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1. ATSDR > Public Health Assessments & Consultations

Comment 51: Page 21 "A. Completed Exposure Pathways," "Off-site Groundwater"

When using 100 µg/l as the appropriate comparison value for chromium, as discussed above, no contaminants were detected at a level of concern in private well 2. Furthermore, considering that private well 1 has been disconnected, it cannot be considered to be a present or future completed pathway. The text should be revised accordingly so that there are no erroneous statements concerning completed pathways.

Also, Table 9 should be modified to show that private well 1 does not present an exposure threat and to delete private well 2 because there is no basis for concluding that there is a completed past, present, or future exposure pathway with respect to that well.

Response to comment 51: ATSDR uses a comparison value of 50 µg/L for chromium in drinking water. The text in the "Completed Exposure Pathways" subsection does not indicate that private well 1 represents a present and future completed exposure pathway. Table 11 (Table 9 of the public comment release petitioned public health assessment) has been revised to indicate that present and future exposure pathways, under "Off-site Groundwater," applies only to users of private well 2.

Comment 52: Page 22 "On-site Ambient Air"

The section discussing "On-site Ambient Air" appears to confuse issues related to on-site and off-site ambient air. All available data clearly show that on-site ambient air complies with OSHA limits. Accordingly, there is no basis for concluding that on-site workers are subjected to any risk that is different from the off-site ambient air pathway. ATSDR should clarify that on-site workers are not exposed in exceedance of the OSHA limits. The discussion concerning off-site ambient air in this section is confusing and highly speculative and therefore should be deleted.

During Pond 6 soil excavation, key contractor employees were monitored for beryllium exposures. No employee monitored was exposed to beryllium concentrations exceeding the OSHA criteria. During this period, no abnormal beryllium concentrations were detected in NGK's ambient air monitoring network. Accordingly, there is no basis for concluding that the continuing corrective actions will create any exposure risk.

Response to comment 52: ATSDR acknowledges that there are no data indicating that on-site workers are exposed to contaminant levels that exceed Occupational Safety and Health Administration (OSHA) limits. OSHA limits are established based upon exposures that would occur during a typical work week (i.e., 8 hours a day or a 40 hours a week). In the context of discussing on-site ambient air and worker exposures, ATSDR finds it necessary to identify the fact that on-site workers who live near the plant may also be receiving additional site-related exposures when they are at home, which would be in excess of the 40 hours a week upon which OSHA's health standard is based. ATSDR has record of individuals who have reportedly worked at the plant and lived nearby. In such instances, ATSDR's Cancer Risk Evaluation Guide (CREG) would apply.

Contrary to your comment that "there is no basis for concluding that on-site workers are subjected to any risk that is different from the off-site ambient air pathway," Table 10 indicates that on-site ambient air concentrations for beryllium are typically higher than ambient air concentrations just off-site.

Comment 53: Page 22 "Off-site Ambient Air"

In Table 7 the data has been incorrectly used in instances where there are multiple samples for a 7 day period. Typically, filters are changed weekly providing weekly beryllium concentrations. Occasionally, filters must be changed more frequently due to filter loading or equipment problems. NGK then provides EPA with separate concentrations for each filter, i.e. one representing the beryllium level for the first half of the week and the other for the latter part of the week. In tabulating the data, ATSDR has added these two numbers and reported the sum of the numbers as the weekly maximum. This grossly overstates the ambient concentration because concentration values are not additive. A more appropriate method would be either to select the higher of the two values, or to add the total mass of beryllium found on the filters and divide by the total volume sampled. Using the data in this manner would show that for the first two months of 1993 no sampling stations are above the comparison value. ATSDR should review all data to ensure that calculations have been made correctly.

Decreases in ambient air concentrations have occurred since process changes at the facility. ATSDR classifies these decreases as not "substantial," without basis. Recent concentrations for beryllium (see Table 7), if calculated correctly, would show that beryllium has been below the comparison value at all off-site sampling stations for the first two months of 1993. As can be seen from this data, even an insubstantial decrease lowers beryllium levels below the comparison value. Accordingly, ATSDR should conclude that there is not a reasonable likelihood of future exposures. This is particularly true in the long term considering the corrective actions being undertaken at the site.

As the Assessment notes (page 12), there are a number of chromium emission sources in the Muhlenburg Township and Reading area. It is thus inappropriate to state throughout the Assessment that there is a completed pathway for chromium attributable to the NGK plant. When the following beryllium concentrations are compared to chromium at the NGK sampling stations, it is apparent that the chromium concentrations detected are from a source other than NGK since there is no correlation between the beryllium and chromium concentrations.

The Assessment indicates that ATSDR "believes" that chromium exposures are occurring based upon a single chromium sample in 1991 that cannot be attributed to NGK's operations. This sort of speculation is unwarranted and unscientific, and the text should be revised to delete all references to chromium as a completed air pathway.

As an informational matter, only the melting furnaces and hot rolling operations were shut down during November 1992. Current plant operations include pickling, mechanical cleaning, slitting and anneal furnaces.

Response to comment 53: After again reviewing the original data sheets, ATSDR made some corrections and changes to Table 9 (Table 7 of the public comment release petitioned public health assessment). Most changes involved referencing the number of days monitors operated in order to obtain the concentrations reported. Prior to 1990 NGK Metals and its former owners reported the dates that air sampling began and ended. This practice was conducted even when filters had to be changed during the week due to filter loading or equipment problems. However, since that time NGK reported only the beginning and ending dates of the routine sampling week, even when filters were changed between those dates. Rather than adding the concentrations, as done in Table 7 of the public comment draft assessment (Table 9 in this document), ATSDR has reported the maximum concentration per number of days sampled. Instances where the actual number of days are not known, are referenced as such. In addition, ATSDR has updated Table 9 through 1994 and revised document text (pages 17-18 and 22), as necessary.

Ambient air data for 1993 and 1994 continue to reveal concentrations that exceed the comparison value. Comparison values are used by ATSDR as health guidelines to select contaminants of concern for further toxicological evaluation. Under the "Off-site Ambient Air" subsection in the public comment release petitioned public health assessment (page 22) it should not have been implied that the exceedance of the comparison value constituted a future pathway. A future pathway exists because there is a source of contamination, an environmental media to transport contamination, and a point and route through which a population can be exposed. Despite changes in plant operation, beryllium is still being detected in off-site ambient air; therefore, a future completed pathway is expected to exist.

Chromium has been detected in NGK's wastewater discharge (Table 7) and on-site subsurface soil samples (Table 2) as evidence that chromium has been a part of NGK's waste stream. Chromium air concentrations were revealed through sampling conducted at two on-site monitors (at ground level) and an off-site monitor during a five week period in July 1991 (see page 13 and Table 10). Reference 2, "Human Health Evaluation and Ecological Assessment", indicates an air exposure pathway for chromium through fugitive dust emissions from the Disposal Area Drain Field. Given the prevailing wind direction and close proximity of the Disposal Area Drain Field to the properly lines, ATSDR does not believe that fugitive dust emissions would remain on-site. The November-December 1992 data submitted in the above comment does not show any clear or consistent pattern (even with wind data for the dates sampling was reported)(9). However, since the second highest concentration in that data set is found at the R1 monitoring station, located adjacent to the site, it would not wholly support the commenter's notion that NGK is not a chromium source.

ATSDR has revised the "Site Description and History" (page 3) and the "Off-site Ambient Air" subsections (page 23) to properly indicate that only the melting furnaces and hot rolling operations were shut down.

Comment 54: Page 23 "Residential Soil"

ATSDR correctly indicates that the levels of beryllium detected off-site are below those that may occur naturally in the region. Also, as stated previously, the beryllium drinking water comparison value is overstated because beryllium has not been shown to be an oral carcinogen. Accordingly, it is not reasonable to conclude that there is a "particular concern" for off-site residents due to soil levels.

Response to comment 54: Beryllium in off-site surface soil is not expected to pose any public health threat, based upon ATSDR's current, further, toxicological evaluation of beryllium concentrations detected in off-site surface soil.

Comment 55: Page 24 "Off-site Soil"

As discussed above, the soil data for the residence where private well 1 is located is of questionable value. Also, as discussed by ATSDR, this soil demonstrates levels of contaminants equivalent to levels occurring naturally in the area. Because existing data show that no significant impact exists at the residence, ATSDR should not speculate that impacts may exist at other locations.

Response to comment 55: During recent off-site surface soil sampling, beryllium (as well as chromium) was detected at 11 other locations. Based on that data, ATSDR changed the "Off-site Soil" pathway from potential to completed.

Comment 56: Page 26 "Off-site Biota"

ATSDR notes that metals, particularly beryllium and copper, are not readily bioconcentrated. In fact, these metals are not readily absorbed, much less concentrated. Accordingly, it is extremely unlikely that any potential exists for exposure through the consumption of biota. The text should be revised to state that ingestion of biota does not present a significant potential for exposure. Also, the text should be revised to delete all speculation concerning ingestion (e.g. references to "contaminated food" when there is no evidence of same).

Response to comment 56: Under "Off-site Biota" in the "Potential Exposure Pathways" subsection (page 26), ATSDR has defined a potential pathway of exposure. That subsection contains discussion regarding the media, that are known to be contaminated, by which plants and animals (namely fish) may result in contamination and then be eaten by humans.

ATSDR has attempted to make readers aware of the fact that some metals are not readily bioconcentrated, accumulation of metals does occur. ATSDR would even agree that significant exposure appears unlikely; however, in the absence of actual data no definite public health determination can be made. Therefore, fish tissue samples are recommended to determine whether actual contamination has occurred and to evaluate whether any potential health threat exists.

Comment 57: Page 28 "PUBLIC HEALTH IMPLICATIONS," "Beryllium"

ATSDR clearly states that beryllium does not present a health concern in on-site ambient air, off-site ambient air, off-site groundwater and off-site soil. Considering that this directly addresses the concerns of the community, this conclusion should be included in the summary of the document.

It should be noted that ATSDR is incorrect in stating that EPA has developed guidelines for an ingestion cancer risk for beryllium. As discussed above, EPA has determined that there is no basis for concluding that ingestion of beryllium poses a risk of cancer. Considering that EPA has concluded that no ingestion risk exists, and considering that beryllium is not absorbed, there is no basis for concluding that the off-site residents at private well 1 have any increased risk of cancer. This is particularly true considering that the reported concentration of beryllium was not significantly higher than the Safe Drinking Water limit and that any exposure to well water has been eliminated with the connection of that residence to the public water supply.

Response to comment 57: Beryllium does not present a public health hazard, based on data reviewed, in on- and off-site ambient air, off-site groundwater, and off-site soil. The current summary reflects that conclusion.

EPA does have an oral cancer slope factor (4.3) for beryllium. This is discussed in the "Response to comment 46" (second paragraph) and in the "Ingestion Exposure" subsection (page 30). ATSDR's approach; however, is not one that relies solely on a single number, but considers numerous medical, toxicologic, demographic, and environmental factors in evaluating contaminant concentrations and the impact they may have on public health.

Comment 58: Page 30 "Chromium" and "Volatile Organic Compounds (VOCs)"

It appears that ATSDR does not find any existing health threat from exposure to chromium or VOCs, considering that private well 1 has been closed. ATSDR should clarify this point. This should also be reflected in the Assessment summary.

Response to comment 58: In the discussion of "Chromium" and "Volatile Organic Compounds," ATSDR mentions that an alternative water supply was provided and that the well is no longer used. ATSDR no longer believes that past exposures in private well 1 were likely to result in adverse health effects.

Comment 59: Page 40 "CONCLUSIONS"

Conclusion 2. Conclusion 2 is confusing considering that ATSDR appears to clearly indicate that existing data do not show a threat to health. Moreover, the major environmental improvements that are either completed or underway (e.g. upgrade of wastewater treatment plant, impervious capping of potential source areas) provide substantial additional protection. Accordingly, ATSDR should clarify this conclusion to indicate that existing data and site conditions show no threat to public health.

Conclusion 3. ATSDR appears to base its cancer risk assessment on a life-time exposure scenario. Considering that private well 1 has been closed, there is not a reasonable basis to conclude that there is an increased risk of cancer.

Conclusion 5. The statement concerning child exposure is purely speculative and should be deleted from this conclusion.

Conclusion 6. ATSDR presents an "extremely unlikely scenario" as a creating a "slight increase in cancer risk." Considering that EPA has concluded that the evidence does not support the conclusion of an ingestion cancer risk from beryllium, there is no basis to conclude that there would be an increased risk of cancer even under ATSDR's extremely unlikely scenario. Thus, this "conclusion" is speculative and should be deleted.

Conclusion 7. Existing data provide sufficient basis for ATSDR's "Toxicological Evaluation," which concludes generally that there are no present health risks. Accordingly, further data is generally not necessary.

Response to comment 59: Conclusion 2. Throughout the document ATSDR clearly and directly states that further data are needed in order to complete ATSDR's evaluation. Data gaps are listed on page 44 and the recommendations on page 45 indicate the data requested to complete this evaluation.

Conclusion 3. ATSDR has reevaluated the past exposure in private well 1 to 1,1-dichloroethene, as well as chromium, and has determined that no adverse health effects are expected. Conclusion 3 from the public comment release petitioned public health assessment has been deleted.

Conclusion 5. ATSDR has eliminated the hypothetical exposure used in Conclusion 5 of the public comment release petitioned public health assessment.

Conclusion 6. Although EPA does have an oral cancer slope factor for beryllium, ATSDR's current toxicological evaluation of beryllium in off-site soil indicates that no adverse health effects are expected. Conclusion 6 was not included in this document.

Conclusion 7. Although ATSDR believes that other media and exposure pathways appear unlikely to pose a public health threat, definite conclusions cannot be made about without fulfilling current data gaps.

Based on the data reviewed by ATSDR, additional data are needed to evaluate potential on-site soil, off-site soil, off-site groundwater, off-site sediment, and off-site biota pathways.

Comment 60: Page 42 "RECOMMENDATIONS"

Recommendation 1. These areas are being addressed by the RCRA corrective action measures currently being undertaken. Thus, additional surface sampling is not necessary.

Recommendation 2. Existing residential soil samples do not show elevated levels of contaminants. Considering that off-site ambient air does not present a health risk, there is no basis for concluding that off-site soils will be contaminated. Accordingly, off-site soil sampling is not warranted.

Recommendation 3. For the reasons discussed above, even under a worst case scenario, there is no basis for concluding that the soils at the private well 1 residence present a health risk. Therefore, there is no basis for further characterization of those soils.

Recommendation 4. The current EPA well inventory area covers a sufficient area to identify all wells with any reasonable potential to be impacted by the site. Accordingly, there is no basis for further efforts to survey wells. Moreover, as part of the RCRA corrective measures work, NGK will be pumping and treating groundwater.

Recommendation 6. The proposal to restrict non-NGK properties is vague and not supportable on the basis of groundwater data.

Recommendation 7. Upstream and downstream sediment samples were collected in Laurel Run during the RCRA Facility Investigation. See Table 8. These samples do not present a health risk. Thus, collection of more samples is not warranted.

Recommendation 8. ATSDR correctly notes that contaminants of concern that may be present in Laurel Run are not readily bioabsorbed. Therefore, there is no reasonable basis to conclude that fish in Laurel Run may be contaminated. Furthermore, if it is assumed as an extreme case that fish have absorbed some minimal concentration of contaminants of concern, no health threat is likely due to the low bioavailability of these contaminants.

Response to comment 60: Recommendation 1. The request for on-site surface soil sampling, though not as important now as when the draft assessment was written, based upon comments identifying the relocation and covering of the Pond 6 waste pile and pending remediation, is still recommended. This sampling should be considered in order to evaluate current contamination of on-site surface soil. Further, to evaluate the effectiveness of remediation and any future potential health threat, ATSDR recommends representative on-site surface soil sampling to establish a baseline subsequent to remedial activities. Recommendation 1 has been revised to reflect those needs.

Recommendation 2. Ambient air data is present only since 1979 and that data shows that beryllium is detected in off-site ambient air, although not at levels of concern. The likelihood for migration of beryllium through the deposition of air emissions and fugitive dust during the plant's operation (1935-present) warranted off-site soil sampling. Fifty additional off-site surface soil samples were collected and analyzed for beryllium and chromium. Those samples were evaluated and are not expected to result in any adverse health effects; therefore, Recommendation 2 was revised accordingly.

Recommendation 3. Recommendation 3 from the public comment release petitioned public health assessment has been deleted based upon ATSDR's current evaluation of off-site surface soil data.

Recommendation 4. Based upon the geology of the area, location of off-site wells monitored, and the concentrations of site-related contaminants found in those wells, ATSDR believes there is reasonable basis for recommending that the well survey be expanded as described in Recommendation 3 of this document (Recommendation 4 of the public comment draft petitioned public health assessment). Recommendations 3 and 5, of this document, are needed until the corrective measures described in the comment, or some other action, is taken to ensure the protection of public health from contaminated groundwater supplies.

Recommendation 6. Figure 8, in Appendix A, shows the EPA specified well inventory area. Properties between that area and the Schuylkill River (which is not completely shown on Figure 8) are also being referred to in Recommendation 5 (Recommendation 6 of the public comment release petitioned public health assessment). Although it is likely that the EPA specified well inventory area indicates the area of primary contamination, it is ATSDR's concern that migration could occur much further west and that contamination could be drawn toward the Schuylkill River. Geological factors, such as karst formations, which are not characteristic of uniform flow and migration, in part, give rise to ATSDR's concern. Tables 4a-4c, in Appendix B, show that the westernmost wells located within the EPA specified well inventory area (see Figure 8), contain varying concentrations of site-related contaminants. ATSDR does not believe that the data sufficiently shows the extent (west) to which contamination may migrate. Therefore, as an initial matter to address ATSDR's concern, Recommendation 3 has been made.

Recommendation 7. ATSDR is requesting additional sediment sampling primarily due the presence of "unusual sediment" that was collected and analyzed (see page 17 under the "Sediments" subsection), as a solution, in September 1991, several months after the most recent sediment sampling was collected (i.e., sampling conducted under the Resource Conservation and Recovery Act Facility investigation in June 1991).

Recommendation 8. The need for fish tissue sampling is based on community concerns which report that fish from Laurel Run have been consumed, as well as the fact that ATSDR attempts to consider the impact of multiple exposure pathways.

Most metals are bioconcentrated to some degree. The levels of metals concentrated in fish are dependent on any number of factors, including: the characteristics of the metal, availability of the metal, and types of fish and their feeding habits. Suckers are a bottom feeding fish, which increases their potential for contamination. Lead and copper in particular were detected in NGK's wastewater discharge at levels that warrant some consideration of the biota pathway. Therefore, ATSDR maintains its recommendation for fish tissue sampling.

Comment 61: That the dose/duration of beryllium is not as important to berylliosis, or chronic beryllium disease as a person's sensitivity.

"...individuals exposed to high concentrations over a shorter period of time could have a total lung burden of beryllium as great or greater than individuals exposed for a longer period of time to lower concentrations."³

"Some of the berylliosis cases at Lorain developed after many years of exposure, but most of them developed after relatively short periods. Of the 21 cases, 18 (86%) were employed for six months or less."⁴

"Chronic beryllium disease continues to occur in the nonoccupational setting and among bystanders in industry, masquerading as sarcoidosis. Because even transient or possibly low levels of exposure may cause disease, this case has important implications for how clinicians, industry, and' government agencies define the populations at risk of chronic beryllium disease."⁵

"Five workers at a precious metal refinery developed granulomatous lung disease between 1972 and 1985. The original diagnosis was sarcoidosis, but 4 of the workers were subsequently proved to have hypersensitivity to beryllium..." "Review of medical records of coworkers and extensive industrial hygiene surveillance of the plant demonstrated that 4 cases occurred in the furnace area where air concentrations of beryllium fume were consistently below the permissible exposure limit of 2 mg/m³."⁶

Response to comment 61: The final document includes reference to the potential for chronic beryllium disease to be misdiagnosed as sarcoidosis. It also points out the value of the beryllium lymphocyte proliferation test in distinguishing between the two diseases. All of the cases reported by Cullen et al. (1987) were occupationally exposed to levels in excess of the 0.01 ug/m³ standard for ambient air around factories. Generally, non-occupationally exposed individuals who develop chronic beryllium disease in response to very low levels of beryllium represent a hypersensitive subset of the population. The immune response of these individuals to beryllium is similar to an allergic reaction in that it appears to be largely independent of dose. The "safe" exposure level for such hypersensitive individuals is presently unknown and, practically speaking, may be unattainable. This hypersensitive subset of the population may someday be identifiable through specific biomarkers of susceptibility on their lymphocytes (33). However, research on the subject has not yet progressed to the point that would make that a practical option at this time (see response to Comment 39).

Comment 62: That the charts are confusing, and that the amounts of beryllium found in and around NGK are magnitudes higher than ATSDR's comparison values.

Instead of using all the different comparison values listed for the different elements, I tried to simplify by noting the amount above the comparison values when they were higher, and a percentage of the comparison values when lower. (I used "X Value" instead of "times comparison value")

Beryllium      2.12 mg/kg      10.6 X Value

This, the only surface soil, was found on a property considered to be upwind. The report seems to downplay the amount of beryllium found. That may be true, but if it is, why use the comparison values used throughout the report? The report is quick to point out when levels are below comparison values.

Please see addendum at the end of this report.

Arsenic		448.00 X Value
Beryllium		54,500.00 X Value
Cadmium		6.39 X Value
Chromium (total)		3.68 X Value
Copper		5.03 X Value
Lead		no comparison value (932)

GROUNDWATER ON-SITE
There were 22 tests done in Dec 1989 (10 shallow - 12 deep)
There were 13 tests done in May 1990 (7 shallow - 6 deep)
There were 4 tests done in Jun 1991 (2 shallow - 1 deep)
	shallow well	deep well
Antimony.......	12.27 X Value..............	7.83 X Value
Arsenic........	360.00 X Value..............	650.00 X Value
Barium.........	1.08 X Value..............	1.44 X Value
Beryllium......	82,625.00 X Value..............	68,875.00 X Value
Cadmium........	26.70 X Value..............
Chromium(total)	51.00 X Value..............	28.40 X Value
Chromium(IV)...	12.60 X Value..............	27.20 X Value
Lead...........	4.43 X Value..............	4.42 X Value
Manganese......	185.40 X Value..............	250.00 X Value
Nickel.........	3.37 X Value..............	3.14 X Value
Selenium.......	2.52 X Value..............	????
Thallium.......	Not Detected................	7.00 X Value
Vanadium.......	7.45 X Value..............	12.05 X Value
Fluoride.......	141.67 X Value..............	266.67 X Value
Nitrate........	52.40 X Value..............	3.70 X Value
1,1-Dichloroethene	550.00 X Value..............	133.33 X Value
Tetrachloroethene	7.14 X Value..............	5.71 X Value
Trichlorothene.	4.33 X Value..............	1.67 X Value
1,1,1-Trichlorothene	2.05 X Value..............	Below Value
Vinyl Chloride.	230.00 X Value..............	155.00 X Value

I would have liked to see the tests from the 80's included in this study as it may relate to diseases that start showing up in studies in the late 90's and beyond.

OFF-SITE

The problems seem to have been dealt with but serve to point out real potential health problems in the future regarding groundwater. As an example of just the beryllium alone:

Private Well 1	Beryllium .... 5.3	663 X Value
Private Well 2	Beryllium .... <5.0	625 X Value
Private Well 3	Beryllium .... NA	(NOT ANALYZED)
Reading Crest Well	Beryllium .... 47.0	5,875 X Value

I included the <5.0 figure for Private Well 2 because 1), it is certainly in keeping with sample values found in groundwater and 2), this symbol represents "contaminant was not detected at the reported value." I don't know what that means. I don't know who does the reporting and who can't detect it.

"...some of the contaminants analyzed for in off-site groundwater are too high." (page 15-paragraph 2)

"...new comparison values show that lower contaminant concentrations may be of health concern." (page 15-paragraph 2)

SURFACE WATER OFF-SITE
BERYLLIUM FOUND IN SURFACE WATER OF LAUREL RUN

DATE	µg/L	SITE
1-13-89	<1	125.0 X Value	US
	1	125.0 X Value	DS
12 - 89	ND	US-1
	2.7B	337.5 X Value	DS-1
	1.5B	187.5 X Value	DS-2
1-26-89	<1	125.0 X Value	US01
	4	500.0 X Value	DS01
	<1	125.0 X Value	DS02
	<1	125.0 X Value	DS03
05 - 90	ND	Not Detected	US-1
	ND	(detected limit	DS-1
	ND	not reported)	DS-2
10-15-91	1	125.0 X Value	US001
	1	125.0 X Value	US002
	<25	3,125.0 X Value	US003
	<25	3,125.0 X Value	DS001
	<25	3,125.0 X Value	DS002
06 - 91	<0.2	25.0 X Value	US-1
	<0.2	25.0 X Value	DS-1
	0.37B	25.0 X Value	DS-2
	0.92B	115.0 X Value	DS-3

Once again I included the "<" figures because this symbol represents "contaminant was not detected at the reported value." I don't know what that means. I don't know who does the reporting and who can't detect it.

BERYLLIUM AND MANGANESE FOUND IN LAUREL RUN ON 5-13-81
Beryllium ....	1000	125,000 X Value	US1
	2500	312,500 X Value	DS1
	1000	125,000 X Value	DS2
Manganese .	340,000	6,000 X Value	US1
	210,000	4,200 X Value	DS1
	450,000	9,000 X Value	DS2
SEDIMENTS UPSTREAM (10-1-91)
CONTAMINANT	(µg/L)
COPPER...........................	766	.58% of Value
LEAD.............................	248	16.00 X Value
NICKEL...........................	39	.39% of Value
TOTAL CHROMIUM...................	<50	?
DOWNSTREAM (NPDES OUTFALL) (1-17-91 AND 10-1-91, respectively)
BERYLLIUM...................	7,290	911,259.00 X Value
	2,440	305,000.00 X Value
TOTAL CHROMIUM..............	276	5.50 X Value
	160	3.20 X Value
COPPER......................	1,845,000	1,419.00 X Value
	615,000	473.10 X Value
LEAD........................	104,000	693.00 X Value
	11,700	700.00 X Value
NICKEL......................	19,600	196.00 X Value
	7,290	72.90 X Value

Although these samples may be flawed, the ATSDR accepts them. (page 19-paragraph 3). The ATSDR also states that there are no comparison levels, however, goes on to explain these levels as being low. Low compared with what?

I used the comparison values used for water because it was the only measurement using µg/L. I know that this is wrong but if relatively small amounts of beryllium are dangerous to the public, i.e .008 for water, .01 for ambient air, .2 for ground etc., then 7290 & 2440 sounds high no matter what kind of comparison levels are used.

AMBIENT AIR
BERYLLIUM FOUND IN AMBIENT AIR ON-SITE

On-site air was sampled for just 1 month in the middle of the summer (during usually calm days), during a time that the plant was closed down for two weeks (the last two of the month), and wind direction was never recorded.

Having noted that, the following was reported during the three weeks that the plant was open:

STATION	RCRA 01		RCRA 02
7- 2-91	0.00062	1.5 X Value	0.00042	1.1 X Value
7- 9-91	0.00011	27% of Value	0.00023	58% of Value
7-16-91	0.00079	2.0 X Value	0.00034	85% of Value
7-23-91	plant closed down
7-30-91	plant closed down

Over the six sampling events while the plant was operating, 50% were above comparison values.

Chromium levels were exceeded at all sites on all days, varying from a low of 0.00145 (or 18 times the Value) to a high of 0.00827 (or 103 times the Value).

BERYLLIUM FOUND IN AMBIENT-AIR OFF-SITE

The ATSDR document points out, regarding TABLE-7, that abnormal stack emissions are responsible for the high values indicated in 1981's figures. Also that this was corrected by February 6, 1981. (I would guess that any excess contaminants found in the air could be attributed to "abnormalities"). However there is no explanation for the high values reported for 1989.

	1981		1989
R-1	0.04279	106.00 X Value	0.03769	94.2 X Value
R-2	0.00129	3.20 X Value	0.02105	52.6 X Value
R-3	0.00161	4.00 X Value	0.02046	51.2 X Value
R-4	0.00031	.77% of Value	0.00204	5.1 X Value
R-5	0.00054	1.40 X Value	0.00178	4.5 X Value
R-6	0.00047	1.20 X Value	0.00122	3.0 X Value
R-7	0.00033	.82% of Value	0.00306	7.7 X Value
R-8	0.00026	.65% of Value	0.00181	4.5 X Value

I think the two violations documented in the report could be one of the reasons for the high 1989 levels.

In June and August 1989, there were two events where the limit was violated (6-89 - 0.03721 µg/m³ [close to 4 X the limit] and 8-89 - 0.02414 µg/m³ [almost double the limit]).

The explanations for these violations is the repair of a drain line, and a subsequent crack in the furnace. In order to make the repair there was excavation on-site. It would seem then that the soil is contaminated with beryllium. It would also seem that the contaminants were carried by wind, since it would be improbable that the stacks were in operation if the furnace was shut down. I would also imagine that on these two occasions there were precautions taken to keep the soil wet to keep down dust, as opposed to what happens in nature on any given day.

The problem with these two violations is that it is thought in the research of beryllium disease that there is less importance given to dose/duration as there is to the sensitivity of individuals. If this is the case it matters less that a plant has a clean record most of the year but exceeds limits for short periods. These short periods could be just as harmful as lifetime exposures. Not only could the exposures effect sensitive persons, the exposures themselves could contribute to making someone sensitive to future exposures.

The fact that the measurements are given in the hundredthousandths speaks to the toxicity of beryllium.

BIOTA

None were taken.

Although as a child I vaguely remember catching suckers in Laurel Run, I don't believe we ever ate any fish, however we did eat many berries, apples, and cherries.

Response to comment 62: ATSDR developed the ATSDR Public Health Assessment Guidance Manual to provide consistency and guidance in presenting information and writing public health assessments. Although ATSDR will not be revising the public health assessment to present the data in the fashion indicated above, your data and comments are included in this appendix. It should be noted that ATSDR is not responsible for any errors, misrepresentations, or miscalculations made in your analysis of the data, but will attempt to respond to questions raised in those comments. Furthermore, it should be noted that revisions to the public comment release document (e.g., Table 9) may result in apparent discrepancies in the data reported and discussed by the commenter and information in the final release.

Surface Soil, Off-site - As ATSDR indicates in the "Environmental Contamination and Other Hazards" section (pages 10-11), comparison values are health guidelines that are used to select contaminants of concern that are then evaluated further. The number of times that a contaminant's concentration exceeds a comparison value is not necessarily a direct indicator of the degree of public health threat posed by a given contaminant. Contaminants that exceed comparison values must be further evaluated, individually, to determine its health threat. Some of the factors that must be considered include actual or potential exposure to a contaminant, the contaminant's concentration, the dose to which one may be exposed, and the strength or evidence of studies upon which the toxicological effects are based.

Groundwater, On-site - The quarterly testing conducted in the 1980's has been reviewed by ATSDR and is referenced in the report. On-site groundwater has not been used for drinking water and would not provide any insight as to the occurrence of illnesses. Therefore, ATSDR has reported (page 12) that higher concentrations existed in the past, but has characterized the site by including data for current groundwater quality. ATSDR has reported the available off-site groundwater data, which would be more indicative of the concentrations to which people using off-site groundwater may have been exposed.

To address your question about what, "contaminant was not detected at the reported value," means? When laboratories analyze samples they set up detection limits. The lower detection limit (generally referred to as simply "detection limit") is established either as the minimum detection limit believed to be needed by the client requesting the analysis or by the minimum level that the laboratory equipment can detect accurately within established data quality parameters. When the established lower detection limit is exceeded (i.e., when the actual concentration is less than the detection limit) no specific number can be reported with accuracy; therefore, the detection limit is reported with a less than symbol (<) in front of it.

Your comments cite two sentences from the public health assessment (page 15, paragraph 3 of this document; paragraph 2 of the public comment release petitioned public health assessment) out of context. The first sentence states, "Also, the detection limits for some contaminants analyzed for in off-site groundwater are too high." This means that a lower "detection limit" should have been used, if possible, because our comparison value is less (lower) than the detection limit used. The other sentence states, "Although those detection limits may have been appropriate in the past, lower detection limits are now needed since new comparison values show that lower contaminant concentrations may be of health concern." This sentence states the reason that a lower "detection limit" should be sought. The reason is that our new or current comparison value is below the detection limit used, although the detection limit might have been adequate when evaluated against former comparison values. That sentence has been revised in this document to provide clarity.

Sediment, Downstream - The comment regarding sediment asks, "Low compared to what?" and implies that ATSDR is suggesting that the samples reported are low when compared to comparison values. In referring to this petitioned public health assessment (page 17, fifth full paragraph), ATSDR discusses the unusual sediment and the subsequent sample results. ATSDR indicates that the samples were not analyzed as in a typical fashion (on a dry weight basis) and therefore could not be evaluated using sediment comparison values. ATSDR further explains that the sediment should be analyzed properly to evaluate the public health significance. The "low" that ATSDR believes you are referring to is stated as, "Given the generally low level of contaminants in the stream sediments, these results need further confirmation." That sentence is referring to sediment samples as generally being low when compared to other sediment samples (see Table 8).

The sediment samples should not be compared to water comparison values. If a water sample had been collected it would indicate the concentration of beryllium available in the water column and would be evaluated against a water comparison value which is based on the amount of water typically ingested by a person. Likewise, sediment comparison values are based upon an assumed amount of soil or sediment that a person might ingest. Using the concentration of a contaminant that has been aggressively leached from sediment and reported in a liter solution does not appropriately reflect a drinking water or sediment ingestion exposure scenario.

Ambient Air, Beryllium Found in Ambient Air Off-Site - Table 9 has been revised and the note regarding the 1981 abnormal stack emissions has been deleted. However, the 1981 abnormal stack emissions has been mentioned in the text of the report along with the 1989 NESHAP violations under the "Ambient Air" subsection (page 18).

ATSDR has no indication that actions were taken, during June and August of 1989, to control fugitive dust emissions during excavation. It is believed, at least in part, that the June and August 1989 NESHAP violations resulted from on-site fugitive dust emissions. As an informational matter, refer to the second paragraph of "Response to comment 22" for discussion of the basis of the NESHAPs and the use of comparison values.

Regarding your concern about dose/duration and individual sensitivity, please refer to Response to Comment 61 and 63.

Biota - Thank you for you comment and information.

Comment 63: That the plant has on occasion released large doses of beryllium into the environment for short periods of time.

I believe this is answered in the chart "beryllium found in ambient air off-site." The two violations that I addressed in the report are violations of NESHAPs regulatory limit of 0.01 µg/m³, a much higher value than ATSDR's comparison value of 0.0004 µg/m³.

Even though the values for beryllium have been decreasing since 1989, they still exceed comparison values at least one week each year (page 18-paragraph 1-2). Considering the fact that there is concern that the "analytical procedure used may not be revealing the total concentration for beryllium (particularly beryllium oxide)," (page 20-paragraph 2) and beryllium oxide being a very toxic form of beryllium, I think that high emission, short duration may be a real health hazard.

Response to comment 63: Regarding the high emission, short duration issue, see the response to Comment 61 above. As stated there, non-occupationally exposed individuals who develop chronic beryllium disease in response to very low levels of beryllium generally represent a hypersensitive subset of the population. The immune response of these individuals to beryllium is similar to an allergic reaction in that it appears to be largely independent of dose. For such hypersensitive individuals, a "safe" level of exposure may be both undefinable and unattainable. NESHAPs regulatory limit of 0.01 µg/m³, and not ATSDR's CREG of 0.0004 µg/m³, is the more appropriate comparison value in this case, since chronic beryllium disease rather than lung cancer is the more realistic health concern. Even in occupationally-exposed populations, the evidence that beryllium causes lung cancer in humans is limited; when results were controlled for smoking, they became statistically insignificant. Historical data suggest that the 0.01 ug/m³ standard has effectively protected people from berylliosis, except perhaps in cases of unpredictable hypersensitivity.

Comment 64: That the report states in several places that "new comparison values" should be considered, as the ones being used may be too high.

"In 1976, OSHA considered lowering the 2.0 µg/m³ standard to 1.0 µg/m³, based largely on evidence of carcinogenicity. But no new standard was promulgated, and the issue was tabled indefinitely."⁷

"The 40-hr-week level for worker exposure of 2 µg/m³ and the neighborhood level of 0.01 µg/m³ averaged over a 30-day period were based on guess work and extrapolations from animal studies. It is a source of personal regret and some shame that I could not persuade the A.E.C. to do more outdoor monitoring while area beryllium contamination was a reality."⁸

Response to comment 64: ATSDR does not state that new comparison values should be considered because the ones being used are too high. The only place in the public comment release petitioned public health assessment where "new comparison value" is used is in the "Off-site Contamination" subsection (page 15 under the "Groundwater" subsection, second paragraph); however, it is not used to make the above statement. In the "Conclusion" section (page 45), under letter "g" of the data inadequacies list, ATSDR does indicate the need for further research on beryllium because the CREG comparison value is well below background levels commonly found in the environment and because more information on potential, non-cancer, adverse health effects from ingestion of beryllium would be useful.

Comment 65: That the report concentrates on the carcinogenicity of beryllium but doesn't tackle berylliosis or chronic beryllium disease. Less debilitating diseases should also be considered when evaluating NGK.

There are many instances in the report where the subject of beryllium's toxicity is discussed. In almost all the instances it is discussed from it's carcinogenicity and rarely anything else. The comparison levels themselves are in terms of cancer ratios.

In regards to a study at a Reading plant in 1971:

"The investigators concluded that beryllium exposure in this plant had caused not only clinical beryllium disease but also a "reservoir of nonspecific respiratory disease."⁷

Response to comment 65: The comment is well taken. With regard to both occupational and residential beryllium exposure, chronic beryllium disease is, in fact, a more relevant public health concern than cancer. The draft document has been amended to better address this issue. See also the Response to Comment 63, above.

Comment 66: The statement that there has been only one case of nonoccupational chronic beryllium disease reported from 1973-1977.

Research is finally catching up to the initial problems of differentiating between sarcoidosis and chronic beryllium disease. I think that there may be a number of people that might have been diagnosed as sarcoid originally, and may have berylliosis.

"Five workers at a precious metal refinery developed granulomatous lung disease between 1972 and 1985. The original diagnosis was sarcoidosis, but 4 of the workers were subsequently proved to have hypersensitivity to beryllium..."⁶

Nor do I think that it may have effected only beryllium workers.

"Chronic beryllium disease continues to occur in the nonoccupational setting and among bystanders in industry, masquerading as sarcoidosis. Because even transient or possibly low levels of exposure may cause disease, this case has important implications for how clinicians, industry, and government agencies define the populations at risk of chronic beryllium disease."⁵

What bothers me is that the report cites one case of nonoccupational chronic beryllium disease between the years 1973 and 1977, excluding 1978 to the present.

The fact is, that the case cited in the quote above was a nonoccupational woman diagnosed with chronic beryllium disease and reported in 1992.

Between 1973 and 1977 fifty-five cases were added. Besides the ATSDR case there were 4 cases for whom the source of beryllium exposure was not listed. (The ATSDR case represent 1.8% of the total. The 4 cases represent 7.2%)

Response to comment 66: The relevant section of the assessment has been rewritten to eliminate any potential confusion. The essential point; however, remains unchanged. To quote Newman and Kreiss (1992), "no air pollution or household cases have been reported in more than 30 years". The authors' discovery of a confirmed case of chronic beryllium disease that had been diagnosed as sarcoidosis in 1989 has alerted the medical community to the possibility that more such cases exist, and the availability of the beryllium lymphocyte proliferation test provides a tool for distinguishing between these two diseases. This issue is fully addressed in the final draft of the assessment. (See also the responses to Comments 7, 12-14, 16, 39-40, 61, and 63, above.)

Regarding the fifty-five cases that were added to the Beryllium Case Registry between 1973 and 1977: the date a case was entered into the registry should not be confused with the date of diagnosis. According to Eisenbud and Lisson, 1983, "no cases [of berylliosis] to date have been reported among [occupationally-exposed] individuals first exposed after 1973", and "no cases of berylliosis have been reported from indirect or non-occupational exposure among individuals whose exposure began after about 1950". New cases may yet be uncovered among sarcoidosis patients using the beryllium lymphocyte proliferation test. Such cases will most likely occur among people with a genetically-determined, dose-independent, hypersensitivity to beryllium. No attainable health-based exposure limit can protect all such individuals. However, sometime in the near future it may become possible to identify hypersensitive individuals by means of a biomarker assay, so that they can be warned to avoid, as much as possible, any exposure to beryllium (33). See responses to Comments 39 and 61, above.

Comment 67: The use of U.S. Bureau of Census 1980's figures.

This may not be important right now, but I do believe that accurate populations would be important for future tracking of the incidence of disease in the Cancer Registry, or the U.S. Beryllium Registry.

I also don't know how the approximate figures for population within the one mile and two mile radius were figured. I don't agree with the numbers and I'll attempt to show my reasoning.

THE CENSUS FIGURES

1980 U.S. Bureau of the Census figures (in the document)

(A) Muhlenberg Twp., 1980		= 13,000
(B) Muhlenberg Twp., 1990 (projected)		= 14,000
(C) 1-mile radius of plant		= 9,000
(D) 2-mile radius of plant		= 24,000

(C) If you draw a circle with a radius of 1-mile using the site as center you' Il notice that most of the area includes Temple, South Temple, Cherokee Ranch and a small section of River View Park. It excludes most of River View Park, most of Muhlenberg, most of Laureldale, and all of Hyde Park. However according to the population figures in (B), accounts for approximately 64% of Muhlenberg's population.

(D) Although the 2-mile radius includes a little more land area than that of Muhlenberg Twp, (12.56 sq. mi. as opposed to 11.3 sq mi.), most still falls within Muhlenberg. The approximately 1/3 that doesn't is in rural Ontelaunee Twp. However according to the figures in (D) the population almost doubles! (171%)

If broken down into simple persons/sq. mile (using ATSDR's figures) it would look like:

(B)   Muhlenberg    = 1,118 persons/sq. mile
(C)   1-mile radius = 2,866 persons/sq. mile
(D)   2-mile radius = 1,911 persons/sq. mile

I also believe that 1990's figures should be used. Especially Temple's as they are the group most likely effected.

1990 U.S. Bureau of the Census Figures

Muhlenberg Twp. 1990 = 12,636
Temple Boro. 1990 = 1,491

Response to comment 67: As suggested, we have updated the 1980 population data included in the public health assessment to reflect the more current figures from the 1990 U.S. Census. The 1990 population figures within one and two miles of the NGK Metals facility were derived using Geographic Information System (GIS) technology. GIS was used to identify the population in census blocks within a one and two mile radius of the NGK Metals facility (4,927 and 14,686 people, respectively).

As shown in Figure 10, Temple Borough and part of Muhlenberg Township (most notably South Temple and a small portion of River View Park) are located within 1 mile of the facility. Located within the 2-mile radius are Temple Borough, most all of Muhlenberg Township, Laureldale Borough and rural parts of Bern Township and Ontelaunee Township. There may be some confusion about the population figures within a one and two mile radius of the facility because Temple and Laureldale Boroughs are within Muhlenberg Township but not included in that Township's population figures.

Comment 68: COMMUNITY HEALTH CONCERNS EVALUATION

NUMBER 5: The detrimental effects of Laurel Run on wildlife, etc.

Even if the 1981 values are discounted for being too far in the past or misread, etc., there are levels recorded for beryllium on 1-26-89 at 4 µg/L (500 times the comparison value), on 12-89 at 2.7 (337.50 times the comparison value), and on 6-91 at .92 (115 times the comparison value).

Beryllium levels were high in 4 of the five tests. The fifth time the "detection limit was not reported."

With regards to the sediment, the Document records elevated levels at all sampling sites on all 3 days at all three sites, ranging from a low of .24 mg/kg (1.2 times the value) to 2.4 mg/kg (12 times the comparison value).

However it also records 2 other days samples, on 10-1-91 and 9-17-91. Although these samples are flawed, I still think it important that wherever there are ATSDR comparison levels given for beryllium, they are usually very low, i.e., 0.008 µg/L, 0.2 mg/kg, 0.0004 µg/m³ etc.

In this sampling event the levels for beryllium are 7,290 and 2,440 µg/L. Copper was 1,845,000 and 615,000 µg/L, and lead was 104,000 and 11,700 µg/L. These numbers for a lay person seem very high.

NUMBER 10: ATSDR recommends surface soil testing downwind of NGK.

I strongly agree. If there are no more stack emissions as a result of the furnace shutting down, then the source of beryllium in ambient air would probably be wind, and dust being kicked up in play etc.. Since it is probable that most beryllium diseases are caused by inhalation, I think if nothing else is done, this may be the most important.

NUMBER 18: NGK's procedures provide for protective garments for plant workers and require showers at the end of each work day.

Since starting this paper I have come in contact with four people who had worked at either Cabot Berylco or Brush Wellman and have been diagnosed as having chronic beryllium disease. One was a secretary, one was a salesman, neither worked in the plant, and neither was required to wear protective clothes.

NUMBER 19: ATSDR has not done sampling to detect whether contaminants have migrated off-site to other areas and recommends additional testing.

Again, because of the possibility of children playing, raising dust, and inhaling it, I think this is a very important step in finding possible areas of contamination.

NUMBER 20: ATSDR has determined that the levels of contaminants in the groundwater are not likely to cause respiratory infections, mottled teeth, stress fractures, and colic in children.

Perhaps not. However just the beryllium found in "Private Well 1," was 5.3 µg/L (662.5 times the comparison value). When does the "value" get too high? This document attempts to explain that beryllium is not toxic when ingested yet it assigns a CREG value of 0.008 µg/L for water to it.

NUMBER 22: Concerning the possibility of being on-site before the facility was fenced in.

I'm not sure. I do know that when we were young we played in Temple Cave, which, I remember to be just across the road from the disposal areas, played in a cemetery across from the plant, found large pieces of slag across from the plant, and played in large "silt" basins where we discovered large quartz crystals.

NUMBER 23: The possibility of illnesses around the site, particularly in the Cherokee Ranch area.

I find it hard to believe that local doctors and hospitals weren't contacted. Even more important than soil testing I think that area doctors, pulmonary specialists, and hospitals should be interviewed, not just regarding cancer, but also for other respiratory illnesses, with particular attention to sarcoidosis. It might be the first line of defense. With such a long latency period for chronic beryllium disease and cancer, an increase in incidence of disease may not show up for decades. Doctors and hospitals might be the first to notice abnormalities in their patients.

NUMBER 24: The communication to the public of the possible health hazards surrounding NGK.

I live far from the area and purely by luck learned of the public health assessment. I'm grateful that I learned of it and have had a chance to participate.

NUMBER 26: Sampling of stream sediments are again recommended.

I would also recommend sampling soil from the banks, where, when the water recedes the sediment is deposited to become dirt, and later, dust. Also areas close to Laurel Run, as I know of quite a few times that it flooded.

NUMBER 27: This deals with orange colored ash from the stacks in the past.

I would think that there must be industry records that exist that would tell what might be likely to make up orange colored smoke billowing from a beryllium plant. (For example: the smoke from the exhaust of a car burns bluish-black when burning too much oil, or white when there is moisture present, etc.).

NUMBER 30: The question of chronic beryllium disease and sarcoidosis.

This is pretty much the way that I as a lay person understand it as well. I just wonder how many people who have lived around the plant may have been misdiagnosed with sarcoidosis and other lung related illnesses.

Response to comment 68: Number 5 - The concentrations of the contaminants detected in the September 17, and October 1, 1991, samples are certainly indicative of contamination from some source. However, as discussed in the "Response to comment 62," under "Sediment," ATSDR is unable to determine the level of contamination and its impact on public health, as well as wildlife.

Number 10 - Off-site surface soil sampling for beryllium and chromium has been conducted. An evaluation of that data is in the "Public Health Implications" section (pages 30-31 under the beryllium "Ingestion Exposure" subsection), which indicates that no adverse health effects are expected.

Number 18 - This public health assessment will be forwarded to the National Institute for Occupational Safety and Health (NIOSH) for follow-up on worker related issues.

Number 19 - Please refer to the above response regarding community health concern "Number 10."

Number 20 - ATSDR does not establish health standards, but evaluates each site, contaminant, and pathway on an individual basis since a number of varying factors must be considered. The concern about the CREG comparison value has been addressed in the body of this report (page 30 under the beryllium "Ingestion Exposure" subsection) and in other responses to comments (please refer to "Response to comment 46" second paragraph).

Number 22 - Thank you for your comment and information.

Number 23 - During the public health assessment process, ATSDR reviews available health outcome data. However, active collection of health information, such as surveillance or studies, is typically not conducted until after the public health assessment is conducted and reviewed by ATSDR's Health Activities Recommendation Panel. That panel makes recommendations for appropriate health follow up if warranted.

Number 24 - Thank you for your comment.

Number 26 - ATSDR has recommended additional sediment sampling. Although ATSDR would evaluate any soil samples collected from Laurel Run's banks and flood plain, such sampling is not being recommended at this time.

Number 27 - Based on information provided from state personnel, NGK uses nitric acid in cleaning (via a pickling bath) beryllium-copper strip. Urea is manually added to this process to control a brown-orange nitrogen emission. This cleaning process does not result in any beryllium emissions.

Number 30 - ATSDR does not routinely request or review personal medical records. ATSDR is only aware of cases of sarcoidosis and beryllium disease that have been reported by individuals to us.

Comment 69: DATA GAPS or DATA INADEQUACIES

c. I think the groundwater characterization should be done, not only to the southeast (downgradient), but also from the northeast part of the site where the ground water runs north.

e. I think that the Reading Eagle-Times would have the wind direction in the weather reports for July 1991.

f. SEE i.

g. The statement, "The unusual sediment may no longer be present for sampling." sounds as if you don't know if it exists or not. I think that would be an easy matter to verify.

i. This report states that "the CREG for beryllium in soil is currently well below background levels commonly found in the environment." However, back at "i" the report states "Local background beryllium soil concentrations are not available."

Also, I don't think ingestion is the most important health threat, inhalation is. But the dust on a property would provide this health risk. I also think that, chronic beryllium disease with latency ranging anywhere from 10 to 40 years is as important to investigate as cancer. If there is a health threat that exists today it may not be known for decades.

j. Is it that there are no comparison levels for lead or that they are just not known?

Response to comment 69: Information to fill data gap "e" and "b" have been obtained or are no longer necessary and therefore the alphabetic ordering in this public health assessment has changed. However, the alphabetic ordering in the above comment and this response remains unchanged and corresponds with that of the public comment document.

c. ATSDR has made the recommendation (page 46, Recommendation 5) for characterization, remediation, or other actions that are protective of public health.

e. ATSDR was able to obtain applicable surface weather observations (wind direction data) from the National Climatic Data Center.

g. ATSDR simply acknowledges that the unusual sediment may have resulted from an isolated incident and no longer be present in the stream; nonetheless, ATSDR has recommended (page 46, Recommendation 6) follow up sediment sampling.

i. ATSDR used background soil data from locations within the United States to explain that the CREG is well below background levels commonly found in the environment. ATSDR stated that "Local background beryllium soil concentrations are not available" because soil background levels for Reading, Pennsylvania, specifically in the area near NGK, are not available.

ATSDR attempts to evaluate all routes and pathways of exposure. Through the public health assessment process, available health outcome data is evaluated (i.e., state cancer data), active collection of health outcomes is conducted if warranted and recommended by ATSDR's Health Activities Recommendation Panel (i.e., health studies).

j. There are no comparison levels for lead.

Comment 70: RECOMMENDATIONS

I agree with the recommendations.

I also recommend that the U.S. Beryllium Disease Registry be examined.

I recommend that doctors and hospitals in the area be contacted and interviewed, not just to see if there is a health risk right at this time, but also to be aware of any increases in lung related diseases.

I recommend that hospitals records could be checked to see if there is an increase of bronchoscopies, etc.

Response to comment 70: Active data collection, such as described in your last two recommendations must be recommended by our Health Activities Recommendation Panel. Regarding the U.S. Beryllium Disease Registry, ATSDR does not believe that this national registry would be useful in examining local incidence. ATSDR has reviewed articles, as discussed in the Response to Comment 66 (second paragraph), that cite national exposure incidence.

This section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch,
MS E-56
1600 Clifton Road NE, Atlanta, Georgia 30333

1. In the Initial Release and Public Comment drafts, ATSDR previously indicated that NGK presented a past public health hazard based on human exposure to off-site groundwater in one private well contaminated with chromium and 1,1-dichloroethene. However, based upon current review of toxicological data those past exposures are not expected to result in any adverse health effects and therefore do not represent a past public health hazard. Refer to the chromium and Volatile Organic Compounds subsections in the Public Health Implications section for the detailed toxicological evaluation.

2. In the Initial Release and Public Comment Release drafts, ATSDR indicated that beryllium found in surface soil at one private residence represented a slight increased risk of cancer. However, after current review of studies regarding carcinogenic effects of beryllium, no increased risk of cancer is expected through ingestion of beryllium. Refer to the beryllium "Ingestion Exposure" subsection of the Public Health Implications section for specific details of that toxicological evaluation.

³ Wagoner JK. Infante PF. Nancuso T. Letter re. Beryllium Carcinocenicity Studies. Science 1978 July 28;Vol 201:298-300

⁴ Eisenbud M. Lisson J. Epidemiological aspects of beryllium induced nonmalignant lung disease: a thirty year update. Journal of occupational Medicine 1983 1983 March;Vol. 25 No. 3:196-202

⁵ Newman LS. Kreiss K. Nonoccupational beryllium disease masquerading as sarcoidosis: Identification by blood lymphocyte proliferative response to beryllium. American Review of Respiratory Disease 1992 May;145 (5):1212-4

⁶ Cullen MR. Kominsky JR. Rossman MD. Cherniack MG. Rankin JA. Balmes JR. Kern JA. Daniele RP. Palmer L. Naegel GP. et. al. Chronic beryllium disease in a precious metal refinery. Clinical epidemiologic and immunologic evidence for continuing risk from exposure to low level beryllium fume. American Review of Respiratory Disease 1987 Jan;135 (1):201-8

⁷ Kreibel D. Brain JD. Sprince NL. Kazemi H. The pulmonary toxicity of beryllium. American Review of Respiratory Disease 1988; 137:464-473

⁸ Hardy, Hariet L. Beryllium disease: a clinical perspective. Environmental Research 1980 21:1-9

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