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Home My WebLink AboutNCD003200383_19920814_Koppers Co. Inc._FRBCERCLA RISK_Baseline Risk Assessment 1988 - 1992-OCRUNITED ST ATES ENVIRONMENT AL PROTECTION AGENCY REGION IV AUG 1 4 1992 4WD-NSRB Shannon Craig Beazer East, Inc. 436 Seventh Avenue 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 Pittsburgh, Pennsylvania 15219 Re: Baseline Risk Assessment Koppers Superfund Site .. Mor:i;;isv~i..i:e·, .Nortn Carolina ____ · r.1t:ar Ms . Craig: lf{fIG\Ei~t~ AUG l !i 199~ sumruNOSECllON Pursuant to the Administrative Order on Consent,89-12-C, Section VI, Paragraph I, this letter notifies you of Agency approval for the Baseline Risk Assessment, August 1992. The appropriate title sheets for the binders and/or new full copies of the reports, as approprciate, should be submitted no later than August 24, 1992. Please contact me to discuss the exact way this should be handled. I can. be reached at 404-347-7791 if you have any questions regarding this letter. Sincerely, ' /) i/))1)/1___,, ,'/2 _,i/.~-1..1.141 _/___.,-l,, {l L(_,, ,,_ / j -!) Barbara H. Benoy Remedial Project Manager Waste Management Division cc: Curt Fehn, NCS Chuck Mikalian, ORC / Bruce Nicholson, NCDEHNRV Susan Allen, ENSR KOP.81492.BRAAPP Printed on Recycled Paper uAo STATES ENVIRONMENTAL PRO-TION AGENCY REGION IV 345 COURTLAND STREET N.E. JUL 3 o 1992 4WO-NSRB CERTIFIED MAIL RETURN RECEIPT REQUESTED Shannon Craig Beazer East, Inc. 436 Seventh Avenue AT~ANTA. GEORGIA 30365 Pittsburgh, Pennsylvania 15219 Re: Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina Dear Ms. Craig: Final review of the Baseline Risk Assessment for the Koppers (Morrisville) NPL Site has been completed. Most of the Agency's comments have been adequately addressed. However, there are items that still must be modified in the final document before the Agency can approve the Baseline Risk Assessment. These items are enclosed as page 2, and must be incorporated into the final report. Final copies of the report must be submitted to me no later that August 7, 1992. Three copies of the entire report are required. Three copies of "change out pages" are also required. Two copies of the final report should be submitted to the State of North Carolina, as required by the Administrative Order. Please contact me at regarding this letter. 404/347-7791 if you have any questions I look forward to the revised document. Sincerely, / .{!~~~::fo Remedial Project Manager Waste Management Division Enclosure cc: Curt Fehn, EPA Cathy Winokur, EPA-ORC Elmer Akin, EPA Rebecca Fox, EPA Susan Allen, ENSR Pat DeRosa, NCDEHNR ,/ Bruce Nicholson, NCDEHNR Peggy Medlin, CWEP 1 1 • Baseline Risk Assessment Koppers Company Site Morrisville, North Carolina July 30, 1992 Page 2 • 1. Section G.2.3.5, Paragraph 1, Last Sentence. Add the phrase "for commercial/ industrial use" after " ... constituent concentrations may not exceed RBTCLs ... ". 2. Sections G.4.1.1 and G.5.1. The comparison of the maximum concentration of PCP in surface soil in ~..rea C with RBTCLs is still incorrect. The discussion in these two sections states that the maximum PCP soil concentration exceeds the RBTCL at the lE-05 level. However, the maximum surface soil concentration ( 3200 ppm) also exceeds the RBTCL at the lE-04 (3000 ppm). The text must be corrected to reflect this information. 3 The deletion that was requestedin the last sentence of comment 1 in the letter to Shannon Craig of July 14, 1992, was not done. EPA requires that the text be edited so that the sentence referenced remove the following " ... which is also at the extreme lower end of the range cf possible concern defined by EPA." . .,<.~s'i,,t;:,~ : ,j/,:T·" ~1: . 1 '1ft'11~.}"',;,i · ~ t-d .\ 11'/J/~' . ~:·,,;;;;;~ State of North Carolina • Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary MEMORANDUM To: Dr. Ken Rudo July 7, 1992 Environmental Epidemiology Section From: Bruce Nicholson,~ Superfund Section Subj: Transmittal of Revised Risk Assessment Koppers Company NPL Site Morrisville, Wake County William L. Meyer Director Attached, please find a copy of the Revised Risk Assessment for the Koppers Company NPL Site in Morrisville, Wake County. As we discussed today, there may be issues you posed in your previous .review regarding cleanup levels which may not have been adequately addressed in this version. I will be contacting you in the future if I need further clarification. If you have any additional concerns, please contact me at 733-2801. bin/mem/kopraee2 Attachment cc: Jack Butler ✓..-~:w.~-~ ~~~;"_;·:_1_:i:\ ~.,,: 5. •S: ~ ,'6 ·,-~ 8 , --~ ,, 'i' J>:,<-.. -•., . . "'-:::.::-. • • State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary MEMORANDUM To: Dr. Ken Rudo July 7, 1992 Environmental Epidemiology Section From: Bruce Nicholson,~ Superfund Section Subj: Transmittal of Revised Risk Assessment Koppers Company NPL Site Morrisville, Wake County William L. Meyer Director Attached, please find a copy of the Revised Risk Assessment for the Koppers Company NPL Site in Morrisville, Wake County. As we discussed today, there may be issues you posed in your previous review regarding cleanup levels which may not have been adequately addressed in this version. I will be contacting you in the future if I need further clarification. If you have any additional concerns, please contact me at 733-2801. bin/mem/kopraee2 Attachment cc: Jack Butler l • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY JUN 2 9 1992 . , ' i I 4WD-NSRB I Shannon Craig Beazer East, Inc. 436 Seventh Avenue REGION IV 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 Pittsburgh, Pennsylvania 15219 Re: Koppers Company Superfund Site . Morrisville, North Carolina -· Dear Ms. Craig: Nf«;[ij~~U:» JUL 13 1992 tl,· SUPERFaruo SECTcoo Please·. note the following regarding ENSR's response to EPA's· comments on the · Baseline Risk Assessment and·· as per our phone conversation of 6/29/92. The Baseline Risk Assessment uses the quotient method to assess the ecological risks to representative species serving as measurement endpoints. The quotient method compares the c.oncentration of a contaminant found on the site to a benchmark value. This ratio determines the potential estimate of the ecological risk associated with that contaminant ; in· that medium. · The_ key to this method is the b_enchmark value. EPA has proposed draft aquatic criteria valu'es for the protection of wildlife·--· of o;oos5 . parts per .quadriilion . for ,2;3;1,8-tetrachlorodibenzo-p-dioxin ( 2, 3 ;7, 8-~CDD) .: in ·· :the ,Great. •Lakes · ·Init.iative program. . --using this value· in ·the ecological --::·risk assessment would lead to different conclusions and should change the need for additional remedial action and the decision concerning the necessity of ecological .risk-based target clean-up goals ( RBTCLs) for surface water and sediments. The Baseline Risk Assessment must be changed accordingly. Please contact me if you have any questions concerning this letter. I can be reached at 404/347-7791 or. facsimile 404/347-1695. /'' ·-·. Sinc.erely 1},'/ · · (~~~ta~/ ,: ()/j/v(_yi. , haf~a H. Benoy . Remedial Project Manager [/ Waste Management Division cc: C. · Fehn, NSRB E •. Akin, WMD L. ·wellman, WMD C. Winokur, ORC "-.._ S. Allen, ENSR "iii. Nicholson, NCDEHNR P. DeRosa, NCDEHNR Printed on Recycf<.'a P.1p&: • UNITED STA.TES EfiVIRONMENTAL PROT!::CTION AGENCY REGION JV , 345 COURTLAf;O STREET. N.E. ATLANTA. GEORGi.A 30365 • i 'JUN 2 9 1992 4WD-NSRB Shannon Craig Beazer East, Inc. 436 Seventh Avenue Pittsburgh, Pennsylvania 15219 Re: Koppers Company Superfund Site Morrisville, North Carolina Dear Ms. Craig: RfCElVtU JUL 13 1992 SUPERRINDS£CTION The Agency is reviewing ENSR's responses to EPA's comments on the Baseline Risk Assessment. Please note that all comments regarding the Reassessment of dioxin •and the potential outcome must be deleted from the document. An example of the language to be removed is "However, use of alternative scientifically appropriate and defensible CSFs would decrease the estimated potential upper- bound cancer risks to below or very near lE-04, which falls at the higher end of the EPA's target risk range forSuperfund sites." Please contact me at 404/347-7791 if you have any questions regarding this letter. Sincerely, I {~,yjy{,{cL~ ··:6,.L-L~j .. 'Barbara H. Benoy Remedial Project Manager (J Waste Management Division Enclosure cc: Curt Fehn, EPA Cathy Winokur, EPA-ORC Rebecca Fox, EPA Bruce Nicholson, NCDEHNR v John Mitsak, Keystone Bill Giarla, Beazer Susan Allen, ENSR Printed 011 R,JC}'Cfc,1 .0.1,ce: • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 4WD-NSRB June 8, 1992 Shannon Craig Beazer East, Inc. 436 Seventh Avenue 345 COURTLAND STREET. N.E ATLANTA. GEORGiA 30365 Pittsburgh, Pennsylvania 15219 Re: Koppers Company Superfund Site Morrisville, North Carolina Dear Ms. Craig: RECEIVED JUN 29 1992. SUPERfUND S[C110N Comments from the State of North Carolina on the Draft Baseline Risk Assessment are enclosed. The revised Report is due to the Agency no later than July 5, 1992 as was identified on the June 4, 1992 EPA correspondence. The tentative project meeting date of June 25, 1992 is acceptable. All responses must be received in writing no less than two full working days before the meeting, or June 23, A.M., 1992. Please contact me at 404/347-7791 if you have any questions regarding this letter. Sincerely, ~• Qr1.11.1~:y D~,7( Remedial Project Manager Waste Management Division Enclosure cc: Curt Fehn, EPA Cathy Winokur, EPA-ORC Rebecca Fox, EPA Lee Thomas, EPA Lee Crosby, NCDEHNR Bruce Nicholson, NCDEHNR....,.. Bob Krasko, Dynamac v John Mitsak, Keystone Bill Giarla, Beazer James G. Martin, Governor William W. Cobey, Jr., Secretary Ms. Barbara Benoy U.S. EPA Region IV April 16, 1992 North Sites Remedial Branch 345 Courtland Street, N.E. Atlanta, GA 30365 Re: Comments on the Risk Assessment Koppers Company NPL Site Morrisville, Wake County, NC Dear Ms. Benoy: • William L. Meyer Director Attached, please find the comments of the NC Environmental Epidemiology Section on the Risk Assessment for the Koppers Company NPL Site. In addition to the attached comments, the NC Superfund Section would like to offer the following comments: 1. Page 4-11, Section 4.3.2. Inhalation factors are based on PM10 concentrations from monitoring stations in Raleigh and Durham. However, the Koppers site is still active and there are dirt roads and unvegetated cleared areas on the site. Therefore, fugitive emissions from wind blown dusts and road traffic could make local particulate levels much higher than at the ambient monitoring stations. Therefore, the Superfund Section would like to see an analysis of fugitive dust emissions from wind· and road travel to compare with the PM10 approach. Fugitive emission estimates should be generated by following EPA's protocol set forth in the Compilation of Air Pollutant Emission Factors, EPA Publication No. AP-42. 2. Pages G-20 and G-22. on page G-20 the Risk Assessment states that the hazard quotient for the muskrat is 0.1 which is in the range of "possible concern". On Page G-22, concerning the muskrat evaluation, it states that because the estimated exposure to all constituents results in a hazard quotient considered to be of "no concern", no RBTCL's were calculated for the muskrat. These two statements are inconsistent; please revise. Ms. Barbara Benoy April 20, 1992 Page 2 • The NC Super fund Section appreciates this opportunity to provide these comments, and we look forward to continued cooperation on this site. If you have any questions concerning these comments, please contact me at (919)733-2801. bin\let\benra2 attachment cc: Jack Butler Pat DeRosa Ken Rudo ~ly1/JJL_ Bruce Nicholson Chemical Engineer Superfund Section • State of North Carolina Department of E.nvironment. Health, and Natural Resources Division of Eplciemlology P.O. Box 27687 • R.lletgh, North Carolina 27611•7687 James G. Martin, Governor William W. Cobey, Jr., Secretary J. N. Maccormack, M.D., M.r.H. MEMORANDUM TO! FROM: SUBJECT: Lee Crosby, Chief Superfund se·ction April 16, 1992 Kenneth Rudo, Ph.D., Toxicolpgist !'.-tnR. Environmental Epidemiology Section Review of Revised Riek Assessment Koppers Company, Inc. NPL Site Morrisville, Wake County Director As a fallow-up to my March 2, 1992 comments on the above risk assessment document, and after reviewing the revised document, I would like to offer the following observations. (1) The Environmental Epidemiology Section (EES) recommends that the use of average constituent concentrations for determining remediation levels not be utilized, If' any specific areas exceed the cleanup goal, then there is a need for remediation and basing it on maximum levels should i.mprove overall health protection at this site in the future. (2) EES recomnende that risk values for carcinogens be based on 10-6 risk values not 10-4 or 10-• levels which are the suggested values in the risk doCUlllent. (3) The proposed PCP soil cleanup value recommended in the document is well above a ea!e level needed to adequately protect human health. The use of a degradation factor for PCP appeare to be, far the moat part, simply a mechanism for a less stringent soil remediation level. The approach used to derive the proposed and revised degradation factors appear to be vague, lacking concise site-specific data necessary to utilize degradation as an assumptive factor in a risk assessment. EES strongly recOJrnnende that degradation rates not be utilized in the derivation of RBTC~a for PCP at this site. An f.qual Opportuni:y Afflrm.,nve A(llon Employer Lee Crosby, Chief • Page 2 April 16, 1992 • r hope these c.omments and recommendations are helpful and if you have any further questions, please feel free to contact ~eat (919) 733-3410, KR:td cc: Pat Derosa Bruce Nicholson Dr, John Freeman ... 4WD-NSRB June 4, 1992 • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 345 couRTLAN□ STREET NE .,~ ...... ~(E~v,0 ATLANTA GEORGIA 30365 / / (;;. JUi'J 2 1992 :,! {~ ,'Ji \"'0-.'. // \~ .. /;"·'/ Shannon Craig ~~~r•' Beazer East, Inc. 436 Seventh Avenue Pittsburgh, Pennsylvania 15219 ~lE(CIE~VlED Re: Koppers Company Superfund Site Morrisvil J e, North Carc,lina Dear Ms. Craig: JUN 1 R 1992 SUPERFUND SECTION The Draft Baseline Risk Assessment (in part) was received and has been review~d. Comments are enclosed. The revised RI Report will be due tq,the Agency no later than July 5, 1992. The Report must be submitted in its entirety. I would like to encourage a meeting to discuss response to comments prior to the due date. Please contact me at 404/347-7791 if you have any questions regarding this letter. Sincerely, CI c--,, - Bar~:ra i_ H:. \ Benoy Remedial Project Manager Waste Management Division Enclosure cc: Cnrt Fehn, EPA Cathy Winokur, EPA-ORC Rebecca Fox, EPA Lee Thomas, EPA "Lee Crosby, NCDEHNR Bruce Nicholson, NCDEHNR Bob Kraska, Dynamac John Mitsak, Keystone Bill Giarla, Beazer Printed on Recycled Paper .. EPA Comments to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 2 GENERAL COMMENTS • 1. EPA has stated its position on the use of degradation to adjust exposure point concentrations several times. However, there still seems to be some misunderstanding. This position will be reiterated this position a final time. Degradation is site-specific and it is difficult to predict the degradation rate of a chemical without site-specific data. Unless site-specific data is presented from which a site-specific half-life can be predicted.-the risk assessment should be based on the actual site concentrations. The alternate risk calculations may be presented in an appendix and discussed in the uncertainty section. If the decision is made to present the degradation calculations in an appendix, the exposure concentration should be based on the revised half-life of one year for phenolics which is discussed in the remediation goal section. The use of degradation to determine risk-based target clean-up levels (RBTCLs) is unacceptable for the same reasons stated above, . Degradation was used to calculate RBTCLs in the previous remediation goal document, although it was not mentioned in the text and in fact the preparers of the document had to be convinced that degradation had actually been used. Rather than recalculate the RBTCLs without using the degradation factors, as EPA requested, the revised document now admits. t.hat degradation was used and the RBTCLs are calculated incorporating degradation. As with the risk assessment, the effect of degradation on the RBTCLs are calculated incorporating degradation,. As with the risk assessment, the effect of degradation on the RBTCLs can be discusEeG in the uncertainty section. A final point is the reality check of the half-life. The document states that, using a half-life of one year, a current concentration of 385 mg/kg would correspond to a concentration in 1975 of 3992 mg/kg. The EPA can not reproduce this estimated original concentration. Calculations indicate that, in this time span with the one year half-life, the original concentration would be greater than a million/ppm, i.e. an unattainable concentration greater that pure product. This does not support the literature half-life information. Please discuss the rate decay calculation in greater detail in the written responses to these comments. 2. Another major issue concerns the use of average • • EPA Comments to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 3 3. concentrations to determine remediation requirements,. The risk assessment staff has stated several times that if the risk assessment indicates that there is a need for remediation, any location at the site which exceeds the cleanup goal, should be remediated. Al though this revision of the RBTCL document does compare the maximum along with the mean and RME concentrations with the RBTCLs, the summary discussion is based on using average concentration,. On the other hand, Section 9.0 in the BRA (Summary of the RBTCL Appendix) compares the maximum concentrations with remediation levels, indicating the intent to remediate any area which exceeds the remediation goal. Apparently, the purpose of .the discussion in the RBTCL appendix is to establish a precedent rather than to affect the remediation outcome for this site. Corrections should be made to align all document remedial discussion with the stated Agency requirements. The term local resident should individual from resident is confusing. The local offsite be identified as such to distinguish this the future onsite resident. 4. It was agreed in previous responses to Agency comments that qualifiers such as highly or greatly. in regard to the uncertainties associated with the BRA, will be removed from the text. Although most of these qualifiers have been removed, some still remain and should also be removed. S. A final general comment concerns the presence of phenolics in offsite groundwater. Although previous sampling indic,.!ted that 2, 4, 6-trichlorophenol was present above health b;;sed levels in several of the offsite wells, the results of the confinuational sampling indicated that the wells have nondetectable levels of this contaminant. We recommend that additional confirmations sampling be performed, in the Remedial Design (RD) phase, to verify this and that the ROD specify that groundwater remediation of the offsite area will be contingent on the results of the RD sampling. SPECIFIC COMMENTS 1. 2. Page ES-7, Paragraph 5 The discussion concerning the toxicity of dioxin is inappropriate considering our current understanding of the dioxin reevaluation study. (See attached journal article.) The dioxin discussion should be revised here are throughout the document. Page 2-5, Page 2 -It is not appropriate to discuss the risk ;: • • EPA Comments to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 4 3. 4. 5. 6 . 7. 8. 9 assessment conclusions about the chemicals which will require remediation in the Hazard Identification Section. Technically, the risks have not been evaluated at this point in the process. Page 2-44, Table 2-12 /Offsite Groundwater -It is unclear if the data summary in this table is for all offsite wells or for the near offsite wells that we agreed should be used in the risk assessment. Please clarify. Page 4-11, Section 4.3.3 and Table 4-4 and Appendix C-3 -The January 1992 version of the Dermal Exposure Assessment Report contains updated PC values which would impact the exposure intakes for several of the site contaminants of concern. These chemicals and the revised PC values are: 2-Nitrophenol - 5. 0E-3 cm/hr and 2, 4-Dimethylphenol -1. 5E-2 cm/hr. These PC values are consistent with information presented in Appendix C-3 of the Koppers BRA. A final point concerns the PC values for 2, 3, 5, 6-tetrachlorophenol and isopropyl ether. As I commented previously, the PC values of 1.5E-3 represents a default value for water. The text in Appendix C-3 should be corrected to reflect this information. Page 4-16, Paragraph 1 -It is not clear how the adjustment of the child's soil ingestion rate incorporates both the positive and negative standard deviation discussed in the text. Please clarify. Page 4-47, Table 4-6 -The reference for this table appears to be incorrect,. The reference cited is for ecological assessment guidance rather than for human health exposur,-1. Pages 5-6 -5-8 -Comparing the. risk levels to 10-5 does not give much information. True the risks associated with exposure to surface soils in Areas Band C do exceed 10-s, but Area Bis 1.3E-5 while Area C is 2E-2. This discussion should be more specific. Also why is the discussion centered around 10-5? The summary should discuss pathways which produce risks which either exceed or are within the 10-• to 10-• risk range. Page 5-9, Paragraph 1 -Would the His have been below unity if degradation had not been used? Page 5-9, Paragraph 2 The statement that the risks associated with undegraded PCP would increase more than two times is an understatement. The risks would increase approximately 100 times. The discussion should more accurately reflect this information. • EPA Comments to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 5 • 10. Page 5-9. Paragraph 3 -The last sentence in this paragraph is misleading. The information should be included that the risk for the onsite resident for PCP exposure would increase from 3E-6 to 3e-4. 11. Page 5-20, Table 5-4 -This table indicates that the HI estimated for ingestion of 2,4-dichlorophenol in Eastern Area onsite groundwater exceeds unity. The risk summary discussion should include this information. 12. Page 7-4, Last paragraph This discussion should bP. clarified. Although, technically all dioxins and furans are converted to TEFs, only the 2,3,7,8 congeners have an impact since all other congeners are considered to have a relative potency of zero. 13. Page 7-5, Paragraph 4 -The argument is made that the level of respirable particles is probably overestimated because this information is based on PM10 levels measured at the Raleigh- Durham monitoring site and the Koppers site is mainly vegetated or covered with pavement. A discussion of the degree of ground cover at the monitoring site would make this discussion more meaningful. Please expand. 14. Page 7-8. Paragraph 1 -This discussion is misleading. The HI ,exceeds unity for one chemical. ( See Comment 10) . The breakdown for endpoints is not needed because one chemical is responsible for the HI exceeding unity. If this were not the case, it would not be the decision of the preparers of the BRA to decide that the onsite ingestion of groundwater is unlikely and therefore to not carry the analysis to completion. The discussion should be modified to reflect this information. 15. Page 9-4, Paragraph 3 -The statement that the RBTCLs for PCP are less than the subchronic protf!ctive co11centrations is not true for all scenarios and risk levels. In fact, Table 9-2 contains the subchronic concentration as the commercial/industrial human health RBTCL. 16. Page 9-5, Paragraph 1 -Discuss the concentration which was developed for protection of acute effects resulting from exposure to PCDD/PCDF. This discussion should include the toxicity value used to develop the protective concentration level. 17. Page 9-6, Section 9. 2, Paragraph 4 -The last complete sentence in this paragraph should indicate that the cleanup levels referred to are for the protection of groundwater. 18. Page 9-7, Paragraph 3 - A discussion of PCDD/PCDF in • • • EPA Comments to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 6 subsurface soils should be included in this paragraph. 19. Page 9-8, Paragraph 3 -It appears that the document preparers have decided that the appropriate soil RBTCL remediation risk level should not be 10-5 • This decision concerning the appropriate remediation risk levels will be made by the Agency. 20. Page 9-8, Paragraph 5 -There is not enough PCDD/PCDF data to make the statement that remediation of PCP will also satisfact.orily remediate for PCDD/PCDF. 21. Page 9-12, Table 9-2 -This table should include PCDD/PCDF data for subsurface soil. 22. · Section 7.1.2.2, Paragraph 2 -The conclusory statement that "current study criteria are almost certain to lead to substantial overestmation of potential assumed cancer risks in humans" should be changed to read: " .. current study criteria may lead to overestimation of ... ". 23. Section 9.2 -There is an inadequate discussion of ARARs, and ARAR based cleanup requirements. At the least, some discussion of the North Carolina MCL for 2-chlorophenol, and a calculation of derived remedial levels must be included, as this is an applicable and relevant standard. Appendix G Comments - 1. 2. 3. 4. 5. General Comment -Previous comments on degradation, average versus maximum concentration, remediation risk level and subchronic remediation levels also apply to this appendix. page G-9 r applies if Therefore, l:'aragraph 3 -The "pick-up level" concept only the average concentration is used for remediation. this is not applicable to the Koppers RBTCLs. Page G-18. Paragraph 1 -Class II groundwater must be remediated to residential consumption protection levels regardless of site use. Page G-24. Paragraph 4 -The statement that all sediment concentrations were below RBTCLs is not true for the 10-• level of risk for residential exposure to the Fire Pond sediment for the RME and maximum concentration levels. Page G-26, Paragraph 2 -The lowest RBTCL for PCDD/PCDF in surface soil is lE-5 (lo-• risk level), not lE-4 as stated in the text. .. • EPA Comments to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 7 6. 7. 8. 9. page G-27. Section G. 4. 3 -The off site groundwater RBTCLs should be based on the future residential consumption of groundwater. Page G-27, Section G.4.3.1, Paragraph 2 -The MCL for TCDD has not been promulgated. It is proposed at this time and should be identified as a proposed MCL. Page G-29, Section G.5.1 -The sediment from Fire Pond should be j_dentified as a media possibly requiring remediation. Pages G-30and G-31, Section G.5.2 -As previous comments indicate, the Agency is not in agreement with several of the assumptions used to develop and interpret the RBTCLs. The risk management decisions made in this section will be made by the Agency. This section must be deleted. • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 4WD-NSRB June 4, 1992 Shannon Craig Beazer East, Inc. 436 Seventh Avenue 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 Pittsburgh, Pennsylvania 15219 Re: Koppers Company Superfund Site Morrisville, North Carolina Dear Ms. Craig: The Draft Baseline Risk Assessment (in part) was received and has been reviewed. Comments are enclosed. The revised RI Report will be due to the Agency no later than July 5, 1992. The Report must be submitted in its entirety. I would like to encourage a meeting to discuss response to comments prior to the due date. Please contact me at 404/347-7791 if you have any questions regarding this letter. Sincerely, c/ ~-I/-,,, Bar~:ra ~Hi.\ Benoy Remedial Project Manager Waste Management Division Enclosure cc: Curt Fehn, EPA Cathy Winokur, EPA-ORC Rebecca Fox, EPA Lee Thomas, EPA Lee Crosby, NCDEHNR Bruce Nicholson, NCDEHNR Bob Kraska, Dynamac John Mitsak, Keystone Bill Giarla, Beazer Printed on Recycled Paper • EPA Comments to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 2 GENERAL COMMENTS • 1. EPA has stated its position on the use of degradation to adjust exposure point concentrations several times. However, there still seems to be some misunderstanding. This position will be reiterated this position a final time. Degradation is site-specific and it is difficult to predict the degradation rate of a chemical without site-specific data. Unless site-specific data is presented from which a site-specific half-life can be predicted, the risk assessment should be based on the actual site concentrations. The alternate risk calculations may be presented in an appendix and discussed in the uncertainty section. If the decision is made to present the degradation calculations in an appendix, the exposure concentration should be based on the revised half-life of one year for phenolics which is discussed in the remediation goal section. The use of degradation to determine risk-based target clean-up levels (RBTCLs) is unacceptable for the same reasons stated above, . Degradation was used to calculate RBTCLs in the previous remediation goal document, although it was not mentioned in the text and in fact the preparers of the document had to be convinced that degradation had actually been used. Rather than recalculate the RBTCLs without using the degradation factors, as EPA requested, the revised document now admits that degradation was used and the RBTCLs are calculated incorporating degradation. As with the risk assessment, the effect of degradation on the RBTCLs are calculated incorporating degradation,. As with the risk assessment, the effect of degradation on the RBTCLs can be discussed in the uncertainty section. A final point is the reality check of the half-life. The document states that, using a half-life of one year, a current concentration of 385 mg/kg would correspond to a concentration in 1975 of 3992 mg/kg. The EPA can not reproduce this estimated original concentration. Calculations indicate that, in this time span with the one year half-life, the original concentration would be greater than a million/ppm, i.e. an unattainable concentration greater that pure product. This does not support the literature half-life information. Please discuss the rate decay calculation in greater detail in the written responses to these comments. 2. Another major issue concerns the use of average • • • EPA Comments to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 3 3. concentrations to determine remediation requirements,. The risk assessment staff has stated several times that if the risk assessment indicates that there is a need for remediation, any location at the site which exceeds the cleanup goal, should be remediated. Al though this revision of the RBTCL document does compare the maximum along with the mean and RME concentrations with the RBTCLs, the summary discussion is based on using average concentration,. On the other hand, Section 9.0 in the BRA (Summary of the RBTCL Appendix) compares the maximum concentrations with remediation levels, indicating the intent to remediate any area which exceeds the remediation goal. Apparently, the purpose of the discussion in the RBTCL appendix is to establish a precedent rather than to affect the remediation outcome for this site. Corrections should be made to align all document remedial discussion with the stated Agency requirements. The term local resident should individual from resident is confusing. The local offsite be identified as such to distinguish this the future onsite resident. 4. It was agreed in previous responses to Agency comments that qualifiers such as highly or greatly, in regard to the uncertainties associated with the BRA, will be removed from the text. Although most of these qualifiers have been removed, some still remain and should also be removed. 5. A final general comment concerns the presence of phenolics in offsite groundwater. Although previous sampling indicated that 2,4,6-trichlorophenol was present above health based levels in several of the offsite wells, the results of the confirmational sampling indicated that the wells have nondetectable levels of this contaminant. We recommend that additional confirmations sampling be performed, in the Remedial Design (RD) phase, to verify this and that the ROD specify that groundwater remediation of the offsite area will be contingent on the results of the RD sampling. SPECIFIC COMMENTS 1. 2. Page ES-7, Paragraph 5 The discussion concerning the toxicity of dioxin is inappropriate considering our current understanding of the dioxin reevaluation study. ( See attached journal article.) The dioxin discussion should be revised here are throughout the document. Page 2-5. Page 2 -It is not appropriate to discuss the risk • EPA Comments to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 4 • assessment conclusions about the chemicals which will require remediation in the Hazard Identification Section. Technically, the risks have not been evaluated at this point in the process. 3. Page 2-44, Table 2-12 /Offsite Groundwater -It is unclear if the data summary in this table is for all offsite wells or for the near offsite wells that we agreed should be used in the risk assessment. Please clarify. 4. Page 4-11, Section 4.3.3 and Table 4-4 and Appendix C-3 -The January 1992 version of the Dermal Exposure Assessment Report contains updated PC values which would impact the exposure intakes for several of the site contaminants of concern. These chemicals and the revised PC values are: 2-Nitrophenol - 5. 0E-3 cm/hr and 2, 4-Dimethylphenol -1. 5E-2 cm/hr. These PC values are consistent with information presented in Appendix C-3 of the Koppers BRA. A final point concerns the PC values for 2, 3, 5, 6-tetrachlorophenol and isopropyl ether. As I commented previously, the PC values of 1.5E-3 represents a default value for water. The text in Appendix C-3 should be corrected to reflect this information. 5. Page 4-16, Paragraph 1 -It is not clear how the adjustment of the child's soil ingestion rate incorporates both the positive and negative standard deviation discussed in the text. Please clarify. 6. Page 4-47. Table 4-6 -The reference for this table appears to be incorrect,. The reference cited is for ecological assessment guidance rather than for human health exposure. 7. Pages 5-6 -5-8 -Comparing the risk levels to 10-5 does not give much information. True the risks associated with exposure to surface soils in Areas Band C do exceed 10-', but Area Bis 1.3E-5 while Area C is 2E-2. This discussion should be more specific. Also why is the discussion centered around 10-5 ? The summary should discuss pathways which produce risks which either exceed or are within the 10-• to 10-• risk range. 8. Page 5-9, Paragraph 1 -Would the His have been below unity if degradation had not been used? 9 Page 5-9, Paragraph 2 The statement that the risks associated with undegraded PCP would increase more than two times is an understatement. The risks would increase approximately 100 times. The discussion should more accurately reflect this information. • EPA Comments to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 5 • 10. Page 5-9. Paragraph 3 -The last sentence in this paragraph is misleading. The information should be included that the risk for the onsite resident for PCP exposure would increase from 3E-6 to 3e-4. 11. Page 5-20. Table 5-4 -This table indicates that the HI estimated for ingestion of 2,4-dichlorophenol in Eastern Area onsite groundwater exceeds unity. The risk summary discussion should include this information. 12. Page 7-4, Last paragraph This discussion should be clarified. Although, technically all dioxins and furans are converted to TEFs, only the 2,3,7,8 congeners have an impact since all other congeners are considered to have a relative potency of zero. 13. Page 7-5. Paragraph 4 -The argument is made that the level of respirable particles is probably overestimated because this information is based on PM10 levels measured at the Raleigh- Durham monitoring site and the Koppers site is mainly vegetated or covered with pavement. A discussion of the degree of ground cover at the monitoring site would make this discussion more meaningful. Please expand. 14. Page 7-8, Paragraph 1 -This discussion is misleading. The HI exceeds unity for one chemical. ( See Comment 10) • The breakdown for endpoints is not needed because one chemical is responsible for the HI exceeding unity. If this were not the case, it would not be the decision of the preparers of the BRA to decide that the onsite ingestion of groundwater is unlikely and therefore to not carry the analysis to completion. The discussion should be modified to reflect this information. 15. Page 9-4, Paragraph 3 -The statement that the RBTCLs for PCP are less than the subchronic protective concentrations is not true for all scenarios and risk levels. In fact, Table 9-2 contains the subchronic. concentration as the commercial/industrial human health RBTCL. 16. Page 9-5, Paragraph 1 -Discuss the concentration which was developed for protection of acute effects resulting from exposure to PCDD/PCDF. This discussion should include the toxicity value used to develop the protective concentration level. 17. Page 9-6, Section 9. 2, Paragraph 4 -The last complete sentence in this paragraph should indicate that the cleanup levels referred to are for the protection of groundwater. 18. Page 9-7, Paragraph 3 A discussion of PCDD/PCDF in • • EPA Comments to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 6 subsurface soils should be included in this paragraph. 19. Page 9-8. Paragraph 3 -It appears that the document preparers have decided that the appropriate soil RBTCL remediation risk level should not be 10-5 • This decision concerning the appropriate remediation risk levels will be made by the Agency. 20. Page 9-8, Paragraph 5 -There is not enough PCDD/PCDF data to make the statement that remediation of PCP will also satisfactorily remediate for_PCDD/PCDF. 21. Page 9-12. Table 9-2 -This table should include PCDD/PCDF data for subsurface soil. 22. Section 7.1.2.2. Paragraph 2 -The conclusory statement that "current study criteria are almost certain to lead to substantial overestmation of potential assumed cancer risks in humans" should be changed to read: " .. current study criteria may lead to overestimation of ... " . · 23. Section 9.2 -There is an inadequate discussion of ARARs, and ARAR based cleanup requirements. At the least, some discussion of the North Carolina MCL for 2-chlorophenol, and a calculation of derived remedial levels must be included, as this is an applicable and relevant standard. Appendix G Comments - 1. 2. 3. 4. 5. General Comment -Previous comments on degradation, average versus maximum concentration, remediation risk level and subchronic remediation levels also apply to this appendix. Page G-9. applies if Therefore, Paragraph 3 -The "pick-up level" concept only the average concentration is used for remediation. this is not applicable to the Koppers RBTCLs. Page G-18, Paragraph 1 -Class II groundwater must be remediated to residential consumption protection levels regardless of site use. Page G-24. Paragraph 4 -The statement that all sediment concentrations were below RBTCLs is not true for the 10-• level of risk for residential exposure to the Fire Pond sediment for the RME and maximum concentration levels. Page G-26. Paragraph 2 -The lowest RBTCL for PCDD/PCDF in surface soil is lE-5 (lo-• risk level), not lE-4 as stated in the text. • EPA Conunents to Baseline Risk Assessment Koppers Company Superfund Site Morrisville, North Carolina June 4, 1992 Page 7 • 6. page G-27, Section G.4.3 -The offsite groundwater RBTCLs should be based on the future residential consumption of groundwater. 7. Page G-27, Section G.4.3.1, Paragraph 2 -The MCL for TCDD has not been promulgated. It is proposed at this time and should be identified as a proposed MCL. 8. Page G-29, Section G.5.1 -The sediment from Fire Pond should be identified as a media possibly requiring remediation. 9. Pages G-30and G-31. Section G.5.2 -As previous conunents indicate, the Agency is not in agreement with several of the assumptions used to develop and interpret the RBTCLs. The risk management decisions made in this section will be made by the Agency. This section must be deleted. • • WEGEIVt.U MAY 11 1992 BEAZER EAST, INC., 436 SEVENTH AVENUE. PITTSBURGH, PA I 5219 USA Dear Ms. Benoy: FEDERAL EXPRESS May 5, 1992 Ms. Barbara Benoy U. S. Environmental Protection Agency Region IV 345 Courtland street, N.E. Atlanta, GA 30308 SUPERRIWDSiCTION RE: Baseline Risk Assessment for the former Koppers Company, Inc. Site in Morrisville, North Carolina Pursuant to our conversation earlier this week, this letter acknowledges our agreement to revise the Baseline Risk Assessment to remove the assumption of degradation from the body of the report. As we discussed, we will include a discussion of the potential impact of degradation of the assumed risks and clean-up levels estimated for the Site in the Uncertainty Section (Section 7.0) and in the Appendix to the report. Your initial request to remove all references to degradation of pentachloro- phenol from the body of the Baseline Risk Assessment came to us in a letter dated March 30, 1992. As you are aware, we submitted the second draft of the body of the Baseline Risk Assessment report (plus Appendices) to EPA on March 19, 1992. The revised clean-up levels evaluation was submitted to EPA on March 31, 1992 as Section 9 and Appendix G to the Baseline Risk Assessment. Notification to remove degradation from the reports was received too late for the incorporation into either submittal. The issue of degradation was also discussed with you, additional EPA representatives, and representatives from the State, at our meeting on March 4, 1992. No decision regarding use of degradation was reached at that meeting. At the March 4, 1992 meeting, it was agreed that ENSR would submit a table in the March 19, 1992 submittal showing the estimated risks assocfated with potential exposure to Area C surface soils assuming degraded concentrations of pentachlorophenol and dioxin as well as estimated risks assuming non-degraded concentrations. ENSR submitted a table as part of the body of the revised Baseline Risk Assessment (Table 5-19) that compared assumed risks from exposure to pentachlorophenol and dioxin for all relevant media assuming degraded and non-degraded concentrations of these constitu- ents. We also agreed at the March 4, 1992 meeting that ENSR would reevaluate the degradation rates used for pentachlorophenol and submit the results of this reevaluation in the March 31, 1992 submittal. Upon review of additional literature materials, ENSR edited the clean-up levels Sections to the Baseline Risk Assessment report to reflect a more conservative degradation rate for pentachlorophenol in various media. • Ms. Barbara Benoy May 5, 1992 Page 2 Although we stand by our position that the use of degradation rates is scientifically appropriate and defensible, and supported by EPA guidance, we will honor your request to remove degradation from the body of the Baseline Risk Assessment report. We would, however, like the opportunity to confirm the degradation of pentachlorophenol during the Remedial Design, should we so choose. In your letter dated March 30, 1992, you state that 'if degradation is allowed in a risk assessment document, it should be based on site-specific data ... ( and) ... actual field observation/confirmation must be presented". Thus, we request acknowledgement in the ROD that, if degradation rates are confirmed during the Remedial Design, clean-up levels will be modified as appropriate. If you are in agreement with this request to conduct confirmational studies on the degradation of pentachlorophenol during the Remedial Design, we will prepare a Workplan to perform these activities. Upon EPA approval of this proposed Workplan, we will commence the degradation study. We also request that all additional comments on the second draft of the Baseline Risk Assessment report be forwarded to us as soon as possible so that, as we revised the report to remove degradation, we can address any additional comments at the same time. Early notification of additional comments will help facilitate our resubmittal of the draft Baseline Risk Assessment to the agency. SKC/dkm cc: W. Giarla, BEI J. Mitsak, KER S. Allen, ENSR C. Fehn, EPA C. Winokur, EPA E. Aiken, EPA B. Fox,_EPA_ L-P~DeRosa, NCDEHNR L. Crosby, NCDEHNR R. Kraska, Dynamac Sincerely, _/ / . y1,A--,.,_,,_,..,,, 0, (,,__ '-<~r' I/ Shannon K. Craig' Program Manager -Environmental Group ' ; • /.,.:: S'\AT[ ,., .f...,~· ,. .. ,.,.,,, ~ !wi.r: ! "-~" l_s ~'11~,., "." ~ ~'6 ·\,d 't .. -B .l,J ·. ~ ~--· .... :~ State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary Ms. Barbara Benoy U.S. EPA Region IV April 16, 1992 North Sites Remedial Branch 345 Courtland Street, N.E. Atlanta, GA 30365 Re: Comments on the Risk Assessment Koppers Company NPL site Morrisville, Wake County, NC Dear Ms. Benoy: William L. Meyer Director Attached, please find the comments of the NC Environmental Epidemiology Section on the Risk Assessment for the Koppers Company NPL Site. In addition to the attached comments, the NC superfund Section would like to offer the following comments: 1. Page 4-11, Section 4.3.2. Inhalation factors are based on PM10 concentrations from monitoring stations in Raleigh and Durham. However, the Koppers site is still active and there are dirt roads and unvegetated cleared areas on the site. Therefore, fugitive emissions from wind blown dusts and road traffic could make local particulate levels much higher than at the ambient monitoring stations. Therefore, the Super fund Section would like to see an analysis of fugitive dust emissions from wind and road travel to compare with the PM1 o approach. Fugitive emission estimates should be generated by following EPA's protocol set forth in the Compilation of Air Pollutant Emission Factors, EPA Publication No. AP-42. 2. Pages G-20 and G-22. On page G-20 the Risk Assessment states that the hazard quotient for the muskrat is 0.1 which is in the range of "possible concern". On Page G-22, concerning the _muskrat evaluation, it states that because the estimated exposure to all constituents results in a hazard quotient considered to be of "no concern", no RBTCL's were calculated for the muskrat. These two statements are inconsistent; please revise. • Ms. Barbara Benoy April 20, 1992 Page 2 The NC Super fund Section appreciates this opportunity to provide these comments, and we look forward to continued cooperation on this site. If you have any questions concerning these comments, please contact me at (919)733-2801. bin\let\benra2 attachment cc: Jack Butler Pat DeRosa Ken Rudo :Cy~ Bruce Nicholson Chemical Engineer Superfund Section • State of North Carolina Department of Environment. Health, and Natural Resources Division of E.pldemlology l'.O. Bo>< 27687 • Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr .. Secretary J. N. Maccormack, M.D., M.l'.H. MEMORANDUM TO: FROM: SUBJECT: Lea Crosby, Chief Superfund Section April 16, 1992 Kenneth Rudo, Ph.D., Toxicologist t'.-ll1R. Environmental Epidemiology section Review of Revised Risk Aaaessment Koppers Company, Inc. NPL Site Morrisville, Wake County Director As a follow-up to my March 2, 1992 comments on the above risk assessment document, and after reviewing the revised document, I would like ta offer the following observations. (1) The Environmental Epidemiology Section {EES) recommends that the use of average constituent: concentrations for determining remediation levels not be utilized, If any specific areas exceed the cleanup goal, then there is a need for remediation and basing it on maximum levels should improve overall health protection at this site in the future. (2) EES recommends that risk values for carcinogens be based on 10-6 risk values not 10-4 or 10-• levels which are the suggested values in the risk document. (3) The proposed PCP soil cleanup value recommended in the document is well above a safe level needed to adequately protect human health. The use of a degradation factor for PCP appears to be, for the most part, simply a mechanism for a less stringent soil remediation level. The approach used to derive the proposed and revised degradation factors appear to be vague, lacking concise site-specific data necessary to utilize degradation as an assumptive factor in a risk assessment. EES strongly recommends that degradation rates not be utilized in the derivation of RETCLs for PCP at this site. An EquaJ Opportunity Afflrn1.1tlve A(tlon Employer ' Lee Crosby, Chief • Page 2 · April 16, 1992 I hope these comments and recommendations are helpful and if you have any further questions, please feel free to contact me at ( 919) 733-3410. · KR:td cc: Pat Derosa Bruce Nicholson Dr, John Freeman • • State of North Carolina Department of Environment. Health, and Natural Resources Divi5ion of Epidemiology P.O. Box 27687 o Raleigh, North Carolina 1.7611-7687 James G. Martin, Governor William W. Cobey, Jr., Secreta,y J. N. Maccormack, M.D., M.r.H. MEMORANDUM TO: FROM: SUBJECT: Lee Crosby, Chief Superfund Section April 16, 1992 Kenneth Rudo, Ph.D., Toxicologistl'.,tl'lf/.. Environmental Epidemiology Section Review of Revised Risk Aaaessmont Koppers Compnny, Inc. NPL Site Morrisville, Wake County Director As a follow-up to my March 2, 1992 comments on the above risk assessment document, and after reviewing the revised document, I would like to offer the following observations. (l) The Environmental Epidemiology Section (EES) recommends that the use of average constituent concentrations for determining remedintion levels not be utilized. If any specific areas exceed the cleanup goal, then there 1s a need for remediation and basing .l.t on maximu.m levels should improve overall health protection at this site in the future. (2) EES recommends that risk values for carcinogens be based on 10-6 risk values not 10-4 or 10-• levels which are the suggested values in the risk document. (3) The proposed PCP soil cleanup value recommended in the document is well above a safe level needed to adequately pi:-otect human health, The use of a degradation factor for PCP appaara to be, for the most part, simply B mechanism for a less stringent soil remediation level. The approach used to derive the pi:-oposed and revised degradation factors appear to be vague, lacking concise site-specific data necessary to utilize degradation as nn assumptive factor in a risk assessment. EES strongly recommends that degradation rates not be utilized in the derivation of RBTCLs for PCP at this site. An Equ,ll Opportunity Affirmative Action Employer ZO'd zoo·□N TT:£1 Z6'9T Jdij 5556-£Zl-6T6-T:731 'Id3 'dinN31dNH3Q Lee Crosby, Chief Page 2 April 16, 1992 • ! hope these comments and recommendations are helpful and if you have any further questions, pleaae feel free to contact me at (919) 733-3410. KR:td cc: Pat Derosa Bruce Nicholson Dr. John Freeman 5556-££l-6t6-T:731 "Id3 "dinN31dNH3Q • '!'AX TRANSMITl'I\L DATE: TO: FAX NUMl3ER: FROM: Env~-~·onll\Gntal Epidemiology Section !'· 0. Box 2708? -----·--·- _Haleiq.rl.J N. c. 27611 .!_'HOMl1_: 919-7 3'.J_-J41Q ·' !!UMBER OF PkGES INCL!Jl2_ING COVER SHF,lcT: ,_...; -·-··--.. -·-·---· TO'd coo·oN.OT:£T c6'9T Jdi:J ' 5SS6-££l-6T6-T:73l 'Id3 'dI0N3idNH3□ • State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary April 1, 1992 MEMORANDUM TO: THROUGH: FROM: RE: John Freeman, D.V.M., M.P.H., Chief Environmental Epidemiology Section Bill Meyer, Director )A( ____.-/' Mike Kelly, Deputy Director~~ Division of Solid Waste Management Lee Crosby, Chief /l c__._.-, Superfund Section A Request for Comments Revised Draft Baseline Risk Assessment, March 1992 Chapter 9, Appendix G Koppers Company, Inc. NPL Site Morrisville, Wake County William L. Meyer Director Enclosed is a copy of the Revised Cleanup Levels Sections (Chapter 9 and Appendix G) of the Revised Draft Baseline Risk Assessment, March 1992, for the Koppers Company, Inc. site in North Carolina. These chapters, prepared by ENSR Consulting and Engineering for Beazer East, Inc., conclude the Draft Baseline Risk Assessment document which was mailed to you on March 25. Please include this document in your review and .provide comments as necessary. The US EPA has requested that comments be submitted to them through the Superfund Section by April 17, 1992. If you have any questions concerning this matter, please contact Pat DeRosa or me at 733-2801. LC/acr Enclosure An u:iuaJ Opportunity Affirmative Action Employer • State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary April 1, 1992 MEMORANDUM TO: THROUGH: FROM: RE: John Freeman, D.V.M., M.P.H., Chief Environmental Epidemiology Section Bill Meyer, Director IA/ --------- Mike Kelly, Deputy Director~~ Division of Solid Waste Management Lee Crosby, Chief /J (.__./ Superfund Section/- Request for Comments Revised Draft.Baseline Risk Assessment, March 1992 Chapter 9, Appendix G Koppers Company, Inc. NPL Site Morrisville, Wake County William L. Meyer Director Enclosed is a copy of the Revised Cleanup Levels Sections (Chapter 9 and Appendix G) of the Revised Draft Baseline Risk Assessment, March 1992, for the Koppers Company, Inc. site in North Carolina. These chapters, prepared by ENSR Consulting and Engineering for Beazer East, Inc., conclude the Draft Baseline Risk Assessment document which was mailed to you on March 25. Please include this document in _your review and provide comments as necessary. The US EPA has requested that comments be submitted to them through the Superfund Section by April 17, 1992. If you have any questions concerning this matter, please contact Pat DeRosa or me . at 733-2801. LC/acr Enclosure An Equal Opporrunity Affirmative Action Employer • • • State of North Carolina Department of Environment, Health, and Natural Resources Division of Eplciernlology l'.O. Box 27687 • Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary J. N. Maccormack, M.D., M.P.H. Director MEMORANDUM TO: FROM: SUBJECT: Lea Crosby, Chief Superfund Section April 16, 1992 Kenneth Rudo, Ph.D., Toxicologist t'.-~R Environmental Epidemiology Section Review of Revised Risk Assessment Koppers Company, Inc. NPL Site Morrisville, Walce County As a follow-up to my March 2, 1992 comments on the above risk assessment document, and after reviewing the revised document, I would like to offer the following observations. (1) The Environmental Epidemiology Section (EES) recommends that the use of average constituent concentrations for determining remediation levels not be utilized. If any specific areas exceed the cleanup goal, then there 1s a need far remediation and basing it on maximum levels should improve overall health protection at this site in the future. (2) EES recommends that risk values for carcinogens be based on 10-6 risk values not 10-4 or 10-• levels which are the suggested values in the risk document. (3) The proposed PCP soil cleanup value recommended in the document is well above a safe level needed to·adequately protect human health. The use of a degradation factor for PCP appears to be, for the most part, simply a mechanism for a less stringent soil remediation level. The approach used to derive the proposed and revised degradation factors appear to be vague, lacking concise site-specific data necessary to utilize degradation as an assumptive factor in a risk assessment. EES strongly recommends that degradation rates not be utilized in the derivation of RBTCLs for PCP at this site. An Equ.~ Opportunity Affirmative A,tlon Employer Lee Crosby, Chief Page 2 April 16, 1992 • • ! hope these comments and recommendationa are helpful and if you have any further questions, please feel free to contact me at (919) 733-3410. KR:td cc: Pat Derosa Bruce Nicholson Dr, John Freeman United States Department of the Interior Ms. Barbara H. Benoy FISH AND WILDLIFE SER\~CE Raleigh Field Office Post Office Box 33726 Raleigh, North Carolina 27636-3726 April 10, 1992 North Carolina Remedial Section North Superfund Remedial Branch U.S. Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, Georgia 30365 Dear Ms. Benoy: A~(J'/'', 0· • TAKE-• PRIDEIN AMERKA As requested in your March 16, letter, the U.S. Fish and Wildlife Ser,ice (Service) has reviewed the Draft Revised Remedial Investigation Report (Draft Revised RI) for the former Koppers Ccmpany, Incorporated Site in Morrisville, Wake County, North Carolina. We also reviewed the Draft Baseline Risk Assessment (Draft BRA) which was provided for review on March 25, 1992 by Keystone Environmental Resources. Comments in this letter are intended to assist your investigations, assessments, and the planning process being conducted pursuant to Section 104(a) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (42 U.S.C. 9601 et seq.). These planning aid comments are being provided on a technical assistance basis only and do not represent any position that the U.S. Department of the Interior (Department) may adopt concerning possible injury to natural resources under the Department's trusteeship. It appears that the Draft Revised RI and Draft BRA were.completed prior to U.S. EPA's receipt of our March 12, 1992 report on earlier site documents (Draft Clean-up Levels Report and Draft Public Health and Environmental Assessment). Consequently, the concerns expressed in that letter have not been addressed in the revised documents; major issues identified in the Service's March 12, review include the following. o The ecological risk assessment for the belted kingfisher, particularly Section 6.5.1.2 (Avian Dose-Response Values), should be revised after review of available toxicological literature concerning sensitive avian species and sensitive endpoints. Until such revisions are complete, statements such as" •.. · conservative assumptions applied in the mammalian and avian evaluations are likely to result in an overestimate of the potential for adverse effect ... • (page 7-10 of the Draft BRA) are inappropriate. o Fish tissue and sediment dioxin and furan residues should be further. evaluated. The Draft BRA should expand the discussion on significance of sediment contamination (Section 6.4.2, Exposure Evaluation), particularly the extent to which contaminated sediments influence water and fish tissue dioxin concentrations. Such an evaluation and discussion will help provide a rationale, other than that based.on human health concerns, for the appropriate course of remediation, if necessary. Sediment and surface water bioassays are recommended. o There is a lack of data for dioxins and furans in the western drainage ditch and associated wetlands. Thank you for the opportunity to review the Draft Revised Remedial Investigation Report and Draft Baseline Risk Assessment. If you have any questions regarding Service comments on the former Koppers Company, Inc. site, please contact Tom Augspurger of this office. Sincerely yours, . LlcrJ1..~~ L.K. Hike Gantt Field Supervisor • --<,;. S(AT[;;;-. .---,, ·••"""• ~-. /~' .r:· -: '."t_ ?s."'- i.:; ;µli\\SJ,j ~\ \_,s '::,I\~§/ --~•.::f~::;~Jl • State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary March 25, 1992 MEMORANDUM TO: THROUGH: FROM: RE: John Freeman, D.V.M., M.P.H., Chief Environmental Epidemiology Section Bill Meyer, Director / , , \ 1 /. _ Mike Kelly, Deputy Directok\J~ Division of Solid Waste Management Lee Crosby, Chief }u Superfund Section if' Request for Comments Revised Draft Baseline Risk Assessment, March 1992 Koppers Company, Inc. NPL Site Morrisville, Wake County William L. Meyer Director Enclosed is a copy of the Revised Draft Baseline Risk Assessment, March 1992, for the Koppers Company, Inc. site in North Carolina. This revised draft, prepared by ENSR Consulting and Engineering for Beazer East, Inc., represents a comprehensive, multi- pathway human health and ecological assessment for the areas investigated in the Remedial Investigation. Please review this document and provide comments as necessary. The US EPA has requested that comments be submitted to them through the Superfund Section by April 17, 1992. If you have any questions concerning this matter, please contact Pat DeRosa or me at 733-2801. LC/acr Enclosure An Equal Opportunity Affirmative Action Employer •• oo~r TAKI-• Cnited States Department of the lnterior PRIDElN AMERICA FISH AND WILDLIFE SERv1CE Raleigh Field Office Post Office Box 33726 Raleigh, North Carolina 27636-3726 March 12, 1992 Ms. Barbara H. Benoy North Carolina Remedial Section Nor...h Superfund Remedial Branch U.S. Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, Georgia 30365 Dear Hs. Benoy, ·--• a FILE COPY As requested in your February 19, 1992, letter, the U.S. Fish and Wildlife Service (Service) has reviewed the Draft Derivation of Clean-up L<c!vels Report for the former Koppers Company, Incorporated Site in Morrisville, Wake County, North Carolina. Comments in this letter are intended to assist your investigations, assessments, and the planning process being conducted pursuant to Section 104(a) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (42 U.S.C.,9601 et seq.). These planning aid comments are being provided on a ~echnical assistance basis only and do not represent any position that the U.S. Department of the.Interior (Department) may adopt concerning possible injury to natural resources under the Department's trusteeship. As Tom Augspurger of this office related to you via telephone last week, the ecological portion of the Draft Clean-up Levels report did not contain sufficient information to evaluate ecological risks. The report presented results of an ecological risk assessment performed previously without data, particularly model parameters, on the components of that risk assessment. Therefore, we referred to the original discussion of ecological risks in the May 1991 draft Public Health and Environmental Assessment (Draft PHEA) for the site. The Service believes values and assumptions in the Draft PHEA's risk assessment for the belted kingfisher are not adequately supported. As a particular example, Section 6.5.1.2 (Avian Dose-Response Values) cites only one study to support a 1,000 pg dioxin/ g egg No Observed Adverse Effects Level (NOAEL) used as the basis for the model. Verrett (1970; as cited in Kubiak et al. , 1989) reported that 10 to 20 pg / g of 2, 3, 7, 8'- tetrachlorodibenzo-p-dioxin in chicken eggs produced embryotoxicity, edema,. and deformities. Dose-related increases in cardiovascular malformations of chick embryos were reported by Cheung et al. (1981; as cited in Kubiak et al., 1989), observing a 20 percent increase in malformations at a dosing level of 6 pg/ g and a doubling of malformations at 65 pg/ g. While the studies cited here are by no means an exhaustive review of the literature, they indicate that an avian NOAEL for dioxins of 1,000 pg/ g is potentially in error by two to three orders of magnitude. _,:.. i.7i~ac:..s .:'er,.:.ce :Jf ::.l11.s t.·/pe .Ji er::-:)..r Jn =:i.3;,: assessmenr. ·;ncC:-=2. .:;ut:;.:1c. ::.r:: ::.c•,:.·.:t.:.s. :-<::c0mme~.ds a mer: r,.:tust. ec'.:r~i:~:..ca:.. ::.sk assi::s:s:n.e!1~ :'.::: ::cr.Ct.:.c::..:d . :;1.ssessmen-c. sh cul d full ·1 investigat~ t.!1e ~o:-:i.c~lcgi~3..!. l.2. :.:r3.:.:...1== availa.bl-: c::ncerning sensi ~i ·1e av:.an specii:s ar .. c: -:£feet..:::. ;rc11ide :Cd:.. :.:sna.i ..caticnalc for assum[::ti•;ns in t..'1.e model (,:. •;., us-: 0£ a.~11::!:'3.ge .E.::..3h ,:ii0:-:i:1 c-:ncent.=3.ti1Jns to rf:pr:sent dietar:.1 ex;osure, and use of cne-i1..3.lf :ts ::!-=: t'er-::entage of .:::,rage cbi:::i.ined fr::-m t:l.e E'i::e Pend;, anC -3.C.d:-~ss ::::::n.:::.J.eDt.:2: .:..t1 t.:14= ~el<2(:t.2:d ;:,a::-31Tlet2rz. The e:•:t.e:n:. t:::> ·.-1hi,:h ;ssumptj,::ns ar.d :1nc~..--·::.; :•"7""·: t.he f_:ar-:::..-:ie::.2r3 ::!:.:ct..:: mcdel out;ut shou:,: 3.2.sc ~E: disc':.lSSP.d. 2i.ni2.arl:', the :-:sul:.z cf fish tissui:: and s.::d::..:ner-.t dio:·:i.:.:. .md £;.lr~ ::-.=:s:..dues .shcu!.d :::e evaluat~d in relation to .3.vail.3.bla 2c:::t.:;:-:icclcg:,r ii t.2rat'..l:r:. :o.r.2. en a.ci~,i::-::-::e ,:ffc:ct.s l-:11-:ls of dio:~::..~s a..n.C. f-..1r-ans :.n [:tey 'J: ;;isc.:.·lcr:us ;nig::-;torf bizds shculd :Je· used to ~valuate t.:."le ::is}: to :.1.esi: -:r;ani:::ms ::i.t. ::·:t:: sit:e. •::..~.,. ,:cmt:ar<: di-=ta::::r J..:=v~l.s 0.f. dic-:ci.n shc.-m t.:J Lni::~i= ~)i2ci·1or:us cf .ma2:1s::..s and discussicn ;;culd ctL:.gmen-: t.!1e .ri3k asses::::nent mcde2. f::::-3..:,::_.=l! Lni;:ac:.s . . ~ ·,ncr-~ i:.::::mpreher1si11e risk assessment shculd r-esu.!.t. in a :ie!:ensi:.:l::: char3.ct.erization of t...~e t::otential risks f:-cm dioxin and fur,m i:ont.aminat.icn. Ther:: i3, hm·1e 1i~r, the mi:,tur~ of pheno li\:; com!_::cunds fer ·.1hicr' ... ;?er:.::..n2nt.. to:{.ici:.:,.: dat3. may not Ce available. Ther:£ore, the St:::rii•.:.:e rei:.2:-.J.t.:s t::1e need for sediment and surface wat:::r bioc.ssays prel,i,)usly =esonm1end.ed in t:'.e Depart.~ne=-it' s Oc~ol:er 20, 1989, Preliminar-1 Natu:-:tl Rescu:-::e:s Sur:E:Y ( c-:py ac.r:ached). Our r.;:view of available analytica_l chemistry data for t:10= site revealed a lack of sampling for dioxins and furans in palustrine forested wetlands in the southwestern comer of the site. Concern for this area also was expressed iri the Department's 1989 Preliminary Natural Resources Survey. Samples from this location analyzed for pentachlorophenol showed presence of site-related contaminants; thus, the entire suite of site-related contaminants should be evaluated at this location. \'le encourage the U.S. Environmental Protection Agency to address these data ne-eds so that future activities associated l'lith remedial actions at this site are based on an adequate information base 1·1ith respect to biological resources and contaminants. ..\., -~·~~::.::_.; activities at 'i:he former. t·,liiill,;,:·: questions regarding · · '., __ Lt), - Thank you for the opportunity Koppers C_cmpany, Incorporated Service comments on the Draft contact I-Ir. Augspurger. Attachment !..~ . ~. ]iif ~;it;ii{ to comment on remedial Site. If you Derivaticn of have any Clean-up Levels Report, please · ·:;\:. Sincerely yours/ ~ t;llaL . L.K .. I-like Gantt Field Supervisor ,. :-;;~~--... . . ; ·r: ~.-:.• :-·t.;;;;;:, : : ··-~.'\!?~:\ -~h;_ ~ ', :;~~~--. ~J,;.,, . _.. 2:!~~ . ... <: .. -9ATcc:., /,•· .. ,. .. , ~-' !:J;r, ,.~} [-aJ_-, 'if~--.. ;;. ~\ ,,:s -~·-·;'. ·\.-: >B b ·2,:1 : (;· ¼8J \'.·f(-' .,;: ,. :7 '-:,~".:::::.:·~ State of North Carolina • Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary Ms. Barbara Benoy NC/SC Site Management Unit Superfund Branch ' Waste Management Division 345 Courtland Street, NE Atlanta, GA 30365 October 28, 1991 Subject: Draft Public Health and Environmental Assessment Response to Comments Koppers Company, Inc. Site Morrisville, NC Dear Ms. Benoy: William L. Meyer Director The subject "Response to Comments" document submitted by ENSR Consulting and Engineering has been reviewed by Dr. Luanne Williams, Toxicologist, Superfund Section and Dr. Ken Rudo, Toxicologist, Environmental Epidemiologist Section, NC DEHNR. They have no additional comments at this time. We appreciate having the opportunity to review this document. If you have any questions, please feel free to contact me at (919) 733-2801. cc: Ken Rudo Luanne Williams File Sincerely, Pat DeRosa, Head CERCLA Branch Superfund Section An E.qual Opportunity Affirmative Action Employer r··::: S1ATc ~ ,,4,.,c,_~•·/'"'•~~ ;"' w.' ~~~, '.:5 \·{\ti'',:.<;. l:s ·;,'D,, : ~ ~J ~ '. . ~, ., ·-...... ,,., .,.,,..., ... ..,....,,.... ¼_. • State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary October 2, 1991 MEMORANDUM TO: THROUGH: FROM: RE: John Freeman, D.V.M. M.P.H., Chief Environmental.Epidemiology Section Bill Meyer, Director &I'\ Division of Solie! Waste Management Lee Crosby, Chief ;J(/ Superfund Section/'°' Response to Comments on the Draft Risk Assessment ' Koppers Company, Inc. NPL Site Morrisville, Wake County William L. Meyer Director Enclosed is a copy ENSR Consulting and Engineering's response to comments submitted by the US EPA regarding the Draft Risk Assessment for the Koppers Company, Inc. NPL site in Morrisville. Comments submitted by the State were incorporated into EPA's comments to the consultant. In order to ensure that the State concerns have been addressed, EPA has forwarded a copy of ENSR's comments to the Superfund Section. Please review these comments and determine whether any additional concerns remain unaddressed. If so, the US EPA has requested that follow-up comments be submitted to them through the Superfund Section by October 18, 1991. If you have any· questions regarding this matter please contact Luanne Williams, Toxicologist, or me at 733-2801. LC/kc Enclosure An Equal Opportunity Affirmative Acdon Employer ~1tO Sr_., ..:,,,. t-s ;,,"" ~ ~.) • ~»Ta~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ~I"," ,:P 1", PROi\.,:, 4WD-NSRB AUG 2 6 19'31 John C. Mitsak, P.E. Project Manager REGION IV 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 Keystone Environmental Resources, Inc. 8600 La Salle Road Suite 502, York Building Towson, Maryland 21204 Re: EPA's Comments on the Koppers Company Superfund Site Draft Baseline Risk Assessment Report (RA Report) Morrisville, N.C. Dear Mr. Mitsak: The Draft Baseline Risk Assessment Report (BRA) was received by the EPA on June 18, 1991. This Draft BRA Report is unapproved. The attachment is the EPA's comments on the Draft BRA Report. I have sent a copy of these comments to your client, Beazer Materials and Services. Initially, we expect a response to each of the EPA's comments which should be submitted in the form of a typed comment followed by the response. Once the responses to the EPA's comments are considered adequate, the comments should be incorporated into a final BRA. The final submittal date of the BRA will be determined once the EPA has received the responses. These responses to the BRA comments are due on September 9, 1991. As I have discussed with Shannon Craig from Beazer on the phone, a meeting will be held on September 11-12, 1991 at 9:00 am at the EPA with the technical staff involved to discuss the findings in the RI and the BRA. The revised schedule will also be determined during this meeting. Please contact me if you have any questions regarding these comments. I can be reache~~ 404/347-7791. r Sincerely, v~ Darcy D~ Remedial Project Manager Attachment cc: Robert Jourdan, EPA Curt Fehn, EPA Cathy Winokur,, ORC, EPA (Pat_DeRosa,,_NCDEHNif Rebecca Fox, EPA Printed on Recycled Paper • UNITED ST ATES ENVIRON MENTAL PROTECTION AGENCY REGION IV 4WD-NSRB AUG 2 6 1991 Shannon Craig Project Manager 345 COURTLAND STREET. N.E. ATLANTA, GEORGIA 30365 Beazer Materials and Services 436 Seventh Avenue Pittsburgh, PA 15219 Re: EPA's Comments on the Koppers Company Superfund Site Draft Baseline Risk Assessment Report (RA Report) Morrisville, N.C. Dear Ms. Craig: The Draft Baseline Risk Assessment Report (BRA) was received EPA on June 18, 1991. This Draft BRA Report is unapproved. attachment is the EPA's comments on the Draft BRA Report. I sent a copy of these comments to your consultant, Keystone Environmental. by the The have Initially, we expect a response to each of the EPA's comments which should be submitted in the form of a typed comment followed by the response. Once the responses to the EPA's comments are considered adequate, the comments should be incorporated into a final BRA. The final submittal date of the BRA will be determined once the EPA has received the responses. These responses to the BRA comments are due on September 9, 1991. As I have discussed with you on the phone, a meeting will be held on September 11-12, 1991 at 9:00 am at the EPA with the technical staff involved to discuss the findings in the RI and the BRA. The revised schedule will also be determined during this meeting. ( Please contact me if you have any questions regarding these comments. I can be reached at 404/347-7791. p,:; Darcy Duin Remedial Project Manager Attachment cc: Robert Jourdan, EPA Curt Fehn, EPA Cathy_Winokur., ORC, EPA (~at_DeRosa,-NCDEHNR~ Rebecca Fox, EPA Printed on Recycled Paper • GENERAL COMMENTS: The following comments are on the baseline risk assessment for the Koppers Superfund Site. Comments on the ecological assessment are also included in this attachment. The organization of this report made it difficult to digest and evaluate. The reader has to continuously flip back and forth between the body of the report, the appendices and the spreadsheets and also return to the RI for missing background information. The report needs to better characterize the exposure setting and to provide more information on the extent of contamination including location of groundwater plume, both on and offsite, and a delineation of the soil contamination. To facilitate the comprehension of the report, a sample calculation should be included in the body of the report for each scenario. Also, the report is incorrectly titled. The correct title is Baseline Risk Assessment (BRA). The preparers of this report editorialize throughout the document on the highly conservative nature of the EPA risk assessment process. There~ many uncertainties inherent in the risk assessment process and the intent of the process is, where these uncertainties occur, to err on the conservative side or to overestimate the risks. The Risk Assessment Guidance for Superfund (RAGS) requires that a section be included which assesses the uncertainties in the risk assessment. The editorializing arid qualifiers, such as highly conservative or greatly overestimates, should be removed from the text and an objective discussion of the uncertainties should be placed where it belongs in the uncertainty section. The document states that the contaminants of concern which were selected for the risk assessment were verbally approved by EPA. Decisions of this magnitude should be verified in writing. The EPA files for Koppers do not contain verification of this decision. However, even if this decision was confirmed in writing, EPA considers the BRA to be incomplete without data summary information for all of the data collected during the RI, including the 15% of the samples which were analyzed for TCL\TAL constituents. This data summary should include a presentation of the inorganic data along with background data for comparison purposes. Tpe Agency does not agree with the conclusion of the BRA which states that remediation is likely required for only onsite, groundwater under the Former Lagoon Area. Although this conclusion and the inputs which lead to this conclusion are discussed in many of the specific BRA comments which follow, a general discussion is provided here. Groundwater exceeds the proposed MCL for PCP and TCDD-TEFs in both the Former Lagoon Area and the Eastern Area. In addition, both PCP and TCDD-TEFs have been detected in offsite groundwater and PCP at -1- • • concentrations which exceed the proposed MCL. Also, a comparison of the surface and subsurface soil and sediment concentrations with the preliminary soil cleanup goals for leaching to groundwater, determined by the Ground Water Technology Support Unit (GWTSU), indicate that these cleanup goals will likely drive remediation of these media in many areas of the site. In addition, fish consumption may be a more important pattern of dioxin exposure than presented. (See specific comment below.) Additionally, many of the sections covered in Exhibit 9-1, page 9-4 of RAGS, for risk assessment were not included (i.e., a complete site history, description of waste, and geographic location relative to offsite areas of interest in Section 1.0; background sampling and sampling locations (including a map), and detailed sampling information in Section 2.0; specific information concerning exposure assessment such as soil type, hydrology, land use, relative location of populations, the exposure pathways in Section 4.0; ARARs that are specific for the site such as MCLs; a summary of the risk characterization that specifically defines the key site-related contaminants and exposure pathways, types of health risk of concern; level of confidence in the quantitative information, major factors driving risk, major factors contributing to uncertainty, exposed population characteristics, comparison with site-specific health studies; and a summary describing the chemicals of potential concern, exposure assessment, toxicity assessment, and risk characterization). The report should describe the surrounding area, for example: population, land use, geology, and all potential pathways.· Direction of surface water runoff and groundwater flow should be provided. The report should contain information concerning the source of potable water including the location of any private and municipal wells and surface water intakes that may be downgradient from the site. A map of well locations would be helpful. The summary should include a discussion of the risk characterization results. The summaries in the BRA were too general. The discussion should be more specific, providing a means of placing the numerical estimates of risk in the context of what is known and what is unknown about the site. At a minimum, the report should include the following as described in RAGS, Section 8.6.1: 1) a discussion of the contaminants and their concentrations; 2) a description of the cancers and· other health risks; 3) level of confidence in the quantitative toxicity information; 4) level of confidence in the exposure estimates; 5) magnitude of the cancer risks and noncancer hazard indices relative to the site remediation goals; 6) the major factors driving the site risks; 7) the major factors reducing the certainty in the results and the significance of the uncertainties; and 8) exposed population characteristics. ' -2- • • This document should also include a brief discussion of the leaching to groundwater of contaminants of concern from soils and sediments. SPECIFIC COMMENTS: 0 0 0 0 0 0 0 0 Page 1-2, Paragraph 1. The report repeatedly attacks EPA's risk assessment conservatism. The intent of the reasonable maximum exposure (RME) is to estimate a conservative exposure case (i.e., well above the average case) that is still within the range of possible exposures. Page 2-1, Paragraph 2. As I discussed previously, this section should present data summary tables of all of the data collected in the RI, including background data. Page 2-1 and 2-2, Paragraph 4 on Page 2-1. A figure should be included along with Table 2-1. The sample numbers presented in Table 1-1 are meaningless without a corresponding figure. This paragraph should also state which media were sampled for dioxins/furans and briefly discuss the method. Page 2-2, Paragraph 3. More detail should be provided concerning the offsite groundwater samples. How do these samples correlate with the private offsite wells which have been shown to be contaminated? Page 2-3, Paragraph 1. The offsite domestic well data should at least be discussed qualitatively as to how the concentrations compare with the offsite groundwater data which was collected in the RI. Section 2.2. A summary of the site data should be presented so that the reader of the BRA can evaluate the chemicals selected as contaminants of concern. Additionally, fish samples were analyzed for pentachloroanisole but this chemical is not discussed in the text or listed in the tables. Does this mean that this chemical was not detected in fish? Table 2-2. This table indicates that surface soils are not very well characterized, i.e. one sample in Area D and two samples in Area C. How were the sampling points determined? Table 2-4. Table 2-4 indicates that dioxins/furans were only analyzed for in the surface soils in Area Band the subsurface soils -3- • • in Areas Band C. The subsurface soils in Area C were positive for dioxins/furans in 13 of 13 samples and contained higher concentrations than the subsurface soils in Area B. This suggests the potential for surface soil contamination with these chemicals in Area C. This should be briefly discussed in the BRA along with the rationale for this sampling strategy. Also, how were surface soil exposure point concentrations determined for PCDDs/PCDFs in the areas other than Area B if no samples were collected. 0 Tables 2-11 and 2-12. 0 0 0 Pentachoroanisole should be included in the data summary for the fish fillet tables. Table 2-12. The text should briefly discuss the groundwater data and the sampling locations. What portion of the 45 samples represent downgradient samples? Samples which are not located within the groundwater plume should not be used to calculate the upper 95th persent confidence interval concentration. Also, as was mentioned in a previous comment, a discussion should be included which compares the domestic well data with the RI groundwater data. Page 2-6, Section 2.4. Sample location numbers are meaningless without a figure. As was stated in a previous comment, a figure(s) which depicts sampling locations should be included in the BRA. The second paragraph in this section makes a statement that phenolics are higher in offsite than onsite samples. This is true for all of the phenols with the exception of PCP which is quite a bit higher in the onsite samples. The text should be corrected to reflect this. Section 2.5. Contaminant degradation is generally not factored into risk considerations for site assessments in Region IV. When it is allowed, definitive data must exist to (1) show that the metabolites are nontoxic and (2) site conditions and data support the degradation assumptions of peer-reviewed published observations. For PCP, it is difficult to accept a 60 day half-life decay rate at this site since considerable products remain 16 years after its release. Dioxin has been found to be resistent to bioremediation technology. Its many family members that have toxic properties have not been studied. The less toxic higher chlorinated compounds may degrade to the more toxic tetra-chlorinated compounds. Therefore the Agency believes that there is insufficient support presented in this document to accept a reduced risk from product biodegradation at this site. The document must show risks from the pathways presented without any degradation factor for PCP and dioxins/furans. -4- 0 0 0 0 0 0 0 • • Pages 4-4 and 4-5, Ingestion of Groundwater Section. The arguement that the groundwater at the site would not likely be used as a source of drinking water because of poor quality does not appear to be valid. Many residents in the vicinity of the site were using the groundwater for drinking water until Bezer paid for the installation of city water lines because a groundwater plume from the site had contaminated the private wells. This discussion should be corrected to reflect this information. In addition, although the risk would be less for the consumption of offsite groundwater than for the consumption of onsite groundwater, this could be a potential future exposure pathway of an offsite resident and therefore add to the cumulative risk for that scenario. Page 4-6, Consumption of Vegetables Scenario. Future onsite residents could also be exposed by consumption of vegetables watered with onsite groundwater. Table 4-2. This table also needs to contain the dermal and oral absorption rates which were used to determine the absorption adjustment factors (AAFs). Section 4.4.1, Paragraph 1. From the information given, it appears that the Florence Leasing employees could also be exposed to surface soils. Additionally, this paragraph states that the highest concentrations of constituents were used to determine exposure point concentrations. This should be rephrased to say the reasonable maximum exposure concentrations were used rather than the highest concentrations. Page 4-11, Paragraph 1. The exposure frequency for swimming and wading of seven days a year is low for the southeastern US. The Region IV Supplemental Risk Assessment Guidance recommends an exposure frequency of 45 days per year for this exposure pathway. Page 4-12, Paragraph 1. The discussion of the study by Clausing should be clarified. The BRA states that Clausing reported a soil ingestion rate of 100 mg per day with a standard deviation of 67 mg per day. The report goes on to say that the E,PA- ingestion rate of 200 mg per day is four times the rate reported by Clausing. The study information presented does not support this statement. Page 4-13, Onsite Exposure Section, Paragraph 1. EPA considers the exposure frequency for the trespasser of twelve times a year to be low, especially when it is factored over four areas, i.e. the esposure frequency for -s- 0 0 0 0 0 0 • • each area is assumed to be four times a year. EPA requests that the exposure frequency be increased to twelve times a year for each area. Additionally, it is not valid to use institutional controls to eliminate exposure pathways or to influence exposure frequency in the BRA. The NCP states that "The role of the baseline risk assessment is to address the risk associated with a site in the absence of any remedial action or control, including institutional controls." Page 4-14, Paragraph 1. The inhalation rate discussion is misleading. An inhalation rate is used for light-to-moderate activity for the trespasser scenario and then the claim is made that this is conservative since it is unlikely that the trespasser will be involved in strenous activity. It is not being conservative to assume a moderate inhalation rate for an assumed moderate activity level. Page 4-14, Paragraph 2. The actual FI which was used for each area is .004 to account for the trespassing being distributed over four areas. However, EPA is requiring that the trespasser exposure frequency be increased to twelve days a year, in each area, in which case the FI term will be .016 as the text states. Page 4-14, Paragraph 3. The exposure frequency discussion, contained in the previous comment, for the trespasser ingestion pathway also applies to the trespasser dermal exposure pathway. Also, the security guard can not be used to justify lower exposure frequencies. Page 4-15, Fire Pond Scenario. EPA requests that a fishing scenario be included which would have the trespasser exposed to surface water and sediments while fishing for an exposure frequency of twelve times a year. Page 4-16, Paragraph 1. The fish consumption rate of two meals a year is low. A fish consumption rate of one meal a month or twelve times a year should be used for the fish consumption exposure route. Pages 4-16 and 4-17, Current Onsite Worker Section. The worker exposure frequency and duration specified in "Standard Default Exposure Factors, OSWER Directive 9285.6-03." are 250 days a year and 25 years respectively. The BRA should be amended to reflect this information. The text states that an FI term of .64 was used but an actual FI of .16 was used to account for the four areas of the site. The text should clarify this. -6- 0 0 0 0 0 0 0 0 • Page 4-18, Paragraphs 1 and 4. Another potential exposure pathway for the local resident is via consumption of contaminated offsite groundwater. This pathway should be added to the future local resident exposure scenario. Page 4-20, Paragraph 1. The future fish consumption rate should be the same as the rate discussed in the comment for Page 4-15. Page 4-22, Residential Site Use Section Due to the milder climate in the southeast, Region IV requests that the outdoor exposure for onsite residents be increased so that there is contact with the outdoor soil for at least one half of the days in the year. Page 4-23, Paragraph 3. Region IV Supplemental Guidance specifies 45 days per year for a swimming frequency in the Southeast. Page 4-23, Paragraph 4. The exposure frequency of onsite residents to ditch water and sediments is low. The frequency should be increased to twelve times a year. Page 4-24, Paragraph 2. The fish ingestion rate for onsite residents should be increased to twelve meals per year. Page 4-24, Paragraph 3. The aquifer at the site is classified as Class II and therefore is considered to be potable and should be remediated per the NCP and the Groundwater Protection Strategy. Additionally, as was discussed in a previous comment, residents in the vicinity of the site~ using private wells until Bezer paid for the city water lines to be extended due to site-related contaminants in the private wells. The discussion which states that the groundwater volume and quality are too poor to support private use should be modified to reflect this information. Page 5-3, Paragraph 2. This paragraph is suggesting that if the groundwater is not being currently consumed and may not be consumed in the future then it should not be remediated. This philosophy· is repeated throughout the BRA. The NCP states that" ••. groundwater is a valuable resource and should be protected and restored ••• ". Class I and II aquifers are considered to be potable usable groundwaters and it is the intent of Superfund to return usable groundwaters to their beneficial uses. This reasoning for not remediating groundwater is not valid and should should be removed from this document. -7- 0 0 0 0 0 0 0 0 • • Page 5-4, Section 5.2.1. This section will need to be rewritten to reflect the changes in the BRA requested by EPA. Additionally, I would like to briefly discuss the current status of dioxin within the agency. EPA believes that there is a need to reassess dioxin and related compounds. EPA's Office of Research and Development (ORD) is beginning a year long study to reevaluate exposures to dioxin and the potential health and environmental effects. However, in the interim, the Agency is using the current slope factor along with the toxicity equivalency approach. Page 5-5, Section 5.2.2. As mentioned previously, the future industrial scenario should include the future consumption of offsite groundwater by local residents. The risks associated with this pathway should be included with the cumulative risks discussed in this section. Pages 5-7 and 8-1, Section 5.3 and Section 8.0. As I discussed in my general comments, EPA does not agree with the conclusions of the risk assessment and specifically does not agree that the only area requiring remediation is groundwater in the lagoon area. These sections should be modified to reflect the review comments presented above. Page 5-8, Section 5.4. As discussed in a previous comment, EPA requests that the BRA be performed using the RI data with no degradation adjustment. Page 8-1, Section 8.1. This section states that the future consumption of groundwater exceeds the risk range in the Former Lagoon Area. The consumption of groundwater in the Eastern Area also exceeds the risk range. This should also be stated in this section. Page 8-2, Section 8.4. As stated previously, EPA does not agree with the conclusion of the BRA which states that remediation is only needed for groundwater under the Former Lagoon Area. Figure 8-1. This figure is irrevelant and should be deleted. Appendix C-1. Although the method used in _the BRA to adjust for absorption is equivalent to the method recommended in Appendix A of the Risk Assessment Guidance for Superfund (RAGS), the RAGS method of adjusting the toxicity value rather than the intake value is the preferred method. -8- 0 0 0 • • However, the method presented is acceptable but should be accompanied by a table which summarizes the oral and dermal absorption rates which were used to derive the absorption adjustment factors (AAFs). In addition, the discussion of the methyl-, chloro-and nitro-phenols should state the dermal and oral absorption rates which were used to derive an AAF of 0.1. Appendix C-3. The default value of 1.5 x 10-3 (cm/hr) is the permeability constant (PC) for water as was stated in the EPA correspondence (Koporec, 1991). It is unclear why the document assumes that it is the PC value for the two unrelated compounds, pregnenolene and progesterone. It is the current EPA policy to use the PC for water if other data is not available for a chemical. Table E-2. A brief discussion is needed to accompany this table which describes how the degradation factors were derived from the half-life information and the exposure duration. Appendix E-2. The reference which is cited in the section for outdoor soil contact (USEPA, 1989d) is not contained in the reference section for this section. Therefore, the exposure frequency can not be verified. However, the climate in the southeast allows for outdoor activities for a greater part of the year than the frequency which was used for residential exposure. Region IV requests that the exposure frequency be increased so that there is contact with the outdoor soil for at least one half of the days in a year. Also, what is the reference to PAH exposure concentration at the bottom of page E-17? PAHs are not a contaminant of concern at this site. ECOLOGICAL ASSESSMENT COMMENTS: Page# 6-3 6-3 Comment 6.17 Habitat Summary -A species should be chosen to represent the conifer forest, e.g. white-tailed deer, Odocoileus virginianus. 6.2 Receptor Characterization -The US Fish and Wildlife Service should be contacted for information concerning endangered and threatened species, in addition to the North Carolina Department of Wildlife Management. The USFWS office for this area is located in Raleigh, North Carolina, Telephone Number -919/856-4520. -9- 6-4 6-5 6-18 6-9 6-9 8-2 • • 6.2 Receptor Characterization -I recommend using Micropterus salmoides, largemouth bass, instead of, or in addition to, lepomis macrochirus, bluegill, as a representative fish species due to its higher trophic position. 6.2 Receptor characterization -Add Anas platyrhynchos, mallard duck, as an additional avian indicator species. Table 6-2 -Replace Freshwater Acute Criterion and Freshwater Chronic Criteria with EPA Region IV Screening Values for the indicated compounds listed in Appendix I (attached), and recompute Tables 6-2, 6-3, and 6-4. This may require additional changes to other sections pending the computation of the resulting Toxicity Quotients. Toxicity tests (both water and sediment) may be required to assist in the determination of effects. Terrestrial Assessment -The muskrat and belted kingfisher inhabit or feed in riparian habitats. I feel including the discussion of these species under the heading of "Terrestrial Assessment" is somewhat misleading. The treatment of the impact of this site on a species such as the white-tailed deer would be more appropriate for this heading. Dose-Response Evaluation -The unit of concern in ecological risk assessment is populations, or a higher category of organization (communities or ecosystems). Individuals are the focus of an ecological assessment only if they are members of an endangered or threatened species. The benefit of conducting individual exposure assessments exists only if the results may be extrapolated to provide an estimate of site effects on the indigenous populations, communities, and/or ecosystems. Summary and Conclusions. 8.3 Ecological Risks, PHEA Summary -The quotients must be recalculated before the information may be interpreted and conclusions can be drawn. -10- • • APPENDIX I Compound Acute Screening Criteria ug/1 Phenol 2-Chlorophenol 2,4-Dimethylphenol 2,4-Dichlorophenol 3-Methyl-4-Chlorophenol 2,4,6-Trichlorophenol 2,4-Dinitrophenol 4-Nitrophenol 2-Methyl-4,6-Dinitrophenol Pentachlorophenol 2,3,7,8-TCDD 1020 438 212 202 3 32 62 828 23 3.23 0.1 -11- Chronic Screening Criteria ug/1 256 43.8 21.2 20.2 0.3 3.2 6.2 82.8 2.3 2.10 0.00001 ,l,'.r1dv dr«Jf-l'/1£/f W/1'1M ti{ .S State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary MEMORANDUM TO: THROUGH: FROM: RE: 20 June 1991 John Freeman, D.V.M. M.P.H., Chief Environmental Epidemiology Section Bill Meyer, Directo~A/\ Division of Solid w·a~Man~gement Lee Crosby, Chief Superfund Section Risk Assessment Review Koppers Company, Inc. Site Morrisville, Wake County William L. Meyer Director Enclosed is a copy of the Draft Public Health and Environmental Assessment for the Koppers Company, Inc. site in North Carolina. This draft, prepared by ENSR Consulting and Engineering for Beazer East, Inc., represents a comprehensive, multi-pathway human health and ecological assessment for the areas investigated in the Remedial Investigation. Please review this document and provide comments as necessary. The US EPA has requested that comments be submitted to them through the Superfund Section by July 12, 1991. · If you have any questions concerning this matter, please contact Luanne Williams, Toxicologist, or me at 733-2801. LC/acr Enclosure • ENSR Consulting and Engineering MEMORANDUM TO: Pat DeRosa DATE: June 19, 1991 FROM: Susan Allen St-+'-FILE: memo12.ral RE: Beazer East, Inc. CC: W. Giarla. Beazer PHEA -Former Koppers Company, Inc. Site, Morrisville, NC One (additional) copy of the Public Health and Environmental Assessment (PHEA) for the Former Koppers Company, Inc. Site in Morrisville, NC, is enclosed. This document was prepared for EPA, Region IV on behalf of Beazer East, Inc. If you have any questions about this document, please do not hesitate to call. -t<t.t;t\\lED j Uil z d i·:l':ll S\WEQiU~U SEC110~ I ., • ,·~·.4_~_-".'.~,,;~~~-1/r. : ~ _y· i{ .,1 'ii? :;c// ,~l ~ '.-';t r;J/ ... ~,}/ '{ .. :,':.:~;:.·~~-/-\/ State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7G87 James G. Martin, Governor William W. Cobey, Jr., Secretary William L. Meyer Director Ms. Darcy Duin: NC/SC Site Management Unit Superfund Branch Waste Management Division 345 Courtland Street, NE Atlanta, GA 30365 July 19, 1991 Subject: Draft Public Health and Environmental Assessment Koppers Company, Inc. Site MonisviHe, NC Dear Ms. Duin: The subject Draft Public Health and Environmental Assessment (PHEA) Report has been reviewed by Dr. Luanne Williams, Toxicologist, Superfund Section and Dr. Ken Rudo, Toxicologist, Environmental Epidemiology Section, NC Department of Environment, Health, and Natural Resources. Their comments are attached for your review. Please note that based on the results of the Remedial Investigation and PHEA, both Dr. Williams and Dr. Rudo disagree with ENSR's summary statement that " ... remediation is likely required for only on-site groundwater under the former Lagoon area ... " Remediation of all environmental media exhibiting carcinogenic risks exceeding 1 x 10-6 should be considered. If you have any questions regarding the attached comments, please do not hesitate to contact me at (919) 733-2801. cc: Luanne Williams Ken Rudo Sincerely, . r~ Pat DeRosa, Head CERCLA Branch Superfund Section • State of North Carolina Department of Environment, Health, and Natural Resources Division of Epidemiology P.O. Box 27687 • Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr.. Secretary J. N. MacCormack, M.D., M.P.H. MEMORANDUM TO: FROM: SUBJECT: Pat DeRosa Superfund Section July 11, 1991 Kenneth Rudo, Ph.D. , Toxicologist \'.-111 (- Environmental Epidemiology Section Review of the Draft Public Health and Environmental Assessment for the Former Koppers Company Site, Morrisville, N.C. Director After reviewing the above document, I would like to offer several connnents and recommendations as requested by your Section. Eased on the calculations done by ENSR, they recommended reluctantly that the only remediation required would be the on-site groundwater under the former lagoon area. Despite what they stated (several hundred times) as overly conservative risk estimates based on overly conservative assumptions, I would disagree with their reconnnendations. The Environmental Epidemiology Section (EES) reconnnends that groundwater should be remediated to groundwater standards, subsurface and surface soil rernediated in area C to reduce pentachlorophenol concentrations and sediment from the two ponds remediated to remove all detectable traces of dioxins. In addition, the consumption of fish from the ponds should be discouraged. The following discussion will serve to explain the rationale for these recommendations. The contractor went to great lengths to explain the process in detail and to illustrate how the calculations were done. However, it was entirely unnecessary to repeatedly state how overly conservative each parameter and assumption used in the calculations were (the report probably would have been 10-20 pages shorter had they not qualified each discussion with these statements). Conservative assumptions are utilized to protect public health, and this includes sensitive populations and, unlikely but possible exposure scenarios. It was also unnecessary to compare their calculated risk values which are the result of non-voluntary, unacceptable exposures to the residents, and which have resulted in an extremely anxious and worried local population to An Eaual Opportunity Affirmarive Action E.molover ?at OeRosa ,age 2 J•Jly 11, 1991 • voluntary, occupational or other types of risk estimates. Several of the exposure assumptions would not be considered overly conservative in our view and should be made more conservative. One example would be soil ingestion rates by children. The contractor put forward levels that EES believes are low and not health protective. The scientific literature has reported a wide range of soil ingestion values, of which the contractor utilized the lower end of this range. Future site uses are uncertain and assumptions and statements by the contractor that they will not result in the use of groundwater or that exposures and specific risks will not exist cannot be said with absolute certainty and, therefore, any carcinogenic risks that exceed 1 X 10-6 based on current contamination levels in specific environmental media should result in the remediation of the specific media. Another consideration necessitating the use of conservative assumptions would be the mechanism of carcinogenicity. In theory, a single exposure to a carcinogen may lock in an initiating event in the cancer process. At this site, in the groundwater, soil, and in fish, carcinogens have been found, and while dioxins are widely thought to act as promoters of cancer, literature evidence also indicates that they may act as initiators. Until the dioxin debate is resolved, exposure to this family of compounds should be avoided where the risks exceed 1 X 10-6 and, therefore, EES recommends the remediation in areas where this applies. Although the contractor's viewpoints on the risk presented by dioxin exposure is in partial agreement with the assessment done by EES, the degree of risk still is not acceptable, especially in fish and in the sediments of the ponds where dioxin settles out, and from where the fish take it up from. To summarize, EES has stated, based on the sampling data and an evaluation of the contractor report, its disagreement with the contractor summary and recommendations. There are several areas, in addition to those discussed in ·this memo, where the contractor utilized assumptions and calculation parameters that EES believes could be more conservative. As a result, the recommendations put forward by EES would indicate a greater degree of site remediation than that suggested by the contractor.· If you have any further questions, or desire a more detailed response to the contractor report or statements made by EES, please feel free to contact me at 733-3410. KR:lp • 9 July -1991 MEMORANDUM TO: FROM: RE: · Pat DeRosa, Head CERCLA Branch Luanne K. Williams, Pharm.D.~IJ./ Environmental Toxicologist Inactive Sites Branch Draft Public Health and Environmental Assessment Review Beazer East, Inc. (Formerly Koppers Company, Inc. Site) NCD003200383 Morrisville, Wake County The Public Health and Environmental Assessment Draft for Beazer East, Inc. has been reviewed·and the following comments are provided: Paragraph /Tables Table 5-13 Table 5-14 Table 5-15 Comments It is stated on page 5-6 paragraph 1 that the majority of the potential carcinogenic risk for the hypothetical on-site residents (#1, #2, and #3) is associated with potential exposures to dioxin. It is also stated that if a more scientifically defensible carcinogenic slope factor (instead of using the US EPA slope factor) was determined for dioxin then there would not be any unacceptable carcinogenic risk to hypothetical on-site residents. However, the carcinogenic risk for the hypothetical on-site residents (#1, #2, and #3) (see above tables) is still greater than l.0E-6 without the consideration of the carcinogenic potential of dioxin. Therefore, remediation should be considered for the carcinogens present at the site. Tables 5-10, 5-11, 5-12, 5-13, 5-14, 5-15, 5-16, 5-17 Comments The tables above show the total carcinogenic risk for each scenario to be greater than the currently acceptable risk of 1.0E-6 (see highlighted tables enclosed). The risk assessment • report states· on page 5-7, paragraph 3, that if an alternative and a more scientific estimate of dioxin's carcinogenic potential was used, then only the hypothetical future use of on-site groundwater from the former Lagoon Area .as a potable water supply would result in a lifetime caricer risk above the US EPA's target risk range for Superfund sites. It is also stated on page 5-7, paragraph 4, that only limited remediation of groundwater is required at the site. Remediation of media other than groundwater should be considered because of the significant carcinogenic risk present at the site. The published and peer reviewed EPA slope factors should be used in determining the risk to· populations potentially exposed _at . Superfund sites until revised slope factors are published. LKW/acr • tn 8 TABLE 5-10 SUMMARY TABLE -LOCAL RESIDENT CURRENT SCENARIO -POTENTIAL CARCINOGENIC RISK. HUMAN HEALTH EVALUATION FORMER KOPPERS COMPANY INC. SITE. BEAZER EAST INC., MORRISVILLE, NC CONSTITUENT . PHENOL 2-CHLOROPHENOL 2-NITROPHENOL 2.4-DIMETHYLPHENOL 2.4-DICII LOROPHENOL 4-CHLORO-3-METHYLPHENOL 2.4.6-TRICHLOROPHENOL 2.4-D!NITROPHENOL 4-N!TROPHENOL 2,3.5.6-TETRACHLOROPHENOL 2-METHYL-4.6.-DINITROPHENOL PENTACl!LOROPHENOL ISOPROPYL ETHER TOTAL TCDD-TE TOTAL Notes: Total.:·.. :. r·r~/. Potcni.w iiiii:: SUrfll.~:SoiJ h~."A) NC NC NC NC NC NC 5.64E-13 NC NC NC NC NC NC NC 5.64E-13 NC -Not calculated: tox_icity standards not available. ND -Not detccled in any sample in this mediuml,area. File Nnm,: SUMCI.WKI 14-Jun-9 I Total'' .. :·:Ti~:;:_::_. Poia.ti.il R11,t I· : s·~t.r~.,~·~µ_. .. , Ard iJ : : .'.'' NC NC NC NC NC NC NC NC NC NC NC 9.27E-12 NC 9.72E--08 9. 72E--08 ., '·.· Total .· jr~k· · >s·uriili ·s6il ·. · : .. •• k~·c> NC,. NC NC NC NC NC 9.91E-13 NC NC NC NC 3.00E--09 NC NC 3.00E--09 . --Total·:.:·•: -!~:§~{.. PotcntW: Risk · :--::··Trespasser::·. · ·, Pritentia! Risk . Surf~~ yi~~~'r,Irigcstio~ & Surrad· sbil -1 :\::-'. Dermitl· COri~ct ·:1--~·J{:."">: .'.-\'-:""-> ·\=)iiilP~nd\, NC NC NC NC NC NC 1.56E-12 NC NC NC NC NC NC NC l.56E-12 ., ·.--.. ' .: NC NC ND NC NC ND NC ND NC NC ND 2.JIE--09 ND 6.63E--06 6.63E--06 ' . Trespgsscr Poti,ntW Risk ' .. -·Sediment Ingestion & Dermal Contact :i:::_":... Fire Pond NC NC NC NC ND ND NC ND NC ND NC 2.30E-11 ND l.21E--07 1.21E--07 • u, c'.., ,,. TABLE 5-10 (CONT'D) .. . . .. Tr~r Pof.cnliA.I RiSk .. ingest.1ciri oi Fish Fram CONSTITUENT Fiie Pond. PHENOL ' NC 2-CIILOROPHENOL NC 2-NITROPIIENOL NC 2,4-DIMETIIYLPllENOL . NC 2,4-DICHLOROPHENOL NC 4-CII LORO-3-METIIYLPH ENOL NC 2,4 ,6-TRICI I LOROPII ENOL NC 2.4-DINITROPHENOL NC 4-NITROPIIENOL NC 2,3,5,6-TETRACHLOROPIIENOL NC . 2-METHYL-4,6,-DINITROPIIENOL NC PENTACIILOROPHENOL ·' NC ISOPROPYL ETHER NC TOTAL TCDD-TE i.93E-05 '. .. .. TOTAL l.93E-05 Notes: NC -Not calc,ulatcd; to,;icity standards riot available. ND -Not' detected in any sample in this medium/area. File Name, SUMC I. WK I 14-Jun-91 Loci] RC&iderit Local RCSident Local Resident Local Resident Pot~t·i~ Risk Potential R.isk · P<>tcnti.! Risk Potcnu.,J Ruk Surrace Water Sediment Ingestion & · lncidentai In&cstio~ VeictAble [)~~mil t~rlt.aci Dcrm.al C_mltacl or G~~d waicr Consumption Wutcrn DitCh Discharge Strca~ From Fire Pond Off-site· Ai-C4 cOff-Silc Area GroundWalcr) ND NC . ND ND ND ND NC ND NC ND NC NC NC NC NC NC ND NC NC ND ND ND NC NC NC 2.BIE--09 NC NC NC NC 1.07E-08 ND ND ND NC NC ND NC NC ND ND ND NC 2.89E-08 1.96E-10 7.28E--09 NC ND ND ND 2.78E--09 I. ISE-06 4.42E-06 9.82E-I0 NC 3.75E-1 I I.IBE-06 4.42E-06 I.IIE-08 I .35E-08 U1 ~ • TABLE 5-10 (CONT'D) ~+~:·p~~iill~ . . · C:::lllik~ ·, d~6r:I-0ea1"R~-d~•fit;. CONSTITUENT c_Cu_~cnt·S_~i6-; . PIIENOL NC 2-Cf!LOROPIIENOL NC 2-NITROPHENOL NC 2,4-DIMETHYLPHENOL NC 2.4-DICIILOROPHENOL NC 4-CI I LOR0-3-M ETII YLPII ENOL NC 2,4,6-TRICIILOROPHENOL 2.81 E-Q9 2,4-DINITROPHENOL NC 4-NITROPIIENOL NC 2.3,5,6-TETRACHLOROPHENOL NC 2-METHYL-4,6,-DINITROPHENOL NC PENTACHLOROPHENOL 4.17E-08 ISOPROPYL ETHER NC TOTAL TCDD-TE 3.17E-05 . \:• .. . ' . ' ... TOTAL Ciisi-~ Ec-05· .. , Notes: NC -Not calculated; toxicity standards not ~vailablc. ND -Not det~ted in any Sllmple in this medium/area. File Name: SUMC I. WK I 14-Jun-9 I (Jl ~ • TABLES-II SUMMARY TABLE -ON-SITE WORKER CURRENT SCENARIO -POTENTIAL CARCINOGENIC RISK HUMAN HEALTH EVALUATION FORMER KOPPERS COMPANY INC. SITE BEAZER EAST INC., MORRJSVILLE, NC CONSTITUENT PIIENOL 2-CHLOROPHENOL 2-NITROPIIENOL 2,4-DIMETHYLPHENOL 2,4-DICIILOROPHENOL : 4-CIILORO-3-METHYLPHENOL 2,4,6-TRICHLOROPHENOL 2,4-DINITROPIIENOL 4-NITROPHENOL 2,3,5,6-TETRACIILOROPHENOL 2-METHYL-4,6,-DINITROPIIENOL PENTACIILOROPHENOL ISOPROPYL ETHER TOTAL TCDD-TE ,; . ' •• , ,!" TOTAL Noles: .·· Total Oii4Jtc V{0~~6{ _.d?iitci·Wci-~k~{ .• Potenu.1 RW<. . pci('~;W RJ.k SurfaCC Soil :.: stirf~~ Soil./ .... ArcaA··. •·• / ~a(. NC NC NC NC NC NC NC NC NC · NC NC · NC 4.08E-12 NC NC NC NC NC NC NC NC NC NC 6.70E-I I NC NC NC I.J0E-06 4.08E-12 I.J0E-06 NC -Not cakule.tcd; to~icity standards not av11ilable. ND -Not detected in any samples in this mediu_m/arca. File Nome: SUMC2.WKI 12-Jun-9 I ' · '• ToW .. -d~ti Wo;k'cf · .. ; P~entiai rusk -'.",:·.'Total--_ · Oll~tc-W6-rkei" .-. Pdential Rid · : __ Surra'ce Soil'/. -.:. SUrfa~ Soil . • •••• ;;.,;;. C ••. ·' .. · < Ar~ D NC NC NC NC NC NC NC NC NC NC NC NC 7. 16E-12 l.13E-I I NC NC NC NC NC NC NC NC 2.17E-08 NC NC NC NC NC 2.17E-08 I. 13E-11 .. diriir~Jb . : __ :=-_-:·;.'tf~t·~~\': ;-: .. -. · CFoi-.on;suc·.work:et .. ~Cfo;iff S~iO . NC NC NC NC NC NC 2.26E-I I NC NC NC NC 2.17E-08 NC I.J0E-06 V.J2E-::06 .. c.n w "SJ • TABLE 5-12 SUMMARY TABLE -LOCAL RESIDENT FUTURE SCENARIO -POTENTIAL CARCINOGENIC RISK HUMAN HEALTH EVALUATION FORMER KOPPERS COMPANY INC. SITE BEAZER EAST INC., MORRISVILLE, NC .. Total.: · Tres~r. Potcritiai lllik surr~~-So~ CONSTITUENT Ai-~ A·. PHENOL NC 2-CllLOROPHENOL NC 2-NITROPIIENOL NC 2,4-DIMETIIYLPHENOL NC 2,4-DICIILOROPHENOL NC 4-CHLORO-3aMETHYLPHENOL NC 2,4,6-TRICHLOROPHENOL 5.64E-13 2,4-DINITROPHENOL NC 4-NITROPHENOL NC 2,3,5,6-TETRACHLOROPIIENOL NC 2-METIIYL-4,6,-DINITROPHENOL NC PENTACHLOROPHENOL NC ISOPROPYL ETHER NC TOTAL TC_DD-TE • NC .. .. -TOTAL 5.64E-l 3 Notes: NC -Not calculated: toxicity standards not available. ND -Not detected in any sample in this medium/are.e.. File Nome: SUMC3,Wl<I 14-lun-9 I Toto! ce· ;l:itfl/ s~fr~J' sb·t-:,, · Arci st NC NC NC NC NC NC NC NC: NC NC NC .. -· ·· .. 9.27E-12 NC 9.72E--08 9. 72E--08 Total· :Total ToW TrC!pUscr··. · . . ,:_::}~~r-fr~r: Tr~pask~ , Pote~tin.i R.Jsk . P~~tili .Risk -.. Po<cntial Risk Potential Risk· · S~rf~~ Wat~ lngcitioli & . ·s·urr~& ·soil Surf~c~ Sou Subsurface Sari o·~r~ Conlad I:: :. Ar~c .-r:·~~ 6 ArCl!C .,,: Fire Pond_: · __ NC NC NC NC NC NC NC NC NC NC NC ND NC NC NC NC NC NC NC NC NC NC NC ND 9.9IE-13 l.56E-12 3.74E-I3 ND NC NC NC ND NC NC NC NC NC NC NC NC NC ·Ne NC ND 3.00E--09 NC 1.15E-09 2.3 I E--09 NC NC NC ND NC NC 5.00E--07 6.63E--06 3.00E-09 l.56E-12 5.02E--07 6.63E--06 • TABLE 5-12 (CONT'D) ... T i~S:Cr Potential Risk · scdir#ent Ingestion ~ · DCrm.al ConlAci CONSTITUENT i=irC Pond PIIENOL NC 2-Cl!LOROPIIENOL NC 2-NITROPl!ENOL NC 2,4-DIMETHYLPl!ENOL NC 2.4-DICl!LOROPIIENOL ND 4-CIILORO-3-METIIYLPHENOL ND 2,4,6-TRICl!LOROPIIENOL ND 2,4-DIN.ITROPI! ENOL .ND 4-NITROPIIENOL NC 2,3,5,6-TETRACII LOROPII ENOL ND 2-~IETH YL--4,6, -DIN ITROPII ENClL NC ., . ' PENT ACHLOROPHENOL 2.J0E-11 ISOPROPYL ETHER ND TOTAL TCDD-TE 1.2 I E--07 ' TOTAL 1.2 I E--07 Notes: NC -Not calcule.led; toxicity standar:ds not available. ND -Not detected in any sample in this medium/area. File Name: SUMC3. WK I 14-lun-9 l Tfespasset Potential Risk. . ·ln!t~io_~ of Fish Frorit .. Fire Pond ... NC NC NC NC NC NC NC NC NC NC NC ND NC l.93E--05 l.93E--05 Trespasser _Tr~r- i>;,.cniW Risk Potential Risk Trespasser Surface W.11.tci Ingest.ion & · ScdilllCnt ~g"c.slioii & Potential Risk Dermal Conltlct Der~ contact Ingestion of Fish From Medlin Pond Mcdliri Pond· . Medlin Pond NC NC NC ND ND NC NC ND NC NC NC NC NC ND NC ND ND NC l.64E-I0 t;D NC NC ND NC ND ND NC NC ND NC NC ND NC l.62E--09 ND ND ND ND NC 5. 75E--07 2. 74E--07 l.35E--06 5. 77E--07 2. 74E--07 1.l5E--06 TA!JLE 5-12 (CONT'D) -Loe.Al Resident Local Resident :-_ · _· -:.' Local Resident Local Resident Potential Risk · PJ~ti.;i Ri~k. Poteritial Risk Poi cntial Risk (1:"""1 ·Pot°'\Ual Surface Watci-~im~t ingC$liOO. & inc_idcntal Ingestion . Vegei.ablc ~Riilc~ Dermal Contttq DCrlD&i cOrilftd of Ground Water Consumption FOr·l:.ocal -Resident Oisch.argC Str~ From Fire Pond·. (Off-Site ArC4 G;oundw.!ltcr) . ----,_ ----J CONSTITUENT Western Ditch Off-site Arca <Euiurc ·Scenario~ . PHENOL ND NC NC NC NC 2-CHLOROPIIENOL ND ND NC NC NC 2-NITROPHENOL ND NC NC NC NC 2.4-DIMETIIYLPIIENOL NC NC NC NC NC 2.4-DICHLOROPHENOL NC ND NC NC NC 4-CIILOR0-3-METIIYLPIIENOL · ND ND NC ' NC NC 2,4,6-TRICHLOROPHENOL ND ND 2.81E-Q9 l.07E-08 l.37E-08 ' 01 2.4-DIN ITROPIIENOL NC NC NC NC NC w <D 4-NITROPHENOL ND ND NC NC NC 2,3,5,6-TETRACHLOROPHENOL NC ND NC NC NC 2-METHYL-4,6,-DINITROPHENOL ND ND NC NC NC PENT ACHLOROPII ENOL : 2.89E-08 ... l.96E-10 7.28E-Q9 2.78E-Q9 4.73E-08 ISOPROPYL ETHER ND ND NC NC NC TOTAL TCDD-TE I.ISE-06 4.42E-06 9.82E-IO 3.75E-I I · 3.44E-05 • .. '• TOTAL l.18E-06 4.42E-06 1.11 E-08 I.JSE-08 CJ~SE=-05 Notes: NC -Not calculated; lo~icity standards not available . . ND -Not detected in any sample in this medium/erea. File Name: SUMCJ. WJ(I 14-Jun-9 I 01 1,. 0 • . ....., TABLE 5-13 SUMMARY TABLE -HYPOTHETICAL ON-SITE RESIDENT (#1) FUTURE SCENARIO -POT°ENTIAL CARCINOGENIC RISK HUMAN HEALTH EVALUATION FORMER KOPPERS COMPANY INC. SITE BEAZER EAST INC., MORRISVILLE, NC . ·/:'• Total:'. ·:c• ····•:• . ~iyp: _o~_-site·_ R6sici_ent • . ··.. Potential ~k \ . · .. Surface Soil :·· ···. • CONSTITUENT •· ·•. :·-.Arai A \·:: .. PHENOL NC 2-CHLOROPl!ENOL NC 2-NITROPHENOL NC 2.4-DIMETHYLPl!ENOL NC 2.4-DICHLOROPHENOL NC 4-CII LORO-3-METII Y LPl!ENOL NC 2,4.6-TRICHLOROPHENOL 2.37E-I I 2.4-DINITROPHENOL NC 4-NITROPl!ENOL NC 2.3.5.6-TETRACHLOROPI! ENOL NC 2-METHYL-4,6,-DINITROPHENOL ' NC PENTACIILOROPHENOL ·-NC ISOPROPYL ETHER NC TOTAL TCDD-TE NC ' ' '. TOTAL 2.37E-ll .. Notes: NC -Not calculated; toxicity standards not available. ND_-Not detected in any sample in this medium/area. File Name, SUMC4.WKI 12-Jun-91 ... "°' • ... , Tcital > · . .:: j_1;-~:,·o~~Sit,~ __ R~l~-~--,:. :: . . PotaitW Rbk . .. ::::;Subs~~race ~ii-< :, . t \. ,;_;,;;; ;.•.•··· NC NC NC NC NC NC 3.87E-13 NC NC NC NC .. NC NC NC 3.87E-13 IIYJ>: On-Site R~lderi.t ... .. .. Byp. On-She Ra,ldeilt_ Hyp._ On-Site Resident . .. . . Potential Risk .... Poti:ntW Risk PotentW RW. .. . S~rf8Ce Water · ··. S1;1rfa~ Water Ingestion &. Sediment Ingest.ion & . ·-:"~~-~ Corila~ · '::··:::·_ .. I;-DerIDA1 COntact :_.· , DerIDAl Coal.ad ._·,_:-<· Fire POJld -. . . -.. .-_',: ·· Wcstcni Ditch Fire Pood NC ND NC NC ND NC ND ND NC NC NC NC NC NC ND ND ND ND ND ND ND ND NC ND NC ND NC NC NC ND ND ND NC 5.22E-08 2.89E-08 l.44E-I0 ND ND ND U0E-04 1.15E-06 l.68E-06 U0E-04 1. IBE-06 l.68E-06 • • TABLE 5-13 (CONT'D) CONSTITUENT PHENOL 2-CHLOROPHENOL 2-NITROPHENOL 2,4-DIMETIIYLPHENOL 2,4-DICHLOROPHENOL 4-CHLOR0-3-METHYLPIIENOL 2,4 ,6-TRICIILOROPII ENOL 2,4-DINITROPIIENOL 4-NITROPIIENOL 2. 3,5,6-TETRACII LOROPII ENOL 2-METIIYL-4,6,-DINITROPHENOL PENTACHLOROPIIENOL ISOPROPYL ETIIER TOT AL TCDD-TE TOTAL Notes: NC -Nol calculated; toxicity standii.rds not available. ND -Not detect~ in any sample in this medium/area. File Name: SUMC4.WKI 12-Jun-91 NC NC NC ND NC NC ND ND ·ND ND ND I.78E-ll ND 5.29E-07 5.29E-07 NC NC NC ND NC NC 3. 78E-07 ND NC NC NC 2.84E-05 NC 5.19E--04 5.48E--04 .-._ > Byp_·-__ ·:_q~~Sit~ RCS!dent :·. . . C CC Po<intial Risk · ·.-: d;~Und_ Wiiei Voiaill~ Inhaliu..iori -· Sho~ci · Eastern Ar~ > : NC NC NC ND NC NC 4.84E-15 ND NC NC NC NC NC I .C>lE-08 l .C>lE-08 .. :·:_:· f1}1i: On-~ite Resid~t · · · PotcntW Risk -= · ',. ·:· Lii·~~ of FL1~ FrOni · FirC Pond . · ·. NC NC NC NC NC NC NC NC NC NC NC: ND NC 8.16E-05 8.l6E-05 • • <.n .I,. N ...... TABLE 5,13 (CONT'D) CONSTITUENT PHENOL 2-Cl!LOROPHENOL 2-NITROPl!ENOL 2.4-DIMETIIYLPHENOL 2.4-DICIILOROPHENOL 4-CIILOR0-3-METl!YLPl!ENOL , 2,4,6-TRICHLOROPH ENOL 2,4-DINITROPl!ENOL 4-NITROPl!ENOL 2 ,3,5,6--TETRACIILOROPH ENOL 2-METl!YL-4,6,-DINITROPl!ENOL PENTACl!LOROPHENOL ISOPROPYL ETHER TOTAL TCDD-TE .·.:-. TOTAL Notes: ,:~· :· 1 NC -Not calculated; to~icity standards not available. ND -Not detected in any sample in this medium/area. File Name: SUMC4.WKI 12-Jun-91 NC NC NC NC NC NC 3.78E-07 NC ,NC NC NC . 2.85E-05 NC 7.54E--04 • (J1 1. w • TABLE 5-14. SUMMARY TABLE -HYPOTHETICAL ON-SITE RESIDENT (lf2) FUTURE SCENARIO -POTENTIAL CARCINOGENIC RlSK HUMAN HEALTH EVALUATION FORMER KOPPERS COMPANY INC. SITE BEAZER EAST INC., MORRJSVILLE, NC CONSTITUENT PHENOL 2-CHLOROPHENOL 2-NITROPHENOL 2,4-DIMETHYLPIIENOL 2,4-D!CIILOROPHENOL 4-C!ILORO-3-METHYLP!IENOL '• 2,4,6-TRICHLOROPIIENOL 2,4-DINITROPIIENOL 4-NITROPIIENOL 2,3,5,6-TETRACHLOROPH ENOL 2-METHYL-4,6,-DINITROPHENOL PENTACHLOROPHENOL ISOPROPYL ETHER TOTAL TCDD-TE . L .i TOTAL Notes: NC --Not calculated; toxicity sta.nd.11r_ds not available. ND -Not detected in any samples in this medium/area. File Name: SUMC5.WJ<I 12-Jun-91 NC NC NC NC NC NC NC NC NC NC NC 3.89E0 I0 NC 9 .0SE-06 9.0BE-06 NC NC NC NC NC NC 4.78E-13 NC NC NC NC NC NC 2.02E-08 2.02E-08 Hyp.:_9il-Site Resident p~i;;,j Risk ~Li~fa~,~afc~ ~gestiori &·.: : · Der~ Contact · _ -. :,: Fire Pond NC NC ND NC NC ND ND ND NC NC ND 5.22E-08 ND I .S0E--04 l.50E--04 \Hyp. Ori-Site Resident·· . PotrntW Risk -: SurfacCa Water ,. Dermal Cont.act :. , .. We.stem Ditch ND ND ND NC NC ND ND NC ND NC ND 2.89E-08 ND I.ISE-06 i.lSE-06 Hyp. On-Site Resident PotcotiA.I Risk Sodtmcnt lnge8tion & Dermal Contact Fire Pond NC NC NC NC ND ND ND ND NC ND NC l.44E-IO ND I .68E-06 l.68E-06 (Jl t • TABLE 5-14 (CONT'D) Hyp; 9ri;_$ii_e ~e&ideri.t · • •.·· · i>oibntial Risk : ~~-~t lng~00-4_., · ,._··.: :-__ 0cr~ c·oniact . · -= · _·_, .··.-West.~riJ-ri\tch :_=:\'.!,, CONSTITUENT PHENOL NC 2-CllLOROPHENOL NC 2-NiTROPHENOL NC 2,4-DIMETHYLPHENOL ND 2,4-DICHLOROPIIENOL NC 4-CIILORO-3-METHYLPHENOL NC 2,4,6-TRICH LOROPHENOL ND 2,4-DINITROPHENOL ND 4-NITROPHENOL ND 2,3 ,5 ,6-TETRACHLOROPH ENOL ND 2-METHYL-4,6,-DINITROPHENOL ND PENTACHLOROPHENOL 1.78E-11 ISOPROPYL ETHER ND TOTAL TCDD-TE 5.29E--07 : ; TOTAL 5.29E--07 Noles: .. NC -Not calculated; toxicity standards not available. ND -Not detected in any samples in this medium/area. File Name: SUMC5.WKI l2-Jun-91 1c·.· Hyp. Ori-.Sitc Rc,ldcnt --Hyj,. Ori-Site ~e81~ .. . · · ... · Potciiu.i Risk :. PotentW Risk ' :. 11}'P. 'tin-sit~ Resid~t ',:,,._<;;rbund Watei.in~~h drOund Wlltet Voi~Uci: ·. •••·•· · PotentW Rl&k • -·-:·;,·.·::.::: ~ o~g Water:· __ :~al~io~ -~ s_bo:w~(::(:·:"_. ingc&iOfl of FiAh Fro~. 1/.··. :(/._ Eist~~ Ar~i . .. . · · Eastern Arca ..... :·: Fi~ Pond ._.. .. NC NC NC NC NC NC NC NC NC ND ' ND l'/C NC NC NC NC NC NC 3. 78E--07 4.84E-15 NC ND ND NC NC NC NC NC NC NC NC NC NC 2.84E--05 NC ND NC NC NC 5.I9E--04 I .04E--08 8. l6E--05 5.48E--04 1.04E--08 8.16E--05 • u, .!,. u, TABLE 5-14 (CONT'D) CONSTITUENT PHENOL 2-CIILOROPIIENOL 2-NITROPHENOL 2,4-DIMETHYLPIIENOL 2,4-DICIILOROPHENOL 4-Cl!LORO-3-METHYLPIIENOL 2,4,6-TRICIILOROPII ENOL 2,4-DINITROPIIENOL 4-NITROPHENOL 2,3,5,6-TETRACH LOROPH ENOL 2-METIIYL-4,6,-DINITROPHENOL PENTACHLOROPHENOL ISOPROPYL ETHER TOTAL TCDDcTE Notes: TOTAL .··· ~yi,W:p~~. ?. i .• ·.· . c::: pj.{.). f .· . . . . . . . . . . . ·• Fodj~;_On°Sjt~ Re.ai#{<A2) ·· . '.: .;··,;:·,puftin(~Ukl .. i~-=:\-;:_:,,:, NC NC NC NC NC NC 3.78E-07 NC NC NC NC --.... .. 2.85E-05 NC 7.63E-Q4 NC -Not calculated; toxicity standards not available. ND -Not detected in any samples in this medium/area. File Name: SUMC5.WKI 12-Jun-91 (Jl & • TABLE 5-15 SUMMARY TABLE -HYPOTHETICAL ON-SITE RESIDENT (#3) FUTURE SCENARIO -POTENTIAL CARCINOGENIC RISK. HUMAN HEALTH EVALUATION FORMER KOPPERS COMPANY INC. SITE BEAZER EAST INC., MORRISVILLE, NC .• . . To!AI . . . . .• Tii<al .. •.• • Jlyp'..On"Site Reoldent . !iyp~~::·L~dcitt .. ii1t~ttd~riii .•. su.i.l't:t ~00 & .· ·Surf~ Soil . r}(,i.f ?Su·b~trf~-Soil-.\··.=~· ·_: ~mai Contact ._-. Arca C ·:-. . >--, -,: ... Area c; · .. _-_·: . . :_ ... ' ' Flf'C Pond CONSTITUENT PIIENOL 2-CIILOROPIIENOL 2-NITROPIIENOL 2.4-DIMETHYLPHENOL 2.4-DICIILOROPHENOL 4-CHLORO-3-METHYLPHENOL 2.4.6-TRICIILOROPH ENOL 2.4-DINrfR.OPHENOL 4-NITROPIIENOL 2. 3.5.6-TETRACII LOROPII ENOL 2-METIIYL-4.6.-DINITROPHENOL PENTACIILOROPIIENOL ISOPROPYL ETHER TOTAL TCDD-TE ' , . TOTAL Notes: NC -Not caJcult1ted; toxicity standards not available. ND -Not detected in any samples in this medium/area. File N•mc, SUMC6.Wl<I 12-Jun-91 NC NC NC NC NC NC 4.16E-I I NC NC NC ·Ne 1.26E-07 NC NC 1.26E-07 NC NC NC NC NC NC 6.57E-13 NC NC NC NC 2.0JE--09 NC i.96E-06 i.96E-06 .. NC NC ND NC NC ND ND ND ' NC NC ND 5.22E-08 ND I.S0E--04 1.S0E--04 Hyj,. On-Site Resident Po<enti.oi Risk · Surfll.OC Watef: · Der~ Co~tad Western Ditch ND ND ND NC NC ND ND NC ND NC ND ., 2.89E-08 ND I.ISE-06 I. I BE-06 ~typ_. On-Site Resldart Potential Risk Sodlmcnt Ingest.Jon & Dermal ContAd Fire Pond NC NC NC NC ND ND ND ND NC ND NC 1.44E-I0 ND 1.68E-06 l.68E-06 • (11 .J,,. ...,, • TAJlLE 5-15 (CONT'D) llyj>. Ori0 Site Resident __ .. /.:. llyj>:.Ori"Site Rcolden.t:•_/: i'<'<intia! ~ · ·... . . ·• r;;btl.i Ri.k i ·':'://1:f}'J>. On-SitC RCS!dent i .-: .. CONSTITUENT PHENOL 2-CHLOROPl!ENOL 2-NITROPHENOL 2,4-DIMETHYLPHENOL 2,4-DICIILOROPIIENOL 4-CIILORO-3-METIIYLPIIENOL. 2,4, 6-TRICHLOROPH ENOL 2,4-DIN ITROPII ENOL 4-NITROPHENOL 2, 3,5.6-TETRACIILOROPH ENOL 2-METIIYL-4,6,-DINITROPIIENOL PENTACIILOROPIIENOL ISOPROPYL ETHER TOTAL TCDD-TE ,.: TOTAL Notes: Scdim~ 1n)l.;.iJ11.!<. . 0e;.;.icori1aci Western D·it~h ::.\ . i NC NC NC ND NC NC ND ND -ND ND ND l.78E-II NC 5.29E-07 5.29E-07 NC -Not calculated; to,;icity standards not available. ND -Not detected in any samples in this medium/area. File Name: SUMC6. WK I l2-Jun-91 . ·_\}:/\ :--Potential Risk · : :-_::_/'biou~c(Wil.;~-fu'g~~l:\_,_· · · -::-: .... G~6uni Water Volalil~ -::' .. · .. \·<_i/ii 6ilii~·ti_Y{JCf;,/(::.=:··: . :,_.-,_.::_'::-inh.aJati~ri -SbowCt'/ .. · --< :·Fcifrriir:~g&J\Aici\,-:" ::,,·:._ .:•·-:. Formei-LagOOn Arc:4 .. NC NC ND ND NC NC ND ND ND ND NC NC 5.18E-07 6.63E-l5 ND ND NC NC NC NC NC NC 1.11 E-03 NC NC NC l.91E--04 2.57E-I0 I .J0E-03 2.57E-IO __ .. · · 1,yjj. on:..Siiri Resident PotbitW lllik .... ·· . lnicst.ion of Fbh Fi~·m'. .. Fire Pond -. NC NC NC NC NC NC NC NC NC NC NC ND_ NC 8.16E-05 8.16E-05 (J1 ~ • TABLE 5-15 (CONT'D) . , . CONSTITUENT . PHENOL 2-CHLOROPIIENOL 2-NITROPHENOL 2.4-DIMETHYLPIIENOL 2.4-DICII LOROPIIENOL 4-CIILORO-3-METHYLPIIENOL 2.4 .6-TRICHLOROPHENOL 2.4-DINITROPH_ENOL 4-NITROPIIENOL 2.3.5.6-TETRACHLOROPHENOL 2-METHYL-4,6,-DINITROPHENOL PENTACHLOROPHENOL i. ISOPROPYL ETIIER TOTAL TCDD-TE TOTAL Notes: NC -Not caJcule.ted; toxicity standards·not available. ND -Not detected in any samples in this medium/area. File Name: SUMC:6. WK I 12-Jun-91 l.'.· I' . NC NC NC NC NC NC 5. IBE--07 NC NC NC NC : _ r_ II E--03 NC 4.28E--04 Ul 1,. <D • TABLE 5-16 SUMMARY TABLE -HYPOTHETICAL ON-SITE RESIDENT (#4) FUTURE SCENARIO -POTENTIAL CARCINOGENIC RISK HUMAN HEALTH EVALUATION FORMER KOPPERS COMPANY INC. SITE BEAZER EAST INC., MORRISVILLE, NC CONSTITUENT . PHENOL NC 2-CHLOROPHENOL ·NC 2-NITROPHENOL NC 2,4-DIMETHYLPHENOL NC 2,4-DICHLOROPHENOL NC 4-CH LORO-3-METHYLPHENOL ., NC 2,4,6-TRICHLOROPHENOL 6.57E-1 I 2,4-DINITROPiiENOL NC 4-NITROPHENOL NC · 2,3.5,6-TETRACHLOROPHENOL. NC 2-METHYL-4,6,-DINITROP!IENOL NC. PENTACHLOROPHENOL '.NC ISOPROPYL ETHER NC TCDD I TCDF NC TOTAL 6.57E-II : :,•,. ,.. Notes: ; :,: ~ NC -Not calcul~tcd; toxicity standards not .11.v11iJable. ND -Not detected in any samples in this medium/area; File Name: SUMC7.WKI l2-Jun-91 NC NC NC NC NC ND NC NC NC NC NC ND NC ND NC ND NC NC NC NC NC ND NC 5.22E-08 NC ND NC I.50E-o4 NC I.50E-o4 .. <HYP-on:..site Resident . ·-.-. llyp. On-Sile R~lde:Qt · •·• · Pofu,ti,J Risk·· · • · .. ·•• Potential iti,k · .,:· Surf~ Wat.ti· · Dermal Conl4ct ; -· : .·.-Western Ditch · ND ND ND NC NC ND ND NC ND N:: ND 2.89E-08 ND I.ISE-06 I. I SE-06 . Sediment mgc,tJon & Dci-m.a.l Cont.ad , Flfc Pood --·. NC NC NC NC ND ND ND ND NC ND NC l.44E-IO ND 1.68E-06 l.68E-06 u, ~ • TABLE 5:16 (CONT'D) CONSTITUENT. PHENOL 2-CIILOROPHENOL 2-NITROPIIENOL 2,4-DIMETH)'LPIIENOL 2,4-DICIILOROPHENOL 4-CIILOR0-3-METIIYLPIIENOL. 2.4,6-TRICHLOROPHENOL 2 ,4-DIN ITROPII ENOL 4-NITROPIIENOL 2.3.5,6-TETRACHLOROPIIENOL 2-METIIYL-4,6,-DINITROPHENOL . PENTACIILOROPIIENOL ISOPROPYL ETHER TCDD I TCDF Notes: TOTAL NC -Not calculated; toxicity standards not available. ND -Not detected in any samples in this medium/area. File Nome: SUMC7.\l'KI l2-Jun-91 NC NC NC ND NC NC ND ND ND ND ND i.78E-0I I ND 5.29E--07 5.29E--07 NC ND NC NC NC NC 6.65E--07 NC NC NC NC I .47E--07 NC NC 8.12E--07 Westerri Aica NC ND NC NC NC NC 8.48E-15 NC NC NC NC NC NC NC 8.48E-l5 NC NC t!C NC. NC NC NC NC •NC NC NC . ·No NC 8.16E--05 8. l6E--05 (J1 U1 ~ • TABLE 5-16 (CONT'D) CONSTITUENT PHENOL 2-CHLOROPHENOL 2-NITROPHENOL 2,4-DIMETHYLPHENOL 2,4-DICHLOROPHENOL 4-CHLORO-3-~1ETIIYLPHENOL 2,4,6-TRICHLOROPHENOL 2,4-DINITROPHENOL 4-NITROPHENOL 2,3,5,6-TETRACHLOROPH ENOL 2-METHYL-4,6,-DINITROPflENOL PENTACHLOROPHENOL ISOPROPYL ETHER TCDD I TCDF .•, 1· TOTAL Notes: NC -Not ca.Jculated; toxicity standards not e.v8.ilablc. , ND -Not detected in any samples in this medium/area. File Nnme: SUMC7.WKI 12-lun-91 NC NC NC NC NC N.C 6.65E-07 NC NC NC NC .. 2.29E-07. NC 2.35E-Q4 (Jl tn f\) • TABLE 5-17 SUMMARY TABLE -ON-SITE WORKER FUTURE SCENARIO O POTENTIALLY CARCINOGENIC. RISK HUMAN HEALTH EVALUATION FORMER KOPPERS COMPANY INC. SITE BEAZER EAST INC., MORRISVILLE, NC· CONSTITUENT PHENOL 2-CHLOROPIIENOL 2-NJTROPJIENOL 2.4-DIMETHYLPIIENOL 2,4-DJCHLOROPHENOL ' 4-CIJLORO-3-METIIYLPIIENOL 2.4.6-TRICIILOROPHENOL 2,4-DINITROPIIENOL 4-NITROPHENOL 2,3,5,6-TETRACHLOROPJIENOL 2-METIIYL-4,6,-DINITROPIIENOL PENTACIILOROPHENOL ISOPROPYL ETHER TCDD I TCDF TOTAL Notes: NC NC NC · NC NC NC 4.0SE-12 NC NC NC NC !NC NC NC 4.0SE-12 NC -Not ca.lculatcd; toxicity standard! not available. ND -Not detected in any samples in this medium/area. File Name: SUMC8.WKI 12-Jun-9 I NC NC NC NC NC NC NC NC NC NC NC 6·.?0E-11 NC 1.30E-06 J.30E-06 NC NC NC NC NC NC 7.l6E-l2 NC NC NC· NC 2. l?E-08 NC NC 2. l?E-08 NC NC NC NC NC NC 1.13E-11 NC NC NC NC ·Ne NC NC l.13E-II . . Toto!· . : 6~sid W~-~k~ . Potential Risk . : Subilltfac<i Soii >'Aicic < NC NC NC NC NC NC 3.I IE-13 NC NC NC NC 6.59E-l0 NC 5.30E-07 5.3IE-07 . _:.. ,:·.>_. ' Q'.ot.,i r6!cii~_, CRisk-·, '}:Of~ on::s1te .Worker--. . . ~~ -future-SccomO_-~ ----\ NC NC NC NC NC NC 2.29E-I I NC NC NC NC 2.24E-08 NC _1.SJE-06 -~ ... -,-· _. _ __;.--• James G. Martin, Governor David T. Flaherty, Secretary Ronald H. Levine, M.D., M.P.H. Stale Health Director MEMORANDUM TO: FROM: SUBJECT: Pat DeRosa CERCLA Unit July 28, 1988 T:ed Taylor, Ph.D., Toxicologist t( Environmental Epidemiology Branch Koppers Site -Pentachlorophenol · I hav~ just received U1e latest i11fo1i1iation or1 the ·risk c1ss2ss:i;ent ~,,irforn,ed by the EPA Carcinogen Assessment Group on pentachlorophenol (penta). Although this still must undergo agency-wide peer review, penta has been assigned a s2 carcinogen classification by CAG (probable human carcinogen) based on the recent findings of the National !1xicology Program in the mouse; the slope that was reported was 0.8( mg/kg/day) . This translates into a drinking water concentration of approgimately 0.04 ug/1 being equal to an excess lifetime cancer risk of l X 10-. Based on the most recent laboratory results, the well water at the Shiloh Baptist Church represents an excess cancer risk of one in a thousand if consumed for a lifetime. Since it is unlikely that members of the church drink two quarts of water per day from the well, which is a basic premise in the risk calculation, their actual cancer risk is probably significantly lower. Also, the recommendations of CAG will likely be challenged in an effort to downgrade the classification of penta from a probable to a possible human carcinogen; this could further reduce any concern. Only one set of laboratory data has detected these elevated levels of penta in the church's water. After consideration of all of this information, however, we believe that it would be prudent public health policy to advise the church that their water should not be.consumed. As for the Lyons' residence, we believe that the trace levels of pent3 th~6well do.not represent a significant cancer risk at this time (10- 10 ), It 1s recom1nended that the Lyons' well and the church well be resampled. When these results are available, the situation will be found in to OeRosa Memorandum Page 2 July 28, 1988 • re-evaluated and we will provide this information to you. Since there may be a correlation with the levels of penta and the levels of isopropyl ether, the selection of other wells for resampling should consider this information. Finally, it must be emphasized that the recommendation to not consume water at the Shiloh Baptist Church. does not imply that those people who have consumed water over the last six months are at a greater risk of developing cancer. The recommendation is intended to serve solely as a precaution against future use and reflects many of the uncertainties that are involved in the estimation of risk to humans from chemicals that cause cancer in laboratory animals. In other words, there is currently no scientific evidence demonstrating that pentachlorophenol is a human carcinogen. I hope this information is useful to you. If you have questions or need further information,· please feel free to contact me at 3410. TT:lp