MINDEN, FAYETTE COUNTY, WEST VIRGINIA
EPA FACILITY ID: WVD981038300
PETITIONED PUBLIC HEALTH ASSESSMENT ADDENDUM
SHAFFER EQUIPMENT COMPANY
MINDEN, FAYETTE COUNTY, WEST VIRGINIA
EPA FACILITY ID: WVD981038300
June 1, 1993
*ADDENDUM*
February 16, 1994
Prepared by:
U.S. Department of Health and Human Services
Public Health Service
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Atlanta, Georgia
TABLE OF CONTENTS
APPENDIX A: SUPPORT DOCUMENTATION
APPENDIX C: PETITIONED PUBLIC HEALTH ASSESSMENT
A public meeting was held on June 28, 1993, following the final release of the Shaffer Equipment Company Petitioned Public Health Assessment. During the meeting a number of concerns and information regarding the site, community, and the document were presented to ATSDR. Based on the information and discussions during the meeting, ATSDR is issuing this addendum to the Final Petitioned Public Health Assessment that was released on June 1, 1993. In addition, ATSDR has included in this addendum a copy of a letter that was sent to ATSDR from a community group and ATSDR's letter of response. To comply with ATSDR policy, names of private citizens were deleted from the letters. ATSDR released a draft of this public health assessment addendum for public comment from September 27, 1993 - November 6, 1993. Public comments have been received and are attached in Appendix B of this addendum.
ATSDR is aware that EPA has conducted additional sampling at the Shaffer Equipment Company site. ATSDR will continue to review new site-related data and information. If evaluation of any new data or information indicates a need for further public health actions, ATSDR will respond to address these public health needs.
Addend by deleting the deleting the following paragraph (and its associated reference) from the Health Outcome Data subsection (page 6).
In 1989, a Beckley, West Virginia gynecologist, who was a member of the Health Department Board of Directors, conducted a health survey and provided the results to the ATSDR Division of Health Studies for evaluation. (11)
ATSDR Comment: During the June 28, 1993, meeting in Minden, West Virginia, an attendee informed ATSDR that the survey mentioned above, is not related to the Shaffer Equipment Company site, but instead is related to a different West Virginia site. ATSDR does not know how the survey was misrepresented and included in the Shaffer Equipment Company file. However, had this information regarding the survey been brought to ATSDR's attention during the public comment period, ATSDR would have addressed it at that time, rather than through this addendum.
Addend the discussion under "Food Chain" in the Potential Exposure Pathways subsection (page 17) to indicate:
Early reports from the community stated that residents might have consumed snapping turtles in the area (15, 16). Snapping turtles have not been analyzed for PCBs, PCDDs, and PCDFs.
The EPA does not believe that snapping turtles are consumed from this area. At a public meeting on May 29, 1990, EPA asked the audience if snapping turtles were being eaten; there was no response. However, because of limited attendance, a lack of response did not necessarily indicate that turtles were not eaten. Because of the uncertainty surrounding the use of turtles for food and the lack of data regarding turtle contamination, ATSDR could not evaluate if exposure to these contaminants is actually occurring by ingestion. If turtles are being eaten and without data to negate contamination, ingestion of turtles would be considered a potential human exposure pathway.
During a public meeting on June 28, 1993, concerns were expressed that domestic animals using water from Arbuckle Creek, downstream from the site, could have been contaminated, particularly in the past. There was also concern that game animals that frequent the site property may be contaminated. Although gardens are not grown in the immediate vicinity of the site, there are gardens that are grown in the community and reports of gardens that have been grown in the flood plain. In addition, it was reported that Arbuckle Creek had been dredged in the past and that sediment from the creek was used in the gardens.
Significant bioconcentration of PCBs can occur in the fatty tissue of domestic or game animals. Such contamination and subsequent human exposure may or may not have resulted. ATSDR does not know whether livestock or game animals are currently being contaminated. However, it appears very unlikely that significant contamination to livestock could occur since off-site sediment and soil samples are relatively low, based on the most recent environmental sampling. Game animals which feed on-site could potentially receive more substantial contamination than livestock raised downstream of the site. However, snapping turtles which frequent the site and adjacent Arbuckle Creek should have the greatest opportunity for significant contamination.
PCBs are not readily taken up into plant tissue or fruits and vegetables. PCB-contaminated dust, that may accumulate on the surface of fruits and vegetables, can sometimes be a concern when gardens are located in or near greatly contaminated soil and when dry dusty conditions exist (43, 44). However, gardens in the Minden community are not located immediately surrounding the site and relatively low PCB levels have been found in off-site soil. Furthermore, peeling and thorough washing of garden produce can eliminate most surficial contamination. Since there are no data to indicate whether or not components of the locally raised food chain are contaminated, a potential human exposure pathway exists through ingestion of those products. The number of potentially exposed people is unknown.
Addend the discussion under "Food Chain" in the Eliminated Exposure Pathways subsection (page 18) to indicate:
EPA has documentation stating there are no game and edible species of fish in Arbuckle Creek. Except for snapping turtles, the aquatic food chain (fish) was eliminated as an exposure pathway.
Addend the first paragraph under the Toxicological Evaluations subsection (page 18) to indicate:
Adults and children who trespass can gain access to the Shaffer site, and may be exposed to polychlorinated biphenyl compounds (PCB) through dermal contact, dust inhalation, and inadvertent ingestion of contaminated soils. Exposure to contaminated on-site soils would be intermittent, and therefore, represents a minimal potential exposure. Children who played in off-site residential yards and those who played in Arbuckle Creek may have been exposed to contaminated soils and sediments. Past PCB sediment concentrations were high. Nothing is known about the frequency and duration of exposure. Therefore, ATSDR could not evaluate the public health implications of this exposure. Current concentrations of PCBs in sediment and residential soil appear to be low and decreasing with time; therefore, exposures are thought to have minimal public health consequences. Remedial and other workers on the site have the same potential routes for exposure; however, remedial workers normally follow appropriate work practices and use personal protective equipment. There are some concerns regarding possible exposure through the ingestion of snapping turtles from Arbuckle Creek, domestic and game animals, and garden produce, but no data are available to evaluate those potential exposures. Past on-site workers and their families were probably exposed to levels of PCBs; however, no data exist to quantify exposure. The public health implications of this exposure therefore cannot be assessed.
Addend by deleting the following paragraph (and its associated reference) from the Health Outcome Data Evaluation subsection (page 23).
Another study was conducted by Beckley, West Virginia gynecologist (11) who submitted a health survey to ATSDR in 1989 for evaluation. Although the survey did indicate areas of health concern similar to those mentioned previously, the survey did not encompass the Minden area. The design and methodology of the study were obscure. Therefore, ATSDR was not able to draw any conclusions for this public health assessment.
ATSDR Comment: As discussed previously, ATSDR is addending discussions involving the health survey above, based on information provided to ATSDR in the June 28, 1993, meeting.
Addend Conclusion number 3 (page 25) to indicate:
A potential health hazard exists for sensitive subpopulations such as fetuses and breast-fed infants, if their mothers eat PCB-contaminated snapping turtles or wild game from the area. Currently, there are uncertainties as to the existence of snapping turtles at the SEC site.
Addend Recommendation number 1 (page 27) to indicate:
Because it is not clear whether snapping turtles are being eaten from the area of the site, the general population and especially pregnant women and women who breast feed infants should be cautioned not to eat aquatic life (snapping turtles) or wild game from the site vicinity, until a bioassay (chemical analysis) is performed to determine if the PCB levels in edible tissues are safe (below regulatory standards). ATSDR could not conclude with any certainty that snapping turtles are not caught and eaten from the site vicinity.
Addend the heading for Table 7 in Appendix 2 (page 55) to indicate:
On-site and Off-site PCB Surface Soil Contamination
Addend by replacing Table 14 in Appendix 2 (page 61) with the following table:
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PATHWAY NAME
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EXPOSURE PATHWAY ELEMENTS
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TIME
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||||
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SOURCE COCs
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MEDIA
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POINT OF EXPOSURE
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ROUTE OF
EXPOSURE |
EXPOSED POPULATION
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COMPLETED EXPOSURE PATHWAYS
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| On-site workers | PCB oils | Air, Direct contact | Plant operations | Dermal, Inhalation, Ingestion |
SEC workers, estimated 30-50 and worker's families | Past |
| Off-site workers | PCB | Residential yards, Arbuckle Creek sediments |
Arbuckle Creek | Inhalation, Dermal, Ingestion |
Children playing in yards, creek-unknown number and frequency of exposure | Past, Present, Future |
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POTENTIAL EXPOSURE PATHWAYS
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||||||
| Off-site use of PCB contaminated oil as fuel | PCB contaminated oils, PCDD/PCDF | Air, Direct contact |
Handling, incomplete burning of PCB contaminated oil |
Inhalation, Dermal, Ingestion |
Off-site residences-unknown number | Past |
| On-site use of PCB contaminated oil as fuel in SEC building |
PCB contaminated oils, PCDD/PCDF | Air Direct contact |
Handling, Incomplete burning of PCB contaminated oil |
Inhalation, Dermal, Ingestion |
SEC workers, estimated 30-50 | Past |
| Food chain | PCB contaminated snapping turtles, domestic or game animals, and garden produce | Locally raised meats or produce, turtles, and game animals | Human consumption | Ingestion | Persons eating garden produce, turtles, and domestic and game animals-unknown number | Past, Present, Future |
| On-site SEC surface soils, sediment | PCB contaminated soils, sediment | Soil, Sediment, Fugitive dust |
Contaminated SEC soils, sediment | Inhalation, Dermal contact, Ingestion |
Trespassers-unknown number and unknown activities, On-site workers |
Past, Present, Future |
| SEC Equipment Building | PCB, PCDD/PCDF |
Air, Dust |
Inside Building surfaces | Inhalation, Dermal, Ingestion |
Workers-unknown number | Past, Present, Future |
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ELIMINATED EXPOSURE PATHWAYS
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||||||
| Remedial workers | PCB | Soil, Air, Sediments |
Remedial activities | Inhalation, Dermal, Ingestion |
Remedial workers-unlikely because appropriate safety measures required for on-site activities | Past, Present, Future |
| Food chain | PCB | Fish | Arbuckle Creek | Ingestion | No edible fish, no exposed population |
Past, |
COCs = Contaminants of concern
ATSDR Comment: Basked upon ATSDR site visits in the past, no gardens or farm animals were observed in the site vicinity. However, information regarding gardens in the area, steam sediment being used in gardens, domestic game raised downstream, and game animals near the site was brought up during the meeting on June 28, 1993. Based on that information, ATSDR has, in this addendum, addressed garden produce and domestic and game animals as a potential, instead of an eliminated, exposure pathway.
43. Travis CC and AD Arms. "Bioconcentration of Organics in Beef, Milk, and Vegetation." Environmental Science and Technology 1988; 3:271-274.
44. Travis CC and HA Hattemer-Frey. "Uptake of Organics by Aerial Plant Parts: A call for Research." Chemosphere 1988; 2: 277-283.
45. ATSDR. Toxicological Profile for Selected PCBs (Aroclor-1260, -1254, -1248, -1242, -1232, -1221, and -1016. April 1993.
APPENDIX A: SUPPORT DOCUMENTATION
CONCERNED CITIZENS TO SAVE FAYETTE COUNTY, INC. 1985
P.O. Box 75 - Minden, WV 25879 - (304) 469-6247
7/28/93
Lydia Ogden Askew
Community Involvement Liaison
ATSDR-Division of Health Assessment and Consultation
1600 Clifton, Road, NE (E32)
Atlanta, Georgia 30333
Dear Lydia,
I am writing you on behalf of Concerned Citizens To Save Fayette and the residents of Minden, West Virginia to express appreciation for members of the ATSDR traveling to Minden on the June 28, 1993 for the meeting to explain the Public Health Assessment for the Shaffer Equipment Company with the residents. However, as stated in the meeting, the Concerned Citizens as well as the residents reject the findings of the ATSDR as to potential danger of the Shaffer site to the community and the possible ill health effects of PCB's on the residents.
We formally request a new health assessment be made on the community of Minden based on a new analysis that will be fair and just. The new analysis must include an accurate interpretation of health data that has been collected by Concerned Citizens over the past eight years, an investigation of the new sampling that the EPA has agreed to conduct (all input on where and how to sample should be directed to the EPA by August 27, 1993), an examination into the health concerns of the residents to be conducted by the ATSDR and the West Virginia State Health Department by using a well established protocol that reflects adverse health conditions of PCB exposure and physical examinations, assistance by the agencies to the Concerned Citizens in their efforts to conduct a health registry (produced by the Environmental Health Network, Inc., Great Bridge Station P.O. 16267 Chesapeake, Va. 16267) of all Minden residents and former Shaffer employees as to discern the possible health effects of PCB's on the community, a reanalysis of all data previously submitted by the EPA relating to the sampling process of the area based on the ill fated and fraudulent direction of On-Site Coordinator Bob Caron, and an intense examination of the site relaing to possible exposure pathways to the community of PCB's and the residual amounts of PCBs in the area of Minden.
I would like to note that the Shaffer site is not secure, that we believe that the community is at a dire health threat from the PCB contamination, and that the health assessment that was presented to community was saturated with inaccuracies. It is hoped that the ATSDR will conduct a new health assessment that reflects the degree of economic and social justice that the Minden residents deserve.
cc:
Jeff Church
Charles Walters
Senator Bob Holliday
Senator Jay Rockefeller
Senator Robert Byrd
Congressman Rahall
Steering Committe of Concerned Citizens to Save Fayette County
Sept. 9, 1993
Concerned Citizens to Save Fayette County
P.O. Box 75
Minden, West Virginia 25879
I am writing in regard to the public meeting held in Minden, West Virginia,
on June 28, 1993, by the Agency for Toxic Substances and Disease Registry (ATSDR).
This meeting was held to discuss ATSDR's final Public Health Assessment of the
Shaffer Equipment Company. In addition, our agency has received your letter
of July 28, 1993, which you addressed to Ms. Lydia Ogden-Askew.
My staff has informed me that you and other attendees raised several issues of concern at that meeting, some of which you have also reiterated in your recent letter. Specifically, these five primary concerns have been expressed:
I would like to briefly discuss each of these five issues.
ATSDR staff did not observe any gardens, farms, or game animals around the site during their August 25, 1989, and May 29, 1990, site visits and therefore discussed the food chain as an eliminated pathway. No information that addressed the issue of PCB exposure to the public through food was provided to ATSDR during the document's public comment period. We first learned this was a concern during the public meeting, at which time we were told chickens and hogs are raised downstream of the site, gardens are raised downstream in the flood plain, sediments dredged in the past from the Arbuckle creek were sometimes used in gardens, and game animals access the site. Research as indicated that polychlorinated biphenyls (PCBs) are bioaccumulated (stored) in fat. Therefore, garden vegetables and fruits are not likely to be a source of exposure. However, domestic and game animals could become contaminated. They can be addressed as a potential pathway in the same manner that snapping turtles were addressed in the document. Specifically, ATSDR's first recommendation on page 27 states, "Because it is not clear whether snapping turtles are being eaten from the area of the site, the general population and especially pregnant women and women who breast feed infants would be cautioned not to eat aquatic life (snapping turtles from the site vicinity until a bioassay (chemical analysis) is performed to determine if the PCB levels in edible tissues are safe (below regulatory standards)." ATSDR will addend the document as needed to address these new food chain issues.
Regarding the concern about the health survey, ATSDR is uncertain how the study, which was pointed out in the meeting as being a part of another site, was represented as part of the Shaffer Equipment Company file. Regardless, ATSDR stated in the Health Outcome Data section of the public health assessment (p. 23) that "...the survey did not encompass the Minden area... Therefore, ATSDR was not able to draw any conclusions for this public health assessment." In other words, it did not affect ATSDR's conclusions and recommendations. However, ATSDR will addend the petitioned public health assessment to reflect the fact that the survey should not be included in the document.
The third and fourth issues raised during the meeting, a door-to-door health survey and a health study, need further clarification. I have enclosed an ATSDR flier that briefly explains what a petitioned public health assessment is and what it does. As stated in the flier, I will reiterate that a public health assessment is not the same thing as a medical exam or a community health study, but it evaluates environmental contamination, exposure pathways, and adverse health effects that might occur. A public health assessment provides the basis for further actions, including health surveys and studies, if needed. Based on the current information and data reviewed, ATSDR's assessment of the Shaffer Equipment Company site indicates that neither a door-to-door health survey nor a health study are warranted at this time.
Lastly, ATSDR does not believe that the document is invalid or that it should be completely reconducted. The Shaffer Equipment Company Petitioned Public Health Assessment was conducted using data and information collected during the site visit, public meetings, public comment period, interviews with former Shaffer employees, from the Concerned Citizens to Save Fayette County, West Virginia Bureau of Public Health, the United States Environmental Protection Agency, and other sources of information as referenced in the petitioned public health assessment. There fore, based on the data and information evaluated at that time, ATSDR believes that its assessment was accurate and appropriate.
However, based on information provided regarding the "Food Chain" pathway and the survey by Dr. Merritt, ATSDR will issue an addendum to the final release of the Shaffer Equipment Company Petitioned Public Health Assessment. This addendum will reflect changes brought as a result of the June 28, 1993, meeting. However, the new information provided and addended, does not support any change in the conclusion category. The conclusion category for the site will remain, a public health hazard on-site and an indeterminate public health hazard for the general off-site population.
The addendum will be released for a 30-day public comment period. Any comments received during the comment period will be addressed and included in the addendum. The addendum; therefore, will contain an explanation of the addendum, and how and where the original document is being addended, a copy of this letter, a copy of your letter to Ms. Ogden-Askew, and the public comments with responses.
If you have any further questions, please feel free to contact Mr. Jeff Church or Ms. Ogden-Askew of my staff.
Sincerely yours,
Robert C. Williams, P.E., DEE
Director
Division of Health Assessment and Consultation
ATSDR Petitioned Public Health Assessments
ATSDR developed this fact sheet to provide the public with information about its Petitioned Public Health Assessments. You may have questions the fact sheet doesn't answer or need more information about ATSDR and its activities. A contact person is listed at the end of the fact sheet.
What is ATSDR?
ATSDR is the Agency for Toxic Substances and Disease Registry, a federal public health agency. ATSDR is part of the Public Health Service in the U.S. Department of Health and Human Services. ATSDR is not a regulatory agency like the U.S. Environmental Protection Agency. Created by Superfund legislation in 1980, ATSDR's mission is to prevent or mitigate adverse human health effects and diminished quality of life resulting from exposure to hazardous substances in the environment. Through its programs—including surveillance, registries, health studies, environmental health education, and applied substance-specific research—and by working with other federal, state, and local government agencies, ATSDR acts to protect public health.
What is a Public Health Assessment?
An ATSDR Public Health Assessment is not the same thing as a medical exam or a community health study. It can sometimes lead to those things, as well as other public health activities. ATSDR conducts a Public Health Assessment for every site on or proposed for the National Priorities List (also known as the Superfund list). ATSDR can also be petitioned to conduct a Public Health Assessment for other sites.
A Public Health Assessment reviews information about hazardous substances at a site and evaluates whether exposure to those substances might cause any harm to people. Public Health Assessments consider—
To make those determinations, ATSDR looks at three primary sources of information—
The petition process is very simple. All you have to do is write to:
Assistant Administrator, ATSDR (CHB)
1600 Clifton Road, NE (E28)
Atlanta, GA 30333
In your letter, you must include the following information:
This information is also helpful to ATSDR, but not required:
What Happens After ATSDR Gets My Petition?
When ATSDR receives a petition, a team of environmental scientists, physicians, toxicologists, and other staff members is assigned to work on it. This team begins to gather information available on the site. Team members visit the site to see it first-hand and talk with the community. After that, the team evaluates all site information and presents the results to the ATSDR petition committee. That committee decides whether ATSDR will perform a Public Health Assessment or if some other action—such as a Public Health Advisory or Health Consultation or community environmental health education—would better meet the community's needs, or if no action is needed. Petitioners are informed of ATSDR's decision and the reasons for it in writing.
Fact sheets are available on Public Health Advisories, Health Consultations, and other ATSDR activities. If you want to know more about ATSDR, please contact the person listed below.
For more information, call or write:
Lydia Ogden Askew
Community Involvement Liaison
ATSDR-Division of Health Assessment and Consultation
1600 Clifton Road, NE (E32)
Atlanta, Georgia 30333
404/330-9543 (24 hours)
Comments Received During the ATSDR Public Comment Period
September 27 - November 6, 1993
Note: The comments are taken directly from a letter written to ATSDR in response to the public comment draft of the Shaffer Equipment Company Petitioned Public Health Assessment Addendum. No changes were made to spelling, wording, or sentence structure to avoid misrepresentation of the comment.
Comment 1: The Concerned Citizens fully supports the comments made to ATSDR by the Environmental Health Network and Director, Linda King relating to the Addendum to Minden.
Response to Comment 1: ATSDR has not received comments directly from the Environmental Health Network, Inc. However, ATSDR was copied on a letter from the Environmental Health Network, Inc., to the Concern Citizens to Save Fayette County. Your comments largely parallels the contents of that letter and are addressed as follows.
Comments 2: The past soil and water analysis by the EPA has been flawed (based upon Bob Caron's fraudulent work and the method of analysis using Archlor 1260 as the comparison base in the gas chromatograph instead of 1254 and other derivatives of PCB's found on the site-point put forth time and time again by Technical Advisor, Paul McGhee).
Response to Comment 2: ATSDR reviewed the Aroclor data submitted by EPA and found that the majority of the samples were analyzed for all aroclor congeners including 1254. Aroclor 1260, in the majority of the cases, appears to be the most predominant and most concentrated Aroclor detected. Furthermore, for health evaluation purposes, ATSDR does not distinguish between Aroclor 1254 and 1260 or any of the other Aroclors, since the toxic effects of the Aroclors are essentially identical at similar concentrations.
Comment 3: There are gardens that lie in the direct pathway of contamination and crops grown in contaminated PCB do in fact retain and absorb levels of contamination. Dr. Marvin Legator, University of Texas Medical Branch and Dr. Theo Colburn, World Wildlife Fund, both concur that resident have and will retain levels of PCB's that will be detrimental to their health. Gardens are a primary source of food in Minden.
Response to Comment 3: ATSDR has addressed gardens as a potential exposure pathway in this petitioned public health assessment addendum (page 2). PCBs are not readily taken up into plant tissue or fruits and vegetables. Although plants can uptake PCBs from the soil, they have a very low bioconcentration factor (i.e., they do not result in significant contamination) (45). Contamination of fruits and vegetables can occur through deposition of contaminated soil onto plants and its fruits or vegetables, which could ultimately result in higher levels of PCB contamination. However, based on the relatively low levels of PCBs detected in off-site soils, which appear to indicate that minimal levels of PCBs are migrating off site by the air or other means, it is unlikely that significant contamination of fruits and vegetables will result.
Comment 4: Many residents do in fact eat wild game from the Minden area and some do have livestock which probably are polluted by PCB's
Response to Comment 4: ATSDR addressed this issue in this petitioned public health assessment addendum (page 2). In the addendum, ATSDR acknowledges the use of livestock and wild game by addressing this as a potential exposure pathway. Based on the relatively low levels of PCBs detected in off-site soil and sediment, significant contamination of livestock appears unlikely. Wild game feeding on site could potentially be exposed to greater levels of contamination. Therefore, in this addendum ATSDR has recommended (Recommendation 1, page 3) that the general population and especially pregnant women and women who breast feed infants should be cautioned not to eat aquatic life (snapping turtles) or wild game from the site vicinity until a bioassay (chemical analysis) is performed to determine if the PCB levels in edible tissues are safe (below regulatory standards).
Comment 5: The tree bark samples should be analyzed for PCDF's and Dioxin an analysis included in the assessment.
Response to Comment 5: ATSDR forwarded EPA the comment, regarding tree bark sampling that was made to ATSDR under the public comment period for the June 1, 1993, petitioned public health assessment (Comment 1, page 72). ATSDR will evaluate any tree bark sampling deemed necessary by EPA. However, the potential for tree bark to be significantly contaminated and the subsequent use of wood resulting in significant exposures to polychlorinated dioxins and furans does not appear to be likely pathway based upon on- and off-site characterization.
Comment 6: There is no "Burm" or protective measure to stop PCB's from migrating from the site and being distributed throughout the community.
Response to Comment 6: PCBs bind tightly to soil and do not readily leach into the groundwater or dissolve in surface water under normal conditions (45). However, PCBs adsorbed to soil particles can migrate off-site as a result of soil erosion. ATSDR discussed this issue in the petitioned public health assessment under the Completed Exposure Pathways subsection (page 16). In that subsection, ATSDR determined that the migration of PCBs from the site appears to have occurred, but that concentrations in the off-site sediment have decreased with time. As discussed in the Toxicological Evaluation subsection (page 19), exposure to current levels of PCBs in off-site sediment are not believed to pose a significant public health threat. In a September 1, 1993, letter to EPA, ATSDR recommended that precautions and/or actions be taken to prevent contaminant migration, if the current condition of the soil or vegetative cover is disturbed.
Comment 7: The site is not secure.
Response to Comment 7: ATSDR reported in the petitioned public health assessment that the site is not secure and recommended (Recommendation 3, page 27) that access to the site be restricted. ATSDR still recommends that access to the site be restricted to prevent possible exposures with elevated levels of PCBs, until adequate surface soil sampling indicates otherwise or other actions are taken to prevent possible exposures to any on-site contamination.
Comment 8: The main dumping area, the "Pit", has not been analyzed by core sampling.
Response to Comment 8: ATSDR has no data regarding dumping or contamination at the dumping area referred to as the "Pit." Specific information and/or data are needed to determine whether this dumping pit poses a health threat. ATSDR has forwarded this comment to EPA for any necessary actions needed to obtain this data. Any further information or documentation (location, history, etc.) regarding the dumping pit should be provided to EPA.
Comment 9: The sediment of Minden Mine #3 has not been analyzed.
Response to Comment 9: Based upon on- and off-site environmental data and completed and potential exposure pathways, ATSDR has made recommendations for additional sampling. In this petitioned public health assessment, ATSDR recommended (recommendation 5, page 27) sampling of raw water supplies based on reports of PCB dumping in mine shafts that are used for raw water supplies. ATSDR is not aware of any pathways of exposure to sediment in mine shafts or the need for such sampling. ATSDR has forwarded this comment to EPA. Any further information or documentation should be provided to EPA.
Comment 10: The ATSDR needs to work with Dr. Hassan Amjad (Oak Hill, WV) in order to conduct an in-depth health survey of the Minden residents.
Response to Comment 10: In the development of the petitioned public health assessment, ATSDR reviewed various environmental, toxicological, and health outcome data. The health outcome data, as discussed in the Health Outcome Data Evaluation subsection (page 21), reviewed adipose (fat) samples for 20 former Shaffer employees and residents (1986-87), 10 serum (blood) samples (1986-87), 43 additional serum samples (1990), a health survey conducted by Vanderbilt University's Appalachian Student Health Coalition (1986), and cancer mortality data for Fayette County. Based on that information, it was concluded (Conclusions 6,7, 9, 10; page 26) that the serum and adipose samples do not indicate an increased exposure to PCBs in comparison to other populations; an increased rate of respiratory deaths for Fayette County (in comparison to U.S. rates) exist, but also existed prior to operation of Shaffer Equipment Company; no clear relationship could be established between PCB contamination and the significantly different observed rates of the four symptoms surveyed in the Vanderbilt Study; and that overall the toxicological and health information do not currently indicate high levels of exposure to PCBs or increases in health outcomes that can be linked to PCB exposure. In addition, ATSDR's Health Activities Recommendation Panel reviewed the petitioned public health assessment. Based on their review, no additional surveys or studies were recommended.
Comment 11: The ATSDR should in fact support the Concerned Citizens in their effort to complete a five year health registry of the Minden Residents and former Shaffer employee, (in conjunction with EHN, Inc.).
Response to Comment 11: ATSDR does not currently have a PCB Subregistry. ATSDR's National Exposure Registry is composed of chemical-specific subregistries as opposed to a site-specific subregistries. The primary purpose of the National Exposure Registry is to assess the possible relationship of adverse health effects of an exposed population to their exposure to a specific chemical. This is accomplished by collecting health data on exposed persons at selected sites where the exposure occurred to that chemical. ATSDR has not yet determined which chemicals will be selected for future subregistries; PCB, as will all chemicals found at waste sites, will be considered for selection. The criteria for selection are contained in the "National Exposure Registry Polices and Procedures Manual." Trichloroethlene, Benzene, and Dioxin Subregistries have been established. Chromium and radioactive substances subregistries will be established next year.