SUBJECT:

FROM:

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III

1650 Arch StreetPhiladelphia, Pennsylvania 19103

Valmont TCE: Review of Residential Soil Samples SDMS DocID

Jennifer Hubbard, ToxicologistTechnical Support Section (3HS41)

Rom Roman, RPMWestern PA Remedial Section (3HS22)

9/4/2003

I have reviewed the data for soil samples taken from residential yards (and onecommercial property) in the neighborhood near the Chromatex plant at the Valmont TCE site.Using current standard default risk assessment procedures for residential ingestion of and dermalcontact with soil, I estimated the risks for exposure 350 days/yr for 30 years (6 years for children,24 years for adults). The details of the risk assessment are presented in attachments to thismemo.

Quantitative risks were estimated only for aluminum, arsenic, iron, manganese,benzo[a]pyrene, and dibenz[a,h]anthracene, which were the only chemicals that exceeded theRegion in Risk-Based Concentration screening levels (HQ = 0.1, cancer risk = 1E-6) in at leastone yard.

In no yard did Hazard Indices exceed 1 when target organs were taken into account.Cancer risks ranged from 3E-6 to 2E-5, within EPA's acceptable risk range.

These risks are from exposure to soil only, and do not include additive effects from othermedia, such as air. Several His were, or approached, 1. (Hazard Indices were rounded to onesignificant figure.) Therefore, while the soil ̂ itself does not appear to pose an unacceptable risk atthis time, this finding is preliminary. The total risks for residents will not be known until, duringthe course of the RI risk assessment, all the exposure pathways are evaluated in combination.

The chemicals associated with a Hazard Index of 1 in yards SS-1, SS-3, SS-5, SS-6, SS-7,and SS-9 were aluminum and manganese. (This is also true of SS-8, but that yard was outsidethe Chromatex plant area and is considered to be background.) It is likely that these metals,which are extremely common as naturally occurring elements of soil, are unrelated to the site.There are insufficient data to perform a meaningful statistical comparison to background.Therefore, the aluminum and manganese data in yards SS-1, SS-2, SS-3, SS-4, SS-5, SS-6, SS-7,and SS-9 are simply shown here with the background data set consisting of SS-8, BG-SS-01,BG-SS-02, and BS-SS-03, for semi-quantitative comparison:

V*'

YardSample

SS-1

SS-2

SS-3

SS-4*

SS-5

SS-6

SS-7.

SS-9

Range

Aluminum(mg/kg)

13900

8280

10200

7675

10200

8850

8780

10800

7675 - 13900

Manganese(mg/kg)

136

181

306

125

463

604

354

165

125 - 604

BackgroundSample

SS-8

BG-SS-01

BG-SS-02

BG-SS-03

Range

Aluminum(mg/kg)

8400

3010

3850

1800

1800-8400

Manganese(mg/kg)

506

31.7

41.3

13.6

13.6-506* Average of duplicates

At first glance, it appears the yards may be significantly higher than most of thebackground samples. Samples BG-SS-01 and -02 were taken from wooded areas; BG-SS-03 wastaken from the grounds of a commercial property. However, because the aluminum andmanganese in SS-8 appears more similar to the concentrations in other residential yards than tothe other background samples, it is possible that residential yards differ naturally from woodedareas. (For example, the wooded area is more likely to be undisturbed soil high in organicmatter, while the residential soils may have undergone grading, fertilizing, and cultivation.) It isalso possible that the background samples are of different soil types from the residential samples.In any case, it is not possible at this point to conclusively attribute the aluminum and manganeseto background.

The Valmont ICE site was originally identified because of the presence of chlorinatedethenes and ethanes in groundwater. Therefore, VOCs were a possible concern in surface andsubsurface soils. Only one chlorinated ethene, tetrachloroethene (PCE), was detected inresidential soil samples. The subsoil samples from yards SS-2 and SS-3 yielded PCE at 4 ug/kg.The surface soil sample from yard SS-3 yielded PCE at 10 ug/kg. (These concentrations are wellbelow concentrations of concern for direct contact.) One of these yards was on Fawn Drive,which is the street closest to the site of an alleged former dry-cleaning dump. The other of theseyards was on Bent Pine. PCE was detected at similar concentrations in background subsoil eastof the plant. The alleged dry-cleaning dump is also east of the site area, but it is unclear howclose these samples were to that area.

No TCE or 1,1,1-TCA (the primary groundwater contaminants) were detected inresidential soils.

The attachments to this memo give more specific details about the risk assessment.

If you have any questions concerning this memo, please contact me at x3328.

cc: Eric Johnson (3HS41)Bruce Rundell (3HS41)Bill Hudson (3HS43)Lora Werner (3HSOO; ATSDR)John Mellow (PADEP; electronic only)Neil Teamerson (TtNUS; electronic only)

Attachments: 2

Attachment 1Risk Assessment Per Yard

The risks for each yard are shown per chemical, below. Aluminum and manganese mayboth affect the nervous system; arsenic first affects the skin and vascular system, and iron affectsthe blood, liver, and gastrointestinal system. Therefore, only the non-cancer effects fromaluminum and manganese are considered to be potentially additive. Cancer risks are alsobelieved to be additive.

SS-1

Chemical

Aluminum

Arsenic

Iron

Manganese

Benzo[a]pyrene

Dibenz[a,h]anthracene

Total

Adult Hazard Index

0.17

0.01

0.087

0.011

——

0.2 (Al/Mn), 0.01(As), 0.09 (Fe)

Child Hazard Index

1.2

0.092

0.8

0.096

—

—1 (Al/Mn), 0.09 (As),0.8 (Fe)

Cancer Risk

—

5.2E-6

—~

~

~

5E-6

SS-2

Chemical

Aluminum

Arsenic

Iron

Manganese

Benzo[a]pyrene

Dibenz[a,h]anthracene

Total

Adult Hazard Index

0.1

0.013

0.049

0.014

—--

0.1 (Al/Mn), 0.01(As), 0.05 (Fe)

Child Hazard Index

0.7

0.12

0.46

0.13

~

—0.8 (Al/Mn), 0.1(As), 0.5 (Fe)

Cancer Risk

~

6E-6

—

——

6E-6

SS-3

Chemical

Aluminum

Arsenic

Iron

Manganese

Benzo[a]pyrene

Dibenz[a,h]anthracene

Total

Adult Hazard Index

0.13

0.021

0.059

0.024

' —

—

0.2 (Al/Mn), 0.02(As), 0.06 (Fe)

Child Hazard Index

0.86

0.19

0.55

0.22

—•

1 (Al/Mn), 0.2 (As),0.6 (Fe)

Cancer Risk

~

1E-5

~

~

1.2E-6

._

1E-5

SS-4

Chemical

Aluminum

Arsenic

Iron

Manganese

Benzo[a]pyrene

Dibenz[a,h]anthracene

Total

Adult Hazard Index

0.094

0.0061

0.071

0.0098

——

0.1 (Al/Mn), 0.006(As), 0.07 (Fe)

Child Hazard Index

0.65

0.055

0.65

0.088

—

—

0.7 (Al/Mn), 0.06(As), 0.09 (Mn)

Cancer Risk

~

3E-6

~

~

7.5E-7

• —

4E-6

SS-5

Chemical

Aluminum

Arsenic

Iron

Adult Hazard Index

0.13

0.0051

0.076

Child Hazard Index

0.86

0.046

0.7

Cancer Risk

~

2.6E-6

—

Chemical

Manganese

Benzo[a]pyrene

Dibenz[a,h]anthracene

Total

Adult Hazard Index

0.036

--

—0.2 (Al/Mn), 0.005(As), 0.08 (Fe)

Child Hazard Index

0.33

—

—

1 (Al/Mn), 0.05 (As),0.7 (Fe)

Cancer Risk

•

~

—

3E-6

SS-6

Chemical

Aluminum

Arsenic

Iron

Manganese

Benzo[a]pyrene

pibenz[a,h]anthracene

Total

Adult Hazard Index

0.11

0.016

0.061

0.047

—

—0.2 (Al/Mn), 0.02(As), 0.06 (Fe)

Child Hazard Index

0.75

0.14

0.57

0.42

~

~

•1 (Al/Mn), 0.1 (As),0.6 (Fe)

Cancer Risk

—

7.9E-6

——

8.3E-6

1.4E-6

2E-5

SS-7

Chemical

Aluminum

Arsenic

Iron

Manganese

Benzo[a]pyrene

Dibenz[a,h]anthracene

Total

Adult Hazard Index

0.11

0.014

0.056

0.028

—0.1 (Al/Mn), 0.01(As), 0.06 (Fe)

Child Hazard Index

0.74

0.12

0.51

0.25

—

—

1 (Al/Mn), 0.1 (As),0.5 (Fe)

Cancer Risk

—6.9E-6

~

„

1.4E-6

—8E-6

SS-8

Chemical

Aluminum

Arsenic

Iron

Manganese

Benzo[a]pyrene

Dibenz[a,h] anthracene

Total

Adult Hazard Index

0.1

0.037

0.069

0.04

—

—

0.1 (Al/Mn), 0.04(As), 0.07 (Fe)

Child Hazard Index

0.71

0.33

0.64

0.36

—

—1 (Al/Mn), 0.3 (As),0.6(Fe)

Cancer Risk

~

1.9E-5

—

—

3.5E-6

7.4E-7

2E-5

Actually, this residence is located outside the area of the Chromatex plant and is considered to bebackground. It can be seen that the risks associated with this yard, and the pattern of chemicals,are very similar to that of the other houses.

SS-9

Chemical

Aluminum

Arsenic

Iron

Manganese

Benzo[a]pyrene

Dibenz[a,h]anthracene

Total

Adult Hazard Index

0.13

0.01

0.063

0.013

—

—0.1 (Al/Mn), 0.01(As), 0.06 (Fe)

Child Hazard Index

0.91

0.092

0.58

0.12

——

1 (Al/Mn), 0.09 (As),0.6 (Fe)

Cancer Risk

— ,

5.2E-6

~

~

1E-6

—6E-6

Residential risks for this yard are probably overestimates because this property is currently usedcommercially rather than residentially.

"Teamerson, Neil" To: Romuald Roman/R3/USEPA/US@EPA<TeamersonN@TtNus. cc:Com> Subject: Valmont TCE Site - Contaminant Mass

11/25/2003 09:36 AM

Rom

We estimated the mass of TCE and cis-1,2-DCE by zone using 3 different calculations.

Under the first option, the average concentration in soil for TCE and cis-1,2-DCE was used for each zone.There was a total of 6.7 Ibs. of VOCs as follows:

Zone A - 0.2 Ibs.Zone B - 0.4 Ibs.Zone C - 5.9 Ibs.Zone D - 0.2 Ibs.

88% of the two VOCs are in Zone C. 22% of all TCE is in Zone B•78V.

Under the second option, we used the highest TCE and cis-1,2-DCE concentration in soil for each zone.There was a total of 54.3 Ibs. of VOCs as follows:

Zone A -1.5 Ibs.Zone B - 4.5 Ibs.Zone C - 40.5 Ibs.Zone D - 7.8 Ibs.

74% of the two VOCs are in Zone C.

Under the third option, we used the highest I ct concentration ever detected in soil (1,800,000 ug/kg) foreach zone. There was a total of 44,060 Ibs. of VOCs as follows:

Zone A - 2,400 Ibs.Zone B-; 21,300 Ibs.Zone C -14,280 Ibs.

SViLU

48% of the TCE is in Zone B.\ The third option did not consider cis-1,2-DCE or any other VOC.

I will send the graph in a few minutes. Neil summary of soilcalcs.x

VALMONTMASS OF CONTAMINANTS IN EACH ZONE BASED ON MAX RECORDEDTl/20/2003 : " : ~" ~~

I N 11*7——f-

Assume 1.5 tons/cy soil density

ZONEABCD

MaxTCE,ug/kg

1,800,0001,800.0001,800,0001,800,000

cis 1,2-DCE,ug/kg

0000

Volume,Ft312,000

106,50071,40030,400

TCE, Ib2,400

21 ,30014,2806,080

cis 1 ,2-DCE, Ib

0000

TotalVOC, Ib

2,40021,30014,2806,080

TCE, as a% of total

TCE5

483214

C12DCE,as a % of

totalC12DCE#DIV/0!#DIV/0!#DIV/0!#DIV/0!

VOCs, asa % oftotal

VOCs5

483214

Total

Note:1,800,000 - Highest sample, 1987

44,060 44,060 100.00 #DIV/0! 100.00

Attachment 2Risk Assessment Assumptions

The following factors were used in estimating risks:

Chemical-Specific Factors

Chemical

Aluminum

Arsenic

Iron

Manganese

Benzo[a]pyrene

Dibenz[a,h]anthracene

OralRfD(mg/kg/day)*

1

3E-4

3E-1

2E-2

—__

OralCSF(1/mg/kg/day)*

—1.5

~

--

7.3

7.3

ABS(forabsorptionfrom soil)**

0.01

0.03

0.01

0.01

0.13

0.13

Adjustment Factor'(for oral-to-dermaltoxicity factors)+

0.005

1

1

0.04 (applied to oralRfDofO.14mg/kg/day)

1

1

*RfDs and CSFs were obtained from the sources listed in the EPA Region HI RBC Table (Apriland June, 2003)**ABS factors were obtained from Risk Assessment Guidance for Superfund, Volume 1, Part E,except for aluminum, iron, and manganese, which were obtained from EPA Region ffl's UpdatedDermal Exposure Assessment Guidance, June 2003.+Adjustment factors were obtained from Risk Assessment Guidance for Superfund, Volume 1,Part E, except for aluminum, which was obtained from the 1999 ATSDR Toxicological Profilefor Aluminum.

Exposure Factors

Soil ingestion rate (mg/day)*

Exposure frequency (days/yr)*

Exposure duration (yrs)*

Body weight (kg)*

Skin surface area exposed (cm2)**

Adult

100

350

24

70

5700

Child

200

350

6

15

2800

Soil-to-skin adherence factor (mg/cm2)**

Averaging time, cancer (days)*

Averaging time, non-cancer (days)*

Adult

0.07

365 x 70

365 x ED

Child

0.2

365 x 70

365 x ED

*Superfund standard default exposures**Defaults from Risk Assessment Guidance for Superfund, Volume I, Part E

"Fajardo, Geroncio" . To: Romuald Roman/R3/USEPA/US@EPA, TeamersonN@TTNus.Com,<gfajardo@state.pa.us "Mellow, John" <jmellow@state.pa.us>, William> Hudson/R3/USEPA/US@EPA, Walter Graham/R3/USEPA/US@EPA,

"Fajardo, Geroncio" <gfajardo@state.pa.us>12/15/2003 11:59 AM cc: "Sivarajah.'Kandiah" <ksivarajah@state.pa.us>, "Burkhart, Keith"

<c-keburkha@state.pa.us>, "Allerton, Barbara"<ballerton@state.pa!us>, "Risser-Clemens, Pauline"<prissercle@state.pa.us>, "Hersh, Joel" <jhersh@state.pa.us>,"Logue, James" <jlogue@state.pa.us>, "Shim, Youn K."<yak3@cdc.gov>, Lora Werner/R3/USEPA/US@EPA

Subject: RE: Responses to Ms. Lutz

Regarding number 24:

ATSDR Toxicological Profile has noted that various human studies(epidemiological studies) had been conducted in the past, and no findings havedefinitely proven that TCE causes a specific type of cancer in man. EPA hasnoted TCE as a B2 carcinogen (probable human carcinogen, i.e. inadequatehuman, sufficient animal studies), IARC noted TCE as Class 2A (probably.carcinogenic to humans, i.e. limited human evidence; sufficient evidence inanimals), and NTP noted TCE as a Class 2 carcinogen (reasonably anticipated tobe a carcinogen). EPA has not classified TCE as either an A-class carcinogen(Human carcinogen) nor Bl carcinogen (probable human carcinogen - limitedhuman, sufficient animal studies. I have also conducted various literaturesearches and I can not find a a single study proving that TCE indeed causes aspecific type of cancer in man.

All we have are findings of association (which.are still flawed because ofseveral limitations of the studies) and not findings of causation. Note thatenvironmental epidemiologic evaluations examine the relationship between humanexposure to hazardous substances and the observed occurrence of disease aftercontrolling for confounding factors.

Any thoughts?

Geroncio C. Fajardo, MD,MBA,MS, TC-NRCCDirector, Health Assessment ProgramDivision of Environmental Health EpidemiologyBureau of' EpidemiologyPennsylvania Department of HealthRoom 925, Health and Welfare BuildingP.O. Box 90 'Harrisburg, PA 17108Phone: (717) 346-3284Fax: (717) 346-3286e-mail: gfajardo@state.pa.us

NOTICE OF CONFIDENTIALITY: This e-mail, including any attachments, is intendedonly for the use of. the individual or entity to which it is addressed and maycontain confidential information that is legally privileged and exempt fromdisclosure under applicable law. If the reader of this message is not theintended recipient, you are notified that any review, use, disclosure,distribution or copying of this communication is strictly prohibited- If youhave received this communication in error, please contact the sender by replye-mail immediately and destroy all copies of the original message.

Original MessageFrom: Roman.Romuald@epamail.epa.gov[mailto:Roman.Romuald@epamail.epa.gov]Sent: Friday, December 12, 2003 2 : 4 8 PMTo: TeamersonN@TTNus.Com; jmellow@state.pa.us;Hudson.William@epamail.epa.gov; Graham.Walter@epamail.epa.gov;gfajardo@state.pa.usSubject: Responses to Ms. Lutz

(See attached file: Control R3-0300302-C Kan-Lutz cover 12-9-03.wpd)(Seeattached file: Control R3-0300302-C Kanj-Lutz 12-11-03.wpd)(See attachedfile: Control R3-0300302-C Kan-Lutz cover 12-9-03.doc)(See attachedfile: Control R3-0300302-C Kanj-Lutz 12-ll-03.doc)

the basis of individual samples, or whether to adopt a comprehensive approach to theneighborhood.

The individual approach would require the preparation of more RAGS D tables, and the

consider the fact that risks in non-sampled houses are unknown, and even in sampled houses, therisks on non-sampled days are unknown. This fact has long been of concern to me, because ofthe potential for underestimation of risk at some locations. In order to mitigate this possibleunderestimation of risk, future air sampling events would probably be needed, along with thecosts and disruptions to the community that such sampling entails.

A comprehensive approach would involve, defining the potentially affected houses, givenour knowledge of the plume location and possibly the characteristics of the houses themselves.For example, alternatives could be evaluated for all houses in a given geographic area, defined bythe extent of the pliime (whether the houses were previously sampled or not, and regardless of

.previous concentrations). If the presence of basements or sumps is believed to play a critical rolein vapor concentration, that would be an example of another criterion that could be used to definethe potentially affected houses for FS alternatives. This approach would have three majoradvantages: 1) no additional RAGS D tables would have to be generated, because the pointestimates of risk become less important than the overall picture; 2) no more air sampling wouldhave to be conducted, unless a limited event is needed to more specifically define an edge of theplume or to confirm that an alternative is working; 3) the problem of uncertainty associated withfluctuating concentrations and non-sampled houses would be eliminated.

For these reasons, I would recommend the comprehensive approach. Please let me knowyour preference, as this will affect my recommendations for incorporating Round 4 into therevised RI risk assessment.

If you have any questions concerning this memo, please contact me at 215-814-3328.

cc: Eric Johnson (3HS41)Bruce Rundell (3HS41)