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PUBLIC HEALTH ASSESSMENT

RICKENBACKER AIR NATIONAL GUARD BASE (USAF)
(a/k/a RICKENBACKER AIR FORCE BASE)
COLUMBUS, FRANKLIN COUNTY, OHIO


APPENDIX B: COMPARISON VALUES

The conclusion that a contaminant exceeds the comparison value does not mean that it willcause adverse health effects. Comparison values represent media-specific contaminantconcentrations that are used to select contaminants for further evaluation to determine thepossibility of adverse public health effects.

Cancer Potency Factor (CPF)
Usually derived from dose-response models and expressed in mg/kg/day, CPFs describe the inherent potency of carcinogens and estimate an upper limit on the likelihood that lifetime exposure to a particular chemical could lead to excess cancer deaths.

Cancer Risk Evaluation Guide (CREG)
Estimated contaminant concentrations that would be expected to cause no more than one excess cancer in a million (10-6) persons exposed over a 70-year life span. ATSDR's CREGs are calculated from EPA's cancer potency factors.

EPA Region III Risk-Based Concentration
EPA combines reference doses and carcinogenic potency slopes with "standard" exposure scenarios to calculate risk-based concentrations, which are chemical concentrations corresponding to fixed levels of risk (i.e., a hazard quotient of 1, or lifetime cancer risk of 10-6, whichever occurs at a lower concentration) in water, air, fish tissue, and soil.

Lowest Observed Adverse Effect Level ( )
The lowest dose of a chemical that produced an adverse-effect when it was administered to animals in a toxicity study.

Maximum Contaminant Level (MCL)
The MCL is the drinking water stand established by EPA and enforced by the California Department of Environmental Protection. It is the maximum permissible level of a contaminant in water that is delivered to the free-flowing outlet. MCLs are considered protective of human health over a lifetime (70 years) for individuals consuming 2 liters of water per day.

Minimal Risk Levels (MRLs)
MRLs are estimates of daily human exposure to a chemical (i.e., doses expressed in mg/kg/day) that are unlikely to be associated with any appreciable risk of deleterious noncancer effects over a specified duration of exposure. MRLs are calculated using data from human and animal studies and are reported for acute (< 14 days), intermediate (15-364 days), and chronic (> 365 days) exposures. MRLs are published in ATSDR Toxicological Profiles for specific chemicals.


APPENDIX C: GLOSSARY

Absorption:
How a chemical enters a person's blood after the chemical has been swallowed, has come into contact with the skin, or has been breathed in.


Adverse Health Effect:
A change in body function or the structures of cells that can lead to disease or health problems.


ATSDR:
The Agency for Toxic Substances and Disease Registry. ATSDR is a federal health agency in Atlanta, Georgia that deals with hazardous substance and waste site issues. ATSDR gives people information about harmful chemicals in their environment and tells people how to protect themselves from coming into contact with chemicals.


Background Level:
An average or expected amount of a chemical in a specific environment. Or, amounts of chemicals that occur naturally in a specific environment.


Biota:
Used in public health, things that humans would eat - including animals, fish and plants.


Cancer:
A group of diseases which occur when cells in the body become abnormal and grow, or multiply, out of control


Carcinogen:
Any substance shown to cause tumors or cancer in experimental studies.


CERCLA:
See Comprehensive Environmental Response, Compensation, and Liability Act.


Completed Exposure Pathway:
See Exposure Pathway.


Comparison Value:
Concentrations or the amount of substances in air, water, food, and soil that are unlikely, upon exposure, to cause adverse health effects. Comparison values are used by health assessors to select which substances and environmental media (air, water, food and soil) need additional evaluation while health concerns or effects are investigated.


Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):
CERCLA was put into place in 1980. It is also known as Superfund. This act concerns releases of hazardous substances into the environment, and the cleanup of these substances and hazardous waste sites. ATSDR was created by this act and is responsible for looking into the health issues related to hazardous waste sites.


Concern:
A belief or worry that chemicals in the environment might cause harm to people.


Concentration:
How much or the amount of a substance present in a certain amount of soil, water, air, or food.


Contaminant:
See Environmental Contaminant.


Dermal Contact:
A chemical getting onto your skin. (see Route of Exposure).


Dose:
The amount of a substance to which a person may be exposed, usually on a daily basis. Dose is often explained as "amount of substance(s) per body weight per day".


Duration:
The amount of time (days, months, years) that a person is exposed to a chemical.


Environmental Contaminant:
A substance (chemical) that gets into a system (person, animal, or the environment) in amounts higher than that found in Background Level, or what would be expected.


Environmental Media:
Usually refers to the air, water, and soil in which chemical of interest are found. Sometimes refers to the plants and animals that are eaten by humans. Environmental Media is the second part of an Exposure Pathway.


U.S. Environmental Protection Agency (EPA):
The federal agency that develops and enforces environmental laws to protect the environment and the public's health.


Exposure:
Coming into contact with a chemical substance.(For the three ways people can come in contact with substances, see Route of Exposure.)


Exposure Assessment:
The process of finding the ways people come in contact with chemicals, how often and how long they come in contact with chemicals, and the amounts of chemicals with which they come in contact.


Exposure Pathway:
A description of the way that a chemical moves from its source (where it began) to where and how people can come into contact with (or get exposed to) the chemical.

ATSDR defines an exposure pathway as having 5 parts:
  1. Source of Contamination,

  2. Environmental Media and Transport Mechanism,

  3. Point of Exposure,

  4. Route of Exposure; and,

  5. Receptor Population.

When all 5 parts of an exposure pathway are present, it is called a Completed Exposure Pathway. Each of these 5 terms is defined in this Glossary.


Frequency:
How often a person is exposed to a chemical over time; for example, every day, once a week, twice a month.


Hazardous Waste:
Substances that have been released or thrown away into the environment and, under certain conditions, could be harmful to people who come into contact with them.


Health Effect:
ATSDR deals only with Adverse Health Effects (see definition in this Glossary).


Indeterminate Public Health Hazard:
The category is used in Public Health Assessment documents for sites where important information is lacking (missing or has not yet been gathered) about site-related chemical exposures.


Ingestion:
Swallowing something, as in eating or drinking. It is a way a chemical can enter your body (See Route of Exposure).


Inhalation:
Breathing. It is a way a chemical can enter your body (See Route of Exposure).


NPL:
The National Priorities List. (Which is part of Superfund.) A list kept by the U.S. Environmental Protection Agency (EPA) of the most serious, uncontrolled or abandoned hazardous waste sites in the country. An NPL site needs to be cleaned up or is being looked at to see if people can be exposed to chemicals from the site.


No Apparent Public Health Hazard:
The category is used in ATSDR's Public Health Assessment documents for sites where exposure to site-related chemicals may have occurred in the past or is still occurring but the exposures are not at levels expected to cause adverse health effects.


No Public Health Hazard:
The category is used in ATSDR's Public Health Assessment documents for sites where there is evidence of an absence of exposure to site-related chemicals.


PHA:
Public Health Assessment. A report or document that looks at chemicals at a hazardous waste site and tells if people could be harmed from coming into contact with those chemicals. The PHA also tells if possible further public health actions are needed.


Plume:
A line or column of air or water containing chemicals moving from the source to areas further away. A plume can be a column or clouds of smoke from a chimney or contaminated underground water sources or contaminated surface water (such as lakes, ponds and streams).


Point of Exposure:
The place where someone can come into contact with a contaminated environmental medium (air, water, food or soil). For examples:
the area of a playground that has contaminated dirt, a contaminated spring used for drinking water, the location where fruits or vegetables are grown in contaminated soil, or the backyard area where someone might breathe contaminated air.


Population:
A group of people living in a certain area; or the number of people in a certain area.


Public Health Assessment(s):
See PHA.


Public Health Hazard:
The category is used in PHAs for sites that have certain physical features or evidence of chronic, site-related chemical exposure that could result in adverse health effects.


Public Health Hazard Criteria:
PHA categories given to a site which tell whether people could be harmed by conditions present at the site. Each are defined in the Glossary. The categories are:
  1. Urgent Public Health Hazard

  2. Public Health Hazard

  3. Indeterminate Public Health Hazard

  4. No Apparent Public Health Hazard

  5. No Public Health Hazard

Receptor Population:
People who live or work in the path of one or more chemicals, and who could come into contact with them (See Exposure Pathway).


Route of Exposure:
The way a chemical can get into a person's body. There are three exposure routes:
- breathing (also called inhalation),
- eating or drinking (also called ingestion), and
- or getting something on the skin (also called dermal contact).


SARA:
The Superfund Amendments and Reauthorization Act in 1986 amended CERCLA and expanded the health-related responsibilities of ATSDR. CERCLA and SARA direct ATSDR to look into the health effects from chemical exposures at hazardous waste sites.


Source (of Contamination):
The place where a chemical comes from, such as a landfill, pond, creek, incinerator, tank, or drum. Contaminant source is the first part of an Exposure Pathway.


Superfund Site:
See NPL.


Toxic:
Harmful. Any substance or chemical can be toxic at a certain dose (amount). The dose is what determines the potential harm of a chemical and whether it would cause someone to get sick.


Volatile organic compound (VOC):
Substance containing carbon and different proportions of other elementssuch as hydrogen, oxygen, fluorine, chlorine, bromine, sulfur, ornitrogen; these substances easily become vapors or gases. A significantnumber of the VOCs are commonly used as solvents (e.g., paintthinners, lacquer thinner, degreasers, dry cleaning fluids).

APPENDIX D: RESPONSES TO PUBLIC COMMENTS

The Agency for Toxic Substances and Disease Registry (ATSDR) received the followingcomments/questions during the public comment period for the Rickenbacker Air NationalGuard Base (RANGB) Public Health Assessment (PHA). For comments that questioned thevalidity of statements made in the PHA, ATSDR verified or corrected such statements. Thelist of comments does not include editorial comments concerning such things as word spellingor sentence syntax. Page numbers reference the Public Comment Draft and may not be thesame as those in the Final RANGB PHA.

  1. Comment 1: (General Comment) With the known high clay content and low migration potential, are the statements about plumes and their potential to pollute still justified?
  2. Response: ATSDR did not change the original text because it states that potential plume migration and a future completed pathway are unlikely.

  3. Comment 2: (Summary) An exact description of the property being discussed shouldbe added to the Summary. Is it just the property that was used to score the base? Thisdoes not seem to be defined.
  4. Response: ATSDR changed the text to include a more detailed description of the RANGB property, as defined and reviewed in the PHA.

  5. Comment 3: (Page 1) ATSDR states "Public exposure (past, current, and future) tosurface water and sediment, however, is minimal, if it occurs at all, so there is no publichealth hazard." EPA does not agree with this statement. If portions of Site 25 aredeveloped (i.e., construction of a culverted ditch system or renovation for residences) inthe future, there may be a potential public health hazard associated with this site. Please clarify.
  6. Response: ATSDR did not change the original text because public exposure is and willcontinue to be limited and no receptor human populations were identified at Site 25. As described in the document, the reuse plan will maintain Site 25 (and the rest of thebase) for industrial/commercial use and not redevelop the area for residential purposes. No potential future public health hazards are associated with Site 25.

  7. Comment 4: (Page 1, para. 4) ATSDR health-based comparison values have been usedto compare against compound concentrations, however, these values are not given inthis document. They should be provided in table format and the use of thesecomparison values should be explained. It has been stated that groundwater containsvolatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), andmetals above ATSDR health-based comparison values. These chemical should be listedand the locations given. For example, are they located at the landfill or the base?
  8. Response: ATSDR clarified the text to state whether contaminants were detected atInstallation Restoration Program (IRP) sites or at the Rickenbacker Landfill. Specificcontaminant detection locations, concentrations, and comparison values are included inAppendix A.

  9. Comment 5: (Page 1, last para.) Sites 1, 12, and 45 should be discussed in thisdocument. Site 1 has groundwater contaminant concentrations over EPA's MaximumContaminant Levels (MCLs) and is currently undergoing closure under ResourceConservation and Recovery Act (RCRA). Site 45 has groundwater contaminantconcentrations over EPA's MCL for benzene and is being monitored by the Air Force. Site 12 has groundwater contaminant concentrations over EPA's MCLs and currentlynothing is being done about this. In addition, potentially Sites 25 and 27 may alsorequire remediation as the sediment contaminant levels in the ditch system are above anunrestricted reuse scenario.
  10. Response: ATSDR changed the text and Appendix A to update and accurately reflectcontaminant and remedial information regarding Sites 1, 12, 25, 27, and 45.

  11. Comment 6: (Page 2) ATSDR states "At Rickenbacker Landfill and five InstallationRestoration Program (IRP) sites with soil contamination, remedial activities have orwill further reduce contaminant concentrations and the potential for incidentalexposure." Remedial activities are not currently planned for the Rickenbacker Landfillas the preliminary assessment and site investigation have not been completed. Inaddition, there are no known "access restrictions" (i.e., fencing) to prevent trespassersfrom frequenting the landfill. As a baseline risk assessment has not been completed,EPA believes that the potential risks associated to exposure to the landfill have not beenquantified. Please clarify.
  12. Response: ATSDR revised the text and tables to accurately reflect detectedcontaminants, remedial activities, and access restrictions at Rickenbacker Landfill andthe IRP sites. ATSDR changed its assessment of public health hazards associated withRickenbacker Landfill from no apparent hazard to an indeterminate hazard because thenature and extent of landfill contamination has not been fully characterized.

  13. Comment 7: (Page 4, para. 2) Site 8 was not folded into the investigation for Site 25. Site 8 was not able to be physically located. Sites 11, 13, and 18 were not removedfrom the site investigation; they were eliminated at the end of the preliminaryassessment. Later on additional samples were collected at Sites 7 and 18 and thosesites were determined to need no additional investigation. Sites 25/27 are undergoingBCT discussion regarding the ditch system.
  14. Response: ATSDR changed the text and Appendix A to accurately reflect this information.

  15. Comment 8: (Page 5, para. 2) It should also be stated that Rickenbacker is not an NPL site.
  16. Response: ATSDR changed the text to explicitly state that Rickenbacker is not an NPL site.

  17. Comment 9: (Page 5, para. 4) In addition to work being conducted under the IRP, workis being conducted under the Bureau of Underground Storage Tank Regulation's(BUSTR) rules and the Resource, Conservation, and Recovery Act (RCRA)regulations. In the second sentence, the information is incorrect. The no further action(NFA) IRP sites were not presented in the Final FS Report. The Feasibility Study (FS)Report presents the alternatives for remediation of five IRP sites. Again, the RemedialAction Decision Document is for the five IRP sites moving forward into the remedialdesign/remedial action stage. NFA sites have their own decision documents, but theydo not include minutes of a public meeting, written comments, or a responsivenesssummary. The five sites undergoing remediation were evaluated by the Air Force, U.S.EPA, and Ohio EPA. The Final Feasibility Study Report and the Remedial ActionDecision Document have been approved. Lastly, the Landfill should probably have itsown paragraph because it is in a different process.
  18. Response: ATSDR changed the text and Appendix A to accurately reflect this information. The Rickenbacker Landfill paragraph was separated from the IRPdiscussion.

  19. Comment 10: (Page 5, Remedial and Regulatory History) A Remedial Action DecisionDocument for Sites 2, 21, 41, 42, and 43 was signed on October 14, 1999, by the AirForce, EPA, and Ohio EPA. The Design Documents for the remedial activities werecompleted on October 21, 1999. The Air Force is currently working on the RemedialAction Work Plans and hope to start work in fiscal year 2000. Please add this currentinformation to this document.
  20. Response: ATSDR updated the text and Appendix A to reflect this information.

  21. Comment 11: (Page 5, Remedial and Regulatory History) Although there may be aMemorandum of Agreement between EPA and the Department of Defense, this is notconsidered a State Memorandum of Agreement. Also, EPA is not clear that thememorandum of agreement states that EPA and Ohio EPA will jointly maintainoversight of the investigation and remedial work conducted. Please provide yoursource of this information.
  22. Response: ATSDR did not change the original text. The information source cited is the Scientific/Management Decision Point for IRP Site 25 at Rickenbacker Air National Guard Base (IT Corp. 1998).

  23. Comment 12: (Page 7, Natural Resources and Land Use [Reuse Plan], para. 3) Please update the information in this paragraph.
  24. Response: ATSDR contacted Alan C. Friedstrom, BRAC Environmental Coordinatorat Rickenbacker Air Force Base Conversion Agency, to discuss the current status of theRANGB reuse plan. ATSDR revised the text to include information about recentlyenacted prohibitions and deed restrictions.

  25. Comment 13: (Page 7, Natural Resources and Land Use [Reuse Plan]) Although aReuse Plan may have been developed for this property, EPA is unaware of any legalauthority which requires the reuse plan to be used for the specified purposes.
  26. Response: ATSDR contacted Alan C. Friedstrom, BRAC Environmental Coordinatorat Rickenbacker Air Force Base Conversion Agency. Regardless of existing legalauthorities, Mr. Friedstrom assured ATSDR that RANGB will enact and enforce anyand all prohibitions and deed restrictions necessary to protect human health. ATSDRincluded and cited this information in the text.

  27. Comment 14: (Page 9, Evaluation of Environmental Contamination and PotentialExposure Pathways, Introduction) In the third paragraph, it might be better to state,"After fully evaluating potential human exposure pathways at RANGB, ATSDRconcluded that current and future public exposures to groundwater, surface water,sediment, soil, and locally-caught fish are not likely to result in adverse human healtheffects because contamination in these media is below levels of health concern and/orthere is no public exposure to contamination in these media." EPA believes that futurepublic exposures to these media has the potential to result in adverse human healtheffects if the sites have an unrestricted use to groundwater or if the property isredeveloped as residential property.
  28. Response: ATSDR contacted Alan C. Friedstrom, BRAC Environmental Coordinatorat Rickenbacker Air Force Base Conversion Agency and affirmed that RANGBproperty will not be redeveloped for residential purposes. If necessary, additionalRANGB prohibitions and deed restrictions will prevent potential future exposures tocontaminated media. ATSDR did not revise the original text because no futurepathways were identified.

  29. Comment 15: (Page 10, Groundwater Use, para. 1) Five production wells, RB-1through RB-5, have been closed and abandoned. They were located in the northwestportion of the base and were deep wells. Production well RB-6 was not located at theheating plant but is located at the golf course to the south of the airfield. Current statusis unknown. There was also a production well located at the heating plant, but I do notknow what its identification was. It was located in the intermediate aquifer.
  30. Response: ATSDR contacted Alan C. Friedstrom, BRAC Environmental Coordinatorat Rickenbacker Air Force Base Conversion Agency, and David Edwards, former WaterPlant Foreman at Rickenbacker Air Force Base. Both individuals and referencedocuments confirmed that RB-6 is located at the heating plant and that an unnamedwell is located at the golf course. ATSDR revised the text to include information aboutthe golf course well, referred to as "a seventh production well."

  31. Comment 16: (Page 10, para. 4, "Groundwater Use" Section) This paragraph is acorrect and factual discussion of the groundwater use of Rickenbacker ANGB (extent1980 - present); however, if the ATSDR evaluation expands to include the formerRickenbacker AFB, then one more well needs to be added to the list. This well, whichas no "RB" designation, was located adjacent to the clubhouse at the former golf courseand provided domestic water for patrons of the clubhouse golf course. The golf course,including the seventh well, were sold by the GSA to a private organization in 1983.
  32. Response: ATSDR obtained historical and recent well records for this seventh well and added the information to the PHA.

  33. Comment 17: (Page 11, Nature and Extent of Groundwater Contamination, para. 1)The second sentence should state that the Army Corps of Engineers is investigating thedioxin contamination at the Landfill. In addition, please explain how the ATSDRcomparison values were used at each site and add Sites 1, 12, and 45 to the list.
  34. Response: ATSDR changed the text to reflect that the Army Corps of Engineers isinvestigating landfill dioxin contamination and that groundwater underlying Sites 1, 12,45 exceeded ATSDR comparison values.

  35. Comment 18: (Page 12, para. 2) Ohio EPA collected samples from five domesticdrinking water wells because they were located in the Upper Water Bearing Zone(UWBZ). The other two wells were not sampled because they were located in theintermediate aquifer. Please correct the text to reflect this.
  36. Response: ATSDR changed the text to "In 1995, OEPA collected and analyzedgroundwater samples (screened in the shallow aquifer) from five of these seven privatewells. All sampled wells drew water from the UWBZ. OEPA deemed it unnecessary tosample two wells that drew water from the deeper intermediate aquifer becausecontaminant concentrations were believed to be below UWBZ levels. Water from thefive tested wells met all federal and state drinking water standards (Waters 1996)."

  37. Comment 19: (Page 12, Nature and Extent of Groundwater Contamination) In the 2ndparagraph on this page, the text indicates, "These interim activities further served toprevent any potential public exposure from potential contaminant plume migrationtowards the village of Lockbourne." How does sampling private well water prevent anypotential public exposure? By hooking up the village to the RANGB drinking watersupply line and subsequently the Columbus Division of Water would serve to preventany potential public exposure to potentially contaminated groundwater. However, thisactivity would not prevent contaminant plume migration as contaminants can movefreely in the groundwater. In addition, sampling private well water in 1995 wouldsimply indicate that potential public exposure to contaminated groundwater did notoccur in 1995.
  38. Response: ATSDR deleted the original sentence referring to groundwater interimactivities. ATSDR agrees that 1995 sampling data can only indicate that no publicexposure to contaminated groundwater occurred in 1995, but when the 1995 data areevaluated with other RANGB groundwater monitoring efforts, the cumulative data setindicates that there is no off-site plume migration and, therefore, no potential publichealth concern.

  39. Comment 20: (Page 13, Off-base Exposures) Although Ohio EPA and RANGB haveannounced that no one in the village should be drinking the groundwater, there are stillresidences in the village which were identified as having wells that draw from the upperwater bearing zone. How will the private water supply systems be monitored to ensurethat these six residences are still not impacted by drinking the groundwater? Pleaseclarify.
  40. Response: ATSDR revised the groundwater text and tables to reflect that contaminantshave not migrated off site. Current private well monitoring data (post 1995) areunavailable, but potential future contaminant migration has been/will be prevented byAir Force remedial activities.

  41. Comment 21: (Page 13, Off-base Exposures, para. 1) Please identify who, person ordivision, at Ohio EPA, stated that residents of Lockbourne should not drink water fromtheir domestic drinking water wells and the date that this was stated.
  42. Response: ATSDR deleted the text and table references to the recommendationattributed to Ohio EPA. During the January 1999 ATSDR site visit, it wasrecommended that residents of Lockbourne should use municipal drinking water ratherthan drink water from their private drinking water wells, but no formal Ohio EPArecommendation has ever been issued.

  43. Comment 22: (Page 13, para. 3) "On-base wells were not tested for water qualityparameters when they were active." This statement is misleading. The productionwells when they were active complied with all drinking water standards in effect forwater quality and these results would be reported to the appropriate authorities. Thewater quality standards would be such things as: hardness, corrosively, bacterial counts,lead, iron... If you meant that a screen for EPA environmental contaminants (benzene,TCE, ...) was not performed, so state.
  44. Response: ATSDR obtained additional historical well logs and water quality reports and revised the text to reflect this information.

  45. Comment 23: (Page 15, para 1, line 2) Of all the investigations conducted by the AirForce and the Army Corps of Engineers related to surface water dioxins, low leveldioxins were only detected at one location in one drainage ditch; therefore the sentenceshould be reworded to read: "Low-level dioxins were detected in one location in onedrainage ditch, but at a level below ATSDR comparison values for drinking water andsoil."
  46. Response: ATSDR changed the text as requested.

  47. Comment 24: (Pages 15 and 16, Nature and Extent of Surface Water and SedimentContamination) The text indicates that the most upgradient portions of the ditch systemare areas which there is no public access. This is not the case for the Northwest andSouthwest portions of the ditch system. In addition, EPA would recommend ATSDRspecify which quadrants contained the greatest contaminant concentrations. Pleasereference the EPA document which established a mercury cleanup standard of soils andsediments of 400 parts per million (ppm). EPA is unaware of establishing this sitecleanup level for RANGB. EPA does not agree with the statement that all sedimentcontaminant concentrations in the Rickenbacker Air National Guard Base drainagesystem are within normal background concentrations are not "site-related." EPAestablishes site-specific background concentrations for inorganics only and not organiccontaminants. "Site-related" contaminants are considered any contaminants whichwere produced by past activities and operations at the base. Although, the Air Force(not the Air National Guard) may be discussing the no further action status for this site,EPA still recommends that the Air Force conduct toxicity testing, a feasibility study, ora "hot spot removal" of the highly contaminated sediments in the ditch system. Inaddition, EPA is unaware of any document which will require the drainage ditch systemto retain an industrial/commercial land use. If this land use is not retained, does thepotential for a public health hazard exist? Please clarify.
  48. Response: ATSDR changed the text regarding the 400 ppm mercury cleanup standardand "site-related" sediment contamination issues. ATSDR added that EPArecommends that the Air Force conduct toxicity testing, a feasibility study, or a "hotspot removal" of the highly contaminated sediments in the ditch system. Appendix Adiscusses ditch system contaminant and exposure issues (Sites 25 and 27) in moredetail, but ATSDR did not elaborate in the text to specify which quadrants containedthe greatest contaminant concentrations. In general, contaminants detected in each ofthe four quadrants of the ditch system were similar (IT Corp. 1998).

  49. Comment 25: (Page 15, para. 5) I know of no cleanup standard of 400 ppm for mercury that was established by U.S. EPA for Rickenbacker. An explanation is needed.
  50. Response: ATSDR changed the text regarding the 400 ppm mercury cleanup standard.

  51. Comment 26: (Page 16, para. 1) The drainage ditch system is undergoing discussion bythe BCT and their technical support members. This includes representatives from theAir Force, U.S. EPA, and Ohio EPA. This should be noted in the text.
  52. Response: ATSDR changed the text as suggested.

  53. Comment 27: (Page 16, Nature and Extent of Soil Contamination, para. 1) Soilremoval will occur at Sites 21, 41, 42, and 43. The soil removal at Site 2 is for thepurpose of installing a reactive wall for the remediation of groundwater and is not forsoil remediation. In addition, soil removals may be required at Sites 1 and 12.
  54. Response: ATSDR updated the document's soil contamination and remedial activities text and tables to reflect this information.

  55. Comment 28: (Page 16, Evaluation of Potential Public Health Hazards) What preventstrespassers and ecological receptors from being exposed to the potentially contaminatedsediment which are above industrial/commercial screening criteria? Also, whatprotective clothing for workers is ATSDR referring to?
  56. Response: ATSDR changed the text to state that public exposure is minimized by theindustrial/commercial land use surrounding the drainage ditches. ATSDR deleted thesentence in the text referring to worker protective clothing.

  57. Comment 29: (Page 16 and 17, Nature and Extent of Soil Contamination) The soilremediation which is being conducted at Sites 21, 41, 42, and 43 is being conducted tominimize the leaching of contaminants into the groundwater. This action is not beingconducted to reduce contaminants in the soil. Please clarify. Also, have VOCs beendetected in soils above ATSDR comparison values at Site 2. In addition, the formerLockbourne Landfill is prime property for trespassers. Selected Phase I and Phase IIsamples have exceeded EPA Region IX's industrial preliminary remediation goals which are estimated contaminant concentrations that would be expected to cause nomore than one excess cancer in a million persons exposed over a 70-year life span. This would indicate that the potential for the contaminated soils to pose a risk to humanhealth and the environment exists. EPA is unclear how these concentrations can bebelow ATSDR comparison values for soil. What risk based concentrations comparisonvalues for soil is ATSDR using? As this site is not fenced, nor is access prevented,how is public exposure to this site prevented? Please clarify.
  58. Response: ATSDR clarified the text to state that remedial activities at Sites 21, 41, 42,and 43 will minimize contaminant leaching into the groundwater. ATSDR also revisedits soil discussion of Sites 1, 2, and 12 and the Rickenbacker Landfill to reflect the mostcurrent available information. ATSDR agrees that trespassers can access RickenbackerLandfill and changed the text accordingly. The nature and extent of landfillcontaminant concentrations have not been fully characterized, so ATSDR classifiedRickenbacker Landfill as an indeterminate public health hazard. ATSDR comparisonvalues (further described in Appendix B) are distinct from EPA Region IX's industrialpreliminary remediation goals for a 70-year exposure. As stated in the text revisions,ATSDR will reevaluate its indeterminate public health hazard conclusion when theArmy Corps of Engineers completes its environmental investigations at RickenbackerLandfill.

  59. Comment 30: (Page 17, Evaluation of Potential Public Health Hazards) The landfill isnot an IRP site. It is a Formerly Used Defense Site (FUDS). This needs to be clarifiedin the text.
  60. Response: ATSDR clarified the text as suggested.

  61. Comment 31: (Page 17, Evaluation of Potential Public Health Hazards) EPA does notagree that the IRP sites (including the five remediation sites and the RickenbackerLandfill) lie in industrial/commercial areas that are infrequently, if ever, contacted bythe public. Since the Air Force closed the base and the Air National Guard and ArmyReserve established their cantonment area, there are sites (i.e., the RickenbackerLandfill and Site 21) which can be accessed by the public.
  62. Response: ATSDR agrees that trespassers can access RANGB and changed the textaccordingly. Minimal, infrequent public exposure to on-site contaminants at IRP sites(if it occurs at all) is not be expected to result in adverse health impacts.

  63. Comment 32: (Page 20) It is inaccurate to state that children do not access RANGB. Children have been seen on Rickenbacker riding their bikes. Teenagers have also beenseen on base in cars and have broken windows in some vacant buildings. There iscurrently no one in place to stop unauthorized access.
  64. Response: ATSDR agrees that trespassers can access certain RANGB areas (includingRickenbacker Landfill) and changed the text accordingly. ATSDR included theseobservations in the ATSDR Child Health Initiative section.

  65. Comment 33: (Page 20, ATSDR Child Health Initiative) EPA would not state thatchildren do not access RANGB. Please see other comments with respect to site accessand the potential public health hazard posed by exposure to the soils at the Landfill. Inaddition, ATSDR indicates on page 12 that Ohio EPA only sampled five of the sevenwells. Therefore, not all off-base exposure points were sampled. Please clarify.
  66. Response: ATSDR agrees that children can access certain RANGB areas (includingRickenbacker Landfill) and changed the text accordingly. ATSDR clarified itsdefinition of drinking water off-base exposure points by inserting "(i.e., productionwells drawing from the UWBZ)" to the text.

  67. Comment 34: (Page 20, Conclusions, Pages 19 and 20) Please indicate that for Sites 2,21, 41, 42, and 43, there are some provisions in place which would prevent potentialfuture exposure to contaminated groundwater due to the remedial action decisiondocument. For Site 1, which is being closed under the Resource Conservation andRecovery Act (RCRA), and Site 45, which is being closed under the Bureau ofUnderground Storage Tank Regulations, ATSDR should check for what provisionshave been made to prevent potential future exposure to contaminated groundwater. Forthe Landfill, there are no provisions in place that would prevent potential futureexposure to contaminated groundwater at this site. Please clarify.
  68. Response: ATSDR revised the text (see also the Public Health Action Plan section) toinclude updated information about RANGB deed restrictions and provisions to preventpotential future exposures.

  69. Comment 35: (Page 20 and 21, Public Health Action Plan, Ongoing/Planned Actions)To clarify Action, EPA does not collect or analyze data pertaining to all regions ofgroundwater contamination and drinking water quality. EPA reviews and evaluatesdata pertaining to RANGB.
  70. Response: ATSDR deleted "USEPA" from the sentence referring to agencies that "willcontinue to monitor, collect, and analyze data pertaining to all regions of groundwatercontamination and drinking water quality."

  71. Comment 36:(Page 26, Table 1, columns 2 and 6) These entries still talk aboutbromochloromethane; a test result the initial lab was not qualified to perform tostandard - and a questionable non-reproducible result - per Ohio Public Health whichin its investigations could not find in any of the wells nor the RANGB, landfill FUDSarea. Does repetition of nonvalidated, untrusted test data serve the public?
  72. Response: ATSDR deleted the reference to bromochloromethane in Table 1.

  73. Comment 37: (Page 26, Table 1, Route of Exposure Column) It seems that inhalationand dermal, as well as ingestion, would be an exposure route and should be included. In addition, five of the domestic drinking water wells are located in the shallow aquiferand this aquifer may be connected to the UWBZ at RANGB. Please add thisinformation.
  74. Response: ATSDR added "(inhalation and dermal contact)" to the potential route ofexposure for groundwater in Table 1. ATSDR revised the text in the Evaluation ofEnvironmental Contamination and Potential Exposure Pathways section to say that fivedomestic drinking water wells draw from the UWBZ.

  75. Comment 38: (Page 27, Table 1, On-base Soil) Under Comments, it is stated that thelandfill is surrounded by a fence. The text needs to reflect that a fence does notsurround the site, and some of the existing fencing can easily be climbed over.
  76. Response: ATSDR revised Table 1 to say "Rickenbacker Landfill is surrounded bylimited fencing and trespassers can access the site."

  77. Comment 39: (Table 1) This table should be revised to incorporate the text commentsregarding potential future exposures.
  78. Response: ATSDR did not revise its assessment of potential future exposures becauseno future exposures were identified at RANGB (see Natural Resources and Land Use[Reuse Plan]).

  79. Comment 40: (Appendix A) Update Appendix A text to reflect current IRP site status. In addition, the current status of some sites indicates that these sites have beendesignated as no further action sites. EPA would like to clarify that these sites aresuitable for no further action in the event these sites retain a commercial or industrialreuse. The Air Force will be responsible to monitor, maintain, and enforce this landuse.
  80. Response: ATSDR updated Appendix A to reflect current site status. The text statesthat RANGB will implement and oversee all provisions and deed restrictions necessaryto prevent potential future exposures (Friedstrom 2000).

  81. Comment 41: (Page A-18, Corrective Activities Column, Current Status) Replacebullet two with: "BUSTR has assigned NFA (No Further Action) on all but two of theUSTs in site 28. BUSTR action on the remaining two USTs is still under evaluation."
  82. Response: ATSDR revised the text as suggested.

  83. Comment 42: (Page A-26, Site 45) Correct second bullet to read: "Pending resultsfrom a Dec. 1999 groundwater sampling event, a Remedial Action Summary Report forSite 45 will be submitted to BUSTR in early 2000."
  84. Response: ATSDR revised the text as suggested.


4. Appendix A lists 45 individual sites, but RANGB consolidated Site 27 into Site 25, thereby creating a total of 44 IRP sites.


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