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PUBLIC HEALTH ASSESSMENT

RICKENBACKER AIR NATIONAL GUARD BASE (USAF)
(a/k/a RICKENBACKER AIR FORCE BASE)
COLUMBUS, FRANKLIN COUNTY, OHIO


APPENDIX B: COMPARISON VALUES

The conclusion that a contaminant exceeds the comparison value does not mean that it will cause adverse health effects. Comparison values represent media-specific contaminant concentrations that are used to select contaminants for further evaluation to determine the possibility of adverse public health effects.

Cancer Potency Factor (CPF)
Usually derived from dose-response models and expressed in mg/kg/day, CPFs describe the inherent potency of carcinogens and estimate an upper limit on the likelihood that lifetime exposure to a particular chemical could lead to excess cancer deaths.

Cancer Risk Evaluation Guide (CREG)
Estimated contaminant concentrations that would be expected to cause no more than one excess cancer in a million (10-6) persons exposed over a 70-year life span. ATSDR's CREGs are calculated from EPA's cancer potency factors.

EPA Region III Risk-Based Concentration
EPA combines reference doses and carcinogenic potency slopes with "standard" exposure scenarios to calculate risk-based concentrations, which are chemical concentrations corresponding to fixed levels of risk (i.e., a hazard quotient of 1, or lifetime cancer risk of 10-6, whichever occurs at a lower concentration) in water, air, fish tissue, and soil.

Lowest Observed Adverse Effect Level ( )
The lowest dose of a chemical that produced an adverse-effect when it was administered to animals in a toxicity study.

Maximum Contaminant Level (MCL)
The MCL is the drinking water stand established by EPA and enforced by the California Department of Environmental Protection. It is the maximum permissible level of a contaminant in water that is delivered to the free-flowing outlet. MCLs are considered protective of human health over a lifetime (70 years) for individuals consuming 2 liters of water per day.

Minimal Risk Levels (MRLs)
MRLs are estimates of daily human exposure to a chemical (i.e., doses expressed in mg/kg/day) that are unlikely to be associated with any appreciable risk of deleterious noncancer effects over a specified duration of exposure. MRLs are calculated using data from human and animal studies and are reported for acute (< 14 days), intermediate (15-364 days), and chronic (> 365 days) exposures. MRLs are published in ATSDR Toxicological Profiles for specific chemicals.


APPENDIX C: GLOSSARY

Absorption:
How a chemical enters a person's blood after the chemical has been swallowed, has come into contact with the skin, or has been breathed in.


Adverse Health Effect:
A change in body function or the structures of cells that can lead to disease or health problems.


ATSDR:
The Agency for Toxic Substances and Disease Registry. ATSDR is a federal health agency in Atlanta, Georgia that deals with hazardous substance and waste site issues. ATSDR gives people information about harmful chemicals in their environment and tells people how to protect themselves from coming into contact with chemicals.


Background Level:
An average or expected amount of a chemical in a specific environment. Or, amounts of chemicals that occur naturally in a specific environment.


Biota:
Used in public health, things that humans would eat - including animals, fish and plants.


Cancer:
A group of diseases which occur when cells in the body become abnormal and grow, or multiply, out of control


Carcinogen:
Any substance shown to cause tumors or cancer in experimental studies.


CERCLA:
See Comprehensive Environmental Response, Compensation, and Liability Act.


Completed Exposure Pathway:
See Exposure Pathway.


Comparison Value:
Concentrations or the amount of substances in air, water, food, and soil that are unlikely, upon exposure, to cause adverse health effects. Comparison values are used by health assessors to select which substances and environmental media (air, water, food and soil) need additional evaluation while health concerns or effects are investigated.


Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):
CERCLA was put into place in 1980. It is also known as Superfund. This act concerns releases of hazardous substances into the environment, and the cleanup of these substances and hazardous waste sites. ATSDR was created by this act and is responsible for looking into the health issues related to hazardous waste sites.


Concern:
A belief or worry that chemicals in the environment might cause harm to people.


Concentration:
How much or the amount of a substance present in a certain amount of soil, water, air, or food.


Contaminant:
See Environmental Contaminant.


Dermal Contact:
A chemical getting onto your skin. (see Route of Exposure).


Dose:
The amount of a substance to which a person may be exposed, usually on a daily basis. Dose is often explained as "amount of substance(s) per body weight per day".


Duration:
The amount of time (days, months, years) that a person is exposed to a chemical.


Environmental Contaminant:
A substance (chemical) that gets into a system (person, animal, or the environment) in amounts higher than that found in Background Level, or what would be expected.


Environmental Media:
Usually refers to the air, water, and soil in which chemical of interest are found. Sometimes refers to the plants and animals that are eaten by humans. Environmental Media is the second part of an Exposure Pathway.


U.S. Environmental Protection Agency (EPA):
The federal agency that develops and enforces environmental laws to protect the environment and the public's health.


Exposure:
Coming into contact with a chemical substance.(For the three ways people can come in contact with substances, see Route of Exposure.)


Exposure Assessment:
The process of finding the ways people come in contact with chemicals, how often and how long they come in contact with chemicals, and the amounts of chemicals with which they come in contact.


Exposure Pathway:
A description of the way that a chemical moves from its source (where it began) to where and how people can come into contact with (or get exposed to) the chemical.

ATSDR defines an exposure pathway as having 5 parts:
  1. Source of Contamination,

  2. Environmental Media and Transport Mechanism,

  3. Point of Exposure,

  4. Route of Exposure; and,

  5. Receptor Population.

When all 5 parts of an exposure pathway are present, it is called a Completed Exposure Pathway. Each of these 5 terms is defined in this Glossary.


Frequency:
How often a person is exposed to a chemical over time; for example, every day, once a week, twice a month.


Hazardous Waste:
Substances that have been released or thrown away into the environment and, under certain conditions, could be harmful to people who come into contact with them.


Health Effect:
ATSDR deals only with Adverse Health Effects (see definition in this Glossary).


Indeterminate Public Health Hazard:
The category is used in Public Health Assessment documents for sites where important information is lacking (missing or has not yet been gathered) about site-related chemical exposures.


Ingestion:
Swallowing something, as in eating or drinking. It is a way a chemical can enter your body (See Route of Exposure).


Inhalation:
Breathing. It is a way a chemical can enter your body (See Route of Exposure).


NPL:
The National Priorities List. (Which is part of Superfund.) A list kept by the U.S. Environmental Protection Agency (EPA) of the most serious, uncontrolled or abandoned hazardous waste sites in the country. An NPL site needs to be cleaned up or is being looked at to see if people can be exposed to chemicals from the site.


No Apparent Public Health Hazard:
The category is used in ATSDR's Public Health Assessment documents for sites where exposure to site-related chemicals may have occurred in the past or is still occurring but the exposures are not at levels expected to cause adverse health effects.


No Public Health Hazard:
The category is used in ATSDR's Public Health Assessment documents for sites where there is evidence of an absence of exposure to site-related chemicals.


PHA:
Public Health Assessment. A report or document that looks at chemicals at a hazardous waste site and tells if people could be harmed from coming into contact with those chemicals. The PHA also tells if possible further public health actions are needed.


Plume:
A line or column of air or water containing chemicals moving from the source to areas further away. A plume can be a column or clouds of smoke from a chimney or contaminated underground water sources or contaminated surface water (such as lakes, ponds and streams).


Point of Exposure:
The place where someone can come into contact with a contaminated environmental medium (air, water, food or soil). For examples:
the area of a playground that has contaminated dirt, a contaminated spring used for drinking water, the location where fruits or vegetables are grown in contaminated soil, or the backyard area where someone might breathe contaminated air.


Population:
A group of people living in a certain area; or the number of people in a certain area.


Public Health Assessment(s):
See PHA.


Public Health Hazard:
The category is used in PHAs for sites that have certain physical features or evidence of chronic, site-related chemical exposure that could result in adverse health effects.


Public Health Hazard Criteria:
PHA categories given to a site which tell whether people could be harmed by conditions present at the site. Each are defined in the Glossary. The categories are:
  1. Urgent Public Health Hazard

  2. Public Health Hazard

  3. Indeterminate Public Health Hazard

  4. No Apparent Public Health Hazard

  5. No Public Health Hazard

Receptor Population:
People who live or work in the path of one or more chemicals, and who could come into contact with them (See Exposure Pathway).


Route of Exposure:
The way a chemical can get into a person's body. There are three exposure routes:
- breathing (also called inhalation),
- eating or drinking (also called ingestion), and
- or getting something on the skin (also called dermal contact).


SARA:
The Superfund Amendments and Reauthorization Act in 1986 amended CERCLA and expanded the health-related responsibilities of ATSDR. CERCLA and SARA direct ATSDR to look into the health effects from chemical exposures at hazardous waste sites.


Source (of Contamination):
The place where a chemical comes from, such as a landfill, pond, creek, incinerator, tank, or drum. Contaminant source is the first part of an Exposure Pathway.


Superfund Site:
See NPL.


Toxic:
Harmful. Any substance or chemical can be toxic at a certain dose (amount). The dose is what determines the potential harm of a chemical and whether it would cause someone to get sick.


Volatile organic compound (VOC):
Substance containing carbon and different proportions of other elements such as hydrogen, oxygen, fluorine, chlorine, bromine, sulfur, or nitrogen; these substances easily become vapors or gases. A significant number of the VOCs are commonly used as solvents (e.g., paint thinners, lacquer thinner, degreasers, dry cleaning fluids).

APPENDIX D: RESPONSES TO PUBLIC COMMENTS

The Agency for Toxic Substances and Disease Registry (ATSDR) received the following comments/questions during the public comment period for the Rickenbacker Air National Guard Base (RANGB) Public Health Assessment (PHA). For comments that questioned the validity of statements made in the PHA, ATSDR verified or corrected such statements. The list of comments does not include editorial comments concerning such things as word spelling or sentence syntax. Page numbers reference the Public Comment Draft and may not be the same as those in the Final RANGB PHA.

  1. Comment 1: (General Comment) With the known high clay content and low migration potential, are the statements about plumes and their potential to pollute still justified?

    2. Response: ATSDR did not change the original text because it states that potential plume migration and a future completed pathway are unlikely.

  2. Comment 2: (Summary) An exact description of the property being discussed should be added to the Summary. Is it just the property that was used to score the base? This does not seem to be defined.

    3. Response: ATSDR changed the text to include a more detailed description of the RANGB property, as defined and reviewed in the PHA.

  3. Comment 3: (Page 1) ATSDR states "Public exposure (past, current, and future) to surface water and sediment, however, is minimal, if it occurs at all, so there is no public health hazard." EPA does not agree with this statement. If portions of Site 25 are developed (i.e., construction of a culverted ditch system or renovation for residences) in the future, there may be a potential public health hazard associated with this site. Please clarify.

    4. Response: ATSDR did not change the original text because public exposure is and will continue to be limited and no receptor human populations were identified at Site 25. As described in the document, the reuse plan will maintain Site 25 (and the rest of the base) for industrial/commercial use and not redevelop the area for residential purposes. No potential future public health hazards are associated with Site 25.

  4. Comment 4: (Page 1, para. 4) ATSDR health-based comparison values have been used to compare against compound concentrations, however, these values are not given in this document. They should be provided in table format and the use of these comparison values should be explained. It has been stated that groundwater contains volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and metals above ATSDR health-based comparison values. These chemical should be listed and the locations given. For example, are they located at the landfill or the base?

    5. Response: ATSDR clarified the text to state whether contaminants were detected at Installation Restoration Program (IRP) sites or at the Rickenbacker Landfill. Specific contaminant detection locations, concentrations, and comparison values are included in Appendix A.

  5. Comment 5: (Page 1, last para.) Sites 1, 12, and 45 should be discussed in this document. Site 1 has groundwater contaminant concentrations over EPA's Maximum Contaminant Levels (MCLs) and is currently undergoing closure under Resource Conservation and Recovery Act (RCRA). Site 45 has groundwater contaminant concentrations over EPA's MCL for benzene and is being monitored by the Air Force. Site 12 has groundwater contaminant concentrations over EPA's MCLs and currently nothing is being done about this. In addition, potentially Sites 25 and 27 may also require remediation as the sediment contaminant levels in the ditch system are above an unrestricted reuse scenario.

    6. Response: ATSDR changed the text and Appendix A to update and accurately reflect contaminant and remedial information regarding Sites 1, 12, 25, 27, and 45.

  6. Comment 6: (Page 2) ATSDR states "At Rickenbacker Landfill and five Installation Restoration Program (IRP) sites with soil contamination, remedial activities have or will further reduce contaminant concentrations and the potential for incidental exposure." Remedial activities are not currently planned for the Rickenbacker Landfill as the preliminary assessment and site investigation have not been completed. In addition, there are no known "access restrictions" (i.e., fencing) to prevent trespassers from frequenting the landfill. As a baseline risk assessment has not been completed, EPA believes that the potential risks associated to exposure to the landfill have not been quantified. Please clarify.

    7. Response: ATSDR revised the text and tables to accurately reflect detected contaminants, remedial activities, and access restrictions at Rickenbacker Landfill and the IRP sites. ATSDR changed its assessment of public health hazards associated with Rickenbacker Landfill from no apparent hazard to an indeterminate hazard because the nature and extent of landfill contamination has not been fully characterized.

  7. Comment 7: (Page 4, para. 2) Site 8 was not folded into the investigation for Site 25. Site 8 was not able to be physically located. Sites 11, 13, and 18 were not removed from the site investigation; they were eliminated at the end of the preliminary assessment. Later on additional samples were collected at Sites 7 and 18 and those sites were determined to need no additional investigation. Sites 25/27 are undergoing BCT discussion regarding the ditch system.

    8. Response: ATSDR changed the text and Appendix A to accurately reflect this information.

  8. Comment 8: (Page 5, para. 2) It should also be stated that Rickenbacker is not an NPL site.

    9. Response: ATSDR changed the text to explicitly state that Rickenbacker is not an NPL site.

  9. Comment 9: (Page 5, para. 4) In addition to work being conducted under the IRP, work is being conducted under the Bureau of Underground Storage Tank Regulation's (BUSTR) rules and the Resource, Conservation, and Recovery Act (RCRA) regulations. In the second sentence, the information is incorrect. The no further action (NFA) IRP sites were not presented in the Final FS Report. The Feasibility Study (FS) Report presents the alternatives for remediation of five IRP sites. Again, the Remedial Action Decision Document is for the five IRP sites moving forward into the remedial design/remedial action stage. NFA sites have their own decision documents, but they do not include minutes of a public meeting, written comments, or a responsiveness summary. The five sites undergoing remediation were evaluated by the Air Force, U.S. EPA, and Ohio EPA. The Final Feasibility Study Report and the Remedial Action Decision Document have been approved. Lastly, the Landfill should probably have its own paragraph because it is in a different process.

    10. Response: ATSDR changed the text and Appendix A to accurately reflect this information. The Rickenbacker Landfill paragraph was separated from the IRP discussion.

  10. Comment 10: (Page 5, Remedial and Regulatory History) A Remedial Action Decision Document for Sites 2, 21, 41, 42, and 43 was signed on October 14, 1999, by the Air Force, EPA, and Ohio EPA. The Design Documents for the remedial activities were completed on October 21, 1999. The Air Force is currently working on the Remedial Action Work Plans and hope to start work in fiscal year 2000. Please add this current information to this document.

    11. Response: ATSDR updated the text and Appendix A to reflect this information.

  11. Comment 11: (Page 5, Remedial and Regulatory History) Although there may be a Memorandum of Agreement between EPA and the Department of Defense, this is not considered a State Memorandum of Agreement. Also, EPA is not clear that the memorandum of agreement states that EPA and Ohio EPA will jointly maintain oversight of the investigation and remedial work conducted. Please provide your source of this information.

    12. Response: ATSDR did not change the original text. The information source cited is the Scientific/Management Decision Point for IRP Site 25 at Rickenbacker Air National Guard Base (IT Corp. 1998).

  12. Comment 12: (Page 7, Natural Resources and Land Use [Reuse Plan], para. 3) Please update the information in this paragraph.

    13. Response: ATSDR contacted Alan C. Friedstrom, BRAC Environmental Coordinator at Rickenbacker Air Force Base Conversion Agency, to discuss the current status of the RANGB reuse plan. ATSDR revised the text to include information about recently enacted prohibitions and deed restrictions.

  13. Comment 13: (Page 7, Natural Resources and Land Use [Reuse Plan]) Although a Reuse Plan may have been developed for this property, EPA is unaware of any legal authority which requires the reuse plan to be used for the specified purposes.

    14. Response: ATSDR contacted Alan C. Friedstrom, BRAC Environmental Coordinator at Rickenbacker Air Force Base Conversion Agency. Regardless of existing legal authorities, Mr. Friedstrom assured ATSDR that RANGB will enact and enforce any and all prohibitions and deed restrictions necessary to protect human health. ATSDR included and cited this information in the text.

  14. Comment 14: (Page 9, Evaluation of Environmental Contamination and Potential Exposure Pathways, Introduction) In the third paragraph, it might be better to state, "After fully evaluating potential human exposure pathways at RANGB, ATSDR concluded that current and future public exposures to groundwater, surface water, sediment, soil, and locally-caught fish are not likely to result in adverse human health effects because contamination in these media is below levels of health concern and/or there is no public exposure to contamination in these media." EPA believes that future public exposures to these media has the potential to result in adverse human health effects if the sites have an unrestricted use to groundwater or if the property is redeveloped as residential property.

    15. Response: ATSDR contacted Alan C. Friedstrom, BRAC Environmental Coordinator at Rickenbacker Air Force Base Conversion Agency and affirmed that RANGB property will not be redeveloped for residential purposes. If necessary, additional RANGB prohibitions and deed restrictions will prevent potential future exposures to contaminated media. ATSDR did not revise the original text because no future pathways were identified.

  15. Comment 15: (Page 10, Groundwater Use, para. 1) Five production wells, RB-1 through RB-5, have been closed and abandoned. They were located in the northwest portion of the base and were deep wells. Production well RB-6 was not located at the heating plant but is located at the golf course to the south of the airfield. Current status is unknown. There was also a production well located at the heating plant, but I do not know what its identification was. It was located in the intermediate aquifer.

    16. Response: ATSDR contacted Alan C. Friedstrom, BRAC Environmental Coordinator at Rickenbacker Air Force Base Conversion Agency, and David Edwards, former Water Plant Foreman at Rickenbacker Air Force Base. Both individuals and reference documents confirmed that RB-6 is located at the heating plant and that an unnamed well is located at the golf course. ATSDR revised the text to include information about the golf course well, referred to as "a seventh production well."

  16. Comment 16: (Page 10, para. 4, "Groundwater Use" Section) This paragraph is a correct and factual discussion of the groundwater use of Rickenbacker ANGB (extent 1980 - present); however, if the ATSDR evaluation expands to include the former Rickenbacker AFB, then one more well needs to be added to the list. This well, which as no "RB" designation, was located adjacent to the clubhouse at the former golf course and provided domestic water for patrons of the clubhouse golf course. The golf course, including the seventh well, were sold by the GSA to a private organization in 1983.

    17. Response: ATSDR obtained historical and recent well records for this seventh well and added the information to the PHA.

  17. Comment 17: (Page 11, Nature and Extent of Groundwater Contamination, para. 1) The second sentence should state that the Army Corps of Engineers is investigating the dioxin contamination at the Landfill. In addition, please explain how the ATSDR comparison values were used at each site and add Sites 1, 12, and 45 to the list.

    18. Response: ATSDR changed the text to reflect that the Army Corps of Engineers is investigating landfill dioxin contamination and that groundwater underlying Sites 1, 12, 45 exceeded ATSDR comparison values.

  18. Comment 18: (Page 12, para. 2) Ohio EPA collected samples from five domestic drinking water wells because they were located in the Upper Water Bearing Zone (UWBZ). The other two wells were not sampled because they were located in the intermediate aquifer. Please correct the text to reflect this.

    19. Response: ATSDR changed the text to "In 1995, OEPA collected and analyzed groundwater samples (screened in the shallow aquifer) from five of these seven private wells. All sampled wells drew water from the UWBZ. OEPA deemed it unnecessary to sample two wells that drew water from the deeper intermediate aquifer because contaminant concentrations were believed to be below UWBZ levels. Water from the five tested wells met all federal and state drinking water standards (Waters 1996)."

  19. Comment 19: (Page 12, Nature and Extent of Groundwater Contamination) In the 2nd paragraph on this page, the text indicates, "These interim activities further served to prevent any potential public exposure from potential contaminant plume migration towards the village of Lockbourne." How does sampling private well water prevent any potential public exposure? By hooking up the village to the RANGB drinking water supply line and subsequently the Columbus Division of Water would serve to prevent any potential public exposure to potentially contaminated groundwater. However, this activity would not prevent contaminant plume migration as contaminants can move freely in the groundwater. In addition, sampling private well water in 1995 would simply indicate that potential public exposure to contaminated groundwater did not occur in 1995.

    20. Response: ATSDR deleted the original sentence referring to groundwater interim activities. ATSDR agrees that 1995 sampling data can only indicate that no public exposure to contaminated groundwater occurred in 1995, but when the 1995 data are evaluated with other RANGB groundwater monitoring efforts, the cumulative data set indicates that there is no off-site plume migration and, therefore, no potential public health concern.

  20. Comment 20: (Page 13, Off-base Exposures) Although Ohio EPA and RANGB have announced that no one in the village should be drinking the groundwater, there are still residences in the village which were identified as having wells that draw from the upper water bearing zone. How will the private water supply systems be monitored to ensure that these six residences are still not impacted by drinking the groundwater? Please clarify.

    21. Response: ATSDR revised the groundwater text and tables to reflect that contaminants have not migrated off site. Current private well monitoring data (post 1995) are unavailable, but potential future contaminant migration has been/will be prevented by Air Force remedial activities.

  21. Comment 21: (Page 13, Off-base Exposures, para. 1) Please identify who, person or division, at Ohio EPA, stated that residents of Lockbourne should not drink water from their domestic drinking water wells and the date that this was stated.

    22. Response: ATSDR deleted the text and table references to the recommendation attributed to Ohio EPA. During the January 1999 ATSDR site visit, it was recommended that residents of Lockbourne should use municipal drinking water rather than drink water from their private drinking water wells, but no formal Ohio EPA recommendation has ever been issued.

  22. Comment 22: (Page 13, para. 3) "On-base wells were not tested for water quality parameters when they were active." This statement is misleading. The production wells when they were active complied with all drinking water standards in effect for water quality and these results would be reported to the appropriate authorities. The water quality standards would be such things as: hardness, corrosively, bacterial counts, lead, iron... If you meant that a screen for EPA environmental contaminants (benzene, TCE, ...) was not performed, so state.

    23. Response: ATSDR obtained additional historical well logs and water quality reports and revised the text to reflect this information.

  23. Comment 23: (Page 15, para 1, line 2) Of all the investigations conducted by the Air Force and the Army Corps of Engineers related to surface water dioxins, low level dioxins were only detected at one location in one drainage ditch; therefore the sentence should be reworded to read: "Low-level dioxins were detected in one location in one drainage ditch, but at a level below ATSDR comparison values for drinking water and soil."

    24. Response: ATSDR changed the text as requested.

  24. Comment 24: (Pages 15 and 16, Nature and Extent of Surface Water and Sediment Contamination) The text indicates that the most upgradient portions of the ditch system are areas which there is no public access. This is not the case for the Northwest and Southwest portions of the ditch system. In addition, EPA would recommend ATSDR specify which quadrants contained the greatest contaminant concentrations. Please reference the EPA document which established a mercury cleanup standard of soils and sediments of 400 parts per million (ppm). EPA is unaware of establishing this site cleanup level for RANGB. EPA does not agree with the statement that all sediment contaminant concentrations in the Rickenbacker Air National Guard Base drainage system are within normal background concentrations are not "site-related." EPA establishes site-specific background concentrations for inorganics only and not organic contaminants. "Site-related" contaminants are considered any contaminants which were produced by past activities and operations at the base. Although, the Air Force (not the Air National Guard) may be discussing the no further action status for this site, EPA still recommends that the Air Force conduct toxicity testing, a feasibility study, or a "hot spot removal" of the highly contaminated sediments in the ditch system. In addition, EPA is unaware of any document which will require the drainage ditch system to retain an industrial/commercial land use. If this land use is not retained, does the potential for a public health hazard exist? Please clarify.

    25. Response: ATSDR changed the text regarding the 400 ppm mercury cleanup standard and "site-related" sediment contamination issues. ATSDR added that EPA recommends that the Air Force conduct toxicity testing, a feasibility study, or a "hot spot removal" of the highly contaminated sediments in the ditch system. Appendix A discusses ditch system contaminant and exposure issues (Sites 25 and 27) in more detail, but ATSDR did not elaborate in the text to specify which quadrants contained the greatest contaminant concentrations. In general, contaminants detected in each of the four quadrants of the ditch system were similar (IT Corp. 1998).

  25. Comment 25: (Page 15, para. 5) I know of no cleanup standard of 400 ppm for mercury that was established by U.S. EPA for Rickenbacker. An explanation is needed.

    26. Response: ATSDR changed the text regarding the 400 ppm mercury cleanup standard.

  26. Comment 26: (Page 16, para. 1) The drainage ditch system is undergoing discussion by the BCT and their technical support members. This includes representatives from the Air Force, U.S. EPA, and Ohio EPA. This should be noted in the text.

    27. Response: ATSDR changed the text as suggested.

  27. Comment 27: (Page 16, Nature and Extent of Soil Contamination, para. 1) Soil removal will occur at Sites 21, 41, 42, and 43. The soil removal at Site 2 is for the purpose of installing a reactive wall for the remediation of groundwater and is not for soil remediation. In addition, soil removals may be required at Sites 1 and 12.

    28. Response: ATSDR updated the document's soil contamination and remedial activities text and tables to reflect this information.

  28. Comment 28: (Page 16, Evaluation of Potential Public Health Hazards) What prevents trespassers and ecological receptors from being exposed to the potentially contaminated sediment which are above industrial/commercial screening criteria? Also, what protective clothing for workers is ATSDR referring to?

    29. Response: ATSDR changed the text to state that public exposure is minimized by the industrial/commercial land use surrounding the drainage ditches. ATSDR deleted the sentence in the text referring to worker protective clothing.

  29. Comment 29: (Page 16 and 17, Nature and Extent of Soil Contamination) The soil remediation which is being conducted at Sites 21, 41, 42, and 43 is being conducted to minimize the leaching of contaminants into the groundwater. This action is not being conducted to reduce contaminants in the soil. Please clarify. Also, have VOCs been detected in soils above ATSDR comparison values at Site 2. In addition, the former Lockbourne Landfill is prime property for trespassers. Selected Phase I and Phase II samples have exceeded EPA Region IX's industrial preliminary remediation goals which are estimated contaminant concentrations that would be expected to cause no more than one excess cancer in a million persons exposed over a 70-year life span. This would indicate that the potential for the contaminated soils to pose a risk to human health and the environment exists. EPA is unclear how these concentrations can be below ATSDR comparison values for soil. What risk based concentrations comparison values for soil is ATSDR using? As this site is not fenced, nor is access prevented, how is public exposure to this site prevented? Please clarify.

    30. Response: ATSDR clarified the text to state that remedial activities at Sites 21, 41, 42, and 43 will minimize contaminant leaching into the groundwater. ATSDR also revised its soil discussion of Sites 1, 2, and 12 and the Rickenbacker Landfill to reflect the most current available information. ATSDR agrees that trespassers can access Rickenbacker Landfill and changed the text accordingly. The nature and extent of landfill contaminant concentrations have not been fully characterized, so ATSDR classified Rickenbacker Landfill as an indeterminate public health hazard. ATSDR comparison values (further described in Appendix B) are distinct from EPA Region IX's industrial preliminary remediation goals for a 70-year exposure. As stated in the text revisions, ATSDR will reevaluate its indeterminate public health hazard conclusion when the Army Corps of Engineers completes its environmental investigations at Rickenbacker Landfill.

  30. Comment 30: (Page 17, Evaluation of Potential Public Health Hazards) The landfill is not an IRP site. It is a Formerly Used Defense Site (FUDS). This needs to be clarified in the text.

    31. Response: ATSDR clarified the text as suggested.

  31. Comment 31: (Page 17, Evaluation of Potential Public Health Hazards) EPA does not agree that the IRP sites (including the five remediation sites and the Rickenbacker Landfill) lie in industrial/commercial areas that are infrequently, if ever, contacted by the public. Since the Air Force closed the base and the Air National Guard and Army Reserve established their cantonment area, there are sites (i.e., the Rickenbacker Landfill and Site 21) which can be accessed by the public.

    32. Response: ATSDR agrees that trespassers can access RANGB and changed the text accordingly. Minimal, infrequent public exposure to on-site contaminants at IRP sites (if it occurs at all) is not be expected to result in adverse health impacts.

  32. Comment 32: (Page 20) It is inaccurate to state that children do not access RANGB. Children have been seen on Rickenbacker riding their bikes. Teenagers have also been seen on base in cars and have broken windows in some vacant buildings. There is currently no one in place to stop unauthorized access.

    33. Response: ATSDR agrees that trespassers can access certain RANGB areas (including Rickenbacker Landfill) and changed the text accordingly. ATSDR included these observations in the ATSDR Child Health Initiative section.

  33. Comment 33: (Page 20, ATSDR Child Health Initiative) EPA would not state that children do not access RANGB. Please see other comments with respect to site access and the potential public health hazard posed by exposure to the soils at the Landfill. In addition, ATSDR indicates on page 12 that Ohio EPA only sampled five of the seven wells. Therefore, not all off-base exposure points were sampled. Please clarify.

    34. Response: ATSDR agrees that children can access certain RANGB areas (including Rickenbacker Landfill) and changed the text accordingly. ATSDR clarified its definition of drinking water off-base exposure points by inserting "(i.e., production wells drawing from the UWBZ)" to the text.

  34. Comment 34: (Page 20, Conclusions, Pages 19 and 20) Please indicate that for Sites 2, 21, 41, 42, and 43, there are some provisions in place which would prevent potential future exposure to contaminated groundwater due to the remedial action decision document. For Site 1, which is being closed under the Resource Conservation and Recovery Act (RCRA), and Site 45, which is being closed under the Bureau of Underground Storage Tank Regulations, ATSDR should check for what provisions have been made to prevent potential future exposure to contaminated groundwater. For the Landfill, there are no provisions in place that would prevent potential future exposure to contaminated groundwater at this site. Please clarify.

    35. Response: ATSDR revised the text (see also the Public Health Action Plan section) to include updated information about RANGB deed restrictions and provisions to prevent potential future exposures.

  35. Comment 35: (Page 20 and 21, Public Health Action Plan, Ongoing/Planned Actions) To clarify Action, EPA does not collect or analyze data pertaining to all regions of groundwater contamination and drinking water quality. EPA reviews and evaluates data pertaining to RANGB.

    36. Response: ATSDR deleted "USEPA" from the sentence referring to agencies that "will continue to monitor, collect, and analyze data pertaining to all regions of groundwater contamination and drinking water quality."

  36. Comment 36:(Page 26, Table 1, columns 2 and 6) These entries still talk about bromochloromethane; a test result the initial lab was not qualified to perform to standard - and a questionable non-reproducible result - per Ohio Public Health which in its investigations could not find in any of the wells nor the RANGB, landfill FUDS area. Does repetition of nonvalidated, untrusted test data serve the public?

    37. Response: ATSDR deleted the reference to bromochloromethane in Table 1.

  37. Comment 37: (Page 26, Table 1, Route of Exposure Column) It seems that inhalation and dermal, as well as ingestion, would be an exposure route and should be included. In addition, five of the domestic drinking water wells are located in the shallow aquifer and this aquifer may be connected to the UWBZ at RANGB. Please add this information.

    38. Response: ATSDR added "(inhalation and dermal contact)" to the potential route of exposure for groundwater in Table 1. ATSDR revised the text in the Evaluation of Environmental Contamination and Potential Exposure Pathways section to say that five domestic drinking water wells draw from the UWBZ.

  38. Comment 38: (Page 27, Table 1, On-base Soil) Under Comments, it is stated that the landfill is surrounded by a fence. The text needs to reflect that a fence does not surround the site, and some of the existing fencing can easily be climbed over.

    39. Response: ATSDR revised Table 1 to say "Rickenbacker Landfill is surrounded by limited fencing and trespassers can access the site."

  39. Comment 39: (Table 1) This table should be revised to incorporate the text comments regarding potential future exposures.

    40. Response: ATSDR did not revise its assessment of potential future exposures because no future exposures were identified at RANGB (see Natural Resources and Land Use [Reuse Plan]).

  40. Comment 40: (Appendix A) Update Appendix A text to reflect current IRP site status. In addition, the current status of some sites indicates that these sites have been designated as no further action sites. EPA would like to clarify that these sites are suitable for no further action in the event these sites retain a commercial or industrial reuse. The Air Force will be responsible to monitor, maintain, and enforce this land use.

    41. Response: ATSDR updated Appendix A to reflect current site status. The text states that RANGB will implement and oversee all provisions and deed restrictions necessary to prevent potential future exposures (Friedstrom 2000).

  41. Comment 41: (Page A-18, Corrective Activities Column, Current Status) Replace bullet two with: "BUSTR has assigned NFA (No Further Action) on all but two of the USTs in site 28. BUSTR action on the remaining two USTs is still under evaluation."

    42. Response: ATSDR revised the text as suggested.

  42. Comment 42: (Page A-26, Site 45) Correct second bullet to read: "Pending results from a Dec. 1999 groundwater sampling event, a Remedial Action Summary Report for Site 45 will be submitted to BUSTR in early 2000."

    43. Response: ATSDR revised the text as suggested.

4. Appendix A lists 45 individual sites, but RANGB consolidated Site 27 into Site 25, thereby creating a total of 44 IRP sites.

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