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1. ATSDR > Public Health Assessments & Consultations

Table 1A. Groundwater Contaminant Summary and Comparison Values

Table 1B. Soil Contaminant Summary and Comparison Values

Table 1C. Soil Gas Contaminant Summary and Comparison Values

Table 2. Country Lane Trailer Park Sampling Data

Table 3. Area Groundwater Table

Table 4. Corco Chemical Sampling Data

Table 5. Meenan Oil Company Sampling Data

Table 6. K-Mart Fire Sampling Data

Table 7. Annual Cancer Rates--Bucks County and State of Pennsylvania

TABLE 1A

GROUNDWATER CONTAMINANT SUMMARY AND COMPARISON VALUES

	MAXIMUM CONCENTRATIONS
COMPOUND	PRIVATE	OTHER	COMPARISON		EPA
	WELLS	GROUNDWATER	VALUE	SOURCE	MCL
	(ppb)	(ppb)	(ppb)		(ppb)
Benzene	18	178	1	CREG	5
Carbon tetrachloride	NI/ND	17	0.3	CREG	5
Chloroform	142	1,880	6	CREG	none
1,1-DCA	NI/ND	3,476	none	none	none
1,1-DCE	NI/ND	2	0.06	CREG	7
Cis 1,2-DCE	NI/ND	4,500	70	LTHA	70
Trans 1,2-DCE	NI/ND	3,257	200	RfD	100
DCE N.O.S.	NI/ND	376	none	none	none
Ethylbenzene	NI/ND	1	1,000	Rfd	700
Lead	NI/ND	52	15	AL	none
Methylnaphthalene	147	NI/ND	none	none	none
Naphthalene	95	NI/ND	20	LTHA	none
0-xylene	32	17	20,000	RfD	10,000
PCE	175	1,600	0.7	CREG	5
1,1,1-TCA	625	450	200	LTHA	200
TCE	1,400	3,700	3	CREG	5
Trimethylbenzene	7	NI/ND	none	none	none
Toluene	NI/ND	356	2,000	RfD	1,000
Xylene	32	NI/ND	20,000	RfD	10,000

TABLE 1B

SOIL CONTAMINANT SUMMARY AND COMPARISON VALUES

COMPOUND	MAXIMUM	COMPARISON
	CONCENTRATIONS	VALUE	SOURCE
	(ppb)	(ppb)
Bis(2-ethylhexyl)phthalate	1,200	50,000	CREG
Chloroform	11	110,000	CREG
Cis 1,2-DCE	50	none	none
Ethylbenzene	130	70,000,000	RfD
Lead	14	none	none
PAHs, high molecular weight	1,674	none	none
PAHs, low molecular weight	1,154	none	none
PCE	116	36	CREG
PCBs	5,300	91	CREG
TCE	84	64,000	none
Toluene	450	140,000,000	RfD
Xylenes	890	1,400,000,000	RfD

ppb = parts per billion/micrograms per kilogram
DCA = dichloroethane
DCE = dichloroethene
PAHs = polynuclear aromatic hydrocarbons
PCBs = polychlorinated biphenyls
PCE = tetrachloroethene
TCE = trichloroethene
RfD = based on EPA oral reference dose
CREG = based on EPA oral cancer slope factor

TABLE 1C

SOIL GAS CONTAMINANT SUMMARY AND COMPARISON VALUES

	MAXIMUM	COMPARISON
	CONCENTRATIONS	VALUE	SOURCE
COMPOUND	(ppb by volume)	(ppb by volume)
Benzene	130,000	0.03	CREG
Benzene	130,000	2	EMEG (acute)
PCE	340,000	0.25	CREG
PCE	340,000	600	EMEG (acute)
1,1,1-TCA	3,000	300	EMEG (acute)
TCE	320,000	0.11	CREG
Toluene	240,000	4,000	EMEG (acute)
Xylene	10,000	none	none

ppb = parts per billion
PCE = tetrachloroethene
TCA = trichloroethane
TCE = trichloroethene
RfD = based on EPA inhalation reference dose
CREG = based on EPA inhalation cancer slope factor
EMEG (acute) = ATSDR Environmental Media Evaluation Guide for acute exposure

TABLE 2

COUNTRY LANE TRAILER PARK SAMPLING DATA

GROUNDWATER - Well Used For Potable Water Until April 1985

PRINCIPAL CONTAMINANTS	CONCENTRATION (ppb)
1,1,1-TCA	19
TCE	308
PCE	60
Chloroform	142
1,2-DCE	109
Benzene	18
Trimethylbenzene	7.2
Naphthalene	95
Methylnaphthalene	147
O-xylene	32
(9)

ppb = parts per billion
TCA = trichloroethane
TCE = trichloroethene
PCE = tetrachloroethene
DCE = dichloroethene

TABLE 3A

AREA GROUNDWATER QUALITY

IN DRINKING WATER WELLS

TABLE 3B

IN NON-DRINKING WATER WELLS

	PRINCIPAL CHLORINATED VOCs (ppb)
GROUNDWATER -From:	1,1,1-TCA	TCE	PCE	CHLOROFORM
Meenan Oil recovery well system by Cedar Lane
1985, 1986 samples	ND to 350	ND to 3,700	ND to 1,200	ND to 1,880
Corco Chemical monitoring wells by Cedar Lane
1982, 1985 samples 1990 samples	ND 5 to 25	2 to 19 186 to 214	ND to 11 1 to 431	2.2 to 3 1 to 77
(4, 14, 16, 26)
	PRINCIPAL NONCHLORINATED VOCs (ppb)
GROUNDWATER - From:	BENZENE	NAPHTHALENE	XYLENE	TOLUENE
Meenan Oil recovery well system by Cedar Lane	8 to 778	NI	NI	20.3 to 356
Corco Chemical monitoring wells	1 to 3	NI	17	6
(4, 14, 17, 26)

* = estimated value
# = sample is raw water, drinking water is filtered for this well
@ = maximum value reported by water authority without supporting documentation
ppb = parts per billion
NI = no information
ND = not detected
TCA = trichloroethane
TCE = trichloroethene
PCE = tetrachloroethene
VOC = volatile organic compound

TABLE 4A

CORCO CHEMICAL SAMPLING DATA

GROUNDWATER - Corco Potable Water Supply Well Used Until Late 1980s

CONTAMINANT	CONCENTRATION (ppb)
1,1,1-TCA	2
TCE	5
Chloroform	<1
(3, 14)

GROUNDWATER - Corco Monitoring Wells

CONTAMINANT	CONCENTRATION (ppb)
TCE	2 to 214
PCE	<1 to 431
Chloroform	2.2 to 77
Carbon Tetrachloride	6 to 10
1,1-DCA	4 to 5
1,1-DCE	1 to 2
Benzene	1 to 3
Ethylbenzene	1
O-Xylene	17
Toluene	6
Lead	52*
(2, 3, 18, 26)

SURFACE WATER - Lake West Of Corco From Which Corco's Cooling Water Is Withdrawn

CONTAMINANT	CONCENTRATION (ppb)
1,1,1-TCA	<1 to 2
TCE	<1 to 1.6
Note: No contaminants were detected in some periodic samples.
(3, 14, 19)

SURFACE WATER - Lake (East Of Cedar Lane) That Receives Corco Cooling Water Effluent

CONTAMINANT	CONCENTRATION (ppb)
TCE	2.8 to 2.9
PCE	1.8 to 3.4
Chloroform	1.0 to 1.1
Toluene	1.7 to 4.0*
Lead	3.9*
(4, 14, 21)

TABLE 4B

SEDIMENT - Lake (East Of Cedar Lane) That Receives Corco Cooling Water Effluent

CONTAMINANT	CONCENTRATION (ppb)
TCE	5*
PCE	8
DCE N.O.S.	10
Xylenes	4*
(21)

CORCO COOLING WATER EFFLUENT - Before Eliminating Key Contaminant Sources

PRINCIPAL CONTAMINANTS	CONCENTRATION (ppb)
1,1,1-TCA	0.9 to 3
TCE	3.1 to >1000
PCE	2.7 to >500
Chloroform	2.5 to >500
Cis 1,2-DCE	1.8
DCE (N.O.S.)	2.8 to 5.0
Ethylbenzene	1.4 to 11
Toluene	3.3 to 9
Xylenes	10 to 120
(3, 20)

SOIL GAS - Around Corco Facilities West Of Cedar Lane

CONTAMINANT	CONCENTRATION (ppb by volume)
1,1,1-TCA	3,000
TCE	320,000
PCE	340,000
Benzene	130,000
Toluene	240,000
Xylenes	10,000
(22)

SOIL GAS - Around Para Scientific Building And On Immediate East Side Of Cedar Lane

CONTAMINANT	CONCENTRATION (ppb by volume)
TCA (N,O.S.)	350
TCE	50,000
PCE	50,000
(22)

TABLE 4C

SOIL GAS - About 300 Feet East of Cedar Lane, At East Edge of Landfill

CONTAMINANT	CONCENTRATION (ppb)
1,1,1-TCA	Compound present but below quantitation limit
TCE	Compound present but below quantitation limit
PCE	300
(22)

SOILS - Around Corco Facilities West of Cedar Lane

CONTAMINANT	CONCENTRATION (ppb)
1,1,1-TCA	ND
TCE	5 to 84
PCE	84 to 116
Chloroform	7 to 11
Cis 1,2-DCE	5 to 50
Ethylbenzene	11 to 130
Toluene	20 to 450
Xylenes	95 to 890
Bis(2-ethylhexyl)phthalate	1,200
High molecular weight PAHs	1,674*
Low molecular weight PAHs	1,154*
Polychlorinated biphenyls	5,300*
Lead	14*
(21, 26)

MATERIALS - Corco Solvent Trap And Junction Box (Before Cleanout)

PRINCIPAL CONTAMINANTS	CONCENTRATION (ppb)
1,1,1-TCA	12,283
TCE	12,334
PCE	10,725
Chloroform	8,649
Cis-1,2-DCE	13
Acetone	107,801
Ethylbenzene	1,688
O-xylene	2,023
Lead	2,910
(22, 23)

* = estimated value < = less than stated value > = greater than value ppb = parts per billion TCA = trichloroethane TCE = trichloroethene PCE = tetrachloroethene

DCA = dichloroethane DCE = dichloroethene N.O.S. = not otherwise specified PAHs = polynuclear aromatic hydrocarbons

TABLE 5A

MEENAN OIL COMPANY SAMPLING DATA

GROUNDWATER - Meenan Recovery Well And Monitoring Wells

CONTAMINANT	CONCENTRATION (ppb)
1,1,1-TCA	ND to 250
TCE	ND to 3,700
PCE	ND to 1,200
Chloroform	ND to 1,200
Trans 1,2-DCE	23 to 1,300
DCE (N.O.S.)	200 to 300
Benzene	9 to 31
Toluene	20 to 74
(4, 12)

GROUNDWATER - Meenan Recovery System Discharge To Warner Lake (South Of Penn Valley Road)

PRINCIPAL CONTAMINANTS	CONCENTRATION (ppb)
1,1,1-TCA	ND to 450
TCE	ND to 3,222
PCE	ND to 1,600
Chloroform	ND to 1,880
Cis 1,2-DCE	ND to 4,500
Trans 1,2-DCE	5.7 to 3,257
DCE (N.O.S.)	376
Benzene	ND to 778
Carbon Tetrachloride	ND to 17
1,1-DCA	ND to 3,476
(4, 19, 24)

SURFACE WATER - Warner Lake (South Of Penn Valley Road)

PRINCIPAL CONTAMINANTS	CONCENTRATION (ppb)
1,1,1-TCA	16
TCE	48
PCE	92
Chloroform	ND
Trans 1,2-DCE	153
Benzene	191
Carbon Tetrachloride	1.5
1,1-DCA	4.0
1,2-DCA	109
Toluene	2.4
(4)

TABLE 5B

SOILS - Pennwood Crossing Property

CONTAMINANT	CONCENTRATION (ppb)
No organic compounds detected
(4)

ppb = parts per billion
ND = Not detected
TCA = trichloroethane
TCE = trichloroethene
PCE = tetrachloroethene
DCE = dichloroethene
DCA = dichloroethane

TABLE 6

K-MART FIRE SAMPLING DATA

FIRE WATER RUNOFF

CONTAMINANT	CONCENTRATION(ppb)
1,1,1-TCA*	ND to 330
TCE	ND
PCE*	ND to 1
DCE (N.O.S.)*	ND to 1
Benzene*	ND to 30
Dichloromethane*	ND to 47
Tetrachloromethane*	ND to 5
Pesticides	ND
Herbicides	ND

* VOCs identified in only one of several samples. Other samples showed no VOCs above detection limits that ranged between 15 and 150 ppb.

(10)

GROUNDWATER

CONTAMINANT	CONCENTRATION (ppb)
Various pesticides and PCBs	ND
VOCs (e.g., TCA, TCE, PCE, DCE)	NI
Note: 6 samples tested
(25)

ppb = parts per billion
ND = Not detected
NI = No information
TCA = 1,1,1-trichloroethane
TCE = trichloroethene
PCE = tetrachloroethene
DCE = 1,2-dichloroethene
PCBs = polychlorinated biphenyls
VOCs = volatile organic compounds
N.O.S. = not otherwise specified

TABLE 7

ANNUAL CANCER RATES--BUCKS COUNTY AND STATE OF PENNSYLVANIA
For men and women

CANCER INCIDENCE

Cancer Type	Bucks Co.		All Penn.
	Rate	SE	Rate	SE
All, men	354.60	12.50	412.50	2.40
All, women	318.50	10.50	345.80	2.10
Breast, women	103.80	6.10	98.90	1.10
Stomach, men	7.9	2.00	11.70	0.40
Stomach, women	3.20	1.00	4.70	0.20
Lung, men*	65.80	5.50	83.60	1.10
Lung, women*	26.40	3.10	31.50	0.60

CANCER MORTALITY

Cancer Type	Bucks Co.		All Penn.
	Rate	SE	Rate	SE
All, men	216.10	5.80	226.30	1.10
All, women	138.40	4.00	146.00	0.80
Breast, women	27.30	1.80	28.90	0.40
Stomach, men	7.30	1.10	8.40	0.20
Stomach, women	2.70	0.60	3.60	0.10
Lung, men*	69.70	3.30	74.80	0.60
Lung, women*	23.00	1.70	25.00	0.30
Reference: Pennsylvania Cancer Control Program

* In this table, lung cancer includes cancers of the trachea, pleura and bronchus.
SE = standard error
1985 cancer data, age adjusted to 1970 standard
All rates per 100,000 population.
Excludes cancers of the skin.

APPENDIX B -- RESPONSE; COMMENTS ON INITIAL RELEASE

The Falls Township Groundwater Contamination Petitioned Public Health Assessment (PPHA)--Initial Release--was provided to government agencies for review and comment. Written comments were received from agency personnel and two other persons. Comments and our responses are summarized in this section.

COMMENT 1:

The Country Lane Trailer park has been connected to public water.

Response:

The Initial Release PPHA includes this information.

COMMENT 2:

Termination of the Meenan Oil Recovery activities was approved by the Pennsylvania Department of Environmental Resources (PADER).

Response:

The PPHA has been amended to include this information.

COMMENT 3:

The landfill and oil reclamation area by Cedar Lane was investigated by PADER.

Response:

ATSDR reviewed landfill information provided by PADER. That information is consistent with what ATSDR presented in the Initial Release PPHA. Hence, the PPHA has not been amended.

COMMENT 4:

Para Scientific obtains its potable water from Corco Chemical's well.

Response:

ATSDR takes note that these companies are among the numerous current groundwater users in the study area.

COMMENT 5:

PADER issued an order to Corco Chemical in 1990 to conduct a groundwater study and to clean up soil and groundwater contamination attributable to their mishandling of solvents. Soil has been cleaned up at the neutralization box. PADER initiated further enforcement action resulting in a Commonwealth Court Order requiring groundwater remediation to begin no later than December 31, 1992. PADER continues to monitor Corco's compliance with that order.

Response:

This information has been added to the PPHA.

COMMENT 6:

The Bucks County Health Department issued a citizen advisory and tested many of the wells in the study area when the Country Lane Trailer Park well contamination was discovered.

Response:

This information has been added to the PPHA.

COMMENT 7:

Oil may never have been received at the oil reclamation facility; the reclamation facilities were removed.

Response:

This information has been added to the PPHA.

COMMENT 8:

When groundwater contamination was noted in 1985, the Bucks County Health Department investigated trucking companies for improper disposal of wastes. No significant violations were found.

Response:

This information has been added to the PPHA.

COMMENT 9:

On Page 14 of the Initial Release PPHA, consider that the levels of groundwater contamination observed near the junction of Penn Valley Road and Bristol Pike also might be related to the operation of Meenan Oil Company's recovery well.

Response:

ATSDR is not sufficiently convinced of such a relationship to include it in the PPHA.

COMMENT 10:

On Page 22 of the Initial Release PPHA, consider that the maximum TCE level in wells is 1,400 ppb, rather than 308 ppb.

Response:

The information has been revised in the PPHA.

COMMENT 11:

Table 4B contains incorrect chemical concentrations for sediment in the lake east of Corco Chemical.

Response:

ATSDR's review of the reference document found the sediment chemical concentrations to be accurately presented in Table 4B of the Initial Release PPHA.

COMMENT 12:

EPA was scheduled to conduct an Expanded Site Inspection at Corco Chemical during FY 1993 and believed that the concerns raised in the recommendations presented in the Initial Release PPHA should be considered as part of that activity. (That activity has since been reconsidered and may not be implemented.)

Response:

The document has not been changed.

COMMENT 13:

The USX Fairless Works plant is nearby and released large amounts of coke oven and blast furnace emissions to ambient air for approximately 40 years (1952 to 1992). These emissions are a more likely cause of any lung or respiratory problems than groundwater.

Response:

ATSDR has received no information about coke oven and blast furnace emissions in particular or air quality in general. Although ATSDR does not dispute that air pollutants can contribute to lung and respiratory problems, this particular potential pathway cannot be evaluated. However, the contribution of volatilized organic compounds to air quality cannot be discounted.

COMMENT 14:

Many of the properties in the study area are still on septic systems.

Response:

The PPHA has been changed to include this information.

COMMENT 15:

The Delaware River is only a mile or so from the site--not several miles.

Response:

The PPHA has been changed to address this information.

COMMENT 16:

The Township of Falls Authority has made public water available to residents in their own containers at their Penn Valley pump station, about a mile from the site.

Response:

The PPHA has been changed to include this information.

COMMENT 17:

Concern was expressed that the Initial Release PPHA was released to the public, prior to its intended publication.

Response:

This is a comment on ATSDR procedure, rather than on document content.

ATSDR does not provide an Initial Release PPHA to the public-at-large. ATSDR provides an initial release public health assessment to the EPA, state environmental and health agencies, and sometimes local agencies that can provide comments to us regarding the technical accuracy of the our initial report. The initial release document is not prepared for, and is not intended for, public distribution. We expect first to receive comments about the initial release from the agencies and revise the document; that revised document then is released to the community for a public comment period of 30 days for their review and response.

COMMENT 18:

Several commenters reported that Para Scientific does not repackage chemicals--they buy and resell chemicals in the same bottle or container. Thus, Para Scientific is not subject to the types of accidental spills and releases that might commonly be associated with repackaging activities.

Response:

The PPHA has been revised in several places to more appropriately characterize Para Scientific's actual operations and any contamination implications.

COMMENT 19:

ATSDR did not contact all business owners to obtain information about facility operations and practices.

Response:

This comment addresses ATSDR procedure rather than health assessment content.

ATSDR staff obtained information about facilities operations from a variety of sources, including some of the business owners. Staff conduct inquiries until they believe their understanding of activities is sufficient to address actual or potential releases of chemicals and actual or potential public health implications.

COMMENT 20:

The community is requesting extension of the public water supply system to make it available to all residents in the study area regardless of their private well water quality. PADER and the Bucks County Health Department support this public need not as much for concern about the currently known VOC contaminants as for concern for health risks created by the use of shallow wells in an area dominated by on-lot sewage disposal systems. Water mains will be extended, possibly in 1993. Public funding is needed to help pay for the expansion.

Response:

The PPHA has been changed to indicate the water supply system will be extended and to expand on PADER's and the county health department's concern for shallow wells and on-lot sewage systems.

COMMENT 21:

Para Scientific Company was, prior to 1979, owned by the same principals who owned Corco Chemical. Under new ownership since 1979, the company leases a building on property owned by Corco Chemical Co.

Response:

The PPHA has been changed to indicate that the present owners of Para Scientific lease the building from Corco Chemical.

COMMENT 22:

The overall conclusion that the area groundwater contamination represents a public health hazard is inappropriate. Information is not sufficient to show that there was exposure to hazardous substances at levels that would be expected to cause adverse health effects. While a limited number of private wells were contaminated with hazardous substances, it was not made clear that the health impacts that might result from such exposure are in the form of potential long term risks. The degree of public health hazard created by that risk should be characterized as indeterminate.

Response:

ATSDR staff estimated cancer risks associated with exposure to groundwater contaminated with PCE and TCE at maximum levels found in private wells at the site, based on a 70 year exposure. ATSDR found that people had a high to very high increased risk of cancer related to exposure. Furthermore, ATSDR staff also evaluated cancer risks associated with a 15 year exposure, and at lower, more representative or "average" levels of contamination, and still found that people had a moderate to high increased risk of cancer. Although some residents have been put on public drinking water, a 15 year period is a reasonable estimate of exposure. Some residents are still using private well water and therefore are still drinking water that increases their risk of cancer. When evidence exists that exposures have occurred, are occurring, or are likely to occur in the future; and the estimated exposures are to substances at concentrations in the environment that, over the long-term (greater than one year), can cause adverse health effects to any segment of the receptor population, ATSDR policy is to consider that situation a public health hazard (42).

COMMENT 23:

ATSDR recommended systematic sampling of wells. A systematic sampling program to identify contaminated wells was performed by the Bucks County Health Department in 1985. Of the original 12 affected residential wells, 6 connected to public water or installed filters. In 1992, the remaining wells still in use were resampled to determine the current levels of contamination. The results of that 1992 testing show consistent and significant reductions in contamination. These data have been provided to ATSDR.

Response:

ATSDR has re-reviewed all private well data. ATSDR concurs that the comparative sampling described above shows substantive reductions in contamination. However, ATSDR believes that more of the wells in use in 1985 and in 1992 need to be sampled to evaluate past and current contamination exposures and has recommended additional sampling. Pertinent issues have been clarified in the PPHA.

COMMENT 24:

Commenter does not concur with recommendations regarding sampling of surface water, ambient air, soil gas, and fish. Based on the available information about current contamination levels and the restricted public use of the lakes nearest to the affected area, commenter does not believe the recommendations are consistent with the degree of hazard posed by these speculative-type exposure pathways.

Response:

Currently, there is little sampling data for surface water and soil gas and none for ambient air or for fish. Therefore, ATSDR is unable to demonstrate that adverse public health effects are not likely to result from plausible, potential exposure pathways associated with these media. ATSDR believes it is appropriate to recommend limited evaluations designed to provide information with which to evaluate these pathways. The PPHA has been revised slightly to clarify those recommendations.

COMMENT 25:

The PPHA fails to identify what resources ATSDR has to implement the recommendations or which federal, state, or local entity has to, or could, implement the recommendations.

Response:

ATSDR is not a regulatory agency, and ATSDR does not conduct environmental sampling it believes is needed to more fully evaluate public health issues. ATSDR is not sufficiently familiar with the jurisdictions and services of all federal, state, and local entities to forthrightly identify those that have to, or could, implement the recommended sampling. However, when ATSDR becomes aware that an agency is conducting or plans to initiate a positive, substantive activity that relates to public health, that information is provided in the Public Health Actions and other appropriate sections of the public health assessment. The PPHA has not been revised with respect to the resource issue.

COMMENT 26:

If contaminated groundwater is flowing to Van Sciver Lake, recreational users should be educated and warned. Why hasn't the Amoco Lake and Snipes Pit been tested.

Response:

ATSDR has recommended sampling surface water at the nearest lakes, including Van Sciver Lake, to determine whether any contaminants are present at levels of public health concern. Because of the large dilution factor afforded by water bodies and the tendency for VOCs to escape from surface water to the atmosphere, it is quite possible that any VOCs present would not be at elevated levels. Thus, education and warnings, without pertinent sampling data, would be inappropriate and possibly unnecessary.

COMMENT 27:

ATSDR considers the area a public health hazard--a category that is used for sites that pose a health hazard as a result of long term exposure to hazardous substances. Does "long term" mean from this point in time forward or commencing in the early 1970s.

Response:

Long term commenced when exposure began.

COMMENT 28:

PADER officials blame most of the chemical contamination on private septic systems. Who's checking septic systems?

Response:

ATSDR does not know whether septic systems are the source of most contamination and does not know who checks them.

COMMENT 29:

Why haven't all well users been informed individually along Cedar Lane, Corbin Lane, Old Tyburn Road, ??? Avenue, and Bristol Pike; and all residents on Wheatsheaf Road and farther south.

Response:

ATSDR would not be responsible for notification or for deciding whether such extensive individual notification is needed.

COMMENT 30:

There is no support for our problem; only stalling, more testing, and delays.

Response:

ATSDR has provided support for the "problem" in as timely a manner as possible. ATSDR responded to a citizens' petition to conduct a public health assessment, which evaluates releases of hazardous substances and whether short-term or long-term exposure to those substances might have adverse health effects. ATSDR has identified concern for long-term exposure to contaminants found in water at some of the private wells that have been tested. ATSDR is not convinced that all private wells in the study area are similarly affected. In ATSDR's opinion, additional testing is desirable to more fully evaluate public health issues, including: 1) selective testing of additional private wells in the area, and 2) testing of other environmental media to decide whether plausible exposures through those media might adversely affect public health. The PPHA has not been revised to reflect the comment.

COMMENT 31:

Water contamination is reported as not posing an immediate threat to residents. Yet contamination has been present during the 1980s and 1970s. Clarify "immediate" threat.

Response:

Levels are not sufficiently high to cause an adverse health effect from an acute (less than 14 days) exposure; one more day of exposure is not expected to make a significant difference in health risk. Hence the threat is not immediate. However, ATSDR would expect health effects, particularly cancer, to occur from exposure over the long term. For this reason the study area poses a public health hazard, and action is called for.

COMMENT 32:

Four sisters who lived in the study area for up to twenty years and were exposed to contaminants in drinking water expressed concern that they have produced six children born with very different birth defects (genetic defect with heart failure, deformed feet, immune deficiency, placenta attached to chest wall, absence of lung surfactant, defective colon) and have had numerous miscarriages. Are these adverse health effects a result of exposure to contaminants? They also are concerned because they still are of child-bearing years and are afraid of carrying any more children.

Response:

ATSDR considers this a community health concern warranting further discussion. This concern has been added to the Community Health Concerns section and a discussion of the concern has been added to the Community Health Concerns Evaluation section of the PPHA.

COMMENT 33:

Only one confirmed cancer case is mentioned in the PPHA. An individual identified 6 cancer cases by talking to neighbors. Although the information regarding additional cancer cases was obtained informally, it still merits investigation. Lung cancer seems prevalent in the area.

Response:

The one confirmed cancer case mentioned in the PPHA was part of the summary of medical records forwarded to this agency and therefore was included in the PHA as part of the health outcome data section. ATSDR recognizes that these records were not necessarily collected in a systematic manner and does not conclude that this case is the only cancer case in the study area. Other cancers reported to agency representatives are mentioned in the Community Health Concerns section. A reported cancer cluster was investigated by the PA Department of Health; more than one cancer evaluated in that study. The study found no excess cancer cases above the expected cancer rate; these results are described in the Health Outcome Data Evaluation section of the PPHA. It is important to remember that the average American has a one in three lifetime probability of getting cancer (43); that risk increases with age. Lung cancer is the most frequent type of cancer.

COMMENT 34:

We cannot locate the cancer cluster study mentioned in the Health Outcome Data section.

Response:

The PPHA has been updated; the reference for the cancer cluster study has been added to the References section above (#39).

APPENDIX C -- RESPONSE; COMMENTS ON PUBLIC COMMENT RELEASE

The Falls Township Groundwater Contamination Petitioned Public Health Assessment (PPHA)--Public Comment Release--was released for review and comment. The written comments received and our responses are summarized in this section.

COMMENT 1:

Page 6--There are 19 homes at Country Lane Trailer Park.

Response:

The PPHA has been revised to reflect this information.

COMMENT 2:

Page 10--Public water came to the study area in 1977. Connections were made at various times through the present.

Response:

The PPHA has been revised to reflect this information.

COMMENT 3:

Page 11--Census data should be updated.

Response:

Census data has been updated.

COMMENT 4:

Page 14--Delete in paragraph 3 under "Private Wells' the sentence "No private wells have been ..."

Response:

The sentence has been deleted.

COMMENT 5:

Page 14--Sentence in last paragraph beginning "Those data show that..." is confusing.

Response:

The sentence has been clarified.

COMMENT 6:

Page 45--In Table 1A, the NI/ND designation should be clarified so the reader knows whether there is no information or the compound was not detected.

Response:

Because of the limited explanatory information provided in many documents from which the data were obtained, ATSDR cannot reliably differentiate between NI and ND for many of the compounds. Therefore, no change has been made in the document.

COMMENT 7:

Page 45--EPA's MCLs should be listed in a separate column for easy comparison to public water supply regulations.

Response:

The table has been expanded to include MCL values.

COMMENT 8:

Page 49--Additional 1992 water quality data are available for a residence on Old Tyburn Road and can be verified by the Bucks County Department of Health (TCE = 0.4 ppb; Chloroform, 0.5 ppb; and 1,1,1-TCA, 3.0 ppb).

Response:

The PPHA has been updated to reflect that information.

COMMENT 9:

Page 49--The "Bristol Pike - farther south of Penn Valley Road" description is confusing, and it appears one 1992 sample should be moved from the "south" area to the "Bristol Pike -- farther south" area; this is of minor concern.

Response:

ATSDR has changed the description to "Bristol Pike - Penn Valley Road to Canal. According to a sample location map and other information provided to ATSDR, the only samples reported for that vicinity along Bristol Pike for 1992 were south of the canal--not north; thus, no change appears warranted.

COMMENT 10:

The commenter takes issue with the Agency's assessment that the "area" represents a public health hazard because (a) it is inappropriate to characterize the entire area based on the highest sample concentrations, regardless of the age of the sample; and (b) the health risk associated with contaminated groundwater in this area is no greater than that in numerous other areas where VOC's have been found, and in fact, the availability of a public water supply to the majority of the area residents has considerably reduced this risk.

Response:

ATSDR considers a site a public health hazard when evidence exists that exposures have occurred, are occurring, or are likely to occur in the future; and when the estimated exposures are to a substance or substances at concentrations in the environment that, upon long-term exposure, can cause adverse health effects to any segment of the receptor population. As is stated in the text of this document, ATSDR does not consider the entire area to pose a public health hazard but considers only those locations in the study area where groundwater in private wells contains contaminants at substantive levels to pose a public health hazard. Other areas where VOC's have been found to pose a public health hazard do not influence ATSDR's evaluation of this study area. The availability of a public water supply considerably reduces the risk to the majority of the area residents but does not eliminate the risk to those residents not receiving the public water.

COMMENT 11:

Page 28--the highest concentration of tetrachloroethylene (PCE) cited (60 ppb) was from a private well which was abandoned in 1985. More recent samples from active wells show considerably reduced levels.

Response:

ATSDR staff reviewed available data to respond to this comment and discovered that the maximum concentration of PCE in a private well was 175 ppb. This error has been corrected in the document and does not change our conclusions regarding health effects related to exposure.

The private well in which 60 ppb PCE was detected is only one of several private wells with PCE levels elevated sufficiently to pose a moderate increased risk of cancer for people ingesting the water regularly for many years. Although recent samples show considerably reduced levels, ATSDR considers the maximum recent PCE level reported (3.4 ppb) to pose a moderate increased risk of cancer for people who have been ingesting water contaminated at higher levels. Furthermore, recent sampling did not include all active drinking water wells. Also, regardless of present levels, the past levels of PCE in these wells are sufficiently high for ATSDR to consider past exposure a public health hazard.

COMMENT 12:

Page 29--we question the basis for the statement that "the level of TCE found represents a significant risk for persons ingesting water regularly for many years." As is the case for PCE (see comment 11 above), recent sampling has shown considerably reduced levels of TCE, thus reducing the risk associated with ingesting groundwater from this area.

Response:

While the reduction of TCE levels in groundwater from those wells which were recently tested does reduce the present risk associated with ingesting groundwater as compared to the risk of several years ago, ATSDR considers the maximum recent TCE level reported (13.8 ppb) to pose a moderate increased risk of cancer for people who have been ingesting water contaminated at higher levels. Furthermore, recent sampling did not include all active drinking water wells. Also, regardless of present levels, the past levels of TCE in these wells are sufficiently high for ATSDR to consider past exposure a public health hazard.

COMMENT 13:

Throughout the report the Agency uses "comparison values" to assess the health effects of drinking water. Comparison values are not MCL's. MCL's should be used as the standard for measuring health effects of drinking water.

Response:

The document has not been changed in response to this comment. Page 12 of the document reviewed by the commenter states that the agency uses comparison values to select contaminants for exposure and public health evaluation, and that discussion of a contaminant in the Environmental Contamination and Other Hazards section or in the Pathway Analysis section does not mean that it will cause adverse health effects through exposure. The agency does not use comparison values, as such, to assess health effects. However, whenever the estimated exposure dose and duration for an affected population exceed the dose/duration conditions for which comparison values were determined, the comparison values then also represent levels above which ATSDR might consider whether public health effects may result.

ATSDR is aware that public drinking water regulation is based on MCLs, and agrees that comparison values are not MCLs. ATSDR selects its comparison values through a protocol which considers several health-related standards (including MCLs) and guidelines. Note on Table 1, which has been amended to show MCLs, that ATSDR's comparison values are higher than, equal to, or lower than MCLs.

COMMENT 14:

On page 22, we agree that it may be unwise to extrapolate the improvement in groundwater quality noted in recent well samples to area wells that have not been sampled. However, it also is not fair to extrapolate contamination and health risk to those unsampled wells solely because they are in the study area.

Response:

ATSDR has not directly extrapolated contamination to unsampled wells; appropriate qualifying terms were provided in the discussion to address that possibility. For example, on Page 22 of the document reviewed we said that water in unsampled wells MIGHT be contaminated. We also have revised the toxicologic discussions to include qualifications of health issues that might relate to use of water from unsampled wells. Please refer to the Toxicologic Implications section to review these changes.

COMMENT 15:

We see no justification for monitoring Van Sciver and Warner Lakes.

Response:

ATSDR believes at least limited monitoring is relevant to understanding whether there public health might be impacted.

COMMENT 16:

We see no justification for interior air quality monitoring at Corco or at other businesses or residences in the study area.

Response:

ATSDR believes at least limited monitoring is relevant to understanding whether public health might be impacted.

COMMENT 17:

We see no justification for further soils sampling at either Para Scientific or the abandoned landfill east of Cedar Lake.

Response:

ATSDR believes at least limited monitoring is relevant to understanding whether public health might be impacted.

COMMENT 18:

Based on discussions with Corco, the lake west of their operation is not open to public fishing. We believe the presence of nonVOCs (PCBs) in one sample of subsurface soil near Cedar Lane does not justify a fish flesh or sediment study in this lake.

Response:

PCBs were found at low levels in all five soil samples taken on the property (depths ranged from "surface", 0-10", 0-12", and 6-12"); one sample was located between the main plant building and the lake. For ATSDR, this information suggests that PCBs are prevalent in surficial soils on that property and are subject to erosion into the lake. PCBs are considered highly toxic at relatively low levels; they are also persistent in the environment and accumulate in fish tissues to greater levels than are present in source materials. Although Corco reported to the commenter that the lake is not open to public fishing, the lake is not fenced and is readily accessible. Thus, ATSDR considers that fishing would likely occur without Corco's knowledge, and believes at least limited evaluations are warranted to understand whether public health might be impacted.

COMMENT 19:

Commenter objects to ATSDR saying that the Meenan fuel leak could be the predominant source of nonchlorinated VOCs in the groundwater.

Response:

ATSDR agrees that there is no basis for saying Meenan could be the "predominant" source of nonchlorinated VOCs in the groundwater and has eliminated that statement.

COMMENT 20:

ATSDR has not presented data that demonstrates the Meenan Oil fuel leak resulted in the direct migration of VOCs or soluble fractions of non-VOCs to groundwater at that location.

Response:

ATSDR believes that two facts--1) many components of fuel oil are at least partially soluble in water, and 2) a zone of fuel oil floated on top of the groundwater--are sufficient bases for making the statement without additional supporting data. The leak resulted in the floating oil layer that, in turn, facilitated release (migration) of soluble compounds into groundwater. ATSDR views the compound(s) released via that mechanism to be one component of the contamination reported in data for the monitoring wells and recovery system discharge--the other component includes any contaminants that migrated into the recovery area from other sources. ATSDR has modified information on Page 20 of the document reviewed to identify the floating oil layer and consequent release of nonchlorinated compounds prior to cleanup.

COMMENT 21:

There are no data that shows that the Meenan product had any impact on the private well in which nonchlorinated VOCs were detected.

Response:

The document reviewed has been changed to indicate that there is insufficient information to determine whether any VOCs that might be associated with the Meenan leak affected any private well.

COMMENT 22:

ATSDR failed to show that Meenan discharged groundwater from its recovery system pursuant to an NPDES permit.

Response:

The statement on Page 8 of the document reviewed; "A state permit limited ... ". has been modified to show that it was an NPDES permit.

COMMENT 23:

No data in the ATSDR report support a finding that workers at the recovery well were likely to have been exposed to VOCs from recovered groundwater and oil, primarily through inhalation and dermal contact. Experienced persons installed and operated the system. Without additional facts concerning procedures and air quality, ATSDR cannot make the finding set forth on pages 22 and 28.

Response:

ATSDR concurs it was inappropriate to indicate that worker exposure did occur. However, there is a strong potential for limited exposure to have occurred, even for experienced workers. Thus, Page 22 of the document reviewed has been revised to reflect the worker exposure pathway to be potential, rather than completed. No reference to this issue could be found on Page 28; hence the requested change on that page was not considered further. ATSDR reviewed information on Page 25, which reflected a potential for worker exposure to fuel oil. Thus, that information was not changed.

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