PUBLIC HEALTH ASSESSMENT
CROSS COUNTY SANITATION LANDFILL
(a/k/a KESSMAN SITE)
PATTERSON, PUTNAM COUNTY, NEW YORK
Figure 1. Cross County/Kessman Site Location Map
APPENDIX B: PUBLIC HEALTH HAZARD CATEGORIES
INTERIM PUBLIC HEALTH HAZARD CATEGORIES
| CATEGORY / DEFINITION | DATA SUFFICIENCY | CRITERIA |
| A. Urgent Public Health Hazard
This category is used for sites where short-term exposures (< 1 yr) to hazardous substances or conditions could result in adverse health effects that require rapid intervention. |
This determination represents a professional judgement based on critical data which ATSDR has judged sufficient to support a decision. This does not necessarily imply that the available data are complete; in some cases additional data may be required to confirm or further support the decision made. | Evaluation of available relevant information* indicates that site-specific conditions or likely exposures have had, are having, or are likely to have in the future, an adverse impact on human health that requires immediate action or intervention. Such site-specific conditions or exposures may include the presence of serious physical or safety hazards. |
| B. Public Health Hazard
This category is used for sites that pose a public health hazard due to the existence of long-term exposures (> 1 yr) to hazardous substance or conditions that could result in adverse health effects. |
This determination represents a professional judgement based on critical data which ATSDR has judged sufficient to support a decision. This does not necessarily imply that the available data are complete; in some cases additional data may be required to confirm or further support the decision made. | Evaluation of available relevant information* suggests that, under site-specific conditions of exposure, long-term exposures to site-specific contaminants (including radionuclides) have had, are having, or are likely to have in the future, an adverse impact on human health that requires one or more public health interventions. Such site-specific exposures may include the presence of serious physical or safety hazards. |
| C. Indeterminate Public Health Hazard
This category is used for sites in which "critical" data are insufficient with regard to extent of exposure and/or toxicologic properties at estimated exposure levels. |
This determination represents a professional judgement that critical data are missing and ATSDR has judged the data are insufficient to support a decision. This does not necessarily imply all data are incomplete; but that some additional data are required to support a decision. | The health assessor must determine, using professional judgement, the "criticality" of such data and the likelihood that the data can be obtained and will be obtained in a timely manner. Where some data are available, even limited data, the health assessor is encouraged to the extent possible to select other hazard categories and to support their decision with clear narrative that explains the limits of the data and the rationale for the decision. |
| D. No Apparent Public Health Hazard
This category is used for sites where human exposure to contaminated media may be occurring, may have occurred in the past, and/or may occur in the future, but the exposure is not expected to cause any adverse health effects. |
This determination represents a professional judgement based on critical data which ATSDR considers sufficient to support a decision. This does not necessarily imply that the available data are complete; in some cases additional data may be required to confirm or further support the decision made. | Evaluation of available relevant information* indicates that, under site-specific conditions of exposure, exposures to site-specific contaminants in the past, present, or future are not likely to result in any adverse impact on human health. |
| E: No Public Health Hazard
This category is used for sites that, because of the absence of exposure, do NOT pose a public health hazard. |
Sufficient evidence indicates that no human exposures to contaminated media have occurred, none are now occurring, and none are likely to occur in the futur |
APPENDIX C: RESPONSE TO PUBLIC COMMENTS
This summary was prepared to address comments and questions on the Public Health Assessment for the Kessman/Cross County site in Patterson, Putnam County. The public was invited to review the draft during the public comment period which ran from July 15 to August 28, 1998. We received oral and written comments from residents and written comments from the New York City Department of Environmental Protection (NYC DEP). Similar comments may be consolidated or grouped together and some statements reworded to clarify the comment. If you have any questions about this summary, you may contact the New York State Department of Health's (NYS DOH) Outreach Unit at the toll free number: 1-800-458-1158, extension 27530.
Comment 1:
I suggest that further studies be done about a possible link between the dump site and residents on Cornwall Hill Road with autoimmune diseases. I have been diagnosed with rheumatoid arthritis and others who reside on Cornwall Hill Road also have autoimmune diseases.
Response 1:
Based on the information reviewed there was no evidence that the residents living near the landfill are being or have been exposed to levels of site related contaminants in soil, leachate, sediment, surface water, ground water or air that would cause adverse health effects. Based on this information a health study of area residents is not warranted at this time. Residents of the area can call the NYS Center for Environmental Health at 1-800-458-1158 to discuss health concerns they may have related to the site.
Comment 2:
The site visit and physical hazards section of the public health assessment, page 6, indicates that people can enter the property by walking around the fence at the driveway. This access seems to indicate that the remedial action is not completely adequate. An additional recommendation should include some action, possible extension of the fencing to deny access of unauthorized persons.
Response 2:
Although there is a fence over 3/4 of the site, there is no fence on the swamp side of the site. Access to the site from the swamp side, however, is difficult. The fencing is not meant to be a remedial action, but instead it is meant to limit access to the site, protect the landfill cover and alert individuals to the fact that the area is an inactive hazardous waste site. Possible exposures to site-related contaminants could occur from trespassing if the integrity of the landfill cover is compromised or if leachate were to leave the landfill and migrate to accessible areas. For those reasons, we recommend implementation of the long-term monitoring program.
Comment 3:
If the polychlorinated biphenyls (PCBs) contaminated sediment which is below the landfill cap caused off-site contamination, how and when will this PCB contamination be removed?
Response 3:
Levels of PCBs as high as 2970 parts per million (ppm) were found in the drum removal area which is east of the landfill in the area between it and the Great Swamp. This PCB contaminated soil was excavated during drum removal and taken off-site to an appropriate facility. The drum area is believed to be the source of the PCB contamination in the Great Swamp. The low levels of PCBs (12.2 ppm) found in the Great Swamp are slightly above the New York State Department of Environmental Conservation (NYS DEC) level of 10 ppm in its Technical and Administrative Guidance Memorandum (TAGM). The low-level PCB-contaminated soil was excavated and placed below the landfill cap. PCBs placed beneath the cap are not expected to migrate.
Comment 4:
Based solely on the public health assessment (PHA) and the remedial actions completed to date, we agree with the general recommendation that the NYS DEC should continue with long-term monitoring. However, the details of the monitoring program should be provided and evaluated to ensure that the monitoring program encompasses all of the areas of potential concern: surface and groundwater, landfill leachate, discharges to/from Great Swamp and Muddy Brook and the four private groundwater wells. To date the quarterly monitoring of the surface water, groundwater and landfill leachate as required by the 1994 Record of Decision (ROD) has not been accomplished. Therefore, no decisions should be made until this required quarterly monitoring has been accomplished and the results analyzed. Further, the leachate collection system was constructed for possible future use should monitoring results indicate that its use is warranted. To date, it has not been activated. The Great Swamp supports many varieties of fish and is used frequently by fishermen. The activation of the leachate collection system would help minimize further impact to all the biota as well as the fishermen through the food chain. This site has the potential to cause a long-term cumulative public health hazard to the drinking water quality of the residents of Patterson. Protection from these cumulative effects can also be mitigated by the activation of the leachate collection system. I urge you to activate this leachate collection system now to prevent further contamination of the Great Swamp and its drinking water resources.
Response 4:
Some, but not all of the long-term monitoring specified in the 1994 Record of Decision (ROD) has been done. Samples of landfill leachate were collected in September 1996, July and August 1997 and October and December 1998. Surface water, groundwater and private well samples were collected in July and August 1997 and December 1998. The data collected from 1996 to 1998 in two areas of the site were high in compounds indicative of landfill leachate. The specific data are presented in the PHA. The NYS DOH recommends that the leachate collection system be activated to reduce contamination entering the Great Swamp. The NYS DEC will determine the feasibility of activating the leachate collection system.
Comment 5:
On page 2 the document states that the railroad tracks separate the east and north sides of the site, which are wetlands, from the Great Swamp of Patterson. Historically the site in question was part of the Great Swamp, DP-22. However, after dumping occurred in the 1970's, the NYSDEC delisted the filled portion of the dump from DP-22 because it was no longer a wetland, but a dump! This is a NYS DEC Class 1 wetland; therefore, the Kessman site requires the highest possible remediation and protection.
Response 5:
Once the landfill filled that portion of the Great Swamp, it technically had to be "reclassified" as a landfill. However, the remainder of the Great Swamp is still a NYS DEC Class 1 wetland and will continue to receive the appropriate protection from contamination to prevent its degradation.
Comment 6:
Recently the Department of United States Geological Surveys (USGS), working with the NYC DEP, documented that the Great Swamp received over 75% of its water from groundwater. On page 5 you state the groundwater is contaminated with VOCs and SVOCs. Other contaminants are listed on page 12 and 13. All these contaminants are above NYS drinking water standards. The documented groundwater flow is north-easterly from the landfill towards the Great Swamp. The Great Swamp is the headwaters of the Croton Reservoir system and overlies the aquifer providing drinking water to the residents of Patterson and surrounding communities. Protection of this vital resource is of utmost importance.
Response 6:
The PCB drum removal and the placement of a cap on the landfill were done to minimize movement of contaminated groundwater from the site into the Great Swamp. There are monitoring wells between the Great Swamp and the landfill which are part of the system to detect whether site-related contaminants are entering the Great Swamp and subsequently the Croton Reservoir. Sampling of these wells is a part of the long-term monitoring program.
Comment 7:
The addition of the cover will not stop the continued contamination of the groundwater; it will only slow down the flow. The rise and fall of the water table beneath the site will continue to wash contaminants from the site into the Great Swamp.
Response 7:
Although there is no liner on the bottom of the landfill, the cap or cover on top of the landfill will significantly reduce the flow of water through the landfill. Prior to the installation of the cap, rain and surface water runoff were able to freely flow through the landfill, moving contaminants from the fill to the groundwater. This caused the greatest transfer of contaminants from the site to the groundwater. The installation of the cap minimizes this transfer of water through the contaminants, reducing the amount of contaminants in groundwater. There will be seasonal shifts of groundwater which are more vertical than lateral due to rise and fall of the watertable. Vertical fluctuation in groundwater will not result in significant additional groundwater contamination. Monitoring wells are in place to determine if contaminants are flowing towards the Great Swamp.
Comment 8:
The leachate collection system was constructed for possible future use should monitoring results indicate that its use is warranted. To date, it has not been activated. On Page (14) you state, "remedial activities at the site, including placing a cover and installing a leachate collection system should minimize the potential for exposures of health concern..." (Emphasis added). I urge you to activate this leachate collection system now to prevent further contamination of the Great Swamp and its drinking water resources. The Great Swamp supports many varieties of fish and is heavily used by fishermen. The activation of the leachate collection system would help minimize further impact to all the biota as well as the fishermen through the food chain. This site has the potential to become a long-term public health hazard to the residents of Patterson who use private wells. Protection from these potential effects can be mitigated by the activation of the leachate collection system.
Response 8:
Although the leachate collection system is in place, the intention was to activate the system only if significant site-related leachate is discharged from the landfill. As stated previously, some, but not all of the long-term monitoring specified in the 1994 Record of Decision has been done. The surface water sampling data collected near the landfill were high in compounds indicative of landfill leachate, suggesting potential leachate outbreak. These specific data are included in the PHA. The NYS DOH recommends that the leachate collection system be activated to reduce contamination entering the Great Swamp. The NYS DEC will determine the feasibility of activating the leachate collection system.
Comment 9:
The PHA indicated that the NYS DEC removed a total of 272 drums and contaminated soil from the landfill, but provided no information as to whether the drums were intact or corroded, and provides no information on the contents and concentration of potential contaminants in the drum or excavated soils. This information (which most likely is in one of the referenced documents) should be included in the PHA, as it provides some indication for the potential for D or L -NAPLs to be present. In turn, this information is needed to evaluate the likely effectiveness of the cleanup, as well as the adequacy of the groundwater investigation.
Response 9:
Although some of the 272 drums removed from the landfill were in fair condition, most were in bad condition. All of the drums were over packed, placed in larger drums to contain their contents. The majority of drums contained waste materials such as concentrated solvents which were inconsistent with the household waste historically disposed of in the landfill. The excavated drums and soils were taken off-site to a designated disposal facility. After the drum and soil excavation, additional soil samples were collected to confirm the contamination had been appropriately removed.
Comment 10:
The PHA indicates that various constituents were detected in leachate seeps located between the east side of the landfill and the railroad tracks. The NYS DOH indicated that this was not an issue for potential future exposures because of the placement of a landfill cap and the installation of a leachate collection system. While a cap and a leachate collection system is a presumptive remedy for a landfill, there is no evaluation in the PHA as to whether the leachate collection system is adequate, and there is no evaluation about the adequacy of the Operations and Maintenance for the cap and leachate system. It should be noted that this information is probably available in the ROD for the site. However, we believe that NYS DOH is correct in their analysis that these actions (cap and leachate collection system) will minimize the potential for exposure, additional details or general engineering designs criterial for the cap should be included in the PHA.
Response 10:
The NYS DOH will summarize and evaluate these data, with respect to the leachate collection system, in a letter to NYS DEC. It will be placed in the site's document repository.
Comment 11:
The PHA indicates that surface water and sediment sampling was limited to two events. Only one off-site sample location was selected downstream of the landfill at the confluence of a culvert and Muddy Brook. The PHA should clarify whether this off-site downstream location was sampled once or twice. The PHA indicates that some constituents were detected in surface water and sediments in the on-site samples collected east of the landfill and west of the railroad embankment, but that none were detected in the sample at the confluence with Muddy Brook. Based on these results, the PHA concluded that potentially significant past or future exposure to contaminants in surface water or sediments is unlikely. Based on the information contained in the PHA, it is impossible to fault this conclusion. However, given the concentrations detected at the on-site locations, and the number of drums removed, this conclusion seems to be based on very limited data. In that context, the nature of the long-term monitoring program should be specified, particularly with regard to any surface water sampling. Moreover, we believe that the groundwater and surface water investigations may not have been adequate for determining potential impacts on the Great Swamp, and by extension, on the surface water leading from the Great Swamp.
Response 11:
As stated in Response #4, some, but not all of the long-term monitoring has been done. Periodic sampling was conducted at the site. Part of that periodic sampling included groundwater and surface water sampling. During the 1993 and 1994 on-site investigations, surface and groundwater samples were collected at strategic areas on and off-site where the potential for off-site migration into the Great Swamp would be greatest. Multiple surface and groundwater samples were collected to determine the landfill's possible impact on the Great Swamp. Site-related contaminants were detected in the groundwater samples at levels slightly above the NYS DOH drinking water standards on-site and off-site within the Great Swamp. Site-related contaminants were detected in the surface water samples at levels slightly above the NYS DOH drinking water standards on-site, but no contaminants were detected in the surface water samples from the Great Swamp or the Muddy Creek. December 1998 monitoring results, however, show that surface water samples contained VOCs. Although groundwater data did not show any VOC contamination, heavy metals were detected at elevated levels during recent sampling.
Comment 12:
Additional information on the groundwater investigation should be provided in the PHA, based on the concentration of constituents detected on-site and in drums. Was or is there a potential for a non-aqueous phase liquid or (NAPL) to be present and was the groundwater investigation adequate to detect a dense, non-aqueous phase liquid or (D-NAPL)? Secondly, the PHA indicates that groundwater flows from the west to east, from the site to the Great Swamp. However, no downgradient off-site wells were installed in the Great Swamp, which is a discharge area for groundwater. Moreover, no surface water or sediment samples were collected from within the Great Swamp, near the railroad embankment, to determine the potential for chemical constituents to migrate via groundwater, under the railroad embankment to determine the potential for chemical constituents to migrate via groundwater, under the railroad embankment and into the Great Swamp. The PHA should evaluate the adequacy of the groundwater investigation for determinating past or future exposures via the groundwater to surface water pathway, both for recreational use and for use as a water supply.
Response 12:
Although high levels of volatile organic compounds (VOCs) were detected in the drums neither NAPL nor
D-NAPL were detected in the groundwater on- or off-site. Before the site remediation, drum and contaminated soil removal, and the placement of the landfill cap, multiple soil and groundwater samples were taken in the Great Swamp and the site side of the railroad tracks. No site-related contaminants were found on the off-site side of the railroad track within the swamp. Monitoring wells were placed between the landfill and the Great Swamp to detect possible site-related contaminated groundwater flowing from the site towards the Great Swamp.
APPENDIX D: ATSDR PLAIN LANGUAGE GLOSSARY OF ENVIRONMENTAL HEALTH TERMS
