NCD003200383_19910925_Koppers Co. Inc._FRBCERCLA RISK_Response to Comments on the Draft Risk Assessment-OCR

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September 25, 1991
Ms. Darcy Duin
Superfund Branch, Waste Management Division
U.S. EPA, Region IV
345 Courtland Street, NE
Atlanta, GA 30308
E~5R Consulting
and Engineering
35 '.\agog Park
Acton, Massachusetts 01720
/5,)!l', 635-9500
15(.;;, 635-9180 (FAX)
Re: Response to comments on the Draft Risk Assessment for the· Former Koppers
Company, Inc. Site, Morrisville, NC
Dear Ms. Duin:
On behalf of Beazer East, Inc. we are submitting five copies of the response to comments
on the Draft Risk Assessment for the Former Koppers Company, Inc. Site in Morrisville,
NC. The EPA prepared a total of 64 comments on the Draft Risk Assessment. The
comments were grouped by EPA as "General' and "Specific". We have numbered the
comments, G-1 through G-12 (General Comments) and S-1 through S-52 (Specific
Comments). The following is a list of each comment with a written response. We hereby
request that the response to comments be docketed and made part of the Administrative
Record for the Morrisville, NC Site.
Some issues related to the comments were discussed with EPA Region IV on September
12, 1991. A copy of the attendance list from the September 12, 1991 meeting at Region
IV headquarters in Atlanta between EPA, Beazer, Keystone and ENSR is attached to this
response to comments. Please note that if a figure is proposed to: be copied from the
RI into the revised risk assessment, a copy of this figure is attached to the back of this
package for your review.
In addition to the comments received from EPA on the Draft Risk Assessment, we were
asked at the meeting on September 12, 1991 to include a section to the revised risk
assessment on risk-based remedial clean-up goals. Once the conciusions of the revised
baseline risk assessment are complete, we will include this additional section requested
by EPA.
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Ms. Darcy Duin
Page 2
Because the RI is also currently being revised and additional sampling is being
conducted, we propose that ENSR submit revisions to EPA on parts of the risk
assessment as they are being worked on over the next few months, in an attempt to
facilitate the next formal review process. '
Sincerely,
Susan L. Allen,
Project Manager
Enclosures
cc: W. Giarla/Beazer
J. Mitsak/Keystone
·P.-DeRosa/DEHNR; Raleigh NC /
0542116.sta; 0845·008-200
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Comments
Former Koppers Company, Inc. Site, Morrisville NC
Draft Risk Assessment
Response to EPA Comments
September 26, 1991
Contents
Attendance list from the September 12, 1991 meeting between
EPA Region IV, Beazer East Inc., Keystone Environmental Resources,
and ENSR Consulting and Engineering
Proposed figures to be copied from the RI
Overheads that summarize review of fish consumption study data,
supplement to response to comment S-24
Excerpt from comments on the fish consumption rates recommended
in the Draft Bioconcentratables document, supplement to response
to comment S-24
AES_ 1. RAS 0645-008-200
·t?tG.tlVED
SEP -~ G 1991
SUPERFOND SECTION
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Comment:
G-1 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.
Response:
The report was designed to introduce the relevant technical information in the main text, and to
provide the supporting, often more detailed, technical information in the appendices. This was
done to keep the main text more understandable for the non-technical reader.
We recommend that the organization of the report remain as it is with the exception of a few
changes requested in other comments from EPA such as the addition of figures and text
summarizing information found in the RI (see following comments).
Comment:
G-2 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.
Response:
See response to comment G-9 for a discussion of exposure setting, including the figures and
text that we propose to add to the revised risk assessment. Figures 4-2 through 4-17 of the RI
show the extent of constituents for all media (except for fish). We would like to discuss how best
to summarize this data in the revised risk assessment.
The extent of constituents in the various media, as presented in the RI, will be summarized in
the revised baseline risk assessment.
Comment:
G-3 To facilitate the comprehension of the report, a sample calculation should be
included in the body of the report for each scenario.
Response:
Sample calculations will be added to the body of the report for each scenario.
Comment:
G-4 Also, the report is incorrectly titled. The correct title is Baseline Risk Assessment
(BRA}.
Response:
The report will be called a Baseline Risk Assessment.
RES_1.AAL, 0845--006-200 2
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Comment:
G-5 The preparers of this report editorialize throughout the document on the highly
conservative nature of the EPA risk assessment process. There file 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 edititorializing and qualifiers, such as highly. conservative or
greatly overestimates, should be removed from the text and objective discussion of
the uncertainties should be placed where It belongs In the uncertainty section.
Response:
As discussed with EPA (9/12/91 meeting), the EPA's intent is for the risk assessment process
to be conservative, yet, because the public may not be aware of the conservative nature of the
process, and to prevent mis-interpretation of the document, it is necessary for the uncertainties
in the process to be identified throughout the report. The qualifiers such as greatly and hi9h!Y
and other strong language will be removed from the report.
Comment:
G-6 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 TXL/TAL
constituents. This data summary should include a presentation of the inorganic data
along with background data for comparison purposes.
Response:
A formal section on the selection of the constituents of interest will be added to the revised risk
assessment following EPA's Risk Assessment Guidance for Superfund (U.S. EPA, 1989). This
section will include a discussion of the sampling rounds and constituents analyzed for in the RI,
and evaluation of quantitation limits, qualified and coded data, and a comparison with blanks and
background samples.
This section will also include summary tables for all RI data containing the following information:
medium/area sampled, analyte lists, sample locations, range of non-detects for all analytes,
range of detects for all anaiytes, frequency of detection, and background concentrations where
available.
Comment:
G-7 The 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
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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 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.)
Response:
As discussed with EPA (9/12/91 meeting), the conclusions of the report will be discussed after
negotiations are complete for the exposure assumptions for the revised risk assessment.
Comment:
G-8 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; 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 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).
Response:
As discussed with EPA (9/12/91 meeting), Section 9 of the RAGS contains a suggested outline
for a baseline risk assessment report. This is a suggested outline, not a required outline. Much
of the requested information can be found in the RI report. Some of this information, such as
a more complete discussion of the site and the history of the site investigation, site hydrology,
geology and land use information, will be summarized in the revised risk assessment. In
addition, a summary of the extent of constituent migration will be added to the revised risk
assessment.
Comment:
G-9 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.
Response:
We propose that the discussion of the surrounding area in the revised risk assessment will
include the following figures:
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RI Rgure 1-1: Site Location Map
RI Figure 3-5: Regional Geologic Map
RI Figures in Appendix E: Zoning Map for Morrisville, NC, and
Updated Land ·Use Study Map
The revised risk assessment will also include a discussion of the local population (from Section
3.7.1 of the RI) and land use (from Section 3.7.2 of the RI). A discussion of geology (from
Section 3.5 of the RI), containing regional and site information, will be included. Finally, a
discussion of both surface water hydrology (from Section 3.3 of the RI) and ground water
hydrogeology (from Section 3.6 of the RI) will be included in the revised risk assessment.
Direction of surface water runoff and ground water flow will be addressed. Relevant figures, if
any, will be added. In addition to the RI, material may also be used in these discussions from
Section 2.0 of the RI/FS Workplan.
All the potential pathways of exposure to the site were presented in Table 4.1 of the draft risk
assessment.
Comment:
G-10 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. '
Response:
All potential private and municipal receptors with potentially affected wells have alternate potable
water sources. A summary of the extent of constituents in ground water, surface water and other
media will be included in the revised risk assessment. Figures will be added to the revised risk
assessment that show the locations of the monitoring wells (also see response to comment S-3).
See Appendix E of the RI for additional information on the domestic well sampling program.
Comment:
G-11 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 devising the site risks:
7) the major factors reducing the certainty in the results and the significance of the
uncertainties; and ·
8) exposed population characteristics.
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Response:
As discussed with EPA (9/12/91 meeting), the conclusions will be edited if necessary to reflect
the changes to exposure assumptions, if any, made to the report. Yet, the level of detail
requested in this comment is not necessary for the revised risk assessment: The conclusions
of the revised risk assessment will be edited ii necessary to reflect any changes in the exposure
assumptions in the report or new information that may be added to the RI Addendum Workplan.
This approach is consistent with the objectives of a baseline risk assessment.
Comment:
G-12 This document should also Include a brief discussion of the leaching to groundwater
of contaminants of concern from soils and sediments.
Response:
A complete discussion of leaching potential at the site will be added to the revised RI. A
summary of the findings in the RI will be added to the revised risk assessment.
Comment:
5-1 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 o.e., well above the average case) that is still within the range of possible
exposures.
Response:
The RME, as defined in this risk assessment, i.S an estimate of a conservative exposure case that
is still within the range of possible exposures, and follows the RAGS guiqance. The discussions
of the RME in the risk assessment merely remind the reader of the conservative intent of this
exposure case. This paragraph will be edited to remove any strong language regarding the
conservative nature of the process.
Comment:
5-2 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.
Response:
See response to comments G-6 and S-6.
Comment:
5-3 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 2-1 are meaningless without a corresponding figure. This paragraph should
also state which media were sampled for dioxins/furans and briefly discuss the
method.
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Response:
We propose to copy the following tables from the RI to supplement Table 2-1 in the revised risk
assessment:
RI Figure 2-1: Soil Sampling Locations
RI Figure 2-2: On-site and Near Off-Site Monitoring Well Locations
RI Figure 2-3: Off-Site Deep Monitoring Well Locations
RI Figure 2-5: Surface Water Sample Locations
RI Figure 2-6: Sediment Sampling Locations
RI Figure 2-7: Fish Sampling Location Map
The report will be edited to state that all media were sampled for dioxins/furans by method 8290.
In addition, the fish analysis methods will be added to the text: pentachlorophenol and
pentachloroanisole = method 8270, and dioxins/furans = method 8290.
Comment:
S-4 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?
Response:
As discussed with EPA (9/12/91 meeting), a brief review of the off-site ground water monitoring
well results will be added to the revised risk assessment. This discussion will include a
statement about the initiation of the domestic well sampling program. Because the domestic well
sampling program is not a part of the RI, that data will not be discussed in the risk assessment.
A discussion will be added to the RI report explaining why the domestic well data are not
included in the baseline risk assessment.
Comment:
S-5 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.
Response:
See response to comment S-4.
Comment:
S-6 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?
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Response:
All sampling data was summarized in Chapter 4 and Appendix F of the RI. As stated in the
response to comment G-6, the revised risk assessment will contain summary tables of all RI data
including the following information: medium and area sampled, analyte lists, sample locations,
range of non-detects for all analytes, range of detects for all analytes, frequency of detection, and
background concentrations where available.
Pentachloroanisole was analyzed for but not detected in fish. See Table 4-52 of the RI for
pentachloroanisole sampling data in fish. This constituent will be added to Tables 2-2, 2-11 and
2-12 of the revised risk assessment.
Comment:
S-7 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?
Response:
Sampling points were discussed in Section 5 of the EPA-approved RI/FS Workplan (Keystone,
1989). As discussed with EPA (meeting 9/12/91), additional surface soil samples will be
collected in Areas C and D. These data will be included in the revised risk assessment.
Comment:
S-8 Table 2-4. .
Table 2-4 indicates that dioxins/furans were only analyzed for In the surface soils In
Area B and the subsurface soils in Areas B and 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.
Response:
See response to comment S-7.
Surface soil exposure point concentrations for PCDDs/PCDFs were only determined for surface
soil Area B in the draft risk assessment. 1
Comment:
S-9 Tables 2-11 and 2-12.
Pentachloroanisole should be included in the data summary for the fish fillet tables.
Response:
Pentachloroanisole was analyzed for but not detected in fish. This constituent will be added to
Tables 2-2, 2-11 and 2-12 of the revised risk assessment.
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Comment:
S-10 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 percent confidence interval concentration. Also, as wa~ mentioned In a
previous comment, a discussion should be Included which compares the domestic
well data with the RI groundwater data.
Response:
The revised risk assessment will contain a brief discussion of potential constituent migration in
ground water. As stated in the response to comment G-2, additional information regarding the
a potential ground water plume will be added to the revised RI report. When this information
becomes available, additional changes may need to be made to the risk assessment data
analysis.
For a discussion of the domestic well sampling program, see the response to comment S-4.
Comment:
s-11 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. ·
Response:
As stated in the response to comment S-3, the following figures will be copied from the RI:
RI Figure 2-1: Soil Sampling Locations
RI Figure 2-2: On-site and Near Off-Site Monitoring Well Locations
RI Figure 2-3: Off-Site Deep Monitoring Well Locations
RI Figure 2-5: Surface Water Sample Locations
RI Figure 2-6: Sediment Sampling Locations
RI Figure 2-7: Fish Sampling Location Map
In most cases, pentachlorophenol is found in higher concentrations in the on-site samples. This
statement will be added to the revised risk assessment. ·
Comment:
S-12 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
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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 reslstent to
bloremediation 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.
Response:
Section 6.3.2 of the RAGS (page 6-11) specifically allows for the evaluation of degradation in the
exposure assessment. We believe that it is appropriate to include degradation factors in risk
assessments. Section 5.4 of the risk assessment contains a discussion of the impact of
degradation on the overall site risks. As stated in this section of the report, removing
degradation from the analysis does not increase site risks to unacceptable levels.
We will expand this discussion in Section 5.4 about the affects of degradation on estimated
potential risks and present a summary of the estimated potential risks, with and without
degradation.
The discussion in Section 2.5 (the discussion of the degradation rates) will also be expanded to
include the equations used to derive the rates, a review of the literature from which the
degradation rates were taken, and a discussion of situations in which the rates may be
overestimated and the situations in which degradation may be underestimated.
Comment: _
S-13 Pages 4-4 and 4-5, Ingestion of Groundwater Section.
The argument 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 Beazer 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 the scenario.
Response:
The argument on pages 4-4 and 4-5 about ground water quality in the report is valid. The
argument states that on-site ground water will not likely be used as a source of drinking water
because of poor quality is true for on-site ground water wells. It appears that'there was some
mis-interpretation of this. This argument was not intended for off-site ground water well use.
This will be made more clear in the revised risk assessment.
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A statement about the potential for use of off-site wells as a drinking water source will be added
to the revised risk assessment. We believe that off-site wells will not be used as a potable water
supply. The domestic wells currently being used as a potable water supply near the site have
been and continue to be tested for selected constituents. All potentially impacted wells have
been closed (for drinking water use) and the residences have been hooked up to city water lines
or have been provided with bottled drinking water. Because these residences will remain on city
water lines, both current and future off-site drinking water scenarios are not potential exposure
pathways. The only potential exposure pathways via off-site ground water ar~ from yard use of
ground water. Two potential yard use pathways were evaluated in the draft risk assessment,
incidental ingestion during yard use and consumption of vegetables watered with off-site ground
water.
In addition, if off-site consumption of ground water as drinking water was added to the risk
assessment, the assumed potential cancer risks fall within EPA's target range near the point of
departure (101 and the potential hazard index is below unity, indicating no assumed potential
for adverse health impacts from exposure. (Also note that the cumulative ris.k for the potential
receptor in question, the local resident with the addition of ground water consumption as a
drinking water source, is still within the EPA's target risk range and the cumulative hazard index
is still below unity.) Thus, we do not believe that this additional scenario shoul.d be added to the
revised risk assessment.
Comment:
S-14 Page 4-6, Consumption of Vegetables Scenario.
Future onsite residents could also be exposed by consumption of vegetables
watered with onsite groundwater.
Response:
We believe that the site will not be developed as a residential property, therefore, we feel that this
additional analysis is not necessary. In addition, potential exposures to on-site ground water
were evaluated in the report as a direct pathway via consumption of ground water as drinking
water. Because: (1) drinking water exposures will be greater than exposures via vegetables
watered with ground water, (2) drinking water exposures showed an assumed risk for the
hypothetical on-site resident in the draft risk assessment, and (3) remediation of on-site ground
water is already being discussed; we do not feel that potential exposures to ground water via
consumption of vegetables is necessary.
We will add a statement explaining this in the revised risk assessment.
Comment:
S-15 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).
Response:
Absorption rate information will be added to Table 4-2. Note that this information is already in
the report in Appendix C-1.
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Comment:
S-16 Section 4.4.1, Paragraph 1.
From the information given, it appears that the Florence Leasing employees could
also be exposed to sur1ace 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.
Response:
Florence Leasing workers may also be exposed to surface soils on the site. Their potential
surface soil exposures will not, however, be in the areas of interest at the site.
The on-site worker scenarios evaluated in the draft risk assessment assume that on-site workers
are exposed to soils in the areas of interest on the site. The potential assumed risks to the on-
site workers were low, and the Florence Leasing worker's potential exposure to site soils is
expected to be even lower than the on-site worker's assumed exposure because fencing
currently prohibits Florence Leasing workers from gaining access to Areas A, B, C, and D.
Therefore, any potential Florence Leasing worker exposures to on-site soils will result in even
lower assumed risks than on-site workers. The text will be edited in the revised risk assessment
to state that Florence Leasing workers may contact site soils, but at a lower frequency than the
on-site worker scenario, and thus are not evaluated further in the risk assessment.
We will make the requested text edits, the highest RME values were used, not necessarily the
highest values.
Comment:
S-17 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.
Response:
When evaluating the potential exposure pathways at this site, ENSR called Dr. Elmer Akin at
EPA, Region IV regarding the exposure frequency for swimming and wading exposures on and
near the site. With Dr. Akin's approval, a frequency of less than 45 days per year was used in
this risk assessment because these surface water bodies are not anticipated to be used as
'swimming holes·. The SEAM (U.S. EPA, 1988) default value for swimming' (7 days per year)
was used in this risk assessment. In fact, the exposure frequency in question here is for local
resident's potential exposure to discharge streams and ditches on and near the site. These
surface water bodies are shallow and intermittent. It is impractical to assume a ·swimming·
exposure in these areas. Thus, 7 days (for 1 /2 hour per day) will, in fact, overestimate potential
exposures for wading in the discharge streams and ditches.
Even if an exposure frequency of 45 days is assumed, however, the potential assumed risks from
surface water and sediment still fall within EPA's target risk range and the assumed hazard
indices are well below unity.
RES_ 1. AAl, 0845-008-200 12
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Comment:
5-18 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 EPA ingestion rate of 200 mg
per day Is four times the rate reported by Clausing. The study information presented
does not support this statement.
Response:
The text will be edited.
Comment:
S-19 Page 4-13, Onslte 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 exposure frequency for
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."
Response:
Even if there are no institutional controls in place at the site, we consider it highly unlikely that
a trespasser will be on the site 48 days a year (12 days on each of four areas). In addition to
the 12 days (or 48 days requested by EPA), the trespasser is also assumed to be on the site an
additional day per year (surface water and sediment exposure to Fire Pond) in the current and
future scenarios and an additional 6 days per year (subsurface soil exposure) in the future. In
addition, the local resident is assumed to contact the discharge streams and ditches 7 days a
year for 17 years. If the surface soil exposure frequency is changed to 12 days per year per
area, and the Fire Pond exposures are increased to 12 days per year as requested by EPA (see
comment S-23), then the trespasser would be assumed to be on the site for 66 days a year in
some instances (with additional near-site exposure to discharge streams and ditches 7 days per
year). This frequency of trespassing is improbable. We recommend that the exposure frequency
for the trespasser remain unchanged.
Even if the frequency requested by EPA is used, however, the potential assumed risks from
surface soil exposure are all well below EPA's point of departure (10"1, and the hazard indices
for trespasser's assumed surface soil exposure are all well below 10·5_ Thus, we do not believe
that the change in trespasser surface soil exposure frequency is necessary.
We also recommend that the discussions about the controls that are in place remain in the
report to prevent mis-interpretations of this document by the public, but we will add a statement
to the report stating that the process requires evaluation of the site in the absence of any
controls, including institutional controls, and that the exposure frequencies used in this report
assume no controls.
RES_ 1.RAL 0845-008-200 13
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Comment:
S-20 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 strenuous
activity. It is not being conservative to assume a moderate inhalation rate for an
assumed moderate activity level.
Response:
The text will be edited as requested.
Comment:
S-21 Page 4-14, Paragraph 2.
The actual Fl 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 Fl term will be .016 as the text states.
Response:
See response to comment S-19.
Comment:
S-22 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 cannot be used to justify lower exposure
frequencies.
Response:
See response to comment S-19.
Comment:
S-23 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.
Response:
It is highly unlikely that a trespasser will be exposed to surface water and sediments 12 times
a year for 8 years. As stated in the report, it is assumed that the trespasser may approach Fire
Pond more than once per year, but it was assumed that the trespasser would contact surface
water and sediment only once per year for eight years. This was assumed because there is very
limited shore access to the Fire Pond. Even if the exposure frequency to surface water and
sediment in Fire Pond was increased to 12 times a year, however, the potential assumed risk
RES_ 1. RAL, 0845-008-200 14
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from surface water and sediments still falls within EPA's target risk range and the potential
hazard index still is well below unity. Thus, we recommend that the exposure frequencies in
question remain unchanged .
Also note, if the exposure frequency for the trespasser's assumed exposure to surface water and
sediment in Fire Pond is increased to 12 times a year, the total number of days that the
trespasser is assumed to be on the site will be 30 days under certain conditions (this assumes
that the exposure frequency for the trespasser to surface soil remains at 12 days a year, also see
comment S-19), or as many as 66 days a year under certain conditions (if the trespasser's
exposure to surface soil is increased to 48 days per year; also see comment S-19). It is unlikely
that a trespasser will be on the site 30 or 66 days in a year.
Comment:
S·24 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 rate.
Response:
We will expand the discussion of consumption rates to include our recent review of all of the
available literature on the subject. That review clearly indicates that an average freshwater fish
consumption rate varies from less than 1 gram per day to less than 3 grams per day. The rates
typically used by U.S. EPA either include saltwater fish and shellfish (in addition to freshwater
fish) i.e. the 6.5 grams, or are rates that are derived from large water bodies (i.e. 20, 30 or more
grams per day) not typical of those being evaluated here. Indeed, a recent study which focussed
on sportfishermen in Maine found that even that subpopulation, assumed to be highly exposed,
had average freshwater consumption rates of less than 6.5 grams per day. Please find attached
copies of a series of overheads that summarize the findings of our literature review. A written
summary of the review can be added to the final baseline risk assessment if' needed. To that
end, also attached is an excerpt from comments prepared by ENSR and submitted to EPA on
the fish consumption rates recommended in the Draft Bioconcentration document. If
Region IV agrees, these could be modified and included in the revised risk assessment to
support the consumption rates used in the draft baseline risk assessment.
Comment:
S-25 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 Fl term of .64 was used but an actual Fl of .16 was used to account
for the four areas of the site. The text should clarify this.
Response:
The worker's assumed risks were calculated before ENSR had a copy of the OSWER Directive
cited above. Thus, values for exposure frequency and exposure duration were based on best
professional judgement. Because the values used in the draft risk assessment are so close to
RES_ 1. RAL. 0845-008-200 15
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the values recommended in the OSWER directive, changing the worker evaluation to include the
EPA recommended values will make little impact on overall site risk.
The value used for worker exposure frequency, 235 days a year, represents a full time worker's
potential time on the site. The time away from the site represents weekends, vacation, holiday
and sick time. Even if we were to adopt the recommended exposure frequ~ncy of 250 days a
year, however, this would have no significant impact on the assumed risk to workers (worker
risks will increase by a factor of 1.06). It is also important to note that the highest risk to workers
(dermal contact with surface soil in Area 8) was at the EPA's point of departure (101, and all
other risks were well below this value. Therefore, we recommend that the worker exposure
frequency remain at 235 days a year.
A change to the worker exposure duration to 25 years will also have no significant impact on the
assumed risk to workers (risks will increase by a factor of 1.25 if 25 years is used as the
exposure duration). In addition, in this day and age it is unusual for workers to be employed in
a single business for many years. In the United States, the median tenure for employees in a
single occupation is 6.6 years (Statistical Abstract of the United States, Table 647). It is therefore
likely that both the assumptions of 20 years and 25 years are representative of the relatively few
workers who stay in a single occupation for an extended period of time: Thus, both are
conservative and will be protective of the majority of workers. Therefore, we recommend that
the worker exposure duration remain at 20 years.
Also note that all potential hazard indices for workers are well below unity. Whether the
exposure frequency and/or duration are changed to the EPA's recommended values, the highest
hazard index is still below 1 x 10-<.
The text (discussing the Fl term) will be edited as requested.
Comment:
S-26 Page 4-18, Paragraphs 1 and 4.
Another potential exposure pathway for the local resident Is via consumption of
contaminated off site groundwater. This pathway should be added to the future local
resident exposure scenario.
Response:
See response to comment S-13.
Comment:
S-27 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.
Response:
See response to comment S-24.
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Comment:
S-28 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.
Response:
The exposure frequencies used for potential exposures to outdoor soil for the future hypothetical
on-site resident represent "best guess values for children" presented in U.S. EPA, 1989 (RAGS).
The RAGS (U.S. EPA, 1989) reports the following 'best guess' values for children's time outside:
winter = O days /week
spring = 3 days/week
summer = 5 days/week
fall = 3 days/week
If one assumes that each season is 3 months long, and that each month is 4 weeks long, the
annual exposure frequency is calculated as 132 days per year. This is the value used in the risk
assessment for all age groups, not just children (future hypothetical on-site resident), potentially
exposed to on-site surface soils. Although we understand that because this site is in the south,
and therefore, children may also be exposed to surface soils in the winter months, the exposure
frequencies were taken from EPA guidance, and we believe that the total days of outdoor
exposure expected will still be close to 132 days per year for children.
Because children are likely to be outside for longer durations than adults, using this value for all
29 years of a hypothetical on-site resident's exposure is conservative. We belie.ve that this value,
not 180 days recommended by EPA, should be used in the risk assessment, but we will use 180
days if required. It is also important to note that, even if the exposure frequency is increased to
180 days per year, all of the potential assumed risks still fall below 10·5 and all of the potential
hazard indices fall below 10 ...
Comment:
S-29 Page 4-23, Paragraph 3.
Region IV Supplemental Guidance specifies 45 days per year for a swimming
frequency in the Southeast.
Response:
When evaluating the potential exposure pathways at this site, ENSR called· Dr. Elmer Akin at
EPA, Region IV regarding the exposure frequency for swimming and wading exposures on and
near the site. With Dr. Akin's approval, a frequency of less than 45 days per year was used in
this risk assessment because these surface water bodies are not anticipated to be used as
'swimming holes' .. The surface water and sediment exposures referred to in this comment are
for future hypothetical on-site resident's potential exposure to Fire Pond and are expected to be
limited 'falling in' exposures associated with activities such as exploring the shoreline or fishing.
In addition, there is limited shore access to Fire Pond. The SEAM (U.S. EPA, 1988) default value
for swimming (7 days per year) was used in this risk assessment. We believe that this exposure
frequency (7 days per year for 29 years for 2.6 hours a day) more than adequately assesses
RES_ 1.RAI...., 0845-008-200 17
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potential exposures to Fire Pond surface water and sediment. Therefore, we believe that this
exposure frequency should remain unchanged.
Comment:
S-30 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.
Response:
We believe that it is unlikely that future hypothetical on-site residents will contact ditch water and
sediment very frequently because these ditches are near road sides and rail road tracks and they
are dry for parts of the year. It was conservatively assumed in the draft risk assessment that
future hypothetical on-site residents would contact ditch water and sediment 7 times a year. This
value is the SEAM (U.S. EPA 1988) default value for swimming exposure frequency. We believe
that the exposure frequency used in the draft risk assessment (7 days·a year, for 29 years)
adequately evaluates potential risk to ditch water and sediment. Even if the exposure frequency
was increased to 12 days a year as requested by EPA, however, the potential assumed risk from
ditch water and sediment would only increase by a factor of 1.7, which results in assumed risks
that Are still within or below EPA's target risk range (surface water assumed risk would increase
to approximately 2 x 10 .. and sediment assumed risk would increase to approximately 9 x 10"7).
The potential hazard indices would still remain well below unity (surface water assumed hazard
index would increase to approximately 2 x 10·• and sediment assumed risk would increase to
approximately 1 x 10-6).
Thus, we recommend that the hypothetical on-site resident's exposure frequency to ditch water
and sediment remain unchanged.
Comment:
S-31 Page 4-24, Paragraph 2.
The fish ingestion rate for onsite residents should be increased to twelve meals per
year.
Response:
See response to comment S-24.
Comment:
S-32 Page 4-24, Paragraph 3.
The aquifer at the site is classified as Class II and therefore is c_onsldered 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 were using private wells until Beazer 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.
RES_1.RAl, 084>-008-200 18
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Response:
See response to comment S-13.
Comment:
S-33 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 be removed from this
document.
Response:
See response to comment S-13.
Comment:
S-34 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. '
Response:
Appropriate changes to the text will be made.
The current EPA dioxin cancer slope factor and the toxicity equivalency approach were used in
the report calculations. The current EPA dioxin cancer slope factor and toxicity equivalency
approach are under review by the agency. This will be stated more clearly in the report.
Comment:
S-35 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.
Response:
See response to comment S-13.
RES_ uw_ 0845--008-200 19
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Comment:
S-36 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.
Response:
The text will be edited to state that the Former Lagoon Area and the Eastern Area on-site ground
water may require remediation. The text will also be edited if necessary, and as appropriate,
based on the results of the revised exposure assessment, revised data analysis, and the
additional sampling that is planned for the site.
Comment:
S-37 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.
Response:
See response to comment S-12.
Comment:
S-38 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.
Response:
The text will be edited as requested.
Comment:
S-39 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.
Response:
See response to comment S-36.
Comment:
S-40 Figure 8-1.
This figure is irrelevant and should be deleted.
RES_ 1.RAL. 0845-008·200 20
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Response:
As discussed with EPA (9/12/91 meeting), we feel that this figure is relevant to the risk
assessment because this is a public document. This figure puts the myriad of numbers
discussed in the document into perspective for the non-technical reader.
Although we understand that EPA would like this figure removed from the document, and we will
remove it if required, we would like to propose and alternate solution to removing the figure from
the report.
We propose to expand the discussion of this figure in the report to emphasize that the risks
shown in the figure are not intended to demonstrate the potential assumed risks from the site
are acceptable, but rather, just to show the relative meaning of those potential risks. Indeed, we
will emphasize that the risks shown in the figure are intended to only provide a yardstick by
which to measure the potential assumed risks, and not to judge acceptability. (A copy of this
figure follows the response to comments, on page 27 .)
Comment:
S-41 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.
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 nitre-phenols should state the dermal and oral absorption rates which
were used to derive an AAF of 0.1.
Response:
Absorption rate information will be added to Table C-1.1. Please note that this information is
already in the report in the text of Appendix C-1.
The requested text edits will be made.
Comment:
S-42 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,
pregnenolone and progesterone. It is the current EPA policy to use the PC for water
if other data is not available for a chemical.
Response:
The permeability constants used in the risk assessment were provided to ENSR by EPA, Region
IV. Appendix C-3 of the risk assessment contains a discussion of these values. While reviewing
RES_1.RAL. 0&\5-008·200 21
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other EPA documents on permeability constants, the value 1.5 x 10·3 was found to be associated
with pregnenolone and progesterone, and not with the phenolic compounds to which this value
was prescribed by EPA Region IV. Our tex1 simply raises this as a question. Further research
can be made into the derivation of the permeability constants recommended by EPA Region IV,
and this information can be added to Appendix C-3 of the revised risk assessment.
The initial correspondence from EPA Region IV lists 1.5 x 10.:i as the PC for water. When using
a default PC, we have generally used the PC for water cited in SEAM (U.S. EPA, 1988) based
on the Blank et al. data (8 x 1 o-<).
Comment:
S-43 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.
Response:
This will be added.
Comment:
5-44 Appendix E-2.
The reference which is cited in the section for outdoor soil contact (US EPA, 1989d)
is not contained in the reference section for this section. Therefore, the exposure
frequency cannot 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-1n PAHs are not a contaminant of concern at this site.
Response:
We will add the requested reference (US EPA 1989d, RAGS) to the reference list and remove the
reference to PAH in Appendix E-2.
Also see response to comment S-28.
Comment:
5-45 Page 6-3, Section 6.17 Habitat Summary
Species should be chosen to represent the conifer forest, e.g. white-tailed deer,
Odocoileus virginianus.
Response:
Because of the high degree of human disturbance and lack of secluded feeding or resting
habitat, the Raleigh/Morrisville site is not likely to provide suitable habitat for white-tailed deer.
In spite of this, it is still possible that deer from suitable habitat elsewhere might visit the site
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sporadically and drink from the pond. However, the occurrence of this is likely to be extremely
low and the potential exposure of deer to the constituents of interest is very limited. By choosing
a mammal who is assumed to be resident on the stte and spend its entire life in the pond
(muskrat), ENSR has adopted a worse case situation in the risk assessment. It is not clear what
advantage would be gained by including a less highly exposed organism such as white-tailed
deer.
We will re-define the receptors as follows: Terrestrial Assessment = white tailed deer (a
qualitative discussion), and Riparian Assessment = muskrat and belted kingfisher.
Comment:
S-46 Page 6-3, Section 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.
Response:
We will contact the USFWS and edit the report.
Comment:
S-47 Page 6-4, Section 6.2 Receptor Characterization ·
I recommend using Micropterus salmoises, largemouth bass, instead of, or In
addition to lepomis macrochirus, bluegill, as a representative fish _species due to its
higher trophic position.
Response:
We can add an assessment of largemouth bass in Medlin Pond to the risk assessment report,
if required, although we do not think such an addition is necessary. The bluegill was chosen in
the draft risk assessment because bluegill were caught in both the Fire Pond and Medlin Pond
and largemouth bass were only caught in the Medlin Pond. In addition, more ecotoxicological
data were available for the bluegill than for the largemouth bass.
Comment:
S-48 Page 6-5, Section 6.2 Receptor Characterization
Add Anas platyrhynchos, mallard duck, as an additional avian indicator species.
Response:
The two main constituents of interest at this site, dioxin and pentachlorophenol, are markedly
hydrophobic (respective Log Kow values are approximately 6.5 and 5.5). Because of this,
virtually all biotransfer will be through the food chain (biomagnification), rather ,than direct uptake
from water. Thus, organisms at higher trophic levels will tend to accumulate.the greatest body
burdens. ENSR chose to carry out a risk assessment on a piscivorous bird_ (belted kingfisher)
because their position at the top of the aquatic food chain will result in maximum exposure to
the constituents of interest. Because of their lower trophic position, mallard ducks would not be
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likely to accumulate comparable body burdens of constituents. Also, because dioxin has been
shown not to be accumulated by vegetation, diet is not a likely exposure route for the
herbivorous mallard duck.
Therefore, by choosing belted kingfisher, ENSR has based its risk assessment on a worse case
situation and including the mallard duck is not necessary.
Comment:
S-49 Page 6-18, 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.
Response: .
It appears that for most compounds, EPA Region IV added a safety factor of 10 to the acute
criteria (LOEL values) used in the draft risk assessment. It.also appears that most of the U.S.
EPA Region IV chronic values were derived by applying a further factor of 10. For the chronic
values for phenol, it appears that EPA added a factor of 10 to the value used in the draft risk
assessment; it is not clear how the values for pentachlorophenol were derived and ENSR would
like to review the source material used by EPA Region IV to arrive at their criteria.
In general, ENSR does not agree with the way in which EPA Region IV has applied these 'safety
factors'. Whereas the data presented as criteria in the draft risk assessment have a scientific
basis (they are derived from toxicity tests), the safety factors are entirely arbitrary and have no
scientific basis. Furthermore, ENSR's criteria are based on LOELs; these should be sufficiently
protective of the organisms at potential risk.
ENSR suspects that the dioxin criteria proposed by EPA Region IV are not appropriate for the
aquatic systems on the Raleigh site. This is because it is likely that the criteria were developed
using primarily the results of toxicity tests on cold water fish. Such fish are more sensitive to the
effects of dioxin than the warm water fish which inhabit the ponds of interest at this site. Before
accepting or rejecting these criteria, ENSR would like to review the data upon which the EPA
Region IV dioxin criteria are based.
Comment:
S-50 Page 6-9, 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.
RES_ 1.RAL. 0845-008·200 24
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Response:
We will change the Section titles as follows: Terrestrial Assessment = white-tailed deer, and
Riparian Assessment = muskrat and belted kingfisher.
Comment:
S-51 Page 6-9, 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.
Response:
ENSR agrees that it would be very valuable to be able to model population and community
responses to the site constituents of interest. As· yet, however, neither the theoretical
underpinnings nor the technical methodologies exist to carry out such analyses. If the reviewer
knows of such a methodology, ENSR will be glad to review it and, if it is suitable, include it in
the Raleigh risk assessment.
As an alternative, a paragraph will be added to the revised risk assessment stating that adverse
population effects are not anticipated given the negative results of the individual receptor
assessments.
Comment:
S-52 Page 8-2, 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.
Response:
The changes will be made if and as appropriate.
RES_1.RAL, 0845-008--200 25
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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
2,3,7,9-TCDD
RES_ 1. RAL. 084f>.008.200
1020
438
212
202
3
32
62
828
23
3.23
0.1
APPENDIX I
Chronic Screening Criteria
ug/1
26
256
43.8
21.2
20.2
0.3
3.2
6.2
82.8
2.3
2.10
0.00001
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IU&k Of IHIGll'I
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1 in 100
10'
IE-02
I
1 in 1,000
10-'
IE-03
1 in 10,000 I
1()"''
IE-04 I
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1 in 100,000
104
IE-05
1 in 1,000,000
104
IE-o6
1 in 10,000,000
10-'
IE-07
So..«it: EPRI Jovff\al (Jl.ll)'IAug1a11aea,
o«~
SMtnan
Race car clri-
Rn,man
Minar
F.,._
Poiceman
Trud< clri-
Banker
Engineer
Insurance_,,
Umtyle
I
I I I Smoking
(one paella day) I I
I Heavy clrinmg
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I I Umg contra<:epti"" pills I
11 Light clrinmg JI
I I I Diagnostic X-<ays
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I Smalpox vaccinalion
(pa occasion)
I Eating c:11arooa1_-1>roiiod
I steak (one a week)
27
A.cddenta Environmental lisb
Skydving I
Rod< climbing I
Canoeing
Driving motor vehicle
All heme accidenll
F""""nt air travel .
Substances in aitvog
water
Skiing I lMng down1tre1WT1 ol
Home 619 •dam
I I I Natlnl bed<groind
Fishing raclation
Poisoning I
Occasianal ... lnMII
(one light • )'8ar)
I HurTicane I I Tornado I
I Lightning I
I Animal bile Of I Insect sting
FIGURE l•I
Putting Risk in Perspective
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ATTENDANCE LIST FROM THE SEPTEMBER 12, 1991 MEETING BETWEEN:
RES_ 1.RAL. 0845--0Q8..200
EPA, REGION IV
BEAZER EAST, INC.
KEYSTONE ENVIRONMENTAL, INC.
ENSR CONSUL TING AND ENGINEERING
28
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D ~~'-\ ~O'f
.j,(. ~\,,~A.<
U -p~ 4"~~~
I ~~.,. Al\c.~
k "-r '<YI<: t)\1,\1cA,1r,,6.\ l~Cli. \ C..:.·)
~~~Q..
ll
o-f)(µ_._c-,-._ CR.A,9 I /3.~ ~·
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~ UNrT£0S'TATt5
CNVlAONICHTAL f"ROTCC'1'lCl'il AGDtC'V
REG,ON flt
LYNN H. WELLMAN
WASTI, MA .... GIMIMT 0,.VISION
[COU)G,CA.L R1$1l As.llHMl•n
Tll..l"I-IONII
34!5, Cou,nl,,.4.NI) ST•tH'T. N.IL ~ 3,,17.1 ~
AT\..AHTA.GlOIIGIA ,03&5 .-TS) 257•1~
29
4tJ+ j 31.ff -11'1 I
•• ..;. I .j-p(.
ll ~ /S~lp
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,r-1;;-~;;;-;-.7b8't-
4,J"t /J'f 7-71 e,;
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Comment:
G-2
G-9
G-10, S-3, and S-11
PROPOSED FIGURES TO BE COPIED FROM RI'
RI Figure:
This will be discussed with EPA.
1-1: Site Location Map
3-5: Regional Geologic Map
Appendix E: Zoning Map for Morrisville, NC, and
Updated Land Use Study Map
2-1 : Soil Sampling Locations
2-2: On-site and Near Off-Site Monitoring Well Locations
2-3: Off-Site Deep Monitoring Well Locations
2-5: Surface Water Sample Locations
2-6: Sediment Sampling Locations
2-7: Fish Sampling Location Map
1 Reduced photocopies of these figures are attached (except the figures from Appendix E
of the RI because they are too big).
RES_ 1.AAL. 0845-008-200 30
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Reference: t
U.S.G.S. 7.5 Minu1e Topographic Map -N-
I. 197.3 Photo Revised 1987 I Cary, North Caro ina,
Scale 1 • • 2000'
I 31
FIGURE 1 • 1
SITE LOCATION MAP
BEAZER EAST, INC.
MORRISVlllE, NORTH CAROLINA
--
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0
11!!1!!! l!!!!!!I
LEGEND
D Upland Sediment (up)
/ _....~ . .-j OlaboH (db)
LJ Fonc;,lom•rote (f91}
D Sondstone-Uud•ton• (H-me)
f==:J Llm•aton• ond Chert (la-ch)
Adomelllte (od)
U.tovol_Fonl~ ond UetoMCflmentory
Rock■ t,nv■)
t.tlco and Hqmblf"d• en.la■
and Sc:hl■t {m9■}
Amphlbolile (om)
Injected Onel11 ond Schl1t (lte)
1--. ·•1 Fel■lc Gn•IH ond Schl■t (f9e)
cm-1km
2 3 5 ml.
Reference
Porker. 1979. Geology and Mln•ol RHaurce•
of Woke County, N.C.G.S. Bull. 88
l!B!I 1111!1 ==
A
liiilll lilii1. -
Figure 3-5
Regional Geologic Uop
liliilll
Former Koppera Sile. Uorrisvllle, North Coronno
-
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CIiio
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0
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... •••
l:::,, SUAf<A~ SOIL UJiF\.I,_ LOCATION
,A SOIL 80AIN8 LOCATION
... ... ...
U4
Cl
FIGURE 2-1
A, (IAQ(IA(Jl.Nj BOIL IKIAI,_ LOCATION
•••-N:AZ•R IA■T. INC, ~TY 9l:IUNDN'll'
....,L ______________ ....;:-::·::·=-:.!'"'~•~•_!•~"""~'"""~•.!"~"'· ~• ua~••~"'..c"°~""~•~••,:__ _____ ,:__ ______ Jl:Dlilll.-----Wll:lllllll
.:AU G'!ETI \~1~~
O lOO NO
5'1/L SAIIPL/N6 LIJCATID/111$
FOR/IIIER KIPPERS ca,pANY. INC. SI"
IIEAHR EAST. J'NC. ,,.,,,,usni.LE. /ltC
--
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--·-
=
/IIKNIITORIN6 lt£LL LOCATION
BEA.lER £A$f. INC. PROP€RTY IIOt.AOAllr'
LNIT STRUCTURES INC, PROPERTY Bl'JUVJAR'I
NOTE:
IIELL Plf/ IIAS UTILIZED AS
A PU#'/N6 TEST /ELL,
• • •
• _, 0
0
•
0
---1111!
BCAU cnnl
0 1110 l00 4190
l!!!!!!!!I m!I
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ICINITDRII# #ELL L(>CAT/0#$
nJltlER 1<01'Pt'R$ C(Jl#fll,ll(Y. /'NC. 6/1'
MALtR EAST, /'NC,
fllORIIISY/LU. NC
iiiil
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... OH-Silt OHP M()NJl(IIIJHG ..:ll lOCA!I0-1
_.,..,._ ~It SlAIJCTUAf.S INC. PRoPfl-llY flOUt«lAR~
D ....
♦ Cl7C
1!!1!!!11
• • CIIC CIC
CIOC
CMRCHST'RE£1
lliiiil -111111
FIGURE 2-3
OFF-SITE' D££P NON/TORh#
CIIC KEYSTONE /ELL LOCATIINS ♦. ,,r.,,,. ICALI! (JFttT1 ~ KIJIIIPER$ CONOtUtY. INC. $/Tr ' --& --· NAllR TASf, f,C, _..-' ""' L~·::_ __________________________ ~•:_~-~~-~~-~----------------.l;m1Z111...--:::'~s:.:."::'.::"::....'/C:...Jla:Diml
- - --l!!!I!!! !!Im
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FIGURE 2-~
SUIFACE _,TF'1 ~£ t«ATrDltt$
FOllf/lE'R KOPPE'RS COIAUIY. /Nc, sr"
.C,UCII £AST. INC.
_,,,,,/Sll/tU, NOl'lfN C,.__PIM
liiiiiil
- - - - -·-- --l!!l!!!!I l!l!!!!I --== ail --lliil iiiil
• • • □
CJ
•
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••-•~O• 100' IIJUIHUII
FIGURE 2-6
snJINENT SUPC.IMS l.OCATIIJ/llt$
F()Rlft.,I KOPPERS COlttP4NY, INC, strr
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0 2000 4000
Reference:
U.S.G.S. 7.5 Minute Topographic Map
Cary, North Carolina.
1973 Photo Revised 1987
t
-N-
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FIGURE 2-7
FISH SAMPLING LOCATION MAP
FORMER KOPPERS CO., INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
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OVERHEADS THAT SUMMARIZE REVIEW OF FISH CONSUMPTION STUDY DATA
(Supplement to response to comment S-24)
RES_ 1. FIAL 0&4 5-008-200 39
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- - - - - - - - - --I!!!!! 11!!1!1 --lliliilil -&iii iiiil
Summary of Existing Freshwater Fish
Consumption Data
Sports Fishermen -Non-Great Lakes Surveys
• Consumption Rates are Less than for
Great Lakes
~ • Less than 3.3 grams/day in Michigan
• Less than 10 grams/day in Ontario
• 1.2 to 5.9 grams in Maine
-- - - - - - - - -l!!!ll!!IJ I!!!!!! 1!!1111 == ---l&il liiiil
Sports Fishermen -Great Lakes Rates
• Large Waters More Productive
• Large Waters Have· More Diverse Species
~ • Large Waters Fished Over Several Seasons
....... ~4'0200.110
-----------l!!!!!l!!!!!!I IIB!I l!l!lllll == ai 111111 liiiiil iiiil
Sports Fishermen
• Most Data from Great Lakes
• These Surveys Find Mean Rates of 10-30
grams/day ·
• Should Not be Extrapolated to_more Typical
Freshwaters
MmO'I.'°"' ....... '''
- - - - - -. - - - - -l!!!!!l!!!I 1!11!!1 -== liaiil ---Iii-'
General Population Data
• Most Applicable to National Standard
• U.S. Per Capita Freshwater Fish
Consumption Rates
Median
Mean
90th Percentile
99th Percentile
0 grams/day
1.5 grams/day
5.1 grams/day
23 grams/day
Overview of Fish Consumption Data
• 19 Surveys and Sources
• 11 on Freshwater Fish
fj, • Most Focus on Sports Fishermen and Great
Lakes
• Few Investigate· General Population
...a»'I.~ .....,..,,o
Conclusions
• National Mean Freshwater Fish Consumption Rate is
less than 2 grams/day
• Great Lakes Sport Angler Mean Freshwater Fish
Consumption Rate is between 10 and 30 grams/day
• National Sport Angler Mean Freshwater Fish
Consumption Rate is less than 6 grams/day
Summary of Consumption Rate Information for
Sports Anglers in Maine ·
All Water Bodies All Anglers
Median 1.1 grams/day
Mean (77th Percentile) 4.5 gram/day
83rd Percentile 6.5 grams/day
95th Percentile 20 grams/day
All Water Bodle& Only Angler& Who Eat Flah
Median 2.0 grams/day
Mean (76th ·Percentile) -5.9 grams/day
78th Percentile 6.5 grams/day
95th Percentile 24 grams/day
....,,"°"-...... ••a
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EXCERPT FROM COMMENTS ON THE FISH CONSUMPTION RATES RECOMMENDED
IN THE DRAFT BIOCONCENTRATABLES DOCUMENT
(Supplement to comment S-24)
RES_ 1.AAL. 0845-008-200 48
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VI Fish Consumption
Chapter 4 of the draft document references four levels of fish
consumption from the EPA guidance manual "Assessing Human Health
Risk from Chemically Contaminated Fish and Shellfish." These are:
6.5 grams/day to represent a low estimate of average
consumption of fish and shellfish from estuarine and
freshwaters by the entire U.S. population (consumers and non-
consumers) .
20 grams/day to represent a high estimate of the average
consumption of fish and shellfish from marine, estuarine, and
freshwaters by the entire U.S. population (consumers and non-
consumers).
165 grams/day to represent average consumption of fish and
shellfish from marine, estuarine, and freshwaters by the
99.9th percentile of the U.S. population consuming the most
fish or seafood.
180 grams/day to represent a "reasonable worst case" based on
the assumption that some individuals would consume fish at a
rate equal to the combined consumption of red meat, poultry,
fish, and shellfish in the U.S. (EPA Risk Assessment Council
assumption based on data from USDA Nationwide Food Consumpt.
Survey of 1977-78).
Of most concern, because of its wide use and apparent
inaccuracy is the "average" freshwater fish and shellfish
consumption rate for the general U.S. population of 6.5 grams/day.
Recent research conducted on consumption of freshwater fish by the
general population and sportfishermen support the use of a much
lower average consumption rate for the general population. The key
findings of this research are summarized below. ,
A. Consumption of Freshwater Finfish by the General
Population
A recent review of the literature on fish consumption (ENSR,
1991a) revealed little information on freshwater fish consumption
rates for the general public, although considerable data on
consumption of freshwater species by sportfishermen exist (see
Table 5) . However, one study by Rupp et al. ( 1980) provides a good
analysis of consumption rates of all fish types including
freshwater, saltwater, and shellfish by the general U.S. population
(for the entire nation and for specific regions; and for three age
groups). Rupp et al., whose analysis is based on data collected in
the 1973-74 National Marine Fisheries Service survey conducted by
NPD Research, report average, 50th and upper percentile consumption
rates for adults (ages 18-98 years) of:
49
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Consumption Rates ·(grams/day)
Ave. 50\ 90\ · 90\ Maximum
Freshwater finfish 1.5 0 5.1 23.0 158. 0
Saltwater finfish 10.7 7.3 23.7 57.6 179.1
Shellfish 3.6 0 11.0 31. 6 120.9
Total = 15.8
Rupp's freshwater finfish consumption rate for adults of 1.5
grams/day is clearly much lower than EPA's 6;5 grams/day for
freshwater and estuarine fish (including shellfish). Rupp's
breakdown of total fish consumption of 15.8 grams/day reveals that
only a small fraction (<10%) of total daily fish consumption by the
general population is comprised of freshwater finfish. The
breakdown also reveals that a significant fraction (70\) of the
combined freshwater and shellfish total is comprised of shellfish.
This supports use of a rate lower than the 6. 5 grams/day to
represent truly average freshwater fish consumption by the general
U.S. population.
It is interesting to note that Rupp's combined shellfish and
freshwater finfish average of 5.1 grams/day is about 20% lower than
EPA' s "average" rate of 6. 5 grams/day. Similar to Rupp et al., the
6.5 grams/day rate is also based on an analysis of the NPD Research
survey data (SRI, 1980). SRI's initial estimate of fish
consumption for all types of fish was 14. 3 grams/day for those
respondents who consume fish. Since this was representative of
fish consumers only, which were estimated to represent about 94\ of
the U.S. population, an average per capita rate was calculated to
be 13.4 grams/person/day (14.3 grams/day x 0.94). Elimination of
open ocean marine species from the total resulted in a combined
shellfish, estuarine fish, and freshwater fish consumption rate of
6.9 grams/day for people who consumed fish, and a per capita
consumption rate of 6.5 grams/day. Presumably, the difference in
the combined freshwater, estuarine, and shellfish consumption rates
derived by SRI (1980) and by Rupp et al. (1980) is due to differing
assumptions about which fish species are marine, freshwater, and/or
estuarine.
When.Rupp et al.'s data are used to construct a distribution
(lognormal) of freshwater finfish consumption for the general
population using Monte Carlo analysis, the expected or mean
consumption rate is 2.4 grams/day, and the upper 95th percentile
rate is 9.5 grams/day (see Figure 7). The U.S. EPA's 6.5 gram/day
consumption rate falls in the 92nd percentile of the distribution,
indicating that only 8\ of the general U.S. population consume
freshwater finfish at a rate equal to or greater than 6.5
grams/day.
50
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B. Consumption of Freshwater Finfish by Sportfishermen
Some data suggest that sportfishermen and their families may
consume, on average, more fish than reported by Rupp et al. for the
general population. While the upper percentiles of the general
population freshwater fish consumption distribution include
sportfishermen, a separate distribution of consumption rates for
this presumably more highly exposed group can be constructed. A
recent review of nine sources that focus on the consumption rates
of sportfishermen found average freshwater fish consumption rates
between 1.2 and 30 grams/day (see Table 5). Eight of these nine
studies pertain at least in part to sportfishermen living near the
Great Lakes. These rates are not applicable to smaller waterbodies
or rivers because of less productivity, diversity, and availability
of sportfish in smaller waterbodies.
A recent survey of freshwater sportfishermen in Maine found
that the average freshwater fish consumption rate varied between
1.2 and 6.0 grams/day (ChemRisk, 1991). For all anglers (including
non-consuming anglers) fishing on all types of freshwater bodies,
the mean consumption rate was 4.5 grams/day (77th percentile), and
the upper 95th percentile was 20 grams/day. For consuming anglers
and all waterbodies, the mean consumption rate was 5.9 grams/day,
and the 95th percentile was 24 grams/day (ChemRisk, 1991). For all
anglers and for consuming anglers on rivers and streams, the mean
and upper 95th percentile consumption rates were even smaller (a
mean of 1.2 grams/day for all anglers and a mean of 3,5 grams/day
for consuming anglers). These data reflect freshwater fish
consumption rates by sportf ishermen that are well below EPA' s
assumed rate of 30 grams/day. Yet, because they reflect fishing
patterns appropriate for locations with many smaller waterbodies,
they are more representative of freshwater fish consumption rates
by the large population of sportfishermen in the U.S. who do not
reside near the Great Lakes.
A recent survey of sportf ishermen in the state of Michigan
(West et al., 1989a,b) reported an average freshwater fish
consumption rate of 18.1 grams/day (adjusted, full-year estimate).
Using the mean and percentile data provided in the study, a
lognormal distribution was constructed using Monte Carlo analysis.
The resulting mean was 17.5 grams/day and the upper 95th percentile
rate was 54.8 grams/day (see Figure 8). ·
EPA' s recommended consumption rates for sportfishennen and
subsistence fishermen are 30 grams/day (50th percentile rate) and
140 grams/day (90th percentile for sportfishermen) respectively
(U.S. EPA, 1989a). EPA's consumption rates are based on studies by
Puffer (1981) and Pierce et al. (1981). Although both studies
looked at recreational fishing' population on the west coast, EPA
concludes that the values reported are representative of fish
"consumption rates for recreational fishermen in any area when
there is a large waterbody present " (U.S. EPA, 1989a). The
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recommended values are the average of the 50th and 90th percentile
values reported by Puffer and Pierce et al.:
50th Percentile 90th Percentile Reference
36.9 g/day 224.8 g/day Puffer (1981)
23.0 glday {est.} 54.0 glday {est. } Pierce et al.
(1981)
Average 30 g/day 140 g/day
EPA considers the 50th percentile value of 30 grams/day to
represent the average sportfisherman, and the 90th percentile value
of 140 grams/day to be applicable to intensive recreational
fishermen or subsistence fishermen (U.S. EPA, 1989a; U.S. EPA,
1990) . In fact, based on the Monte Carlo results, EPA' s rates
correspond with the 85th and the 99 .. 5 percentiles of the
distribution.
The draft EPA guidance references a 180 grams/day "reasonable
worst case" consumption rate, based on the extremely conservative
assumption that some individuals consume fish at a rate equivalent
to a combined consumption rate for red meat, poultry, fish, and
shellfish in the U.S. While the average U.S. fish consumer would
not consume freshwater finfish at this rate, it is possible that
intensive sportfishermen or subsistence anglers consume 180 grams
of freshwater fish every day. This rate corresponds to the 99.7
percentile of the distribution for the sportfishing population.
Finally, the use of fish consumption rates in establishing
RACs for bioconcentrable contaminants assumes consumption at the
daily rate for 365 days per year for 70 years, and that all of an
individual's daily fish diet comes from an affected water body.
These are obviously extremely conservative assumptions. In fact,
the U.S. EPA recognizes that few people spend their entire lifetime
in a single residence and has recently recommended reducing the
duration of potential lifetime exposure from 70 to 30 years (U.S.
EPA, 1989b). In addition, due to the wide availability of all fish
types, including non-native species, in local supermarkets, very
few people obtain all of their daily fish diet from one potentially
affected waterbody. A reanalysis of the data on consumption of
freshwater, saltwater, and estuarine species should address the
relatively low rates of freshwater fish consumption by the general
population, as well as the individual who is potentially maximally
exposed. It should also account for the fact that only a fraction
of the freshwater fish consumed comes from an affected waterbody.
52
!Ill == liliii iiiii -

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-

-

-
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Source,
GENERAL POPULATION
I. Cordle et ■I.
2. Rupp d ■I.
SPORTFISHING POPULATION
I. Co, d al. (On1arlo MOE).
2. Humphrey d al. (from Cordle).
). Klelm•n (EnYlron).
•· Rupp d ■I.
5. SUvcrman.
Table 5
Summary of freshwater Pi1b Consumption Data
Survey
o., ••
(1983)
(1980)
1989
1916
(1912)
(1915)
1983
undo<ed
(1980)
19~7
1973-7•
(1990)
1911
Mean
Consumption
(1/doy)
I.S
I.I
20.l
1•.1
)0
14
JI
7.7
0.5
18
,
Woterbody/State
Eight Ota! L.itu Stat ...
Nationwide.
s-i, Allonllc s1111 ...
All watcrbodlc,IOnl•rlo.
Orea.I Lakca/Mlchlgan.
All welo,t,odle&IOntar&o.
I.Ake Ontario/Ontario.
Columbia Rlver/Wolhlng,on.
I.Ake MlchlgwMlchlA■n,
All watcrt,od-1Mkhlgan.
-lliil -
liiiii --

-
-

-
--11!!!1!!1 == liiilil
Source
6. Weal et 1I.
7. W11eon1ln Div. or Health.
8. Smllh and En~cr.
9. ChemRi,k.
SUBSISTENCE ANGLERS
I. Krlcn cl al.
Notes:
Table 5 (Cont.)
Summary of freshwater fish Coosumption Data
Survey
Date•
1918
(1987)
1917
1990
(1911)
Mean
Consumption
(g/day)
18.J uudjulled
(Jen.-Junc)
12.J
0 (47.4")
3.J (77.9")
4.5 (•)
5.9 (b)
1.2 (e)
J.5 (d)
Median R11c1:
21 (before n1h advt•.)
2 (aOer O•h advl,.)
I 5 (ancr O•h aidvl1. ind
Olh auppllod for froo)
• -Dale• 1h11 rcnect publiceOon or communkellon nlhcr than 1urvcy dale •re cncloacd ln p■rcnthc1i1.
I -Mean no« reported: upper 90lh pcrccntUc con,ufflpoon rele w11 15.7 g/d.
(•) -All an,;lcn, ell watcn.
(b) -Consuming angJcn, all watcre.
(c) -All uglcr•. rlvcra/llrcam1.
(d) -Con1Umlng angler■, rlveu/91rcam1.
SUMTABFF.WKI
ENSR 1991
Wat.erbody/Stale
All wa1erbodlea/Mlchl9U1.
All welcrbodleal'WIK0n1ln.
Lower Titt1h1w1tee RivcrlMlchlgu.
All waterbodlea/Malne.
Jndlan Croek/AJ1b1ma.
iiiiil ..
•
I
I
I
I
I
I
I
D
I
I
I
I
I
I
I
I
I
I
I
FIGURE 7
Freshwater Fish Consumption Rate
General Population
.19 -...--------------------'---1,832
Expected Result = 2.4
14 .i--&.-----------Upper 95% = 9.5
~ . .., Maximum=131.1 ..,, ,
CD D ~ .09
D e
1-------------------4 916 C CD
EPA's Consurrption Rale :,
a.. I --11111 6.5 grams/day c2 .05,.. ---------=-------------'-458
.00
.99
~ .74 .., --~ .49
D 0 I.. a.. .25
.00
0.00
/
I
' -~
• .
0.00
5.00 10.00 15.00 20.00
Freshwater Fish Consumption Rate
General Population
,,,,. ...... -111111111
. Expected Result = 2.4 I -· Upper 95% = 9.5
: Maximum = 131.1
-·
>-~
'
5.00 10.00 15.00 20.00
55
9,856
0
..,, ,
CD D
C
CD :, n cc
I
I
I
I
I
I
I
B
I
I
I
I
I
I
I
I
I
•
::,') ..,
-D c:,
D
0 L. a..
::,') ..,
D c:,
.0
0 L. a..
.23
.17
.11
.06
.00
1.00
.75
.50
.25
.00
FIGURE 8
Freshwater Fish Consumption Rate.
(Sportfishing Population)
--,-----------------------2.267
0.00
..._
.
·-
0.00
EPA's Consu ion Rate
Sportfishermen • 30 g/day .
EJ:pected Resul • 17.5
Upper 95% • 54.8
Maximum • 358.2
EPA's Consu tion Rate --1--------='--.:;...c,~"-'"=-"-','.:;.;;:..------+~7
Subsistence Fishermen • 140 Q/day
100.00 200.00 300.00
Freshwater Fish Consumption Rate
(Sportfishing Population)
400.00
,, -,
CD D
C
CD :::,
0
IC
I I I I I I I 10,000
/,/"
-
100.00 200.00
56
Expected Resul • 17.5
Upper 95% • 54.8 •
Maximum • 358.2
-· •
-•
'
300.00 400.00
0
,, -,
CD D C
CD :::,
0
IC
I
I
I
I
I
D
R
I
I
I
I
I
I
I
I
I
I
I
I
•
..
References for Section VI
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Freshwater Fish by Maine Residents: Working Draft.
1991.
Rate of
March 8,
Cordle, Frank. 198 3. Use of Epidemiology in the Regulation of
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Puffer, H. 1981. Consumption rates of potentially hazardous
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Rupp, E.M., F.L. Miller, and C.F. Baes, III. 1980. Some results
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57
I
I
I
I
I
I
n
I
I
I
I
I
I
I
I
I
I
I
SRI. 1990. Seafood Consumption Data Analysis. Final Report.
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West, Patrick c., J. Mark Fly, Robert Marans, and Francis Larkin.
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58