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PRELIMINARY PUBLIC HEALTH ASSESSMENT

MONARCH TILE, INC., FLORENCE DIVISION
LAUDERDALE COUNTY, ALABAMA


APPENDIX A


Figure 1. Area Location Map


Figure 2. City Location Map


Figure 3. Site Location Map


Figure 4. Sediment Sampling Location Map


Figure 5. Drainage Patterns



APPENDIX B

Contaminants of Concern Tables

Table 1.

Contaminants of Concern in On-site Surface Water
ContaminantLevels
(ppb)
ReferenceComparison Value
ppbSource
Arsenic5
5
0.02CREG
Barium7,210
5
2000Adult RMEG
Chromium328
200Adult RMEG
Lead1,060
5


Nickel1,920
5
700Adult RMEG



Table 2. Contaminants of Concern in On-site Sediment

Table 2.

Contaminants of Concern in On-site Sediment
Contaminant Levels(ppm) Reference Comparison Value
ppmSource
Arsenic14.2
3,4
0.4CREG
Lead994.2
3,4





Table 3. Contaminants of Concern in Off-site Sediment

Table 3.

Contaminants of Concern in Off-site Sediment
Contaminant Levels(ppm)ReferenceComparison Value
ppmSource
Arsenic11.340.4CREG
Barium186.44100RMEG
Pica Child
Cadmium19.841.0Chronic EMEG
Pica Child
Chromium29.7410.0Chronic EMEG
Pica Child
Lead1,328.64

Nickel69.4440RMEG
Zinc10,410.54600RMEG
Pica Child



APPENDIX C

Pathways Tables

Table 4. Potential Exposure Pathways

Table 4.

Potential Exposure Pathways
Pathway Exposure Pathway Elements Time
Source Environment Point of Route Exposure
SedimentMonarchsedimentSouthern &
Northern
drainage
pathways
ingestion,
inhalation,
dermal
childrenpast,
present,
future
SoilMonarchsoilOn-site,
residences
near plant
ingestion,
inhalation,
dermal
workers,
adults,
children
past,
present,
future
Ambient AirMonarchairOn-site,
residences
near plant
inhalationworkers,
adults,
children
past



APPENDIX D

RESPONSE TO PUBLIC COMMENTS

The following comments were offered by Walston, Stabler, Wells, Anderson & Bains on behalf of Monarch Tile, Inc.:

  1. Cover sheets; P. iii; P. 1, 1st, 1st line; P. 2, Part A, 1st; P. 15, 3rd; and P. 16, last:substitute "Rickwood Road/Cox Creek Site: for "Monarch Tile, Inc." where the name ofthe CERCLA site which is the subject of the proposed NPL listing is intended. Where theplant facility is meant, refer specifically to it. Otherwise delete all references to "MonarchTile, Inc." (See text of letter below re name change.)

    Response: At this time, EPA has not decided on a new name for this site. ATSDR willtrack this site by the name of Monarch Tile, Inc.; therefore, we retain the use of "MonarchTile, Inc." for this site.

  2. P. 1,1, 5th line: delete "lead, barium and cadmium." See affidavit of Henry Stamper,attached as Exhibit 2 to the Comments submitted on July 9, 1993 to the EnvironmentalProtection Agency Office of Emergency and Remedial Response (hereafter "Comments"). Mr. Stamper stated the "the facility did not use barium, cadmium or lead as a colorant." An accurate statement would be: "Former operations included the use of glaze materialscontaining compounds of zinc, lead, and barium." As Mr. Stamper reported, to hisknowledge the facility did not use cadmium-based compounds in its processes.

    Response: As suggested, the statement was changed to read, "Former operations includedthe use of glaze materials containing compounds of zinc, lead, and barium." Regardless ofthe origin of the compound, cadmium is an environmental contaminant of concern both onand off site and as such, was evaluated in this report.

  3. P. 1,1, 8th line: replace the first "1980" with 1976. In 1976, all discharge from thesettling basins was routed to the city sewer pursuant to a State Indirect Discharge permitissued by the Alabama Department of Environmental Management.

    Response: The suggested change was made in the document.

  4. P. 1,1, 8th line, last sentence: replace "1980" with "1979." See Affidavit of HenryStamper, Comments, Exhibit 2. After 1979, use of barium carbonate was discontinued. After 1979, use of lead compounds stopped.

    Response: The suggested change was made in the document.

  5. P. 2, part A, 3rd;, last line: replace "1989" with "1988."

    Response: The suggested change was made in the document.

  6. P. 2, Part A, last, 6th line: replace "eastern drainage ditch" with "east drainage channel"to be consistent with Figure 3.

    Response: The suggested change was made throughout the document.

  7. P. 3, Part B, 3rd bullet, 1st line: insert after "ditch," "which was dry and overgrown at thetime of the visit."

    Response: The inspection of the area outside the facility property behind Plant 1 was notsufficiently detailed to justify a determination that the ditch was "dry and overgrown"along its entire length. Therefore, this change was not made in the document.

  8. P. 3, Part B, 3rd bullet, 5th line: add "or the creek" to the end of the sentence.

    Response: The item denoted by the 3rd bullet refers only to the ditch, not the creek;therefore, this change was not made in the document.

  9. P. 4, last line, and P. 5, 1st line: delete "either southwest or northwest" and insert"southwest." See E&E, p. 2-7 (6).

    Response: The suggested change was made in the document.

  10. P. 5, first full, 1st line: replace "drainage ditch" with "facility."

    Response: The suggested change was made in the document.

  11. P. 5, first full, 4th line: insert "designated as" before "suitable."

    Response: The suggested change was made in the document.

  12. Pp. 6-9, Environmental Contamination and Other Hazards (this comment applies to thisentire section with respect to contaminants of concern, and particularly to the listing ofon-site and off-site contaminants of concern on P. 6). Based on backgroundconcentrations reported in the Background Sampling Analysis Report by ENSRConsulting and Engineering, August 1994, submitted to EPA Region IV, contaminants ofconcern at the site should be limited to barium, lead, nickel and zinc. Based on the HazardRanking System Guidance Manual, any contaminant within three times backgroundconcentration would not be considered as a release. Section 5.1, p. 58. Since cadmiumwas never used at the site and since cadmium concentrations measured at the site arewithin three times established background, Monarch believes it should not be listed as acontaminant of concern. Other metals (except lead, nickel, barium, and zinc) were withinbackground concentrations reported at the site. See Background Sampling AnalysisReport, Tables 6-1 and 6-2. A copy of this report is included.

    Response: ATSDR's protocol for PHAs requires evaluation of all contaminants of concernat a site by comparing them to established comparison values. All available environmentaldata are to be included. Any substances present at concentrations above the comparisonvalues are classified as contaminants of concern.

  13. P. 8: add available information on "Offsite Surface Water," as follows:

    "As reported in ENSR's August 1994 report submitted to EPA, Stormwater RunoffSampling Report, metals analyses conducted on runoff samples collected from offsiteditches during a rain event indicate that metals did not exceed MCLs, with the exceptionof two samples which were barely above the MCLs. ENSR conducted stormwater runoffsampling in both the north and south ditches on May 26, 1994, during a significant rainevent. Samples were analyzed for arsenic, barium, cadmium, chromium, lead, nickel andzinc. All tested parameters in the north ditch were below drinking water MCLs, with theexception of one sample which tested at 10 ppb lead (4 ppb above the MCL). Thatsample, 5/26-W-1, was collected from the north ditch where it discharges into Cox Creek,and may reflect other potential contaminant sources. All tested parameters in the southditch were below MCLs with the exception of the lead concentration in sample 5/26-W-3,which was only 2 ppb over the MCL."

    A copy of ENSR's August 1994 report is included.

    Response: The above information does not substantially change the findings orconclusions of the document. It reinforces the information reported in EliminatedPathways, Public Water Supply and Biota Pathways, p 11. However, the finding of leadin the surface water runoff strengthens the conclusion that the sediment pathway is apotential exposure pathway in that lead is migrating off site.

  14. P. 8, Onsite Groundwater: E&E installed five groundwater monitoring wells in 1987. Groundwater analysis of samples from the wells in 1987 indicated that metalsconcentrations were below MCLs. (6)

    Response: Comment noted.

  15. P. 9, Sediment, 1: Monarch contends that contaminants of concern should be limited tobarium, lead and zinc on the south ditch, and to barium, lead, nickel and zinc on the northditch sediments. Refer to the Background Sampling Analysis Report. Cadmium shouldnot be included, as discussed above (item 12).

    Response: See response to Comment 12.

  16. P. 11, Biota Pathway: Monarch concurs with the conclusion that sediments are highlyunlikely to migrate in sufficient quantity to pose a health risk, and concurs that sedimentconcentrations are unlikely to pose any health threat. ADPH could cite as supporting dataENSR's recent study of watershed dilution factors, which supports ADPH's conclusionconcerning the migration of sediments from the ditches to the respective creeks. ENSRcalculates that flow in the north ditch is diluted by a factor of over 100 when it reachesCox Creek (ratio of north ditch to Cox Creek is 0.009, or 1 to 111.1); similarly, flow inthe south ditch is diluted by a factor of almost seven (ratio of south ditch to SweetwaterCreek is 0.147, or 1 to 6.8). Engineering Evaluation and Cost Analysis Work Plan,Appendix A, July 1994, ENSR Consulting and Engineering. A copy of Appendix A is included.

    Response: See response to Comment 12.

  17. P. 12, 1st sentence: Monarch objects to this statement. Substitute: "The monitoring wellsaround the settling basins indicate no leaching of the material from the settling basins intoadjacent groundwater." Analytical results of groundwater samples obtained fromupgradient wells were the same or higher than results of downgradient wells in allsampling events. Therefore, there is no basis to indicate any leaching of material from thesettling basins into groundwater. Furthermore, the electromagnetic conductivity studyconducted by E&E in 1987 indicated there was no leaching of materials from the settlingbasins. (6)

    Response: The sentence has been changed to read, "The monitoring wells around thesettlement basins indicate very little if any leaching of the material into the adjacentgroundwater."

  18. P. 12, Section A: The Toxicological Evaluation should only address contaminants ofconcern, consistent with item 12 above, which would limit the metals to barium, nickel,lead and zinc.

    Response: See response to Comment 12.

  19. P. 12, Section A, 2nd: Monarch contends the Comparison Values contained in AppendixB to the Public Health Assessment are excessively conservative based on the chemicalstructures and physical properties of the compounds used at the facility (fritted andcalcined metals). As indicated by the Comments submitted by Monarch on the proposedNPL listing, metals were used at the site only in a calcined and/or fritted form. Metals insuch forms exhibit far lower bioavailability, and are therefore less toxic, than elementalmetals or metal oxides. Refer to Comments, Section F.1 and throughout, and Exhibit 1 tothe Comments (ENSR Consulting), Comment 15, Comment 18, Comment 21, andreferences (including references in the Comments) cited therein. With respect to MinimalRisk Levels, metals at the site are not found in the forms for which the MRLs wereestablished. Furthermore, the Comparison Values contained in Appendix B to the PublicHealth Assessment are for the elemental forms of the metals listed.

    Response: ATSDR's protocol requires the use of these comparison values.

  20. P. 15, 2nd, 3rd line: In 1973, Monarch did not purchase the facility, but leased it.

    Response: The suggested change was made in the document.

  21. P. 15, 2nd, 4th line: Monarch ceased using such compounds in 1979.

    Response: The suggested change was made in the document.


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