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PUBLIC HEALTH ASSESSMENT

NATIONAL ELECTRIC COIL/COOPER INDUSTRIES
DAYHOIT, HARLAN COUNTY, KENTUCKY


FIGURES


Figure 1. General Location Map
of National Electric Coil



Figure 2. Areas of PCB
Concentrations Above 10 PPM



Figure 3. Areas of Total VOC
Concentrations Above 10 PPM



Figure 4. Approximate Location
of Areas with Pb and/or Cr Concentrations
in Soil Above Target Clean Up Levels



Figure 5. Potentiometric Surface Map,
of Shallow-Aquifer Monitoring Well



Figure 6. Bedrock Potentiometric
Surface Map Non-Pumping 12/1/89



Figure 7. Off Site Soil
Sampling Results



Figure 8. Approximate Location
of VOC Plume - July 1993



APPENDIX A - ENVIRONMENTAL CONTAMINATION TABLES

Explanation of Environmental Contamination Tables

Most of the on-site data contained in the environmental contaminant tables have been taken fromthe October 1991 Removal Action Report by Law Environmental (10). That report includedprevious assessments from other contractors: Lozier Architects and Engineers, Environmetrics,Environmental Technology Corporation, and International Technology Corporation. Some of the reports have been referenced separately, as indicated in the tables. Some of the 1989data collected by Lozier Inc. was unusable because the sample identifications could not bedeciphered. However, the site is considered to be fully characterized with respect toenvironmental contaminants because all maximum concentrations have been reported.

Table 1.

Table 1. ON-SITE SOILS (9, 10, 11) ORGANIC COMPOUNDS

MARCH - AUGUST 1991:
RF=RIVERBANK FILL AREA, 0 - 18 ft
OF=OUTFALL 1 AREA, 0 - 6 ft
ED=EQUIPMENT DRUM & STORAGE AREA, 1 - 8 ft
FL=SOUTH FENCELINE AREA, 0 - 2 ft

CONTAMINANTAREACONCENTRATION
RANGE
COMPARISONVALUE (CV) FORINGESTION - PICACHILDFREQ>CV
(>ND)


ppmppmSource
BenzeneN/AND - 0.00924CREG0/20*
ChloroformN/AND - 0.002J20EMEG0/45
Total 1,2-DCE
(dichloroethene)
N/AND - 7.720LTHA0/184
EthylbenzeneN/AND - 168200Rfd0/47
Total PCBs
(Polychlorinatedbiphenyls)
RF
OF
ED
FL
ND - 610
ND - 49
ND - 9.6
ND - 58
0.09CREG57/117
11/18
1/65
9/22
1,1,2,2-
Tetrachloroethane
N/AND - 0.053.5CREG0/45
TolueneN/AND - 4.3400Rfd0/47
TCE
(trichloroethene)
RF
OF
ED
FL
ND - 40**
ND - 480
ND - 19
ND - 9.8
NoneN/A(75/102)
(30/32)
(51/62)
(2/18)
Vinyl chlorideN/AND 0.04EMEG0/45
Different areas have been specified because of the variation in concentrations betweenareas and their accessibility to public use.

N/A = not applicable

ND = constituent analyzed for but not detected above the instrument detection limit.

J = an estimated value

* The values in the May 1991 data set were not included because of their presence in theblank (possible lab contamination).

** The maximum value for TCE reported in the 1989 Lozier Report is 15,000 ppm.



Table 2.

ON-SITE SOIL (10)
INORGANIC COMPOUNDS*

JUNE - AUGUST 1991:

CONTAMINANTCONCENTRATION
RANGE
COMPARISONVALUE (CV) FORINGESTION - PICACHILDFREQ>CV

ppmppmSource
AntimonyND 0.8RfdNot
known**
ArsenicND - 5.60.6 RfdAt least
14/27**
Barium19.8 - 150140Rfd1/27
Beryllium0.26 - 0.850.16CREG22/22
CadmiumND - 20.4EMEG1/27
ChromiumND - 12010EMEG8/29
Lead5.3 - 2145None---N/A
Manganese137 - 1260200Rfd20/22
Nickel5.9 - 22040EMEG3/22
ND = constituent analyzed for but not detected above the instrument detection limit.

* Summary of data from four main areas: riverbank fill, outfall 1, equipmentdrum and storage, and southern fence line.

** The detection level exceeds the comparison value.



Table 3.

N-SITE SOIL GAS (11)
ORGANIC COMPOUNDS

SEPTEMBER - OCTOBER 1989

CONTAMINANTCONCENTRATION
RANGE
COMPARISON VALUE(CV) FORINHALATION FREQ>CV
ppmppmSource
trans 1,2-DCE
(dichloroethene)
ND - 16.5none------
TCE
(trichloroethene)
ND - 4070.25NIOSHTWA/10013/29
Vinyl chlorideND 0.002intermediateEMEGUnknown*
ND = constituent analyzed for but not detected above the instrument detection limit.

*The instrument detection limit was above the comparison value.



Table 4.

ON-SITE GROUNDWATER, OVERBURDEN (9,10) ORGANIC COMPOUNDS

JANUARY 1990 - MAY 1991:
BOREHOLES 0-5

CONTAMINANTCONCENTRATION
RANGE
COMPARISONVALUE (CV) FORINGESTION -REFERENCE ADULTFREQ>CV

ppbppbSource
BenzeneND - 19,0005MCL4/11
ChloroformND 5.74CREG0/11
cis 1,2 DCE
(dichloroethene)
Not specified70LTHAN/A
trans 1,2 DCE
(dichloroethene)
Not specified100LTHAN/A
Total 1,2 DCE
(dichloroethene)
ND - 370070LTHA4/11
EthylbenzeneND - 31001000Rfd2/11
Total PCBs
(Polychlorinatedbiphenyls)
ND0.004CREG0/11
1,1,2,2-Tetra-chloroethaneND - 2J0.175CREG1/11
TolueneND - 37,0002000Rfd4/11
TCE
(trichloroethene)
ND - 17,0005MCL10/11
Vinyl chlorideND - 770.2EMEG1/11
ND = constituent analyzed for but not detected above the instrument detection limit.

For evaluation purposes, on-site groundwater was divided into two separateunits: wells in the overburden or shallow aquifer and wells in the confinedbedrock aquifer.

Methylene chloride was not listed as a contaminant of concern because it wasfound in the blank(s) and could be attributed to laboratory contamination.



Table 5.

Table 5. ON-SITE GROUNDWATER, OVERBURDEN (9,10) INORGANIC COMPOUNDS

JANUARY 1990 - APRIL 1991
BOREHOLES 0 - 5

CONTAMINANTCONCENTRATION
RANGE
COMPARISONVALUE (CV) FORINGESTIONFREQ>CV

ppmppmSource
AntimonyND0.004Rfd0/6
ArsenicND - 0.004B*0.003RfdN/A*
Barium0.164 - 1.0500.7Rfd3/6
BerylliumND - 0.0088.1CREG0/4**
CadmiumND0.002EMEG0/6
Chromium0.055 - 0.6220.05Rfd6/6
Lead0.004 - 0.1270.005PMCL6/6
Manganese0.293 - 7.311.0Rfd5/6
Nickel0.049 - 0.4040.2EMEG2/6
ND = constituent analyzed for but not detected above the instrument detection limit.

* Arsenic was found in the blank (B) as well as in the samples and may have beendue to laboratory contamination.

** Beryllium was detected in the blank run for two of the samples; therefore, theywere not considered for inclusion.

Zinc concentrations did not exceed the comparison value of 3 ppm in this data set orAugust 1993 (12).

August 1993 concentrations were lower than those reported here for each metal. Therefore, there are no new maximums to report.



Table 6.

ON-SITE GROUNDWATER, BEDROCK AQUIFER (9,10)ORGANIC COMPOUNDS

MARCH 89 - JULY 1991:
MONITORING WELLS 0,2,10,11

CONTAMINANTCONCENTRATION
RANGE
COMPARISONVALUE (CV) FORINGESTION -REFERENCE ADULTFREQ>CV

ppbppbSource
BenzeneND5MCL0/10
ChloroformND - 205.74CREG1/6
cis 1,2-DCE
(dichloroethene)
8770LTHA1/1
trans 1,2-DCE
(dichloroethene)
ND - 456100LTHA3/4
Total 1,2-DCE
(dichloroethene)
ND - 310070LTHA3/6
EthylbenzeneND1000Rfd0/10
Total PCBs
(Polychlorinatedbiphenyls)
ND0.004CREG0/4
1,1,2,2-Tetra-chloroethaneND0.175CREG0/10
TolueneND2000Rfd0/10
TCE
(trichloroethene)
ND - 48005MCL6/10
Vinyl chlorideND - 10310EMEG3/11
ND = constituent analyzed for but not detected above the instrumentdetection limit.

Only wells in use at the time of sampling have been included.

Methylene chloride was not listed as a contaminant of concern because it wasfound in the blank(s) and could be attributed to laboratory contamination.



Table 7.

ON-SITE GROUNDWATER, BEDROCK AQUIFER (9,10) INORGANIC COMPOUNDS

JANUARY 1990 - APRIL 1991
MONITORING WELLS 0,2,10,11

CONTAMINANTCONCENTRATION
RANGE
COMPARISONVALUE (CV) FORINGESTIONFREQ>CV

ppmppmSource
AntimonyND0.004Rfd0/4
ArsenicND -0.045B*0.003RfdN/A*
Barium0.121 - 0.5750.7Rfd0/4
BerylliumND0.008CREG0/4
CadmiumND0.005EMEG0/4
ChromiumND - 0.6360.05Rfd1/4
LeadND - 0.0150.005PMCL1/3**
Manganese0.028 - 0.1871.0Rfd0/4
NickelND - 0.4490.2EMEG1/4
ND = constituent analyzed for but not detected above the instrument detectionlimit.

* Arsenic was found in the blank as well as in the samples and may have beendue to laboratory contamination.

** One of the samples had a blank that showed contamination; therefore, it wasnot considered for inclusion.

Zinc concentrations did not exceed the comparison value of 3 ppm in this data setor August 1993 (12).

August 1993 concentrations were lower than those reported here for each metal. Therefore, there are no new maximums to report.



Table 8.

OFF-SITE SEDIMENT (12) CUMBERLAND RIVER


Polychlorinated biphenyls (PCBs)

DECEMBER 1993*

CONTAMINANTCONCENTRATION
RANGE
YEARCOMPARISON VALUE(CV) FORINGESTION - PICACHILDFREQ >CV

ppm


ppmSource

Upstreamof NECDownstream
of NEC



Upstreamof NECDown-stream
of NEC
Total PCBs:AroclorsND -0.038JND - 0.210J19930.09CREG0/21/7
J = an estimated value

*Sediments were also sampled for PCBs in December 1989- Estimates of 0.16 ppm(sample CR-D1) and 0.054 ppm (CR-D2) were given for aroclor-1248 in the vicinity of thesite.



Table 9.

OFF-SITE SOIL GAS (11) ORGANIC COMPOUNDS

SEPTEMBER - OCTOBER 1989

CONTAMINANTCONCENTRATION
RANGE
COMPARISON VALUE(CV) FORINHALATION FREQ>CV

ppmppmSource
trans 1,2-DCE
(dichloroethene)
NDnone------
TCE
(trichloroethene)
ND - 5.950.25NIOSHTWA/1003/85
Vinyl chlorideND 0.002intermediate
EMEG
Unknown*
ND = constituent analyzed for but not detected above the instrument detection limit.

*The instrument detection limit was above the comparison value.



Table 10.

OFF-SITE SOILS (11, 12) ORGANIC COMPOUNDS

Mobile Home Park
Jan 1990, 0 to 4 feet
August 1993, 0 to 0.5 feet

CONTAMINANTDATECONCENTRATION
RANGE
COMPARISONVALUE (CV) FORINGESTION - PICACHILDFREQ>CV


ppmppmSource
PCBs-aroclors* 8/93ND - 0.960.09CREG5/20
PCBs-aroclors 1254and 1248 1/90ND - 1.50.09CREG9/27
ND = constituent analyzed for but not detected above the instrument detection limit.

PCB = Polychlorinated biphenols

*The total PCBs (aroclors) maximum was 1.053 ppm.

The riverbank adjacent to NEC was considered on site (Tables 1 and 2).



Table 11.

OFF-SITE SOIL (12) INORGANIC COMPOUNDS

AUGUST 1993
SURFACE SOIL (0 to 0.5 feet)

CONTAMINANTCONCENTRATION
RANGE
COMPARISONVALUE (CV) FORINGESTION - PICACHILDFREQ>CV

ppmppmSource
AntimonyNot analyzed0.8RfdN/A
Arsenic1.8N - 4.50.6 RfdUnknown
Barium28.2 - 102140Rfd0/20
BerylliumND - 1.00.16CREGAt least16/20
Cadmium1.1 - 3.10.4EMEG20/20
Chromium9 - 18.310RMEG19/20
Lead*9.8 - 219NNone---2/20 > 200ppm
Manganese195 - 854200Rfd19/20
Nickel9.6 - 27.1 40EMEG0/20
ND = constituent analyzed for but not detected above the instrument detection limit.

N = spiked sample recovery not within control limits.

* The detection level exceeds the comparison value.

** The metals concentrations are within natural soil composition levels with theexception of lead. Lead maximums are above local background soil and sedimentconcentrations (11.5 -13.9 ppm) (31).



Table 12.

OFF-SITE GROUNDWATER (10) PRIVATE WELLS - BEDROCK AQUIFER
ORGANIC COMPOUNDS

FEBRUARY 1989 - JAN 1990

CONTAMINANTCONCENTRATION
RANGE
COMPARISONVALUE (CV) FORINGESTION -REFERENCEADULTFREQ>CV

ppbppbSource
BenzeneND5MCL0/15
ChloroformND5.74CREG0/15
cis 1,2-DCE
(dichloroethene)
ND - 13370LTHA2/100
trans 1,2-DCE
(dichloroethene)
Not Analyzed100LTHAN/A
Total 1,2-DCE
(dichloroethene)
ND - 39 70LTHA0/15
EthylbenzeneND - 7JB1000Rfd0/15
Polychlorinated
biphenyls (PCBs)
ND 0.004CREG0/2
1,1,2,2-Tetra-chloroethaneND - 1200.175CREG2/15
TolueneND2000Rfd0/15
TCE
(trichloroethene)
ND - 20J5MCL2/15
Vinyl chloride*ND - 3500.2EMEG19/115
ND = constituent analyzed for but not detected above the instrument detectionlimit.

B = found in laboratory blank
J = an estimated value

Methylene chloride was not listed because of its presence in blanks (possiblelab contamination).

Only those wells in use at the time of sampling were included. Most privatewells are deep and lie in the confined aquifer.

* Sampling in July 1991 at the Yo-Yo market, about 1 mile southwest fromNEC, found 63.9 ppb vinyl chloride. Two wells tested in the Fresh Meadowsarea showed non-detect in 1992.



Table 13.

FISH TISSUE FILLET SAMPLES -COMPOSITES (12) CUMBERLAND RIVER

Polychlorinated biphenyls (PCBs)- aroclor-1260

NOVEMBER & AUGUST 1993

CONTAMINANTCONCENTRATIONS FROM COMPOSITESCOLLECTED AT TWO LOCATIONS

ppb
Fish:Upstream of NECDownstream of NEC
Rock Bass190, 200140, 160
Golden redhorseND, 740440, 690
Channel catfishNot
measured
950
ND = not detected



APPENDIX B - PATHWAYS ANALYSES


Table 12.

COMPLETED EXPOSURE PATHWAYS
PATHWAYNAME/ENVI-RONMENTAL MEDIA EXPOSURE PATHWAY ELEMENTS TIME
SOURCEPOINT(S) OFEXPOSUREROUTE OFEXPOSUREEXPOSED POPULATION
GroundwaterTransformers,
Cleaning solvents
NEC,
Holiday Mobile HomePark (HMHP)/
Drive-in theater,
Dayhoit
Ingestion
Inhalation
Skin Contact
Residents, workers, anddrive-in goers who drankwater from wells within theplume of contamination orused it for bathing.Past
Surface waterDrainage lines,surface runoffCumberland Riverdownstream of NEC(outfall 1).
Areas of HMHPreceiving drainage fromNEC.
Ingestion
Skin Contact
Swimmers
Children playing in drainageareas.
Past
Food Chain/
Fish
Outfalls, surfacerunoff, sedimentCumberland Riverupstream & downstreamof NEC including sitevicinityIngestionCumberland River fish eatersPast
Present
Future
SoilWaste in soil(transformers,
cleaning solvents)
NEC Yard
HMHP near NEC
Ingestion
Inhalation ofdusts
Residents of HMHP, on-sitetrespassers, previous drive-ingoersPast
Present
Future
Ambient AirDegreaser pit, Leadpot, burn-out oven, waste materialsInside NEC plant,
outside plant nearburning and waste areas.
InhalationFormer workersPast
Waste
Material
Degreaser pitInside plantInhalation
Skin contact
Former workers Past


Table 13.

POTENTIAL EXPOSURE PATHWAYS
PATHWAYNAME/
ENVIRONMENTAL MEDIA
EXPOSURE PATHWAY ELEMENTSTIME
SOURCEPOINT OFEXPOSUREROUTE OFEXPOSUREEXPOSEDPOPULATION
Soil Gas/SoilWaste in soil, VOCsfrom shallowgroundwatercontamination.On siteInhalationWorkers and
trespassers
during soil excavation.
Past
Off siteInhalationChildren playing intrenches.Past
Present
Future
SedimentWaste in sediment,outfallsCumberland Riverbanks near NECIngestionCumberland RiverusersPast
Present
Future
Food Chain/VegetablesGardens in the area ofNECOff site in the HMHPand in flooded areas.IngestionResidents eatingvegetablesPast
Present
Future
Ambient AirVOCs in waste,
Fuel oils,
air stripper
HMHP, residencesnorth of the siteInhalationResidents near the sitePast
Present
Future


Table 14.

ESTIMATED POPULATION FOR COMPLETED AND POTENTIAL EXPOSURE PATHWAYS
Exposed Populations and Potentially Exposed PopulationsAffected by a Completed or Potential Exposure Pathway* For:
LocationMinimum No. ofPersonsHeavy Metals
ex. lead
Chlorinated
Solvents
ex. TCE
BTEX
Compounds
ex. benzene
PCBs
ex. Aroclors
Residents** ofDayhoit:on-site at NEC andoff-site exposure inthe HMHP &
Cumberland Riverareas.
350Surface water,
Groundwater,
Soil

Sediment
Vegetables
Ambient Air

Surface water,
Groundwater,
Soil

Soil gas
Sediment
Ambient Air

Soil gas
Ambient Air

Surface water,
Groundwater,
Soil
Fish

Sediment
Vegetables
Ambient Air

FacilityWorkers** on-site
exposure
120 Waste materials,
Ambient air,
Groundwater
Waste
materials,
Ambient air,
Groundwater
Waste materialWaste material,
Ambient air,
Groundwater

* potential exposure pathways are underlined

** residents who trespassed or workers who also lived near NEC may have a combination of exposures to on- and off-site contaminants.

APPENDIX C - HEALTH CONCERNS

Health Concerns Reported at the Public Availability Meeting

Cancer

liver
gynecologic (cervix, ovary)
musculoskeletal (bone, spine)
breast
hematologic (multiple myeloma, leukemia, Hodgkin's disease)
lung
gastrointestinal (bowel, esophagus, colon)
skin
throat
brain
prostate

Neurologic/Psychiatric Disorders

nervous problems
epilepsy
memory loss
mental stress
headaches
numbness in arms or hands
dizziness
Alzheimer's disease
blacking out
insomnia

Gastrointestinal Disorders

ulcers
gastrointestinal hemorrhaging
digestive problems
stomach problems
constipation
gallbladder problems
sores in mouth and throat
diarrhea
burping blood
cracking and splitting of tongue
nausea
stomach hernia
elevated liver enzymes
hepatitis
circulatory problems

Dermatologic (skin) Disorders

blisters on eyelids, in mouth, and elsewhere
skin rashes
"dead" spots on skin
cysts
eczema
scalp problems
knots
toenails will not grow
hair falling out
boils
plantar warts

Allergy and Immune System Disorders

persistent colds
allergies
immune system problems
enlarged glands

Reproductive Disorders

miscarriage
sterility
birth defects
premature birth

Cardiovascular Disorders

closed artery
heart irregularities
strokes
high cholesterol
arteriosclerosis
heart attack
blood pressure problems
swelling of legs
enlarged heart

Genital/Urinary Disorders

kidney problems, including infection
blood in urine
difficulty urinating
problems controlling bladder
kidney stones

Pulmonary Disorders

lung problems
lung spots
cavities in lungs
shortness of breath
asthma
bronchitis
pneumonia

Vision Disorders

blurred vision
loss of vision
eye problems

Musculoskeletal Disorders

arthritis
fusing of backbone
deteriorating backbone
skin drawing up
pain around ribs
muscle and joint pain

Endocrine Disorders

Graves' disease
thyroid problems
diabetes

Ear/Nose/Throat

earache
ear infection
sinus infection
precancerous throat polyps
nose bleeds

Developmental Disorders

child will not gain weight

Benign Breast Disorders

fibrocystic disease

Gynecologic Disorders

ovarian cysts
female hormone problems

Hematologic Disorders

blood disease requiring transfusions

Dental Disorders

chronic gum disease
teeth requiring being pulled

Miscellaneous

chronic fatigue
PCBs in blood
lead in blood
febrile seizures
surgeries


APPENDIX D - ADDITIONAL DOCUMENTS

Water Consumer Advisory
ATSDR Health Consultation- Groundwater, March 1989
ATSDR Health Consultation- Dioxins/Furans, May 1993

The following section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services
Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333


APPENDIX E - PUBLIC COMMENTS

RESPONSE TO COMMENTS RECEIVED DURING PUBLIC COMMENT PERIODFOR
NATIONAL ELECTRIC COIL
PETITIONED PUBLIC HEALTH ASSESSMENT

The National Electric Coil Public Health Assessment (PHA) was available for public review andcomment from December 14, 1992 through January 27, 1993. Copies of the PHA were sent tothe Harlan County Library, a repository for the site. A final copy of the PHA will also be sent tothe South East Community College Library in Cumberland, Kentucky. Comments were receivedfrom EPA, the Commonwealth of Kentucky (Department of Environmental Protection), CooperIndustries, a potentially responsible party, and two Harlan County residents.

Comments and responses on the PHA are summarized below. The comment letters can berequested from ATSDR through the Freedom of Information Act.

COMMENT: Verify off-site contamination levels by PCBs in soil.

RESPONSE: The PCBs levels reported in Table 10 for off-site soils (ND - 1.5 ppm) are correctand were samples taken near the fenceline of the mobile home park with NEC (Map from Lozierreport, dated 1990, sheet number 3, reference 11).

COMMENT: References to PCBs in river sediments downstream of NEC at levels of 54 ppm to720 ppm should be verified because commenters were not aware of data indicative of theselevels.

RESPONSE: PCBs in river sediments were inaccurately reported in previous versions of thePHA. PCB concentrations in Cumberland River sediments in the December 1989 data were lessthan 0.2 ppm. Sampling in 1993 indicated total PCBs in river sediments downstream of NEC as:not detected through an estimate of 0.21 ppm (Reference 12). ATSDR addressed the incorrectPCB concentrations in a flier and discussion with the community when we returned to explainour health assessment in March 1993.

COMMENT: The Kentcuky Department of Environmental Protection measured PCB sediment inthe river upstream of the NEC site at 0.028 ppm in 1989.

RESPONSE: Thank you for the information. We have used 1993 data which indicate themaximum upstream level to be 0.038 ppm.

COMMENT: The units are believed to be incorrect for on-site PCB contamination along theNEC and mobile home fence line and should be 0.029 and 0.100 ppm rather than 290 to 9100ppm. Additionally, the presence of a drainage ditch that flows from the NEC site to the MobileHome Park is questioned.

RESPONSE: The units are indeed incorrect, however, ATSDR believes that the correctionshould be 0.29 to 9.1 ppm (NUS sheet number 1, Lozier Inc. 1989, reference 11).

Our editors requested that we change the term swale so we used drainage ditch instead. However, since this term could be misleading (thought to be man-made), we will change it to alow lying area adjoining the two properties.

COMMENT: Please confirm the reference to tetrachloroethane in groundwater. The commenterbelieves it should be tetrachloroethene.

RESPONSE: The May 1991 Law Environmental Report (Table 4-2) indicates tetrachloroethaneis correct. However, we have no longer emphasized it in the discussion since it is not a major contaminant.

COMMENT: Identify source of comparison values for beryllium and manganese.

RESPONSE: The sources have been identified in the environmental contamination tables. ATSDR's Cancer Risk Evaluation Guide (CREG) for 1x10-6 excess cancer risk for beryllium insoil is approximately 0.16 ppm. ATSDR's comparison value for manganese in soil based onEPA's reference dose is 200 ppm. According to information in the March 1994 RemedialInvestigation Report (31), these comparison values are lower than background concentrations ofthese metals in the Dayhoit area. The health assessment was revised to acknowledge theseconcentrations as background levels. However, they have been retained for consideration ofhealth implications.

COMMENT: Please confirm and verify the number of wells found to be contaminated. It wouldappear that only 13 wells were contaminated.

RESPONSE: ATSDR's original estimate of fifteen wells excluding the Mobile Home Parkincluded two on-site wells. We have changed the number to 13 in the off-site contaminationsection.

COMMENT: Based on Cooper's data, wind direction has been found to be primarily northerly,rather than southerly (as stated in the public health assessment). Thus, the air quality in the mobile home park would not have been substantially affected.

RESPONSE: Substantial meteorological data was not provided to ATSDR until the draftRemedial Investigation Report, received in March 1994. ATSDR has updated the final release toreflect this information.

COMMENT: Community members reported the following health effects:

cancer, loss of kidney, fibrocystic disease, cysts, warts, hysterectomy.

RESPONSE: Cancer occurs in one in three people's lifetime. It is very difficult for scientists todetermine who will get cancer. Further, if someone gets cancer, scientists and physicianstypically cannot know the cause of the person's cancer. We do know, however, that somesite-related chemicals are carcinogens. Please refer to the Toxicologic Evaluation section for adiscussion of vinyl chloride; asbestos; 1,1,2,2-tetrachloroethane; PCB's; and trichloroethene,which are known or probable human carcinogens. Please refer to the Community HealthConcerns Evaluation section for a discussion of cancer in the community.

Fibrocystic disease, warts, cysts, illnesses requiring a hysterectomy, and illnesses requiring theloss of a kidney are all health effects which could be due to a wide variety of underlying causes. In many cases, such as fibrocystic disease and endometriosis (an illness which often requires ahysterectomy), physicians do not know what causes the illness; none of the theories for theseeffects are based in environmental exposures. Warts are caused by viruses. Information aboutthe underlying condition which required the hysterectomy or the kidney removal would enable usto discuss the possible role, if any, that contamination had in the development of the condition.

A series of comments pertain to particular exposure pathways commenters felt were notacknowledged in the public health assessment. These potential exposures would have occurredin the past. No new exposure pathways or additional exposed segments of the population wereidentified through these comments. The following 5 comments pertain to exposure pathways.

    COMMENT: There used to be a school downriver from NEC, and children drank the water fromthe pump right outside the school.

    RESPONSE: The commenter describes an additional route by which children were exposed togroundwater. Without information about contaminant levels, we cannot evaluate the potentialhealth effects of that exposure. It is likely that exposures from that well would have been atsimilar levels as exposures at other wells in Dayhoit. Because that well is no longer used, wecontinue to consider exposure to groundwater a past concern.

    COMMENT: In the past, children used to play and collect coal frequently in the river. Baptismswere performed in the river, too.

    RESPONSE: We are aware that people were exposed to contaminants in the river, as discussedin the Completed Exposure Pathways section. We have included participants in baptism ritualsin the discussion.

    COMMENT: There is a garden near the discharge pipe from NEC, and many people haveworked in the garden and eaten vegetables grown in it. There also used to be a chicken farm inDayhoit where people bought their eggs.

    RESPONSE: The vegetable garden is discussed in the Food Chain Pathway section of theEnvironmental Pathways section. With no information about contaminant levels in air during theoperation of NEC, and no information about the feed supplied to the chickens, ATSDR cannotevaluate the likelihood of contaminated eggs.

    COMMENT: In the past, air discharges from the facility would be blown into Dayhoit, and thatduring rainy and foggy times the discharge would be kept right on top of the community.

    RESPONSE: Weather conditions such as inversions affect concentration and residence time ofair-borne contaminants; however, as stated in the Environmental Contamination and OtherHazards section, the potential effect air contamination had on public health cannot be evaluatedbecause of the lack of data collection during plant operations.

    COMMENT: Residents used to collect copper in the dump site behind NEC, and the dump sitewas a continuous smoldering pit.

    RESPONSE: The exposures those people would have sustained from the fumes areacknowledged in the Ambient Air Pathway. People also were exposed to whatever wastematerial they handled, although we have no information by which to evaluate the health impactof that exposure.

COMMENT: There was a drainage pipe from NEC downriver from the trailer park and thereforesoil testing should extend beyond the trailer park.

RESPONSE: The authors were aware of this drainage pipe. The pipe discharged directly to theRiver and the downstream sediments were characterized. Additionally, further off-site soiltesting was not recommended because even the Mobile Home Park contaminant concentrationswere low as reported in the Off-site Contamination section.

COMMENT: Death statistics do not always accurately reflect cancer information; for example, ifa person has cancer but died of heart failure, heart failure will be listed as the cause of death andcancer will not.

RESPONSE: The commenter is correct to point out that the death statistics do not alwaysaccurately reflect cancer information. According to the International Statistical Classification ofDiseases and Related Health Problems, tenth revision, mortality is coded to the underlying cause,that is, to the disease or injury which initiated the train of morbid events leading directly to death. For example, the death of a person with cancer who dies in a traffic accident would not be listedas a cancer death statistic. However, if a person dies of heart failure and if cancer were the causeof the heart failure, then the person's death would be considered a cancer death statistic. Thephysician completing the death certificate determines the underlying cause.

Public health investigations can be designed to identify all people who have cancer (cancerincidence) rather than all people who died of cancer (cancer mortality).

COMMENT: Insufficient documentation is presented to determine if the risk assessments areperformed according to standard procedures and calculations.

RESPONSE: ATSDR evaluated the health and environmental information according to standardprocedures and calculations as described in the ATSDR Public Health Assessment GuidanceManual. Additional discussion describing how we estimate exposure doses and calculateincreased cancer risks has been added to the Public Health Implications section.

COMMENT: How are ATSDR soil levels determined, and what are the chemical-specific soilaction levels? Particularly, what about PCB levels?

RESPONSE: As described in the Environmental Contamination and Other Hazards section,ATSDR selects contaminants of concern by comparing the concentration of the contaminant witha comparison value for noncarcinogenic and carcinogenic endpoints. These comparison valuesare media-specific concentrations used to select environmental contaminants for furtherevaluation, and are not used as predictors of adverse health effects or for setting clean up oraction levels. The EPA determines clean up and action levels. They have set the action level for PCBs at 10 ppm (12).

Non-carcinogenic comparison values (environmental media evaluation guides, EMEGs) arederived from minimal risk levels (MRLs) presented in the ATSDR Toxicological Profiles. AnMRL is defined as an estimate of daily human exposure to a chemical that is likely to be withoutan appreciable risk of deleterious effects over a specified duration of exposure. If no MRL hasbeen developed, the estimated exposure dose is then compared to a comparison value (environmental reference dose evaluation guide, EREG) derived from the EPA's reference dose. Carcinogenic comparison values (cancer risk evaluation guides, CREGs) are based on an excesscancer rate of one in a million persons and are calculated using a cancer slope factor developed by the EPA specifically for each cancer-causing chemical.

When evaluating soil exposures, ATSDR uses the assumptions stated in the EnvironmentalContamination and Other Hazards section. Using those assumptions and EPA's slope factor forPCBs, we derived a comparison value (CREG) of 0.09 ppm for PCBs.

COMMENT: Will air monitoring take place, even though it is not required by the KentuckyDivision for Air Quality?

RESPONSE: Yes, due to the air stripping operation, air monitoring conducted by EPA or theircontractors is necessary.

COMMENT: Sampling for chemicals of concern in wells should include trichloroethylene, vinylchloride and polychlorinated biphenyls as well as 1,2-dichloroethene.

RESPONSE: By recommending that well sampling differentiate between cis- andtrans-1,2-dichloroethene, we did not intend to imply that other chemicals need not be sampledfor. We have altered the recommendation to eliminate the ambiguity.

COMMENT: Is the USEPA "Guidance Manual for Assessing Human Health Risks fromChemically Contaminated Fish and Shellfish" to be used in assessing the fish tissue data, or are the Food and Drug Administration action levels to be used?

RESPONSE: ATSDR recommends using the USEPA "Guidance Manual for Assessing HumanHealth Risks from Chemically Contaminated Fish and Shellfish". The EPA and FDA concurwith this choice in situations such as the one presented here.

COMMENT: Although Giardia should not be discounted at the site, it is more likely that someother pathogenic bacteria would have caused health symptoms. Many amoeboid pathogens arequite common in Kentucky and may result in health problems in children that spend considerabletime in the water.

RESPONSE: We have amended the recommendation to include these pathogens and suggestedthat this issue be taken up by local health officials and citizens who wish to pursue it.

COMMENT: Since many of the trailers in the Holiday Trailer Park appear to be 10-15 years old,formaldehyde or some other organic may have seeped into homes from trailer insulation. Werecommend some of the trailers be monitored for possible contaminants unrelated to the NationalElectric Coil contamination and the contribution of these indoor air contaminants to healtheffects be assessed.

RESPONSE: The commenter's request is outside ATSDR's purview. After 10 to 15 years,formaldehyde would have already dispersed from these trailers. Formaldehyde can be a problemfor hypersensitive individuals particularly in new trailer homes and cars. Individuals who may be hypersensitive can contact the local or state health departments to learn how to reduce exposure.

COMMENT: The proposed sampling of soil at the Holiday Mobile Home Park is at a screeninglevel and provides insufficient information to perform a risk assessment.

RESPONSE: The off-site soil sampling completed by EPA (date) goes beyond a screening leveland provides sufficient information to determine if residents are being exposed to contaminantsat levels of health concern.


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