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1. ATSDR > Public Health Assessments & Consultations

PUBLIC HEALTH ASSESSMENT

HOOKER CHEMICAL/RUCO POLYMER
HICKSVILLE, NASSAU COUNTY, NEW YORK

Table 1.

On-Site Soil and Sediment Sample Results for the Hooker Chemical/Ruco Polymer Site
Collected During 1990 Remedial Investigation⁺
(All values in milligrams per kilogram, mg/kg)
[See Table 2 for Public Health Assessment Comparison Values]

	On-site shallow soils from 0.0 feet to 2.0 feet deep		On-site soils greater than 1.0 feet deep***		Sediments****
	Range	Frequency	Range	Frequency	Range	Frequency
Volatile Organic Chemicals
*1,2-dichloroethene (total)	ND-0.011	5/30**	ND-3.4	9/63	ND-0.076	2/13
*carbon tetrachloride	ND-0.68	05/30	ND-<2.0	7/63	ND	0/13
*trichloroethene	ND-0.720	12/30	ND-7.60	26/63	ND-0.002	4/13
*tetrachloroethene	ND-0.710	16/30	ND-57.0	49/63	ND-0.001	2/13
Semi-volatile Organics
*PCBs 1248	ND-5.3	11/30	ND-2,100.0	15/63	ND-73.0	7/13
*PCBs 1254	ND	0/30	ND-2.4	2/63	ND	0/13
Inorganics
*antimony	ND-28.0	13/30	ND-28.0	28/63	ND-31.0	8/13
*cadmium	ND-7.9	15/30	ND-11.0	30/63	ND-9.0	7/13

ND - not detected

< = less than

*Contaminant selected for further evaluation

**Frequency values represent the number of times the contaminant was found (5) out of the total number of samples collected (30) (5/30).

***This column does not include the data for soils reported as 0-2 feet in Appendix 10 and reported in the first column of this table.

****Total number of samples including a set of duplicates.

⁺Leggette, Brashears and Graham, Inc., 1990. Draft Remedial Investigation, Hooker Chemical/Ruco Polymer Site. Hicksville, New York. Draft Report I-IV.

Table 2.

Public Health Assessment Comparison Values for Contaminants
Found in On-Site Soil and Sediment at the Hooker Chemical/Ruco Polymer Site.
(All values in milligrams per kilogram, mg/kg) Comparison Values

 

	Typical Background Range	Comparison Values
		Minimal Health Risk Nonresidential*				Minimal Health Risk Residential Exposure**
		Cancer	Source	Noncancer	Source	Cancer	Source	Noncancer	Source
Volatile Organic Chemicals
1,2-dichloroethene (total)	ND	-	-	14,000	EPA RfD	-	-	2	NYS RfG
carbon tetrachloride	ND	5.4	ATSDR CREG	490	EPA RfD	0.03	NYS CREG	0.7	NYS RfG
trichloroethene	ND	56	EPA CPF	5,200	EPA RfD	0.2	NYS CREG	5	NYS RfG
tetrachloroethene	ND	14	EPA CPF	7,000	EPA RfD	0.06	NYS CREG	10	NYS RfG
Semi-Volatile Organics
PCBs 1248	<0.01-0.04a	0.09a	ATSDR CREG	42	NYS RfG	0.03a	NYS CREG	4	NYS RfG
PCBs 1254	<0.01-0.04a	0.09a	ATSDR CREG	70	NYS RfG	0.03a	NYS CREG	5	NYS RfG
Inorganics
antimony	0.6-10	-	-	20	EPA RfD	-	-	NA	-
cadmium	<0.5-1.0	-	-	140	ATSDR EMEG	-	-	10	ATSDR EMEG

NA - not available
^aTotal PCBs

*Soil ingestion by adults

**Ingestion of soil and homegrown vegetables by adults (cancer values) and children (noncancer)

ATSDR CREG = ATSDR Cancer Risk Evaluation Guide
ATSDR EMEG = ATSDR Environmental Media Evaluation Guide
EPA CPF = EPA Cancer Potency Factor
EPA RfD = EPA Reference Dose
NYS CREG = New York State Cancer Risk Evaluation Guide
NYS RfG = New York State Risk Reference Guide
NYS EMEG = New York State Environmental Media Evaluation Guide

Table 3.

Groundwater and Surface Water Data for Hooker-Ruco Site Collected
During 1990 Remedial Investigation
Hooker Chemical/Ruco Polymer Site
(All values in micrograms per liter, mcg/L)⁺

Comparison Values

Standards

New York State

US EPA

Groundwater++ On-Site

Groundwater Off-Site Downgradient

Groundwater Upgradient

Surface Water

Ground Water

Drinking Water

Drinking Water

Minimal Health Risk For Drinking Water

Range

Frequency

Range

Frequency

Range

Frequency

Range

Frequency

Cancer

Source**

Noncancer

Source**

Volatile Organic Chemicals

*1,2-dichloroethene (total)

ND-54.0

14/29***

ND-2.0

ND

0/4

ND

0/3

5.0

5.0j

100t; 70k

-

-

70

EPA LTHA

*trichloroethene

ND-18.0

10/29

ND-10.0

1/5

ND

0/4

ND

0/3

5.0

5.0

5.0

3

NYS CREG

52

EPA RfD

*tetrachloroethene

ND-98.0

12/29

ND-180.0

1/5

ND-3.0

0/4

ND

0/3

5.0

5.0

5.0

0.7

NYS CREG

70

EPA RfD

*vinyl chloride

ND-94.0

6/29

ND-560.0

1/5

ND

0/4

ND

0/3

2.0

2.0

2.0

0.02

EPA CPF

0.2

ATSDR EMEG

Semi-Volatile Organics

PCBs 1248

ND

0/29

ND

1/5

ND

0/4

ND-2.0

1/3

PCBs 1254

ND

0/29

ND

1/5

ND

0/4

ND

0/3

Inorganics

*antimony

ND-66.0

3/29

ND

1/5

ND

0/4

ND

0/3

3g

NA

6

-

-

6

*cadmium

ND-130.0

14/29

ND-3.0

2/6

ND

0/4

3.0-7.0

3/3

5

10

5.0

-

-

2

ATSDR EMEG

NA - not available
ND - not detected

g = guidance value
p = proposed standard
t = total dichloroethene
c = total PCBs
j = applies separately to cis and trans isomers

*Contaminant selected for further evaluation

**ATSDR EMEG = ATSDR Environmental Media Evaluation Guide
EPA CPF = EPA Cancer Potency Factor
EPA RfD = EPA Reference Dose
EPA LTHA = EPA Lifetime Health Advisory
NYS CREG = New York State Cancer Risk Evaluation Guide

***Frequency values represent the number of times the contaminant was found (14) out of the total number of samples collected (29) (14/29).

⁺Leggette, Brashears and Graham, Inc., 1990. Draft Remedial Investigation, Hooker Chemical/Ruco Polymer Site. Hicksville, New York. Draft Report I-IV.

⁺⁺This data is a summary of the information given in Table 4 and represents the results from sampling conducted in 1987 to 1990.

Summary of Historical Water-Quality Results
From USGS Monitor Wells Near Hooker/Ruco Polymer
(micrograms per liter, mcg/l)
[See Table 3 for comparison values]⁺

		N10812a	N10593b*	N10594b	N10597b	N10598b	N9079c
tetrachloroethene
	1987(S)	3	2	ND	320	790	ND
	1987(F)	7	ND	ND	30	240	1
	1988(S)	8	78	ND	52	NS	ND
	1988(F)	7	9	ND	9	NS	ND
	19901/	ND	ND	ND	NS	180	NS
trichloroethene
	1987(S)	ND	36	170	5	5	7
	1987(F)	ND	3	180	1	2	14
	1988(S)	ND	40	230	3	NS	4
	1988(F)	ND	51	440	ND	NS	3
	1990	ND	ND	ND	NS	10	NS
dichloroethene
	1987(S)	ND	340	ND	15	ND	15
	1987(F)	ND	91	ND	1	ND	22
	1988(S)	ND	330	ND	ND	NS	14
	1988(f)	ND	260	ND	ND	NS	ND
	1990	ND	ND	ND	NS	ND	NS
vinyl chloride
	1987(S)	ND	67.4	ND	ND	6	ND
	1987(F)	ND	280	1	ND	35	ND
	1988(S)	ND	72	1	ND	NS	ND
	1988(F)	ND	776	ND	ND	NS	ND
	1990	ND	530	ND	NS	ND	NS

1/ - 1990 RI groundwater sample results. S - Denotes Spring F - Denotes Fall ND - Not Detected NR - Results Not Reported NS - Not Sampled

a - Upgradient Monitoring Well b - Downgradient Monitoring Well b* - Immediately Downgradient c* - Side Gradient

⁺Leggette, Brashears and Graham, Inc., 1990. Draft Remedial Investigation, Hooker Chemical/Ruco Polymer Site. Hicksville, New York. Draft Report I-IV.

Table 5.

Toxic Release Inventory (TRI) Data for Facilities Near the
Hooker Chemical/Ruco Polymer Site - Air Releases of Chemicals
(Stack Plus Fugitive) in Pounds Per Year⁺⁺

Facility Chemical	Release
Grumman Aerospace Corporation
methanol	499
1,1,1-trichloroethane	97,158
methylene chloride	48,030
Freon 113	154,376+
methyl ethyl ketone	76,990
trichloroethene	217,875*+
toluene	10,000
tetrachloroethene	522,500*+
hydrogen fluoride	499
nitric acid	1,233
chromium	499
General Instrument Corporation
sulfuric acid	20
Alsy Manufacturing Inc.
1,1,1-trichloroethane	96,236
methyl ethyl ketone	4,418
Metco, Incorporated
aluminum	1,700
nickel	5,100
chromium	1,400
cobalt	1,180
Multiwire/EED
copper	5
Altana, Incorporated
isopropanol	12,610

*Hooker/Ruco Polymer site contaminant of concern.

⁺Contaminant anticipated to exceed 1 microgram per cubic meter within 1/2 mile of the Hooker/Ruco Polymer site.

⁺⁺1988 Toxic Release Inventory, US EPA

Hooker Chemical/Ruco Polymer
Responses to Public Comments

This responsiveness summary was prepared to respond to the public's comments and questions on the draft Public Health Assessment for the Hooker Chemical/Ruco Polymer site. The public was invited to review this draft public health assessment during the public comment period which ran from March 31, 1993 to May 3, 1993. Some comments were grouped together to incorporate similar concerns raised by more than one person. Comments made by the Occidental Chemical Corporation and Ruco Polymer Corporation are listed separately. If you have any questions about the responses to public comments for the Hooker/Ruco site, contact the New York State Department of Health, Health Liaison Program at the toll-free number, 1-800-458-1158, extension 402.

Local Citizen Comments

Comment #1

Does the New York State Department of Health have any plans to evaluate health outcome data specific for the area surrounding the Hooker/Ruco site? Will a community health survey be conducted?

Response #1

At this time the New York State Department of Health does not have plans to evaluate health outcome data specific to the area surrounding the Hooker/Ruco site. However, in the 1989 Breast Cancer Incidence Study this area was examined and found to have rates consistent with that for all of Nassau County. The 1989 study showed the rates for Suffolk and even more so for Nassau County are elevated compared to national rates and is the basis for additional work sponsored by the Centers for Disease Control and Prevention (CDC).

Comment #2

Synergistic exposures to a variety of these toxics could have a cumulative effect leading to cancer and serious medical problems (non-cancerous).

Response #2

When there is exposure to multiple contaminants selected for further evaluation, the risks are evaluated for cancer and noncancer health effects from such exposure to each contaminant. If the cancer and noncancer toxicological effects associated with each of these contaminants are the same or very similar, then the individual risks are added. This assumption of additivity of effects was used to determine the health risks described in the toxicological evaluation section of the Public Health Assessment for the Hooker Chemical/Ruco Polymer site. On the other hand, if these contaminants acted in a synergistic fashion, then the degree of risk would be greater than the sum of the risks associated from exposure to each chemical. Although synergism or antagonism of effects from exposure to multiple contaminants is a possibility, data on toxicological mechanisms are inadequate to evaluate what extent this synergism would occur.

Comment #3

An essential part of risk assessment is to determine whether or not the contamination will reach the public water supply wells; therefore, testing should be performed to determine if the contamination will reach the public water supply wells.

Response #3

The State of New York (the New York State Departments of Environmental Conservation (DEC) and Health (DOH)) have actively pursued further study of the groundwater contamination as it relates to public water supplies. Recently, Occidental Chemical Corporation submitted a workplan for studying off-site groundwater contamination. This work, in addition to work already in progress by Grumman Aerospace Corporation and the U.S. Navy, will provide information necessary to assess and protect the potential for impacts on public wells.

Comment #4

Water treatment should be a combination of air stripper and Granular Activated Carbon (GAC).

A)	Does an air stripper or GAC remove VOC's or PCB's at the Bethpage Water District?
B)	Would air stripping cause PCB's to be airborne?

Response #4

A)	PCBs have not been detected in samples of water from the Bethpage Water District or in groundwater anywhere off-site. The contaminants detected so far are volatile organic chemicals which are treatable by an air stripper or GAC. If PCBs were found, treatment would most likely be a GAC filter since air stripping would not remove all the PCBs.
B)	Air stripping of PCB contaminated water, if present, would volatilize some PCBs.

Comment #5

Will a 325 foot or 450 foot supply or production well pull in contamination? In other words, will a well change the natural course of groundwater flow?

Response #5

Any well of any depth has an area from which it withdraws water. This area is known as the "cone of influence". The size of the "cone of influence" depends on the pumping rate and the characteristics of the aquifer. Computer modelling and field testing have been used to characterize the cone of influences of many of the wells in the Bethpage area.

Comment #6

Is the contamination still occurring? If the soil is still contaminated with hazardous wastes, they will eventually end up in the ground and the wells.

Response #6

The major areas of soil contamination have been identified and these soils should be remediated shortly. The regulatory agencies for this site have worked to identify and eliminate on-going sources of contamination. In addition, Grumman Aerospace Corporation, as part of its response to contamination at its facility, is installing groundwater monitoring wells between Bethpage Water District supply wells and the Grumman Aerospace and Hooker/Ruco sites. These wells will help to warn of contamination which could reach the Bethpage Water Supply wells.

Further evaluation of the hydrogeology and contamination will be performed as additional information becomes available. Additionally, the US EPA and NYS DEC have requested Occidental Chemical Corporation, the responsible party for this site, to conduct off-site groundwater monitoring. This work would be carried out under Federal and/or State Superfund Programs.

Comment #7

The presence of contamination that are known carcinogens, mutagens, toxins are always of concern to the public. Soil should be cleaned to zero contamination. Clean up to a level of 10 mg per kg soil of PCBs is unacceptable.

Response #7

The cleanup level of 10 mg of PCBs per kg of soil was set with the understanding that the site will remain an industrial facility. The main objective of the PCB cleanup was to prevent further migration of the PCBs. No members of the public should be exposed to the soils left on-site if site conditions remain unchanged. Most of the PCB contaminated soils left on-site are covered by pavement. Additionally, institutional controls are part of the remediation of this site. The purpose of the institutional controls is to prevent changes in site use which result in exposure to these soils.

Comment #8

Why have off site soil samples not been collected?

Response #8

The practices that resulted in the contamination of on-site soils should not have resulted in contamination of off-site soils. These practices were the discharge of wastes to recharge basins on-site, and spills/leaks of liquids on-site. Sampling confirms that the contamination is limited to on-site soils.

Comment #9

You need to determine whether leaking sewer lines have contaminated the soils and ground water underneath the sewers.

Response #9

This comment has been forwarded to the US EPA and NYS DEC, which are responsible for investigating the sources and migration of the contamination. We do not believe this is a significant concern for public health. The industrial waste water was discharged to sumps on-site which have been investigated. This includes the beds of pipes used to transfer the waste water to these sumps. There is no information to indicate that the sanitary sewer systems are now used to discharge these wastes.

Comment #10

Has the source of tetrachloroethene upgradient of Hooker been identified? (Are there two sources of contamination?)

Response #10

Given the low levels of tetrachloroethene found in the upgradient wells and that there are no supply wells affected by this contamination, this requested work is of low priority. However, further work into the source of this contamination is warranted.

Comment #11

When did the state start issuing SPDES permits? Where are reports filed? When SPDES permits are issued for use and storage of hazardous wastes on site, does the county and the NYS DEC follow-up on investigations at frequent intervals to keep track of compliance?

Response #11

SPDES is an acronym for the program State Pollutant Discharge Elimination System which was, along with the national program, set up under the Clean Water Act of 1970. The New York State Department of Environmental Conservation oversees the SPDES program. For details on the SPDES program contact the NYS DEC Region 1 Office in Stony Brook. Their number is 516/751-7900.

Comment #12

Is the storage area for these wastes kept in proper condition to prevent further contamination?

Response #12

The handling and storage of waste on-site have significantly improved in recent years. Oversight of these practices is provided by the NYS DEC and the Nassau County Health Department. These agencies should be contacted if more information is desired.

Comment #13

Grumman should use recycling of water and a cap put on pumping to reduce plume movement. Air releases from Grumman are unacceptable. As long as Grumman continues to pump more than 14 million gallons per day in the summer, VOCs will be pulled in to the wells at a faster rate.

Response #13

The NYS DOH agrees with the general opinion of the hydrogeologists that have studied this area that shutting down the Grumman production wells may be a greater concern than leaving them on-line. The current pumping by Grumman is retarding off-site migration of contaminated groundwater. Since the water Grumman pumps from the aquifer is contaminated, they are required to treat their water before they discharge it to recharge basins on-site. This in essence is helping to remediate the contaminated groundwater.

Comment #14

What can be done to prevent ambient air releases of trichloro-ethene, Freon 113 and tetrachloroethene.

Response #14

Air emissions of these three chemicals, as well as all others in Nassau County, are regulated by the New York State Department of Environmental Conservation's Division of Air Resources and the Nassau County Health Department. For more information please contact Mr. Bryan Matthews of the Nassau County Health Department at 718-514-3719 or the New York State Department of Environmental Conservation (NYS DEC), Division of Air Resources at 516-444-0240.

Comment #15

A warning should be placed on the deed for this property.

Response #15

The New York State Department of Health and ATSDR agree with the need for institutional controls for this property. Institutional controls in the form of a deed notification have been requested. The US EPA is calling for institutional controls as part of the remedial design for operable unit 1.

MAJOR CONCERNS EXPRESSED BY RUCO POLYMER CORPORATION
AND/OR OCCIDENTAL CHEMICAL CORPORATION

The major concerns expressed by Ruco Polymer Corporation and/or Occidental Chemical are that the report did not accurately and consistently reflect the nature and extent of remedial work already performed, and that the text speculates about or implies that the Ruco site is or may be the source of various kinds of odor or groundwater pollution without offering any substantiation.

The report was reviewed to address these concerns and many changes were made. ATSDR and NYS DOH recognize that there has been significant remedial work completed at the Hooker/Ruco site. However, NYS DOH and ATSDR do not believe the 10.0 part per million clean up level used for on-site PCB contaminated soils is appropriate for a residential setting. This appears to be the basis for many of their comments. Additionally, Ruco Polymer correctly indicates that the groundwater contamination off-site can not be directly linked to the Hooker/Ruco site. The information available is not sufficient to make this determination. However, practices at the Hooker/Ruco site led to groundwater contamination and that the contamination may have migrated off-site.

Finally, Ruco Polymer expressed concern about the discussion of ambient air quality and its relation to the Toxic Release Inventory (TRI) data and odors. Ruco Polymer is correct in stating that based on the TRI data the amount of chemicals that they emit to ambient air is small compared to that of the Grumman Aerospace Corporation. However, local residents have complained to government agencies of odors that they attributed to the Hooker/Ruco site.

Specific Comments from Ruco Polymer Corporation

There were 47 comments received from Ruco Polymer Corporation. Thirty-five comments resulted in changes to the text to address the concerns expressed. Most of these comments improved the accuracy of the report. For this reason, specific responses to these comments are not presented.

Page numbers referenced in the following comments relate to the Public Comment Release Public Health Assessment (March 1993).

Comment #1

Page 1, paragraph 2: This paragraph creates the erroneous impression that the soils underlying the Ruco plant site are presently contaminated. A successful remediation of PCB contaminated soils was performed with the approval of the United States EPA and completed with the removal of 3,028,786 pounds of soil. The soil was taken off site and disposed of according to applicable regulations. The remediation was completed in August 1992 in conformance with the remedial work plan.

Given the completion of the remediation efforts at the site, current site conditions and compliance efforts, the potential for either worker or public exposure to contaminated soils is minimal. We accordingly request that this paragraph be revised to read as follows:

On-site soils in certain areas at the Hooker/Ruco Polymer site were formerly contaminated with polychlorinated biphenyls (PCBs), specifically the PCB known as Aroclor 1248. This contamination was limited in area, was in a location removed from most workers and has undergone successful remediation pursuant to a Remedial Action Plan approved by the United States EPA. The Plan involved the removal of some 3,000,000 pounds of affected soil. The remediation was completed in August 1992. In view of these actions and the fact that the entire site is fenced and patrolled by a 24-hour security force, there is little or no remaining potential for either worker or public exposure to PCB contaminated soils on site.

Response #1

Changes to the text were made to show that PCB contaminated soils on-site were cleaned to a level of 10.0 parts per million. changes were made throughout the text to indicate that this work was done. Included in the changes was an effort to portray that the potential for on-site workers or the public to be exposed to PCB contaminated soils is minimal. However, the text was amended to also make it clear that a clean-up level of 10.0 ppm is not considered acceptable for a residential setting by NYS DOH and ATSDR. It is for this reason that NYS DOH requested that institutional controls be included as part of the Record of Decision (ROD) to limit the potential for the site to be developed for residential property without further clean-up.

Comment #2

Page 4, paragraph 3: Has a syllabus for the community health education been approved? Will Ruco be given the opportunity to participate in the process?

Response #2

Specifics of the community health education program have not been developed. Ruco Polymer will have an opportunity to participate in the process, however, the NYS DOH and ATSDR will determine the content and presentation of the program.

Comment #3

Page 15, paragraph 2, sentence 2: Please revise "workers that should be trained" to read "workers who are routinely trained...".

Response #3

This change was not made since the statement "The workers should be trained" is appropriate whether they are trained or not. Obviously, we encourage Ruco Polymer to continue to train their employees as implied in this comment.

Comment #4

Page 19, paragraph 2: We would like to offer the following comments bearing on the relevance of this paragraph: According to the EPA at a recent seminar on TRI compounds, in all of Nassau County during 1992, 2,293,000 pounds of TRI compounds were emitted. Of this number, 1,028,000 pounds were emitted by a large industrial neighbor to our east. This is 44.83% of the total for Nassau County. Ruco emitted 1,600 pounds of TRI compounds. This is 0.069% of the Nassau County total. None of the compounds emitted by Ruco were involved in any of the investigations. Accordingly, we cannot perceive what relevance, if any, the emission of such compounds from the Ruco site can reasonably have to any assessment of public health implications.

Response #4

The local citizens feel that this is very relevant and for this reason it has been discussed in this document. Many residents have complained of offensive odors they attributed to the Ruco Polymer Corporation. In addition, these emissions are evaluated to determine whether they represent an additional human exposure to those already presented by the hazardous waste site.

Comment #5

Page 19, paragraph 4: We fail to see how an admitted lack of toxicity data can serve as a basis for a finding that the site "currently presents an indeterminate health hazard". Since there is no reasonable basis for such a conclusion, we request that this paragraph be revised accordingly.

Response #5

The indeterminate public health hazard category is based on the lack of environmental data for the groundwater pathway, not the lack of toxicity data.

The Hooker/Ruco site was given this classification since at this time it is not possible to determine the exact contribution the Hooker/Ruco site has had to off-site groundwater contamination. Additionally, we know that groundwater is the sole source for potable water and if government did not monitor or regulate this use, people may be drinking water contaminated by the Hooker/Ruco site.

Comment #6

Page 19, paragraph 5: The text here speculates about possible future exposure to contaminated groundwater when in fact, neither the constituents, quantities or sources of the "contamination" have yet been established. What use is served by speculation about possible human exposure in the future to what has not been established as existing in the present?

Response #6

The purpose of considering potential future exposures is to prevent exposures from occurring. For example, it will allow for the time necessary to install a treatment system on a water supply well before it becomes contaminated and, therefore, prevent water shortages or human exposure.

Comment #7

Page 20, paragraph 1, sentence 1: The text should read "...residents in the area of the Hooker/Ruco plant site...". Page 20, paragraph 2: Air quality in the area of the Ruco site may be impacted by a large industrial neighbor. There is a disproportionate amount of chemicals released by this neighbor as compared to Ruco Polymer Corporation. Ruco releases less than 0.16% of the amount released by our neighbor.

Response #7

Some changes to the text were made; however, the text already showed that for TRI emissions, the Grumman Aerospace Facility is a greater source of emissions than the Ruco Polymer Corporation.

Specific Comments from Occidental Chemical Corporation

Comment #1

The remedial program for PCB's in soil has been completed and has received United States Environmental Protection Agency (US EPA) approval. Therefore, all references to current or future exposure to levels in excess of 10 mg/kg (milligrams per kilogram) are now inappropriate and should be deleted.

Response #1

These changes have been made.

Comment #2

The document should discuss the fact the vinyl chloride in the ground water in the area is likely a result of the degradation of tetrachloroethene or trichloroethene.

Response #2

Changes were made to indicate that the vinyl chloride found is potentially from the degradation of tetrachloroethene or trichloroethene. However, the document also indicates that the vinyl chloride could also be directly from disposal practices.

Comment #3

The Public Health Assessment contains references to trichloroethylene in the Bethpage Water District well. By far the largest users of trichloroethylene in the area are Grumman and the Navy. It is extremely unlikely that the Hooker/Ruco site has had an adverse effect on the public supply well.

Response #3

Agreed, but the off-site data detailing the migration of contamination from the Hooker/Ruco site does not allow for this possibility to be ruled out.

Comment #4

A distinction must be made between the Hooker/Ruco site and Ruco Polymer Corporation. The former refers to the CERCLA site, which is on the National Priorities List because of past waste disposal practices. The latter is an operating chemical manufacturing facility. This distinction is especially important when discussing current air quality.

Response #4

Agreed. Changes were made to help make this distinction.

Comment #5

Page 11, Ground Water. This section concludes that "...the site is the source of contamination in groundwater off site..." The sentence should be changed to state that the site is a "contributing source", not "the source". This section should include a discussion about other known downgradient sources of trichloroethene, tetrachloroethene and vinyl chloride. The discussion should include a statement that discusses the degradation of trichloroethene and tetrachloroethene to vinyl chloride.

Response #5

Changes made in text.

Comment #6

Page 11, Ground Water. This section also has a qualifying statement about the data being generated from wells completed to depths of less than 200 feet. Occidental Chemical Corporation believes that the RI has completely characterized the extent of site-related chemistry in ground water both horizontally and vertically, and deeper data are not needed. Concentrations of chloroethylene compounds in the deeper wells at the downgradient property line were at levels less than 100 ug/l (micrograms per liter).

Response #6

The NYS DOH believes deeper wells are needed because all of the public water supply wells are at a depth of about 500 feet. No changes made.

Comment #7

Page 11, Soils. This section states that no off site soil sampling was conducted to determine if off site soils have been impacted by activities at the Hooker/Ruco site. The Risk Assessment concluded that there was not risk to human health related to on site soils, so there is not need to assess off site soil, especially given the multiple sources of chemicals in the area.

Response #7

The risk assessment concluded that the risk was acceptable according to US EPA guidelines, but that there is a risk. The better point, as made in the report, is that the activities on-site should not have contaminated off-site soils.

Comment #8

Page 15, On site Soils. This entire section fails to take into account the fact that PCB's in soil have been removed from the site to a level of 10 mg/kg. The Risk Assessment did not demonstrate any current risks to site workers from exposure to shallow soils. The future use scenario of this site as residential is improbable for the immediate future. Regardless of the frame it is not impossible that it becomes residential. However, were this to occur, site remediation would be required and exposure potential would be removed. This would apply to inorganic and organic chemicals.

Response #8

Amendments were made. The risk assessment demonstrated that the current risks to on-site workers are acceptable according to US EPA guidance, but that there are risks.

Comment #9

Page 16 and 17, On site and Off site Groundwater. This section then goes on to describe the toxicological implications of ingesting groundwater at the highest observed concentrations of certain chemicals. This situation will not occur, and the descriptions are, therefore, meaningless in this document. This report may be read by the local populace who may not be aware that there is no chance for them to be exposed to the chemistry in the groundwater at or near the Hooker/Ruco site. This document also focuses on trichloroethene, which is predominantly associated with the Grumman/Navy sites, not the Hooker/Ruco site.

Response #9

The discussion of the toxicological implications of ingesting groundwater at the highest concentration shows the need for remediation and further investigation of groundwater contamination. Groundwater is the sole source of potable water in this area and, therefore, it is important to determine the implications of using groundwater as it is. The ultimate fate of the contaminated on-site groundwater is unknown and is why more study is needed.

Comment #10

Several comments on the accuracy of the tables in public health assessments were made. Occidental Chemical Corporation provided tables with changes to improve the accuracy of the ones in the public health assessment.

Response #10

Changes to the tables have been made according to needed corrections indicated by Occidental Chemical Corporation. However, some of the requested changes were not made. The amended tables as provided by Occidental Chemical Corporation are included in the comment section of the final Public Health Assessment.

Comment #11

Table 1 amendments provided by Occidental Chemical Corporation are shown in the following table.

On-Site Soil and Sediment Sample Results for the Hooker
Chemical/Ruco Polymer Site Collected During 1990 Remedial
Investigation

	On-Site Shallow Soils		Sediments
Compound	Range	Frequency	Range	Frequency
1,2-dichloroethene (total)		6/30	ND-0.076	2/13
carbon tetrachloride		3/30		0/13
trichloroethene		13/30		4/13
tetrachloroethene		18/30	ND-0.0006	2/13
PCB 1248	ND-51	10/30		7/13
PCB 1254	ND-1.2	2/30		0/13
antimony	ND-33	10/30		10/13
cadmium		12/30		9/13

Response #11

Table 1 in this report was amended, however, not all changes were made. Table 1 in this report was generated from review of Appendix 10 of the 1990 RI.

Comment #12

Occidental Chemical Corporation does not concur with inclusion of the USGS Monitor Well N10597 for the Groundwater Off site Downgradient data. As noted in table 4, Summary of Historical Water - Quality Results from USGS Monitor Wells near Hooker/Ruco Polymer, Well N10597 was last sampled in the fall of 1988. Because the latest sampling round was done over one year prior to the RI sampling, this data is not representative of ground-water quality evaluated during the RI. In addition, the title of table 3 refers specifically to data collected during the 1990 RI.

Response #12

Table 3 was amended to include a notation that the off site data are from Table 4.

Comment #13

Table 3 amendments provided by Occidental Chemical Company are shown in the following Table.

Groundwater and Surface Water Data for Hooker/Ruco Site
Collected During 1990 Remedial Investigation

	Groundwater		Groundwater		Groundwater		Surface Water
Compound	Range	Frequency	Range	Frequency	Range	Frequency	Range	Frequency
1,2-dichloroethene (total)				1/5		0/4
trichloroethene			ND-10	1/5		0/4
tetrachloroethene				1/5	ND-3	2/4	ND	0/3
vinyl chloride				1/5		0/4
PCB 1248				0/5		0/4
PCB 1254				0/5		0/4
antimony				0/5		0/4
cadmium		10/29	ND-3	2/5	ND-4	1/4

Response #13

Amendments were made and others were not since errors were found in the original table and the amended table provided by Occidental Chemical Corp. The Table 3 in this report was generated from review of Appendix 10 of the 1990 RI.

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