the runoff carry contaminants off-site? Where are particles deposited? Is storm water runoff erosion a significant pathway? Details of the observed erosion should be provided.

RESPONSE:
Changes have been made in the document to address the comments you have provided. The changes in the Pathways Analyses section should explain what pathways are important at this site and which are not.

COMMENT:
...states that private wells in the Beaver Park community, adjacent to the site, have an average depth of 40 feet. A 40 foot well is generally considered shallow. In the Summary, it states that shallow groundwater is not used as a drinking water source. Please explain what is meant be "shallow groundwater" in the Summary. Does it mean the overburden aquifer, and that residential wells are drilled into the bedrock aquifer?
 
RESPONSE:
Changes have been made in the document to address your comment.

COMMENT:
The discussion of the comparison values should note that the values do not take into account the carcinogenic effects of the contaminants of concern. Also an explanation should be given as to why each type of comparison value was chosen.

RESPONSE:
Text has been added, and definitions have been added to the Glossary. The added text and definitions should clarify why certain comparison values were chosen. Also, some comparison values have been up-dated to reflect the current values used to select contaminants for further evaluation.

COMMENT:
The reason(s) comparison values are calculated for a child should be stated (e.g., worse case scenario?)

RESPONSE:
Some clarifications have been made in the text.

COMMENT:
The tabulated comparisons show only maximum concentrations of site contaminants. It is recommended that either average values be shown as well, or the range of values be given to provide a more realistic view of the site conditions.

RESPONSE:
ATSDR agrees that ranges of concentrations provide information on the overall site conditions; however, the maximum value provides for evaluation of the worst-case possibilities. Therefore, the maximum contaminant values have been retained in the document.

COMMENT:
...the contaminants presented in Table 1 are those for which the comparison values are exceeded. However, the concentration presented for barium is below the comparison value. The criteria used for including contaminants in this table should be clarified. The criteria used for subsequent tables is unclear as well. For example, all of the contaminants listed in Table 2 have concentrations below the comparison values.

RESPONSE:
The tables have been modified to reflect only contaminants found at levels above comparison values. At the time this document was released for public comment, ATSDR guidance suggested that when a contaminant was found above comparison values in one environmental medium, information on that contaminant should be carried through for all environmental media tested. As indicated by your comment, by doing that, confusion has resulted. For that reason, the health assessor now determines when it is appropriate and useful to do that.

COMMENT:
It is suggested that the EPA recommended clean-up levels for lead (500-1,000 mg/kg) be used as comparison values for soil.

RESPONSE:
Comparison values are calculated from health values or guidelines that are based on human or animal studies. At this time, ATSDR does not feel that adequate studies are available for lead to determine a comparison value for lead in soil.

COMMENT:
Page 8...refers to the cover over the landfill as a "soil cap," then later in the same paragraph it is called a "clay cap." Clayey soil is the material which was used; therefore, the cover should be described as such. Also, it should be stated that the cap is not in compliance with current regulations for landfill caps.

RESPONSE:
The statements have been changed to read "soil cover" rather than a cap in order to prevent any confusion about compliance with regulations.

COMMENT:
Table 2 indicates that the maximum concentrations of lead in on-site surface soil is 242 mg/kg. However, soil sample FP-107 (Technical Memorandum Subtask 4.15 Soil Sampling) indicates a lead concentration of 1,430 mg/kg....

RESPONSE:
The sampling result has been evaluated, and the change has been made in the document.

COMMENT:
Table 5--It should be noted that a reference dose for zinc is now available on IRIS....

RESPONSE:
All tables have been updated to reflect current comparison values, including the comparison values for zinc.

COMMENT:
Sediment sampling locations are shown on Figure 4, not figure 3 as indicated.

RESPONSE:
Thank you. The change has been made.

COMMENT:
[The Old Disposal Area is stated as] the suspected source of contamination in the Southern Drainage...the ROD states that the Carbon Black Pile is considered to be the source....

RESPONSE:
Corrections have been made in this document.

COMMENT:
[In the QA/QC section], the units presented...are incomplete and should be corrected.

RESPONSE:
Thank you. The corrections have been made.

COMMENT:
Page...states that a fence which impedes access to the area of the 30-foot high wall...exists. However,...the fence does not enclose the site completely...This should be considered in this section.

RESPONSE:
The site is now completely fenced; however, some changes have been made to the document to better reflect past conditions.

COMMENT:
The rationale for eliminating the waste pile as an [exposure pathway] is stated to be because it is unlikely that anyone would eat shredded rubber and debris...A more reasonable rationale...would be that exposure to this contaminant source would be much less frequent than daily....

RESPONSE:
ATSDR agrees. Changes have been made to address the comment.

COMMENT:
Page...[Toxicological Evaluation section]...states that the MRL or RfD will be used to calculate the quantity of a media needed to be ingested in order to exceed the dose which may cause adverse health effects...It appears that a literature value for typical ingestion levels of arsenic was used rather than the RfD...In addition, the difference between a MRL and a RfD should be stated, and MRL should be included in the Glossary.

RESPONSE:
MRLs and RfDs are used to help evaluate the potential for developing non-cancer adverse health effects upon exposure to contaminants. When current comparison values were used to select contaminants of concern and exposure pathways were considered, arsenic discussions were deleted from the document because no information available indicates that people have been exposed to arsenic at levels that could cause adverse health effects. If information becomes available that suggests otherwise, ATSDR will evaluate that information and determine if follow-up health actions are indicated. MRLs are now defined in the Glossary.

[NOTE: Other comments were received regarding the arsenic toxicological evaluation as well as other contaminants that have been deleted from toxicological evaluation discussions. Those discussions, as with arsenic, were deleted because no one has been exposed to those contaminants at levels that may cause adverse health effects. As with arsenic, if information becomes available to indicate otherwise, ATSDR will evaluate that information and determine if follow-up health actions are indicated.]

COMMENT:
It is noted...that cancer risk is not considered in calculating the amount of contaminated media needed to be ingested to cause an adverse effect. It should also be noted that if cancer risk were considered the amounts needed to cause an adverse effect (for carcinogens) would probably be lower.

RESPONSE:
ATSDR uses Cancer Slope Factors, when available, to calculate possible increased cancer risks to exposed people. ATSDR also uses Cancer Slope Factors to calculate Cancer Risk Environmental Guides (CREGs, which are defined in the Glossary) to establish comparison values for possible and known carcinogens present in environmental media. CREGs are not always listed as the comparison value because another guide may also be exceeded. However, when people have been exposed to a contaminant, the possible cancerous health effects are discussed as well as the possible non-cancer, adverse health effects.

COMMENT:
Page...states that studies have not determined what environmental levels of lead cause elevated blood levels. While this is true, there is a model available to predict concentrations in...media that would cause elevated blood levels...although the scenario on which the model is based is not directly applicable to the site, this concentration could be used as a comparison value.

RESPONSE:
The model is a practical tool for EPA to use, in some instances, to help establish clean-up levels that are protective of human health and the environment when other data are lacking. However, the purpose of the public health assessment is to identify actual human exposures and to provide information to those people on what health effects may occur, if any, as a result of those exposures. Because so much uncertainty still exists about the correlation between lead in the environment and the effects on blood lead levels upon exposure, ATSDR prefers not to use such models to establish comparison values.

COMMENT:
Page...states that white males between 40 and 59 years of age are among the population segments at risk from the effects of lead...A discussion of the effects on this population segment should also be included.

RESPONSE:
Thank you. Information has been added to clarify the statement.

COMMENT:
Page...states that there are insufficient data to determine if there is a level of manganese in water that is unsafe for humans to drink. This sentence should be clarified since there were enough data to set a reference dose for drinking water.

RESPONSE:
The discussion on manganese has been modified to consider the established RfD. An interesting note is that the average daily diet includes enough manganese to exceed the RfD. That is why more information on manganese in drinking water would be helpful in better evaluating possible health effects.

COMMENT:
The toxic effects of manganese should also be discussed.

RESPONSE:
The maximum levels of manganese found in private wells would not be expected to cause adverse health effects; therefore, a long discussion of health effects is not warranted. If someone would like to know more about manganese toxicity, ATSDR will be glad to provide information on the chemical and explain how a Toxicological Profile for Manganese can be ordered.

COMMENT:
Page...states that site trespassers may have been exposed to contaminants at levels high enough to cause disease or illness...Contaminants which are thought to have caused adverse effects to trespassers should also be addressed in [other sections of the document.

RESPONSE:
The wording was confusing. Changes have been made throughout the document that clarify assumptions made and conditions expected from trespassing.

COMMENT:
Page...states that the Danville Health Department will continue to monitor residential wells. When was the last time the residential wells were tested? What kind of framework is proposed for future testing?...A mechanism to insure [sic] that action is taken...should be included in the public health action plan.

The public health action plan should also specify what actions will be taken to determine the source of contamination in residential wells.

RESPONSE:
The role of the Danville Health Department has been clarified in this document. The private wells were last tested in October 1993. (They may have been sampled since that time, but information is not available if that is the case.) Iron was the only constituent, of those tested, that exceeded an EPA standard, the Secondary Maximum Contaminant Level (see Glossary). The public health action plan does provide a mechanism for continued monitoring.

A recommendation is made in the public health assessment to determine the source of the private well contamination. ATSDR presently does not have resources to conduct such activities. If an individual or another agency wishes to commit to provide that investigation, ATSDR will incorporate that commitment into the public health action plan.

COMMENT:
The residential well data which the Virginia Department of Health (DOH) concluded could "cause illness or injury"...should be tabulated...Also, a map showing the location of the contaminated well should be included...Finally, DOH's recommendation to sample residential wells periodically...should be identified as a public relations gesture, which is not necessary for the protection of public health.

RESPONSE:
Modifications have been made in the document to clarify what contaminants are of concern. ATSDR feels that showing the location of the private wells that contained non-site related contamination would violate confidentiality policy. The owners of the wells would need to request that we incorporate that information. Lastly, DOH and ATSDR recommend periodic private well sampling because the community is concerned about their health. Concerns that are not addressed may result in stress, which is a health effect. ATSDR feels that to label the recommendation as "a public relations gesture, which is not necessary for the protection of public health" is inappropriate.

COMMENT:
In the text preceding the statement, "residents are relying on local government to effectively deal with the problem," the report should describe the problem. As written, there exists a clear implication that residents' water supplies are contaminated, or in danger of becoming contaminated, by releases from the site. There is considerable evidence that this is not so.

RESPONSE:
Numerous modifications have been made to this document to clarify these points.

COMMENT:
EPA was not able to duplicate the RfCs for soil exposure. The report should describe how RfCs were calculated, including ingestion rate, days per year exposed, years exposed, and body weight.

RESPONSE:
The document has been changed to reflect current comparison values and more definitions have been added to the Glossary to help eliminate misunderstandings about comparison values.

COMMENT:
Comparing sediment concentrations with [comparison values] based on residential soil exposure is overly protective. EPA expects exposure to sediments to be much less, and the sediment [comparison values] should be correspondingly higher.

RESPONSE:
In most instances, people are less likely to come into contact with sediments than with backyard soils. However, comparison values are not intended to reflect any information on possible health effects. They are used only to select contaminants for further evaluation. For that reason, the soil guides are appropriate for use. If a completed exposure pathway is identified, and that contaminant is part of that pathway, then evaluations of those exposures are provided in the Toxicological Evaluation section. The exposure assumptions, which you point out, are considered in estimating doses as part of those evaluations.

COMMENT:
EPA suggests using 15 g/L lead...and 3,000 g/L zinc...as comparison values....

RESPONSE:
Comparison values have been changed to reflect current information.

COMMENT:
Comparing surface water concentrations with [comparison values] based on potable water ingestion is overly protective. [Comparison values] for surface water should be based on a less restrictive recreational exposure scenario.

RESPONSE:
See the previous response concerning sediment versus soil comparison values.

COMMENT:
As regards private well exposure, the first two elements of the five described in the Pathways Analyses...are missing. With no source and no transport mechanism, the residential drinking water exposure pathway cannot be considered complete. This conclusion might be defensible for a pre-remedial site having inadequate data, but not for a site which has an existing RI/FS.

RESPONSE:
ATSDR assumes you feel that no source or transport mechanism exists because the contamination found in private wells is not site-related. The document now emphasizes that the contamination is not site-related. However, ATSDR has an obligation to inform people who are exposed to contaminants, regardless of the source, about their exposures. The source, until further defined, is the well water. Levels of chemicals that exceed comparison values were found in the well water. The transport mechanism is the home plumbing system, which may prove to be a source of contamination. The exposure point is the tap, the exposed population are the people who use the water, and the primary route of exposure is ingestion.

COMMENT:
It is not clear why DOH based its comparison value for arsenic on the RfD rather the oral carcinogenic potency slope. The decision to omit carcinogenicity from quantitative evaluation should be acknowledged and discussed.

RESPONSE:
ATSDR and DOH agree about the choice of comparison values. The change has been incorporated into the document.

COMMENT:
...should also make it clear that lead concentrations in tap water often exceed 15 g/L, even in municipal systems, because of contributions from household plumbing. Other sections in the report imply that the source of contamination is a mystery...In fact, such lead levels are all too common.

RESPONSE:
The fact that home plumbing is often found to be the source of high metals such as lead and iron in water has been incorporated into the document. However, that does not eliminate the possibility that other, as yet unidentified, sources of contamination may exist.

COMMENT:
The conclusions are essentially the same as those made in the RI/FS, so EPA concurs. The recommendation to sample residential wells is stated exactly correctly--"because of community concern." There is no evidence these wells can ever be contaminated by the site, even if the site were not remediated.

RESPONSE:
Because this is opinion rather than a comment, no response is needed.

COMMENT:
As written, the Draft for Public Comment Public Health Assessment for the First Piedmont Rock Quarry contains a few comments that could be misinterpreted. The Pittsylvania-Danville Health Department conducted a public education program and private well testing program in 1985, but has not done so since, contrary to the comments...of the draft. Also, the local Health Department may not be aware of recent actions by other agencies, nor have immediate access to all the technical data, such that it may not always be in the best position to provide public education. However, it should be involved in the process.

[Danville Health Department] recommends the following changes:

[Summary] Such efforts should be coordinated with the Pittsylvania-Danville Health District who in turn will monitor and assess local requirements for further education. Also, the District will assist in collecting samples from residential wells within the site vicinity in coordination with other monitoring efforts.

[Public Health Actions] Education efforts from involved agencies will be coordinated with the Pittsylvania-Danville Health District, who in turn will assess public reaction and requirements for further educational efforts.

The Pittsylvania-Danville Health District will assist in collecting samples for residential wells within the site vicinity in coordination with other monitoring efforts.

RESPONSE:
Thank you for the clarifications. The changes have been incorporated into the document.

COMMENT:
[The statement], "Several private wells in the area have relatively high iron, lead...but these are not suspected to be Site related." The word suspected should be deleted since it has been shown that the site is not a source of contamination to the private wells.

RESPONSE:
ATSDR agrees that the word "suspected" is inappropriate. The word has been replaced with "considered."

COMMENT:
The section of Recommendations...states "The following recommendations are made to reduce or prevent exposure to contaminants at the FPRQ site."...[the Recommendations] are not related to reducing or preventing the potential for exposure to contaminants at or related to the Site. These recommendations, if made, relate to unknown sources, unrelated to the Site. This distinction need[s] to be clear.

RESPONSE:
Some changes were made in the wording. However, the recommendations are appropriate.

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  1. A
  2. B
  3. C
  4. D
  5. E
  6. F
  7. G
  8. H
  9. I
  10. J
  11. K
  12. L
  13. M
  14. N
  15. O
  16. P
  17. Q
  18. R
  19. S
  20. T
  21. U
  22. V
  23. W
  24. X
  25. Y
  26. Z
  27. #