HEALTH CONSULTATION
SHIAWASSEE RIVER SUPERFUND SITE
HOWELL, LIVINGSTON COUNTY, MICHIGAN
APPENDIX A: RAW PCB DATA AND
RESULTS FROM META-ANALYSIS
Table A-1. Floodplain soil sampling data
from Shiawassee River.
| Transect |
# of Samples |
MDL (ppm) |
Range (ppm) |
Reference |
| 1 |
4 |
0.33 |
< 0.33 |
TTEM |
| 2 |
4 |
0.33 |
< 0.33 |
TTEM |
| 3 |
4 |
0.33 |
< 0.33 |
TTEM |
| 4 |
12 |
0.1, 0.33, 3.3 |
< 0.33-9.2 |
TTEM, ECCS |
| 5 |
4 |
0.33 |
< 0.33-0.43 |
TTEM |
| 6 |
4 |
0.33 |
< 0.33 |
TTEM |
| 7 |
5 |
0.3, 0.33 |
< 0.33-26 |
TTEM, ECCS |
| 8 |
5 |
0.33 |
< 0.33 |
TTEM |
| 9 |
16 |
0.1, 0.33 |
< 0.33-78 |
TTEM, ECCS |
| 10 |
4 |
0.33 |
< 0.33-1.9 |
TTEM |
| 11 |
4 |
0.33 |
< 0.33 |
TTEM |
| 12 |
13 |
0.33 |
< 0.33-0.79 |
TTEM |
| 13 |
4 |
0.33 |
< 0.33-2.8 |
TTEM |
| 14 |
5 |
0.33 |
< 0.33-5.2 |
TTEM |
| 15 |
4 |
0.33 |
< 0.33-5.4 |
TTEM |
| 16 |
8 |
0.1, 0.33 |
0.15-6.9 |
TTEM, ECCS |
| 17 |
4 |
0.33 |
< 0.33 |
TTEM |
| 18 |
8 |
0.33 |
< 0.33 |
TTEM |
| 19 |
4 |
0.33 |
< 0.33-1.8 |
TTEM |
| 20 |
4 |
0.33 |
< 0.33-8.7 |
TTEM |
| 21 |
5 |
0.33 |
< 0.33-1.2 |
TTEM |
| 22 |
5 |
0.33 |
< 0.33-0.41 |
TTEM |
| 23 |
5 |
0.33 |
< 0.33-0.55 |
TTEM |
| 24 |
4 |
0.33 |
< 0.33 |
TTEM |
| 25 |
7 |
0.1, 0.33 |
< 0.33-2.7 |
TTEM, ECCS |
| 26 |
36 |
0.1, 0.33, 1.32, 1.65 |
0.13-220 |
TTEM, ECCS |
| 27 |
5 |
0.33 |
< 0.33-3.7 |
TTEM |
| 28 |
30 |
0.1, 0.33, 2.97, 3.63, 3.63, 3.96,
6.27, 6.6 |
< 0.33-28 |
TTEM, ECCS |
| 29 |
4 |
0.33 |
< 0.33-5.3 |
TTEM |
| 30 |
5 |
0.33 |
< 0.33-1.0 |
TTEM |
| 31 |
5 |
0.33 |
< 0.33-4.7 |
TTEM |
| 32 |
4 |
0.33 |
0.47-8.5 |
TTEM |
| 33 |
4 |
0.33 |
< 0.33-2.5 |
TTEM |
| 34 |
4 |
0.33 |
< 0.33-3.1 |
TTEM |
| 35 |
5 |
0.33 |
< 0.33-1.5 |
TTEM |
| 36 |
5 |
0.33 |
< 0.33 |
TTEM |
| 37 |
10 |
0.1, 0.33 |
< 0.33-85 |
TTEM, ECCS |
| 38 |
5 |
0.33 |
< 0.33-5.3 |
TTEM |
| 39 |
4 |
0.33 |
< 0.33-0.89 |
TTEM |
| 40 |
5 |
0.33 |
< 0.33 |
TTEM |
| 41 |
5 |
0.33 |
< 0.33 |
TTEM |
| 42 |
5 |
0.33 |
< 0.33 |
TTEM |
| 43 |
6 |
0.33 |
< 0.33 |
TTEM |
| 44 |
6 |
0.33 |
< 0.33-5.0 |
TTEM |
| 45 |
4 |
0.33 |
< 0.33-2.3 |
TTEM |
| 46 |
5 |
0.33 |
< 0.33-0.58 |
TTEM |
| 47 |
4 |
0.33 |
< 0.33-2.3 |
TTEM |
| 48 |
4 |
0.33 |
1.3-6.2 |
TTEM |
| 49 |
4 |
0.33 |
< 0.33-2.9 |
TTEM |
| 50 |
4 |
0.33 |
< 0.33-1.2 |
TTEM |
| 51 |
4 |
0.33 |
< 0.33-1.7 |
TTEM |
| 52 |
4 |
0.33 |
< 0.33-2.2 |
TTEM |
| 53 |
8 |
0.33 |
< 0.33-1.1 |
TTEM |
| 54 |
4 |
0.33 |
< 0.33-3.5 |
TTEM |
| 55 |
4 |
0.33 |
0.96-2.9 |
TTEM |
| 56 |
4 |
0.33 |
< 0.33 |
TTEM |
| 57 |
4 |
0.33 |
< 0.33 |
TTEM |
| 58 |
4 |
0.33 |
< 0.33 |
TTEM |
| 59 |
4 |
0.33 |
< 0.33 |
TTEM |
| 60 |
6 |
0.33 |
< 0.33 |
TTEM |
| 61 |
4 |
0.33 |
< 0.33 |
TTEM |
| 62 |
5 |
0.33 |
< 0.33 |
TTEM |
ECCS = Mobile lab results from March 2003 sampling (ENTACT
2003)
TTEM = Tetra Tech EM, Inc. surface soil sampling from 1999 (Tetra Tech 2001)
MDL = Method Detection Limit (MDL values in bold are above "normal"
and presumed to be due to matrix effects within individual samples)
Table A-2. River sediment sampling data
from Shiawassee River.
| Transect |
# of Samples |
MDL (ppm) |
Total PCB Range (ppm) |
Reference |
| 1 |
3 |
0.33 |
< 0.33 |
TTEM |
| 2 |
3 |
0.33 |
< 0.33 |
TTEM |
| 3 |
3 |
0.33 |
< 0.33 |
TTEM |
| 4 |
11 |
0.1, 0.3, 0.33, 6.6 |
0.11-46 |
TTEM, ECCS |
| 5 |
3 |
0.33 |
< 0.33- 5.2 |
TTEM |
| 6 |
3 |
0.33 |
< 0.33- 0.44 |
TTEM |
| 7 |
23 |
0.1, 0.3, 0.33, 1.65, 3.3, 8.25,
8.25, 16.5 |
0.14- 300 |
TTEM, ECCS |
| 8 |
2 |
0.33 |
1.0-3.6 |
TTEM |
| 9 |
2 |
0.33 |
< 0.33- 0.54 |
TTEM |
| 10 |
2 |
0.33 |
0.7-1.9 |
TTEM |
| 11 |
11 |
0.1, 0.33, 0.66, 1.32 |
0.12-26 |
TTEM, ECCS |
| 12 |
60 |
0.1, 0.3, 0.33, 0.66, 3.63 |
0.12-190 |
TTEM, ECCS |
| 13 |
3 |
0.33 |
0.92-9.2 |
TTEM |
| 14 |
2 |
0.33, 0.66 |
1.4-7.1 |
TTEM |
| 15 |
3 |
0.33 |
0.58-1.3 |
TTEM |
| 16 |
2 |
0.33 |
< 0.33- 0.78 |
TTEM |
| 17 |
2 |
0.33 |
< 0.33- 1.3 |
TTEM |
| 18 |
2 |
0.33 |
< 0.33- 0.92 |
TTEM |
| 19 |
2 |
0.33 |
1.5-6.6 |
TTEM |
| 20 |
2 |
0.33 |
< 0.33- 1.4 |
TTEM |
| 21 |
30 |
0.1, 0.33 |
0.13-40 |
TTEM, ECCS |
| 22 |
2 |
0.33 |
0.87-1.4 |
TTEM |
| 23 |
2 |
0.33 |
0.48- 0.76 |
TTEM |
| 24 |
3 |
0.33 |
< 0.33 |
TTEM |
| 25 |
7 |
0.1, 0.33, 16.5 |
0.12-100 |
TTEM, ECCS |
| 26 |
2 |
0.33 |
< 0.33 |
TTEM |
| 27 |
5 |
0.33 |
0.53-13 |
TTEM |
| 28 |
2 |
0.33 |
< 0.33- 2.7 |
TTEM |
| 29 |
2 |
0.33 |
< 0.33- 0.97 |
TTEM |
| 30 |
2 |
0.33 |
< 0.33- 0.35 |
TTEM |
| 31 |
2 |
0.33 |
0.34- 0.96 |
TTEM |
| 32 |
2 |
0.33 |
0.38-1.6 |
TTEM |
| 33 |
3 |
0.33 |
< 0.33- 0.82 |
TTEM |
| 34 |
2 |
0.33 |
< 0.33 |
TTEM |
| 35 |
2 |
0.33 |
0.39-1.0 |
TTEM |
| 36 |
2 |
0.33 |
< 0.33- 2.6 |
TTEM |
| 37 |
3 |
0.33 |
1.2-1.3 |
TTEM |
| 38 |
2 |
0.33 |
0.48- 0.72 |
TTEM |
| 39 |
3 |
0.33 |
0.64- 0.86 |
TTEM |
| 40 |
2 |
0.33 |
0.43-2.9 |
TTEM |
| 41 |
2 |
0.33 |
< 0.33- 2.5 |
TTEM |
| 42 |
2 |
0.33 |
< 0.33- 1.4 |
TTEM |
| 43 |
2 |
0.33 |
0.67- 0.89 |
TTEM |
| 44 |
2 |
0.33 |
< 0.33- 0.83 |
TTEM |
| 45 |
3 |
0.33 |
< 0.33 |
TTEM |
| 46 |
2 |
0.33 |
< 0.33- 2.0 |
TTEM |
| 47 |
2 |
0.33 |
0.71- 0.91 |
TTEM |
| 48 |
2 |
0.33 |
< 0.33- 1.3 |
TTEM |
| 49 |
2 |
0.33 |
< 0.33- 3.0 |
TTEM |
| 50 |
3 |
0.33 |
1.1-8.9 |
TTEM |
| 51 |
4 |
0.33 |
1.2-2.0 |
TTEM |
| 52 |
2 |
0.33 |
1.2-1.3 |
TTEM |
| 53 |
2 |
0.33 |
1.2-4.0 |
TTEM |
| 54 |
2 |
0.33 |
0.61- 0.86 |
TTEM |
| 55 |
2 |
0.33 |
< 0.33- 0.97 |
TTEM |
| 56 |
2 |
0.33 |
1.9-7.5 |
TTEM |
| 57 |
2 |
0.33 |
1.4-4.2 |
TTEM |
| 58 |
2 |
0.33 |
< 0.33 |
TTEM |
| 59 |
2 |
0.33 |
1.1-1.8 |
TTEM |
| 60 |
2 |
0.33 |
0.81- 0.98 |
TTEM |
| 61 |
2 |
0.33 |
< 0.33 |
TTEM |
| 62 |
2 |
0.33 |
< 0.33 |
TTEM |
ECCS = Mobile lab results from March 2003 sampling (ENTACT
2003)
TTEM = Tetra Tech EM, Inc. surface soil sampling from 1999 (Tetra Tech 2001)
MDL = Method Detection Limit (MDL values in bold are above "normal"
and presumed to be due to matrix effects)
APPENDIX B: EXTENDED SITE HISTORY
The first reported confirmation of PCB contamination in the South Branch of
the Shiawassee River was in 1974, during a routine stream survey conducted by
MDNR, when PCBs were found in sediment collected downstream of the former CFC
property (MPE 1997).B1 Various sampling investigations involving biota, river
sediment, floodplain soils, groundwater, and on-site soils were conducted by
MDNR from this time until 1998.
During 1978–1979, MDNR detected high concentrations of PCBs in soils surrounding
the former CFC facility, as well as in on-site monitoring wells. Other state-led
sampling investigations at this same time found both sediment and aquatic life
to have elevated levels of PCB concentration. In fact, trace concentrations
(approximately 0.6 ppm) of PCBs were found 40 miles downstream in the sediments
of the Shiawasseetown Reservoir (MPE 1997). After reports of unauthorized PCB
discharges from CFC in 1978, three shallow groundwater monitoring wells were
placed around the on-site former lined wastewater lagoon. Sampling done at this
time reported on-site soil concentrations as high as 41,000 ppm, in addition
to low concentrations in groundwater (MPE 1997).
Pursuant to the findings of 1978, MDNR filed suit against CFC to address contaminated
soils from the former CFC property, removal of contaminated sediment from the
river channel downstream from the facility, and removal of contaminated soils
from the floodplain. CFC hired an outside contractor in 1980 to replicate the
on-site sampling results done in 1978 as well as to perform sampling out to
10 miles downstream of the facility. These results reported no PCBs detected
in groundwater; however, elevated PCB concentrations were found in soils up
to 8 feet deep near a former on-site drainage ditch. A consent judgment was
signed in 1981; it required remediation of the former CFC property as well as
remediation of the 8-mile stretch of the South Branch immediately downstream
of the facility. This remedial action was partially carried out in 1982, when
over 1,800 cubic yards of contaminated sediment were removed from a 1.5-mile
stretch immediately downstream of the facility. Investigations of the area during
the 1970s, as well as residual post-remediation PCB contamination of the river
sediment, were the basis for placement of the site on the National Priorities
List in 1983.
MDNR collected and analyzed fish from the South Branch of the Shiawassee River
several times from 1981 to 1987 as part of the Michigan Fish Contaminant Monitoring
Program (MDEQ 2003). The most recent fish sampling event was in July 1987, near
the Marr Road bridge crossing, where 10 rock bass and 10 white suckers were
collected and fillet samples were analyzed by the MDPH laboratory (ATSDR 1993).
Rock bass tissue averaged 7.95 ppm, while the white sucker tissue averaged 17.52
ppm. Because of the lack of fish length data, it is impossible to derive any
reliable relationship between fish body length and PCB tissue concentration
(ATSDR 1993). MDNR also collected fish from the South Branch at New Lothrop
Road near Byron, Michigan (Shiawassee County) in July 1987, collecting 10 carp,
3 northern pike, and 7 smallmouth bass. Maximum concentrations in fillet samples
of carp were 7.45 ppm; in pike, 1.21 ppm; and in smallmouth bass, 0.31 ppm.
MDCH uses the U.S. Food and Drug Administration (USFDA) trigger level of 2 ppm
for total PCB concentrations when developing fish consumption advisories for
the general public (MDEQ 2003).
The initial Remedial Investigation (RI) of the former CFC property and South
Branch was initiated in 1986 by Warzyn, Inc., and released in 1992 as part of
the MDNR RI/Baseline Risk Assessment document (Warzyn 1992). Part of the RI
involved splitting the 40-mile stretch of river than runs from the former CFC
property to the Shiawasseetown Reservoir into just over 60 irregularly spaced
sampling transects (which have been used by a majority of the studies that have
been done on the river since the RI). Results of the 1992 RI indicated that
residual PCB contamination persisted both on- and off-site, with most of the
off-site sediment contamination limited to within 6,000 feet of the former CFC
facility. Further investigation and remediation of river sediments were suggested
in the RI at the time, and sediment quality objectives were generated in the
baseline risk assessment for later use in the EPA ROD. The sediment quality
objectives selected ranged from 0.0009 to 0.553 ppm; they were based on baseline
risk assessment (Warzyn 1992).
A supplemental Feasibility Study (FS) was issued in 1997, based on 1992 RI
data and supplemental data collected from the sites in 1994 (MPE 1997). Similarly
to the RI, sediment, site soil, biota, and groundwater samples were collected.
Also similarly to the RI, the FS suggested further investigation and remediation
of river sediments. Two preliminary clean-up levels for soil (10 and 25 ppm)
and four preliminary clean-up levels for sediment (1, 5, 10, and 25 ppm) were
identified for evaluation in the FS report.
A final supplemental FS was performed by EPA Region 5 in 1999 to assess the
most current extent of PCB contamination in on-site soils, in South Branch river
sediment, and in adjacent floodplain soils (Tetra Tech 2001). On-site sampling
was limited to areas previously sampled and to the reported remaining residual
on-site soil contamination in the low-lying lagoon areas east and northeast
of the former facility buildings. Sediment and soil samples were collected from
the 61 transects set up during the RI; five floodplain (Transects 9, 16, 26,
28 and 37) and six sediment (Transects 4, 7, 11, 12, 25, and 27) locations were
shown to be PCB "hotspots." Results from the final FS formed the basis
of many of the decisions made in the EPA ROD. A fish-shocking protocol was followed
in the final FS for the purpose of examining stunned fish for lesions; none
were found through this sampling effort.
Gradient Corporation (2000) performed a statistical evaluation of this 1999
data for those samples taken within 3.5 downstream miles of the former CFC facility.
Gradient reported a "sample mean concentration of PCBs in river sediments
downstream of Cast Forge property" of 5.43 ppm; however, Gradient considered
the geometric mean a "more appropriate and more stable estimate."
The corresponding geometric mean was reported to be 2.14 ppm, with a 95th
upper confidence limit (UCL) of 3.37 ppm. This 95th UCL is one full
order of magnitude higher than the current Michigan clean-up standard of 0.33
ppm for PCBs in sediment. The Michigan standard is based on the MDL for SW-46
standard method 8082 for the higher chlorinated Aroclor mixtures (1242, 1248,
1254, and 1260).
In April 2002, EPA issued an administrative order directing the excavation
and off-site disposal of PCB-contaminated soils and sediment; remediation action
levels (RALs) of 5 and 10 ppm were chosen for river sediment and floodplain
soil, respectively. These RALs were based on an estimated post-remediation Surface
Weighted Average Concentration (SWAC) goal of 1 ppm along the first river mile
downstream of the former CFC property. EPA reported that the calculated SWAC
value will result in attainment of a SWAC Preliminary Remediation Goal (PRG)
of 0.2 ppm in sediment after seven years. The SWAC PRG falls within the long-term
PRG range of 0.002 to 0.3 ppm, as determined from an ecological risk assessment
that used mink as the receptor. (The primary component of the mink's diet is
fish.)
MDEQ prepared a work plan in 2002 outlining the steps necessary for delineation
of river sediment contamination within the South Branch (Gannett Fleming 2003).
This study sampled sediment along the entire 40-mile stretch from the former
CFC facility to the Shiawasseetown Reservoir. The 40-mile stretch was split
into three smaller study areas: Study Area 1 consisted of the area between the
former CFC facility and the Chase Lake Road crossing (about 7 miles downriver);
Study Area 2 consisted of the 33-mile stretch between Chase Lake Road and the
Shiawasseetown Reservoir; and Study Area 3 was the reservoir itself. The final
report from the sampling is still being created as of the writing of this health
consultation; however, preliminary data results confirm continuing residual
PCB contamination within Study Area 1. In addition, this sampling effort examined
roughly 20% of the samples for the presence of dioxin, using a rapid screening
method. All measured levels of dioxin in sediment were found to be consistent
with Michigan background concentrations.
The results from Gannett Fleming (2003) were not included in the meta-analysis
because this sampling event did not use the transect system employed in most
other recent reports. The unique aspects of this data collection are that sediment
samples were taken from outside the original 8-mile study area and that some
samples were screened for polychlorinated dioxin (PCDD) and furan (PCDF) congeners.
All PCB samples taken outside the original 8-mile study were non-detect at an
MDL of 0.33 ppm. Two of 13 samples screened for PCDDs/PCDFs showed detectable
concentrations, and all were found to be consistent with Michigan background
concentrations. The MDL for the PCDD/PCDF screen is 4 parts per trillion.
The EPA PDI sampled river sediment, on-site soil, and floodplain soil during
March to July 2003. Sampling was limited to the first river mile downstream
of the former CFC facility and to the "hotspots" identified in both
sediment and soil in the final FS report. The PDI confirmed residual PCB contamination
in on-site soils, river sediment, and floodplain soils.
This health consultation examines the data generated by the 1999 final FS report,
by the 2003 pre-design investigation, and by the as yet unpublished results
of the LOE contractor (MDCH has the raw data from this sampling effort). These
three data reports represent the most recent and most extensive characterization
of the PCB contamination found in river sediment and floodplain soil of the
40-mile stretch of the South Branch of the Shiawassee River.
APPENDIX C: ESTIMATION OF PCB DOSE THROUGH ANIMAL CONSUMPTION AND SOIL INGESTION PATHWAYS
All algorithms used to estimate dose through the fish consumption pathway were
adapted from the EPA's 1998 guidance titled Human Health Risk Assessment Protocol
for Hazardous Waste Combustion Facilities.
Table C-1. Estimated consumption rates
for freshwater fish for adults and children of Michigan.
| Age |
CT (mean) |
RME (95th p'tile) |
Reference |
| Adult-general |
6 g/day (0.000084) |
19 g/day (0.00026) |
EPA 1997 |
| Adult-rec. fisher |
12 g/day (0.00017) |
39 g/day (0.00054) |
EPA 1997A |
| Child-general |
1.88 g/day (0.000033) |
13.9 g/day (0.00024) |
EPA 2002 |
A This data appears in a 1989 study of Michigan freshwater anglers as cited
in EPA 1997.
The estimated consumption rates for freshwater fish in the table (CRfish) were used
as input into the algorithm below to calculate total intake of PCBs through
fish consumption (Ifish, in mg/kg-day). First, the given consumption rates had to
be converted to kilograms of fish tissue consumed per kilogram body weight (BW)
per day. Body weights were assumed to be 71.8 kg for adults and 57.1 kg for
children (here defined as no older than 14 years of age). These converted values
are listed in Table C-1 in parentheses in units of kg of PCB per kg BW per day.
Ifish = Cfish × CRfish × Ffish
where
Cfish = concentration in fish tissue (mg/kg)
CRfish = consumption rate of fish (kg/kg-day)
Ffish = fraction of fish that are contaminated
Fish concentration data were taken from FRG (1999), which reported 2.56 ppm
in the white sucker. For the sake of conservatism, 100% of all fish are considered
to be contaminated, so that Ffish is assumed to be 1.
Table C-2. Estimated PCB intake rates
from consumption of freshwater fish for adults and children of Michigan. All
intakes/standards are in mg/kg-day.
| Age |
CT (mean) |
RME (95th p'tile) |
Risk-Based StandardA |
| Adult - general |
0.00022 |
0.00066 |
0.00002 |
| Adult - rec. fisher |
0.00044 |
0.0014 |
0.00002 |
| Child - general |
0.000084 |
0.00061 |
0.00002 |
A The PCB intakes here are
compared to ATSDR's chronic oral Minimum Risk Level (MRL). The intermediate
oral standard is 0.00003 mg/kg-day.
Uncertainties related to this dose estimation are as follows:
- The assumption that 100% of fish consumed are contaminated may not
adequately reflect site-specific conditions.
- Site-specific fish consumption rates for adult and children of both
the general population and the recreational angler population may not be identical
to the assumption.
- The fish concentration used (white sucker sampled in 1994) may not
necessarily reflect current site conditions with regard to fish contamination
or preferred species consumed from the site.
- 100% gastrointestinal absorption is assumed, for the sake of conservatism.
Actual absorption values are likely to be between 50 and 100%, with the co-planar
PCB congeners tending to be more completely absorbed.
From the estimated doses from fish consumption alone (consideration of other
pathways would serve only to increase total daily dose, dependent on site-specific
exposure patterns) from Table C-2, all adult and child consumption scenarios
exceed both the ATSDR chronic oral MRL and the intermediate oral MRL of 0.00003
mg-kg-day.
This chronic oral MRL is based on feeding studies done with Aroclor 1254 and
Rhesus monkeys. A low-observed adverse effect level (LOAEL) of 0.005 mg/kg-day
was identified from these studies, based on an immunologic endpoint of decreased
antibody response. A total uncertainty factor of 300 was applied to this LOAEL
to derive the chronic MRL (and coincidently, the EPA oral reference dose as
well). From consulting Table C-2, one sees that all intake scenarios exceed
the LOAEL from the Rhesus monkey feeding studies.
Given that the white sucker data used to generate the dose estimations are
associated with a sediment concentration of 0.72 ppm (see FRG 1999), it is quite
probable that much higher sediment concentrations (as seen at hotpots 7 and
25, Table 3) are associated with higher doses than those reported in Table C-2,
assuming the same exposure patterns.
CERTIFICATION
This Shiawassee River Superfund Site Health Consultation was prepared by the
Michigan Department of Community Health under a cooperative agreement with the
Agency for Toxic Substances and Disease Registry (ATSDR), an agency within the
U.S. Department of Health and Human Services. It is in accordance with approved
methodology and procedures existing at the time the health consultation was
begun.
Alan W. Yarbrough
Technical Project Officer, SPS, SSAB, DHAC, ATSDR
The Division of Health Assessment and Consultation, ATSDR, has reviewed this
public health consultation and concurs with the findings.
Lisa C. Hayes
for Chief, State Programs Section, SSAB, DHAC, ATSDR
B1 As of October 1, 1995, the environmental
protection and regulation functions of the Michigan Department of Natural Resources
(MDNR) were transferred to the newly formed Michigan Department of Environmental
Quality (MDEQ).
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