ATSDR-PHA-HC-Northside Sanitary Landfill-p4

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PUBLIC HEALTH ASSESSMENT

NORTHSIDE SANITARY LANDFILL
ZIONSVILLE, BOONE COUNTY, INDIANA

APPENDICES

Appendix A - Figures

Figure 1. Site Map

Figure 2. Phase I -- Surface Water, Sediment, and Soil Sample Locations

Figure 3. Northside Sanitary Landfill Subsurface Soil and Monitoring Well Sample Locations

Figure 4. Phase II -- Surface Water, Sediment, Soil, and Leachate Sample Locations

Figure 5. Residential Well Sampling Locations

Figure 6. Historical Bioaccumulation Study Sites

Figure 7. Fish Population Assessment

Appendix B - Tables

On-Site Surface Soil Sample Results, Phase I.

(Data used to develop Table 1.)

Chemical	Sample Location Number	Concentration Range - ppb
Chemical	Sample Location Number	Concentration Range - ppb
Organic Chemicals
acetone	SL022-01 SL020-01	6-7
methylene chloride	SL022-01 SL020-01	12-14
Inorganic Chemicals
aluminum	SL022-01 SL020-01	8,400-19,000
calcium	SL020-01 SL022-01	21,000-97,000
chromium	SL021-01 SL020-01	10-20
copper	SL020-01 SL022-01	20
iron	SL022-01 SL020-01	13,000-23,000
lead	SL022-01 SL020-01	8-22
magnesium	SL020-01 SL022-01	9,700-26,000
manganese	SL022-01 SL020-01	390-460
mercury	SL020-01	<1
nickel	SL020-01	20
potassium	SL021-01 SL020-01	2,000-3,000

All data collected from Final Remedial Investigation Report.

On-Site Subsurface Soil Sample Results, Phase I.

(Data used to develop Table 2.)

Chemical	Sample Depth (Feet)	Sample Date	Sample Location Number	Concentration Range - ppb
Chemical	Sample Depth (Feet)	Sample Date	Sample Location Number	Concentration Range - ppb
Organic Chemicals
acetone	0-3 8-9	12/84	SL008-01 SL008-02	65-16,000,000
benzene	9-12 5-9	1/85	SL011-03 SL011-02	6-7
benzoic acid	5-9	1/85	SL011-02	900
bis(2-ethylhexyl) phthalate	9-12 0-2	1/85 12/84	SL011-03 SL012-01	200-390,000
2-butanone	13-15 8-9	12/84	SL012-03 SL008-02	13-1,100,000
butyl benzyl phthalate	0-5	1/85	SL010-01	200
carbon disulfide	10-13 9-12	1/85	SL010-02 SL011-03	5-6
dieldrin	0-3	12/84	SL014-01 SL008-01	4
di-n-butyl phthalate	0-5 0-2	1/85 12/84	SL015-01 SL013-02	1,700-390,000
di-n-octyl phthalate	0-3 0-2	1/85 12/84	SL011-01 SL012-01	200-390,000
ethylbenzene	0-3 8-12	1/85	SL009-01 SL009-02	280-300
fluorene	3-10	12/84	SL012-02	380,000
methylene chloride	13-15 12-15	12/84	SL012-03 SL008-03	6-7,200
2-methylnaphthalene	5-9 0-2	1/85 12/84	SL011-02 SL012-01	200-390,000
naphthalene	3-10 0-2	12/84	SL012-02 SL012-01	380,000-390,000
phenanthrene	0-3 0-2	12/84	SL014-01 SL012-01	370,000-390,000
toluene	10-13 8-9	1/85 12/84	SL010-02 SL008-02	5-140,000
trans-1,2-dichloroethene	13-15	12/84	SL012-03	13
trichloroethylene	13-15	12/84	SL012-03	51
1,1,1-trichloroethylene	0-3	1/85	SL009-01	410
xylenes, total	0-5 0-3	1/85	SL010-01 SL009-01	6-800
Inorganic Chemicals
aluminum	6-9 0-5	1/85	SL017-03 SL010-01	3,200-11,000
arsenic	9-11	12/84	SL013-03	30
calcium	8-9 11-14	12/84 1/85	SL008-02 SL015-03	21,000-160,000
chromium	0-3 8-9	12/84	SL008-01 SL008-02	10
cobalt	23-30	1/85	SL010-03	20
copper	0-2 5-9	12/84 1/85	SL012-01 SL011-02	10-30
cyanide	0-2	12/84	SL012-01	<1
iron	6-9 8-9	1/85 12/84	SL017-03 SL008-02	8,400-19,000
lead	5-9 2-4	1/85 12/84	SL011-02 SL013-02	2-15
magnesium	0-3 6-9	1/85	SL018-01 SL017-03	3,000-32,000
manganese	13-15 0-3	12/84 1/85	SL012-03 SL018-01	240-470
mercury	0-3 0-2	12/84	SL014-01 SL012-01	<1
nickel	0-3	12/84 1/85	SL008-01 SL011-01	20-200
potassium	8-9 12-15	12/84	SL008-02 SL008-03	1,000-2,000
sodium	0-5	1/85	SL015-01	3,000
vanadium	0-3 10-13	1/85	SL011-01 SL010-02	10-30
zinc	9-12 0-3	1/85 12/84	SL011-03 SL014-01	30-67

On-Site Groundwater Sample Results, Glacial Till Water Bearing Zone, Phases I & II.

(Data used to develop Table 3.)

Chemical	Sample Date	Sample Location Number	Concentration Range - ppb
Chemical	Sample Date	Sample Location Number	Concentration Range - ppb
Organic Chemicals - Phase I
acetone	4/85	GW08S-01 GW016-01	11-13,000
benzene	2/85 4/85	GW018-01 GW016-01	5-500
di(2-ethylhexyl)phthalate	2/85	GW018-01 GW016-01	10-14
2-butanone	2/85 4/85	GW09S-01 GW016-01	10-1,000
chloroethane	2/85 4/85	GW09S-01 GW016-01	10
di-n-butyl phthalate	2/85	GW10S-01	10
ethylbenzene	4/85	GW018-01 GW014-01	5-50
4-methyl-2-pentanone	4/85	GW08S-01	1
methylene chloride	2/85 4/85	GW018-01 GW016-01	5-500
2-methylnaphthalene	4/85 2/85	GW08S-01 GW016-01	8-110
2-methylphenol	2/85	GW10S-01	10
4-methylphenol	2/85	GW10S-01	10
naphthalene	2/85	GW018-01 GW015-01	10-33
phenol	2/85	GW10S-01	10
phenanthrene	2/85	GW016-01	10
toluene	2/85	GW018-01 GW016-01	19-500
trichloroethylene	2/85	GW09S-01	5
xylenes, total	4/85 2/85	GW08S-01 GW016-01	3-830
Inorganic Chemicals - Phase I
aluminum	2/85 4/85	GW11S-01 GW08S-01	24-63
antimony	2/85	GW014-01 GW018-01	32-33
arsenic	2/85	GW014-01	21
barium	2/85	GW015-01 GW014-01	69-1,110
beryllium	2/85	GW018-01	1
calcium	4/85 2/85	GW08S-01 GW10S-01	54,000-228,000
chromium	2/85	GW09S-01	4
cobalt	2/85	GW11S-01 GW018-01	6-17
copper	2/85	GW09S-01	8
cyanide	4/85 2/85	GW08S-01 GW018-01	3-4
iron	2/85	GW016-01 GW014-01	8-17,000
lead	4/85 2/85	GW08S-01 GW016-01	9-53
magnesium	2/85	GW015-01 GW014-01	22,900-165,000
manganese	2/85	GW11S-01 GW018-01	112-4,330
nickel	2/85	GW10S-01 GW09S-01	32-87
potassium	2/85	GW015-01 GW014-01	1,450-152,000
sodium	2/85	GW015-01 GW014-01	8,930-534,000
vanadium	2/85	GW014-01 GW018-01	4
zinc	2/85	GW014-01 GW10S-01	4-290
Organic Chemicals - Phase II
acetone		GW0105-02 GW016-02	10-550
benzene		GW016-02	22
di(2-ethylhexyl)phthalate		GW011S-02 GW010S-02	10-26
2-butanone		GW0095-02 GW014-02	10-370
carbon disulfide		GW016-02	1
di-n-butyl phthalate		GW011S-02	10
2-methyl-2-pentanone		GW014-02	110
methylene chloride		GW010S-02 GW011S-02	7-15
2-methylnaphthalene		GW011S-02 GW014-02	31-110
2-methylphenol		GW016-02	10
naphthalene		GW011S-02 GW016-02	24-110
phenol		GW016-02 GW011S-02	4-10
toluene		GW016-02	28
trichloroethylene		GW011S-02 GW015-02	5-32
xylenes, total		GW011S-02 GW016-02	5-1,100
Inorganic Chemicals - Phase II
aluminum		GW010S-02	300
arsenic		GW014-02	44
barium		GW009S-02 GW014-02	400-900
calcium		GW008S-02 GW010S-02	51,000-207,000
iron		GW018-02 GW014-02	2,230-22,200
lead		GW015-02 GW011S-02	14-30
magnesium		GW015-02 GW014-02	21,000-150,000
manganese		GW016-02 GW018-02	50-4,330
nickel		GW014-02 GW009S-02	70-100
potassium		GW010S-02 GW014-02	6,000-156,000
sodium		GW015-02 GW014-02	9,000-495,000

On-Site Groundwater Sample Results, Sand & Gravel Water Bearing Zone, Phases I & II.

(Data used to develop Table 3.)

Chemical	Sample Date	Sample Location N umber	Concentration Range - ppb
Chemical	Sample Date	Sample Location N umber	Concentration Range - ppb
Organic Chemicals - Phase I
acetone	4/85 2/85	GW08D-01 GW10D-01	5-710
benzene	2/85	GW013-01 GW065-01	5-110
2-butanone	2/85	GW012-01 GW10D-01	13-205
butyl benzyl phthalate	2/85	GW004-01	10
chloroethane	2/85	GW065-01 GW001-01	10-100
1,1-dichloroethane	2/85	GW005-01 GW013-01	5-60
1,1-dichloroethene	2/85	GW013-01	5
diethyl phthalate	2/85	GW002-01	10
di-n-butyl phthalate	2/85	GW004-01	10
methylene chloride	2/85	GW019-01 GW001-01	5-50
trans-1,2-dichloroethene	2/85	GW019-01 GW005-01	5
1,1,1-trichloroethane	2/85	GW013-01	5
trichloroethylene	2/85	GW019-01	5
vinyl chloride	2/85	GW019-01 GW001-01	10-100
Inorganic Chemicals - Phase I
aluminum	4/85 2/85	GW08D-01 GW005-01	50-114
antimony	2/85	GW09D-01 GW065-01	30-58
arsenic	2/85 4/85	GW09D-01 GW08D-01	12-37
barium	4/85 2/85	GW08D-01 GW065-01	96-1,580
beryllium	2/85	GW065-01	1
calcium	2/85	GW004-01 GW065-01	25,000-192,000
chromium	2/85	GW006-01 GW065-01	3-10
cobalt	2/85	GW012-01 GW065-01	7-9
copper	2/85 4/85	GW005-01 GW08D-01	3-5
cyanide	2/85	GW09D-01 GW065-01	4-5
iron	2/85	GW003-01 GW065-01	11-10,400
lead	4/85	GW08D-01	10
magnesium	2/85	GW004-01 GW065-01	12,400-169,000
manganese	2/85	GW004-01 GW013-01	12-1,380
nickel	2/85	GW09D-01 GW001-01	24-87
potassium	2/85	GW005-01 GW065-01	717-147,000
silver	2/85	GS002-01 GW065-01	3-6
sodium	2/85	GW005-01 GW065-01	6,540-536,000
tin	2/85	GW11D-01 GW007-01	13-15
vanadium	2/85	GW09D-01 GW065-01	3-10
zinc	2/85	GW006-01 GW001-01	3-41
Organic Chemicals - Phase II
acetone		GW004-02 GW002-02	10-9,500
benzene		GW001-02	1
di(2-ethylhexyl)phthalate		GW002-02	10
2-butanone		GW007-02 GW002-02	18-4,800
chloroethane		GW001-02	24
1,1-dichloroethane		GW001-02	20
di-n-butyl phthalate		GW002-02	10
di-n-octyl phthalate		GW007-02	1
4-methyl-2-pentanone		GW002-02	220
methylene chloride		GW004-02 GW002-02	5-7
n-nitrosodi-n-propylamine		GW005-02	1
trans-1,2-dichloroethene		GW001-02	23
1,1,1-trichloroethane		GW001-02	2
trichloroethylene		GW001-02	4
vinyl chloride		GW001-02	7

On-Site Leachate Liquid Sample Results, Phase II.

(Data used to develop Table 4.)

Chemical	Sample Location Number	Concentration Range - ppb
Chemical	Sample Location Number	Concentration Range - ppb
Organic Chemicals
acetone	LL002-01	44,000
2-butanone	LL002-01	27,000
isophorone	LL002-01	69
4-methyl-2-pentanone	LL002-01	3,500
methylene chloride	LL002-01	2,800
4-methylphenol	LL002-01	12,000
Inorganic Chemicals
aluminum	LL001-01 LL002-01	2,800-3,600
barium	LL002-01	1,200
calcium	LL001-01 LL002-01	67,000-660,000
chromium	LL002-01	30
iron	LL001-01 LL002-01	3,480-65,000
lead	LL001-01 LL002-01	10-42
magnesium	LL001-01 LL002-01	12,000-160,000
manganese	LL002-01	6,220
nickel	LL002-01	120
potassium	LL002-01	310,000
sodium	LL001-01 LL002-01	6,000-345,000
zinc	LL002-01	50

On-Site Leachate Solid Sample Results, Phase II.

(Data used to develop Table 4.)

Chemical	Sample Location Number	Concentration Range - ppb
Chemical	Sample Location Number	Concentration Range - ppb
Organic Chemicals
acetone	LS001-01 LS002-01	11-8,600
2-butanone	LS001-01 LS002-01	14-690
di(2-ethylhexyl)phthalate	LS001-01 LS003-01	110-91,000
butyl benzyl phthalate	LS002-01 LS003-01	540-18,000
chlordane	LS003-01	2,600
di-n-butyl phthalate	LS003-01	13,000
di-n-octyl phthalate	LS003-01	10,000
ethylbenzene	LS003-01	150
2-hexanone	LS002-01	21
4-methyl-2-pentanone	LS002-01	650
methylene chloride	LS001-01 LS003-01	15-97
4-methylphenol	LS002-01	3,400
naphthalene	LS002-01	370
phenol	LS002-01	1,400
tetrachloroethene	LS001-01	8
toluene	LS002-01 LS003-01	10-140
trichloroethylene	LS001-01	7
Inorganic Chemicals
aluminum	LS002-01 LS003-01	4,700-7,400
calcium	LS003-01 LS002-01	49,000-78,000
chromium	LS001-01	10
iron	LS001-01 LS002-01	9,100-16,000
lead	LS002-01 LS003-01	9-22
magnesium	LS003-01 LS002-01	14,000-22,000
manganese	LS001-01 LS003-01	330-1,400
zinc	LS002-01 LS003-01	30-63

Off-Site Private Well Sample Results, Phase II

(Data used to develop Table 5.)

Chemical	Sample Location Number	Concentration Range - ppb
Chemical	Sample Location Number	Concentration Range - ppb
Organic Chemicals
2-butanone	RW003-01	16
methylene chloride	RW003-01	8
phenol	RW001-01 RW002-01	2-6
Inorganic Chemicals
calcium	RW005-01 RW002-01	49,000-85,000
iron	RW005-01 RW002-01	330-3,300
magnesium	RW005-01 RW004-01	17,000-29,000
manganese	RW005-01	70
sodium	RW002-01 RW003-01	13,000-174,000
zinc	RW005-01	120

Off-Site Surface Water Sample Results, Phase I

(Data used to develop Table 6.)

Chemical	Sample Location Number	Concentration Range - ppb
Chemical	Sample Location Number	Concentration Range - ppb
Organic Chemicals
acetone	SW008-01 SW010-01	15-280
di(2-ethylhexyl)phthalate	SW001-01 SW004-01	13-146
2-butanone	SW010-01	190
4-methyl-2-pentanone	SW010-01	27
methylene chloride	SW001-01 SW002-01	6-10
4-methylphenol	SW010-01	31
phenol	SW010-01	14
trans-1,2-dichloroethene	SW010-01 SW008-01	11-15
Inorganic Chemicals
aluminum	SW004-01	400
calcium	SW002-01 SW004-01	8,000-188,000
cyanide	SW006-01 SW005-01	10-30
iron	SW001-01 SW010-01	150-1,950
magnesium	SW001-01 SW004-01	21,000-42,000
manganese	SW005-01 SW004-01	30-440
mercury	SW004-01 SW003-01	<1-1
potassium	SW010-01	6,000
sodium	SW006-01 SW004-01	6,000-14,000
vanadium	SW002-01 SW001-01	20-30
zinc	SW005-01 SW006-01	20-30

Off-Site Bottom Sediment Sample Results, Phase I

(Data used to develop Table 6.)

Chemical	Sample Location Number	Concentration Range - ppb
Chemical	Sample Location Number	Concentration Range - ppb
Organic Chemicals
acetone	SD010-01 SD004-01	7-49
aroclor-1242	SD004-01	1,700
aroclor-1254	SD004-01	1,800
di(2-ethylhexyl)phthalate	SD005-01 SD008-01	220-320
2-butanone	SD004-01 SD002-01	7-11
1,2-dichlorobenzene	SD008-01	220
methylene chloride	SD003-01 SD004-01	5-14
4-methylphenol	SD008-01	290
toluene	SD005-01 SD002-01	3-10
xylenes, total	SD005-01	3
Inorganic Chemicals
aluminum	SD002-01 SD004-01	4,100-26,000
calcium	SD003-01 SD002-01	21,000-87,000
chromium	SD008-01	20
copper	SD008-01 SD005-01	10-20
iron	SD010-01 SD004-01	7,600-35,000
lead	SD002-01 SD004-01	9-31
magnesium	SD003-01 SD002-01	7,000-36,000
manganese	SD003-01 SD004-01	260-730
mercury	SD004-01	<1
nickel	SD006-01 SD005-01	20-30
potassium	SD005-01 SD004-01	2,000-5,000
vanadium	SD005-01 SD004-01	10-50
zinc	SD002-01 SD004-01	20-150

Off-Site Surface Water Sample Results, Phase II.

(Data used to develop Table 6.)

Chemical	Sample Location Number	Concentration Range - ppb
Chemical	Sample Location Number	Concentration Range - ppb
Organic Chemicals
acetone	SW011-02 SW010-02	10-2,900
benzene	SW010-02	250
benzoic acid	SW010-02	300
di(2-ethylhexyl)phthalate	SW003-02	10
2-butanone	SW011-02 SW010-02	10-1,900
chloroform	SW007-02	5
1,1-dichloroethane	SW008-02	5
di-n-butyl phthalate	SW011-02 SW005-02	10-20
2-hexanone	SW010-02	500
isophorone	SW010-02	10
methylene chloride	SW011-02 SW010-02	5-250
4-methylphenol	SW010-02	40
naphthalene	SW010-02	36
phenol	SW011-02 SW010-02	10-38
toluene	SW007-02	5
trans-1,2-dichloroethene	SW011-02 SW008-02	6-9
1,1,1-trichloroethane	SW008-02	5
trichloroethylene	SW008-03	5
vinyl chloride	SW008-02	10
Inorganic Chemicals
aluminum	SW002-02 SW012-02	1,000-1,800
calcium	SW002-02 SW010-02	69,000-133,000
cyanide	SW011-02	20
iron	SW011-02 SW010-02	400-4,000
magnesium	SW002-02 SW010-02	18,000-36,000
manganese	SW002-02 SW010-02	50-840
potassium	SW010-02	31,000
zinc	SW012-02 SW002-02	30-50

Off-Site Sediment Sample Results, Phase II.

(Data used to develop Table 6.)

Chemical	Sample Location Number	Concentration Range - ppb
Chemical	Sample Location Number	Concentration Range - ppb
Organic Chemicals
acetone	SD003-02 SD008-03	33-82
aroclor-1254	SD008-03	160
benzo(a)anthracene	SD008-02 SD008-03	47-110
benzo(a)pyrene	SD008-02 SD008-03	57-110
benzo(b,k)fluoranthene	SD006-02 SD008-03	126-380
benzo(g,h,i)perylene	SD008-03	78
di(2-ethylhexyl)phthalate	SD012-02 SD008-03	98-1,700
2-butanone	SD005-02 SD012-02	19-34
butyl benzyl phthalate	SD005-02 SD008-03	338-1,400
chrysene	SD006-02 SD008-03	46-100
dibenzo(a,h)anthracene	SD008-03	49
1,2-dichlorobenzene	SD008-03 SD008-02	56-120
dieldrin	SD011-02	20
di-n-butyl phthalate	SD002-02 SD008-03	54-1,600
di-n-octyl phthalate	SD008-02 SD008-03	41-200
fluoranthene	SD008-02 SD008-03	88-150
indeno(1,2,3-cd)pyrene	SD008-03	87
methylene chloride	SD006-02 SD008-03	12-48
4-methylphenol	SD010-02 SD008-03	71-860
phenanthrene	SD008-02 SD008-03	84-140
pyrene	SD008-02 SD008-03	81-140
Inorganic Chemicals
aluminum	SD005-02 SD002-02	3,900-14,000
calcium	SD002-02 SD008-03	7,500-74,000
chromium	SD008-02 SD008-03	20-30
copper	SD008-03	30
cyanide	SD010-02	<1
iron	SD003-02 SD002-02	8,200-16,000
lead	SD012-02 SD008-02	12-37
magnesium	SD012-02 SD008-03	5,000-27,000
manganese	SD006-02 SD008-03	150-500
zinc	SD011-02 SD012-02	20-94

Appendix C - Comments & Responses

RESPONSE TO COMMENTS
Northside Sanitary Landfill (NSL)

1.	COMMENT	The report confuses the term "detected constituents" with constituents present at, or the result of, Northside Sanitary Landfill. Several of the detected constituents are naturally occurring and there is no evidence that the detected constituents are attributable to the NSL.
	RESPONSE	The document will be reviewed. All inferences of naturally occurring chemicals being present as a result of the landfill will be adjusted accordingly. Please note, however, that the document does have qualifiers with this regard on the following pages: page 8 - 1st paragraph, "All chemicals found in sampled media have been assessed for adverse health effects.." page 9 - 3rd paragraph, "Aluminum is not considered a contaminant of concern because it is one of the most common natural constituents of soil.."
2.	COMMENT	There is a complete lack of physical or chemical evidence connecting constituents detected in groundwater at residential wells and constituents detected at NSL. In fact, Finley Creek to the South of NSL is the regional discharge point for groundwater flow, and no residential wells exist between NSL and Finley Creek.
	RESPONSE	On-site groundwater samples and on-site leachate samples did show sodium contamination, thus the correlation with the residential wells (please note page 21 of the document under the Pathways Analyses section, last paragraph). Groundwater flow is from the southeast to the northwest (please note Figure 5 of residential well sampling locations). Private wells do exist between the site and Finley Creek. The Endangerment Species Report also indicated that it is not certain that groundwater does not flow underneath Finley Creek. If it does this would leave all private residential wells that are northwest of the site as potential recipients of contaminants found in on-site groundwater.
3.	COMMENT	The apparent concern of the ISDH for sodium in the groundwater was never a concern of either the EPA or IDEM.
	RESPONSE	When a public health assessment is written for a site, the primary focus is the health of the community surrounding the site. Any chemical found in a private residential well whether it is site-related or not (in this case, it is not conclusive), is of concern to the ISDH, especially if this is the primary source of drinking water. Please note that the reason that this chemical was selected for discussion is because the report of the National Academy of Science stating that individuals with hypertension who are on salt-restrictive diets could suffer adverse health effects if concentrations in the primary drinking water source are greater than 20,000 ppb. The concentrations found have, in some cases, been 174,000 ppb. Long-term ingestion of high concentrations of sodium is associated with the development of hypertension.
4.	COMMENT	Groundwater in residential wells is completely void of any detectable concentrations of organic or inorganic chemicals potentially related to NSL. This would lead to the conclusion that NSL could not be the source of sodium.
	RESPONSE	Please see page B-15, Appendix B, which contains the data used to create Table 5 in the document. According to the data reviewed, there were six inorganic chemicals found (calcium, iron, magnesium, manganese, sodium, and zinc). Sodium was the only chemical considered to be at a level of health concern. Because the other chemicals were present, there is a potential for migration of site contaminants into the private wells.
5.	COMMENT	Finley Creek near the landfill is not a recreational body of water.
	RESPONSE	It is quite apparent that Finley Creek is not conducive for all types of recreational activities. There is still a potential, however, for individuals to wade in or play around the creek. Recreation was qualified as such in the document.
6.	COMMENT	The analytical data used in the development of the public health assessment for this site is over 10 years old. We believe it is a highly questionable practice to alert people that they are at risk today based upon 10-year-old data.
	RESPONSE	A public health assessment is written based on all available data. The Environmental Epidemiology Section of the ISDH does not perform any environmental sampling. We are dependent on IDEM and EPA to provide us with sampling data. It is important to note that a public health assessment document is never final. If any pertinent new data is collected after the public comment period of the document, an addendum can be added to the public health assessment. We are required to analyze all data for past, present, and future potential and completed exposure pathways. This of course includes the evaluation of all environmental sampling performed at the site, including the data that are 10 years old. We would appreciate your forwarding to us a copy of the new data so that we can update this document.
7.	COMMENT	The remedial actions currently in design for implementation in 1994 at the NSL will mitigate all current potential pathways exposure.
	RESPONSE	This is very good news. However, it is important to note that until the remedial actions are implemented, the potential pathways of exposure still exist and will remain as such.
8.	COMMENT	The Consent Decree is the legal instrument prepared by the federal government and approved by the state of Indiana, which directs the cleanup of the site according to the standards determined by the state and the EPA.
	RESPONSE	The conclusions reached in the public health assessment are based on an independent review of the available site data. The finding of one agency should not influence the findings and conclusions of another independent agency. Please note that the only portion of the document that does not agree with the RI/FS is the contamination levels of sodium in the private wells. Please recall that there are qualifiers within the document explaining our position on the levels of sodium found in the private well samples.
9.	COMMENT	The RI report does not mention 320,000 drums as being deposited in the landfill, and there is no support for this conclusion.
	RESPONSE	This information was reviewed and appropriate changes were made to the document.
10.	COMMENT	The NSL was not licensed in 1971 to accept hazardous waste. And the term hazardous waste did not exist relative to permitting of waste disposal facilities.
	RESPONSE	This information was reviewed and appropriate changes were made to the document.
11.	COMMENT	As stated in the Remedial Investigation and Feasibility Study reports, and the Endangerment Assessment, potential public health impacts do not include groundwater.
	RESPONSE	Based on the ATSDR guidelines for writing public health assessments, if private wells are located in a known contaminated aquifer, and the private wells are in the path of the groundwater flow, there is a potential for these private wells to become contaminated. The ISDH draws its conclusions independent of other agency conclusions on the same subject matter.
12.	COMMENT	The Consent Decree and ROD amendment have been finalized and the remedial design is in process. In fact, the intermediate design was submitted in June 1992.
	RESPONSE	Please note that this document contains available information up until December of 1992, thus this information would not be included in this version of the document.
13.	COMMENT	There is no program currently in place which provides for groundwater quality monitoring as indicated in item 8 of the site visit (page 5).
	RESPONSE	The information was reviewed and appropriate changes were made to the document.
14.	COMMENT	The concentrations reported in soil, sediment, leachate, and groundwater at NSL (with the exception of one sample at one location) are less than the MCL of 50 g/.
	RESPONSE	The EPA's Action Level for lead in groundwater is 15 g/. As stated on page 7, if there is no comparison value for a chemical in a specific media, based on the ATSDR guidelines for writing public health assessments, it is automatically considered a chemical of concern.
15.	COMMENT	The procedure followed by the ISDH for selecting contaminants of concern does not follow EPA guidance or practice. In addition, the contaminants of concern for groundwater listed in Table 3 of the document differ from those in the RI/FS report.
	RESPONSE	The ISDH writes public health assessments based on guidelines provided by the Agency For Toxic Substances and Disease Registry. The EPA selects chemicals of concern with the ultimate goal in mind of protecting the environment and selecting a remedial design. The ATSDR and ISDH select chemicals of concern based on the past, present, and future completed and potential pathways of exposure, and the resulting affect on human health.
16.	COMMENT	Private well RNOO2-01 is not an off-site well. This well is owned by the Bankert family and is located on the site property.
	RESPONSE	This information was reviewed and appropriate changes were made to the document.
17.	COMMENT	The Health Assessment Report should take into account the potential effects of Finley Creek realignment on biota.
	RESPONSE	This comment is beyond the scope and purpose of the public health assessment.
18.	COMMENT	Landfill gas venting systems are not currently in place at the site. A landfill gas venting system has been designed and is currently under review by both the EPA and IDEM. Once the design is finalized, a landfill gas venting system will be constructed during the remedial action as part of the landfill cover system.
	RESPONSE	This information was reviewed and appropriate changes were made to the document.
19.	COMMENT	There are no federal drinking water standards, promulgated or proposed, for sodium. As such, no enforceable standards or guidelines exist. Sodium is not a contaminant associated with the NSL as identified by the federal or state agencies involved in this site since its original inclusion on the National Priority List.
	RESPONSE	We agree that there are no federal drinking water standards for sodium. There is, however, a research-based guideline provided by the National Academy of Sciences which is accepted by ATSDR. This guideline states that wherein water contains greater than 20,000 ppb of sodium, adverse health affects could occur in hypertensive individuals on medically advised, salt-restrictive diets. The ISDH has associated sodium with the NSL site as it was found in the on-site wells. (Please see Response #3.)
20.	COMMENT	Private well RN002-01 is not an off-site well. This well is owned by the Bankert family (NSL owner/operator) and is located on the site property.
	RESPONSE	The well is, however, is used for drinking purposes and must be addressed regardless of who owns it. This information was reviewed and appropriate changes were made to the document.
21.	COMMENT	There is a direct contradiction to the conclusion regarding sodium presented in the public health assessment report. The public health assessment report for the Envirochem site (directly west of NSL) states that "the source of sodium (in private wells) is not certain".
	RESPONSE	This conclusion was made because the on-site monitoring wells for Envirochem did not show any sodium. On the other hand, the on-site monitoring wells for the NSL did show concentrations of sodium.
22.	COMMENT	Sodium is not a carcinogen as noted in the conclusions.
	RESPONSE	We agree, sodium is not a carcinogen. The sentence does not suggest that sodium is a carcinogen but that other site-related chemicals in residential wells, upon longer exposures, can cause adverse health effects, including cancer.
23.	COMMENT	Sampling of fish in Finley Creek is not necessary. Previous studies support this conclusion.
	RESPONSE	This information was reviewed. Previous studies of Finley Creek suggest that the population of fish downgradient from the site is less than that found upgradient. Appropriate changes were made to the document.
24.	COMMENT	Impacts from the leachate will be mitigated by the remedial actions currently in design.
	RESPONSE	We are required to make our conclusions and recommendations based on the status of the site at the time of the writing of the public health assessment.
25.	COMMENT	Off-site surface soils were sampled as a part of the supplemental investigation during remedial design.
	RESPONSE	This data gathering was performed subsequent to the writing of the public health assessment. Our conclusions and recommendations are based on the status of the site at the time of the writing of the public health assessment.
26.	COMMENT	Based on the result of the RI/FS, standards were established for the remediation to mitigate potential health impacts.
	RESPONSE	We are required to make our conclusions and recommendations based on the status of the site at the time of the writing of the public health assessment.
27.	COMMENT	Residential well monitoring is not necessary based on the results of previous investigations, including the RI/FS.
	RESPONSE	Regardless of the conclusions of other investigations, the recommendation in this report still stands that private wells should be monitored on a practical basis to ensure that site-related chemicals are not migrating to the private wells.
28.	COMMENT	Any response actions taken relative to sodium should not be conducted relative to the remedial actions at the NSL.
	RESPONSE	It is a fact that sodium was found in the on-site wells of the NSL site. The information regarding this data was reviewed and appropriate changes were made to the Recommendations section of the document.
29.	COMMENT	Off-site groundwater monitoring is not planned for this site. The data do not indicate any need for off-site sampling.
	RESPONSE	Based on our review of the data, there is a need for continued private well sampling, especially for those wells that had elevated site-related chemical concentrations.
30.	COMMENT	The Consent Decree requirements relative to remediations of NSL will protect Finely Creek. Sampling of fish in Finley Creek is not necessary.
	RESPONSE	This information was reviewed and appropriate changes were made to the document.
31.	COMMENT	Off-site soil was been investigated by EPA and IDEM in June 1993. Based on the results of those studies, the trustees have concluded that no off-site activities relative to the soils are necessary.
	RESPONSE	At the time this public health assessment was written, this information was not available. Our conclusions and recommendations are appropriate based on the data we reviewed.
32.	COMMENT	The public health assessment should be revised to reflect the facts today, not supposition based on data from nearly 10 years prior. The conclusions should be changed, and the public should be informed the concerns presented in the prior report were in error, or are being mitigated by the RA. The public should not be left with the erroneous conclusion presented in the public health assessment report that they are at risk from drinking groundwater from their supply wells impacted by NSL.
	RESPONSE	The public health assessment is a document that is never considered final. It is important to note, however, that the public health assessment is written based on information or data that are available up until the document is released for public comment. Thus, the conclusions and recommendations are not erroneous, just time dated. Any new data that affect the conclusions and recommendations of this document have been added at the end of the HARP statement. The conclusions and recommendations contained in the public health assessment with regard to risk from drinking groundwater still stand. We are responsible for reporting information to the public based on the data we reviewed. Our conclusions and recommendations suggest that individuals on salt-restrictive diets because of doctor-diagnosed hypertension should be aware that the levels of sodium found in their wells may prohibit them from following their doctor's orders.

Due to time delays in the release of this document, it is important to note that the remedial investigation and design have been initiated since the public comment period. This has resulted in some of our recommendations being obsolete as the PRPs have already taken care of the concern before the public health assessment for the NSL site is put in final form. The following is a list of completed actions at the NSL site at the time we submitted this document for final printing.

The off-site soils have been investigated. Soil sample results from Old Finley Creek are provided in the intermediate remedial design report, June 1993. Based on the results of those studies, the Trustees have concluded that no off-site activities relative to soils are necessary.
Appropriate health and safety precautions will be undertaken during the RA to mitigate any potential health impacts (as a result of the remediation) on remedial workers or other persons on- or off-site. On-site workers will follow the appropriate OSHA regulations and the site-specific health and safety plan for personal protection.

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