HOOKER-102ND STREET
NIAGARA FALLS, NIAGARA COUNTY, NEW YORK
APPENDICES
Olin Corporation Chemical Inventory
102nd Street Landfill Site
The following inventory of chemicals was developed from all available records, the Interagency Task Force (ITF) Report on Hazardous Waste (1978) and additional information.
Inorganics
| Reported | Tonnage | |
| Black Cake | 19,760 cubic yards | 18,673 |
| Graphite | 742 tons | 742 |
| Concrete | 6,625 tons | 6,625 |
| Lime Sludge | 22,695 cubic yards | 22,978 |
| Brine Sludge | 15,899 cubic yards | 67,186 |
| Flyash | 5,472 truckloads | |
| Total | 116,204 | |
Disposal quantities of inorganic were generally based on production factors rather than actual recorded amounts. Inorganics can roughly be translated to tonnages through the use of the conversion factors. Estimated tonnages are as shown.
"Black Cake" resulted from the production of sodium chlorite and had a dry basis composition approximately as follows:
18% carbon
80% calcium carbonate/calcium hydroxide
Organics
| Reported | Tonnage | |
| Benzene Hexachloride (BHC) | ||
| Trichlorophenol (TCP) | ||
| Trichlorobenzene (TCB) and Benzene | 295 truckloads | 2,000 |
| V-Tetrachlorobenzene | 310,550 gallons | 2,327 |
| Total | 4,327 | |
Available records indicate truckload shipments of these materials to the landfill. There is no way to determine the specific quantities of the different chemicals, however, there is also no reason to believe they constitute a mixture. Rather, it is believed they were simply loads of some bulk and some drummed material on the same truck. Tetrachlorobenzene is a separate known quantity. Trichloroanisole was a probable impurity in one of the production processes. It was not disposed of as a separate item.
All the organic materials are solids at STP (Standard Temperature and Pressure) except benzene and 1,2,4-trichlorobenzene. The quantity of benzene and 1,2,4-trichlorobenzene (if the 1,2,4-isomer was disposed of at the site) are unknown.
The organic disposal can roughly be translated to tonnages through use of the conversion factors of eight cubic yards per truckload and a density of 0.85 grams per cubic meter (g/cc). Tetrachlorobenzene has a density of 1.8 g/cc.
Adapted from the Remedial Investigation Final Report, Volume I, July 1990; Conestoga-Rovers
and Associates and Woodward-Clyde Consultants.
Occidental Chemical Corporation Chemical Inventory
102nd Street Landfill Site
| Type of Waste | Physical State | Estimated Quantity (tons) | Container |
| Organic phosphites | L,S | <100 | D |
| Sodium hypophosphite mud | S | 20,000 | B |
| Phosphorus and inorganic phosphorus derivatives (excluding sodium hypophosphite) | L,S | 1,300 | D |
| BHC cake (including lindane) | S | 300 | D |
| Chlorobenzenes* | S | (?) | (?) |
| Misc. 10% including cell parts used in chlorate production | S | 2,200 | D,B |
| SUB-TOTAL | 23,800 | ||
| Brine, sludge & gypsum | 53,200 | ||
| TOTAL WASTE REPORTED | 77,000 | ||
| Notes: | L = liquid S = solid D = drummed B = bulk |
From Occidental Chemical Corporation's November 17, 1978 and May 23, 1979 responses to the New York State Interagency Task Force.
Adapted from the Remedial Investigation Final Report, Volume I, July 1990; Conestoga-Rovers jand Associates and Woodward-Clyde Consultants.
TABLE 3.
HNAPL Analysis from OCC Property*
Ranges of Constituents Found in Percent Weight
| Range | Frequency of Detection in 10 Samples | ||
| ALIPHATIC HYDROCARBONS | |||
| (unidentified) | 0.02-1.119 | 5 | |
| cyclohexadecane | 0.46 | 1 | |
| cyclohexane | 0.0078 | 1 | |
| dimethylcyclohexane | 0.7 | 1 | |
| hexane | 0.0032-2.2 | 4 | |
| hexadecane | 0.27 | 1 | |
| methylcyclopentane | 0.004 | 1 | |
| trimethylpentene | 0.0027-0.053 | 3 | |
| AROMATIC HYDROCARBONS | |||
| (unidentified) | 0.017 | 1 | |
| benzene | 0.018-1.5 | 6 | |
| benzoic Acid | 0.018 | 1 | |
| 1,1-biphenyl | 0.8 | 1 | |
| diphenyl ether | .017 | 1 | |
| naphthalene | 0.017-0.053 | 2 | |
| toluene | 0.015-0.36 | 9 | |
| CHLORINATED AROMATIC HYDROCARBONS | |||
| (unidentified) | 0.016-28.6 | 3 | |
| chlorobenzene | 0.08-1.4 | 8 | |
| dichlorobenzene | 0.16-1.9 | 9 | |
| trichlorobenzene | 0.038-42.0 | 9 | |
| tetrachlorobenzene | 0.48-67.0 | 8 | |
| pentachlorobenzene | 0.18-17.0 | 7 | |
| hexachlorobenzene | 0.13-2.5 | 8 | |
| chloromethylbenzene | 0.046-0.47 | 3 | |
| bromodichlorobenzene | 0.056 | 1 | |
| trichloro (methyl,ethyl) benzene | 0.25-0.4 | 2 | |
| trichloropropylbenzene | 1.2 | 1 | |
| chloroethylbenzene | 0.032 | 1 | |
| dichloroethylbenzene | 0.005 | 1 | |
| trichloromethoxybenzene | 0.029 | 1 | |
| chlorotoluene | 0.039-2.1 | 7 | |
| dichlorotoluene | 0.023-0.789 | 4 | |
| trichlorotoluene | 0.013-0.1 | 4 | |
| tetrachlorotoluene | 0.047-0.35 | 2 | |
| pentachlorotoluene | 0.17 | 1 | |
| 2,4,5-trichlorophenol | 0.013-0.019 | 2 | |
| 2,4,6-trichlorophenol | 0.16 | 1 | |
| chloronaphthalene | 0.042-0.11 | 2 | |
| dichloronaphthalene | 0.091-1.0 | 3 | |
| trichloronaphthalene | 0.017-0.299 | 3 | |
| chlorobenzotrifluoride | 0.077 | 1 | |
| dichlorobiphenyl | 0.07-0.59 | 2 | |
| tetrachlorothiophene | 0.21-0.77 | 2 | |
| trichlorobiphenyl | 0.01-0.24 | 2 | |
| tetrachlorobiphenyl | 0.07 | 1 | |
| pentachlorocyclohexene | 0.54 | 1 | |
| chlorobenzaldehyde | 0.13 | 1 | |
| CHLORINATED ALIPHATIC HYDROCARBONS | |||
| (unidentified) | 0.51 | 1 | |
| carbon tetrachloride | 0.012 | 1 | |
| chloroform | 0.29 | 1 | |
| hexachlorobutadiene | 0.02-2.9 | 6 | |
| 1-chlorododecane | 0.11-49.0 | 3 | |
| 1-chlorotetradecane | 25.0 | 1 | |
| 1-chlorohexadecane | 4.9 | 1 | |
| 1-chloroctadecane | 0.4-1.5 | 2 | |
| methylene chloride | 0.06-2.4 | 2 | |
| trichloroethylene | 0.015-0.024 | 2 | |
| 1,1,2,2-tetrachloroethane | 0.031-0.15 | 3 | |
| 1,1,2,2-tetrachloroethene | 0.076-0.19 | 2 | |
| tetrachloroethylene | 0.73 | 1 | |
| PESTICIDES | |||
| alpha-hexachlorocyclohexane | 0.43-1.27 | 4 | |
| beta-hexachlorocyclohexane | 0.022-0.075 | 3 | |
| delta-hexachlorocyclohexane | 0.13-0.67 | 4 | |
| gamma-hexachlorocyclohexane | 0.069-0.58 | 4 | |
| Aroclor 1248 | 0.24-0.4 | 3 | |
| Aroclor 1260 | 0.21-0.31 | 3 | |
| p,p'-DDT | 0.015-0.044 | 3 | |
| p,p'-DDE | 0.18 | 1 | |
| p,p'-DDD | 0.048-0.14 | 2 | |
| heptachlor | 0.021-0.037 | 2 | |
| OTHER | |||
| (minor constituents) | 0.085-9.05 | 9 | |
| WATER | 0.08-63.8 | 9 | |
| DENSITY (specific gravity) | 1.006-1.455 | ||
*HNAPL is considered a contaminant selected for further evaluation.
TABLE 4. HNAPL Analysis from Olin Property
Ranges of Constituents Found in Percent Weight
| Range | Frequency of Detection in 5 Samples | ||
| VOLATILE ORGANICS | |||
| trans-1,2-dichloroethene | 0.0105 | 1 | |
| chloroform | 0.0125-0.029 | 3 | |
| trichloroethene | 0.0045-0.0065 | 1 | |
| benzene | 0.012-5.5444 | 5 | |
| 1,1,2,2-tetrachloroethane | 0.0119-5.808 | 5 | |
| tetrachloroethene | 0.0147-7.809 | 5 | |
| toluene | 0.0064-0.0083 | 1 | |
| chlorobenzene | 0.074-5.7884 | 5 | |
| ethylbenzene | 0.0569-0.06 | 1 | |
| carbon tetrachloride | 0.086-0.088 | 1 | |
| BASE NEUTRALS | |||
| 2-chloroethylether | 0.0008-0.015 | 3 | |
| dichlorobenzenes (including 1,3; 1,4; 1,2 isomers) | 0.019-2.1213 | 5 | |
| 1,2,4-trichlorobenzene | 4.620-38.2755 | 5 | |
| An Isomeric trichlorobenzene | 1.434-13.2447 | 5 | |
| naphthalene | 0.0060 | 1 | |
| hexachlorobenzene | 0.2021-1.332 | 5 | |
| phenanthrene | 0.008-0.0102 | 2 | |
| anthracene | 0.007-0.0301 | 2 | |
| fluoranthene | 0.011-0.0198 | 2 | |
| pyrene | 0.009-0.015 | 2 | |
| benzo(a)anthracene | 0.0076-0.0107 | 2 | |
| chrysene | 0.0076-0.0105 | 2 | |
| bis-2-(ethylhexyl)phthalate | 0.008-0.0807 | 4 | |
| benzo(k)fluoranthene | 0.0058-0.029 | 2 | |
| benzo(a)pyrene | 0.072 | 1 | |
| 1,2,3,4-tetrachlorobenzene | 3.5348-72.567 | 5 | |
| 1,2,4,5-tetrachlorobenzene | 3.8131-42.5893 | 5 | |
| pentachlorobenzene | 4.8277-20.144 | 5 | |
| PESTICIDES/PCBs | |||
| Aroclor-1254 | 0.0196-0.1259 | 4 | |
| Aroclor - 1260 | 0.038-0.2247 | 4 | |
| alpha-hexachlorocyclohexane | 0.5254-3.0393 | 5 | |
| beta-hexachlorocyclohexane | 0.009-0.1978 | 5 | |
| gamma-hexachlorocyclohexane | 0.110-2.4121 | 5 | |
| delta-hexachlorocyclohexane | 0.0724-1.2345 | 5 | |
| heptachlor | 0.005 | 1 | |
| endosulfan II | 0.0047 | 1 | |
| p,p'-DDD | 0.0097 | 1 | |
| p,p'-DDT | 0.0121 | 1 | |
| DENSITY (specific gravity) | 1.421-1.613 | ||
*HNAPL is considered a contaminant selected for further evaluation.
102ND STREET LANDFILL
CHLORINATED DIOXIN AND FURAN RESULTS
FROM HNAPL ANALYSIS
(all values in parts per million)
| Chlorodibenzo-p-dioxins* | OCC | Olin |
| 2,3,7,8-tetra CDD | 0.059-0.19 | ND-0.06 |
| total tetra CDD | 0.060-0.78 | ND-0.07 |
| 1,2,3,7-penta CDD | X | ND-0.03 |
| total penta CDD | 0.15-8.9 | ND-5.0 |
| 2,3,7,8,x,x-hexa CDD | X | ND-2.0 |
| total hexa CDD | 2.2-27.0 | ND-6.0 |
| 2,3,7,8,x,x,x-hepta CDD | X | ND-8.0 |
| total hepta CDD | 23.0-49.0 | ND-14.0 |
| total octa - CDD | 25.0-430.0 | ND-10.0 |
| Chlorodibenzofurans* | OCC | Olin |
| 2,3,7,8-tetra CDF | 0.11-0.64 | ND-0.5 |
| total tetra CDF | 0.33-1.7 | ND-0.8 |
| 2,3,7,8,x-penta CDF | X | ND-0.5 |
| total penta CDF | 0.96-8.1 | ND-7.0 |
| 2,3,7,8,x,x-hexa CDF | X | 0.01-10.0 |
| total hexa CDF | 5.4-18.0 | 0.01-11.0 |
| 2,3,7,8,x,x,x-hepta CDF | X | ND-12.0 |
| total hepta CDF | 11.0-48.0 | ND-15.0 |
| total octa CDF | 16.0-82.0 | ND-6.0 |
*All chlorodibenzo-p-dioxins and chlorodibenzofurans in HNAPL are contaminants selected for further evaluation.
ND - not detected
X - data not available
Table 6.
102nd Street landfill
Summary of Monitoring Well Data
Remedial Investigation
(all values in micrograms per liter)
| Parameter | Fill Groundwater | Native Soil Groundwater | Standards/Guidelines | Comparison Value** | Source*** | ||||
| Range of Concentration | Number of Wells With Detects (out of 17) | Range of Concentration | Number of Wells With Detects (out of 23) | New York State | U.S. EPA | ||||
| Groundwater | Drinking Water | Drinking Water | |||||||
| *benzene | 5-3600 | 8 | 77-79,000 | 10 | 0.7 | 5 | 5 | 0.7 | NYS CREG |
| *toluene | 12-2300 | 2 | 213-320 | 1 | 5 | 5 | 1,000 | 1,000 | EPA LTHA |
| *monochlorobenzene | 7-5500 | 9 | 5-17,000 | 10 | 5 | 5 | 100 | 140 | EPA RfD |
| *2-monochlorotoluene | 6-36 | 2 | 98-150 | 1 | 5 | 5 | - | 100 | EPA LTHA |
| *4-monochlorotoluene | 200-300 | 1 | 73-110 | 1 | 5 | - | - | - | - |
| *1,2-dichlorobenzene | 15-860 | 6 | 14-1100 | 9 | 4.7e | 5 | 600 | 600 | EPA LTHA |
| *1,4-dichlorobenzene | 15-1500 | 6 | 26-4800 | 8 | 4.7e | 5 | 75 | 1.5 | EPA CPF |
| *1,2,3-trichlorobenzene | 47-2700 | 2 | 94-4500 | 5 | 5 | 5 | - | - | - |
| *1,2,4-trichlorobenzene | 31-5300 | 5 | 370-15,000 | 6 | 5 | 5 | 70 | 70 | EPA LTHA |
| *1,2,3,4-tetrachlorobenzene | 22-8100 | 5 | 110-40,000 | 5 | 5 | 5 | - | - | - |
| *1,2,4,5-tetrachlorobenzene | 97-2400 | 3 | 12-6000 | 5 | 5 | 5 | - | 2 | EPA RfD |
| *hexachlorobenzene | 140 | 1 | 75-360 | 1 | 0.35 | 5 | 1 | 0.02 | ATSDR CREG |
| *alpha hexachlorocyclohexane | 33-730 | 5 | 23-840 | 6 | ND | 5 | - | 0.15 | EPA CPF |
| *beta hexachlorocyclohexane | 10-140 | 6 | 11-120 | 4 | ND | 5 | - | 0.02 | NYS CREG |
| *gamma hexachlorocyclohexane | 25-440 | 5 | 14-720 | 5 | ND | 5 | 0.2 | 0.03 | EPA CPF |
| *delta hexachlorocyclohexane | 66-900 | 5 | 19-1200 | 6 | ND | 5 | - | - | - |
| *2,5-dichloroaniline | 12-14,000 | 4 | 18-13,000 | 3 | 5 | 5 | - | - | - |
| 3,4-dichloroaniline | ND | 0 | ND | 0 | 5 | 5 | - | - | - |
| *phenol | 26-120 | 4 | 10-180 | 5 | 1 | 50 | - | 4,000 | EPA LTHA |
| *2-chlorophenol | 14-280 | 4 | 11-260 | 4 | 5 | 5 | - | 40 | EPA LTHA |
| *4-chlorophenol | 58-1000 | 4 | 16-3900 | 8 | 5 | 5 | - | - | - |
| *2,4-dichlorophenol and 2,5-dichlorophenol | 14-4200 | 4 | 12-3400 | 8 | 0.3g | 5 | - | 20 | EPA LTHA |
| *2,4,5-trichlorophenol | 95-190 | 2 | 10-290 | 3 | 5 | 5 | - | 700 | EPA RfD |
| *2,4,6-trichlorophenol | 190-230 | 1 | 10-50 | 2 | 5 | 5 | - | 3 | ATSDR CREG |
| *2-chlorobenzoic acid | 600-860 | 1 | 100-450 | 2 | - | 50 | - | - | - |
| *3-chlorobenzoic acid | 530-860 | 1 | 100-220 | 2 | - | 50 | - | - | - |
| *4-chlorobenzoic acid | 120-2160 | 2 | 100-200 | 2 | - | 50 | - | 1,400 | EPA RfD |
| phosphorous | 100-205,000 | 16 | 130-3,420,000 | 21 | - | - | - | - | - |
| *mercury | 0.6-50 | 4 | 1.2-13 | 3 | 2 | 2 | 2 | 2 | EPA LTHA |
| arsenic | ND | 0 | 200 | 1 | 25 | 50 | 50 | 11 | EPA RfD |
e = applies to total of 1,2- and 1,4-isomers
ND - not detected
*Contaminant selected for further evaluation.
g = guidance value
p = proposed maximum contaminant level (MCL)
**Comparison value determined for a 70 kilogram adult who drinks 2 liters of water per day.
***ATSDR CREG = ATSDR Cancer Risk Evaluation Guide
EPA CPF = EPA Cancer Potency Factor
EPA RfD = EPA Reference Dose
EPA LTHA = EPA Drinking Water Lifetime Health Advisory
NYS CREG = NYS Cancer Risk Evaluation Guideline
102nd Street Landfill
Ranges of Chemical Concentrations Found in
Bulkhead Seep Samples
(all values in micrograms per liter)
| Concentration Range | Number of Detects (out of 5 samples) | |
| benzene | 71-2,000 | 3 |
| toluene | ND | 0 |
| monochlorobenzene | 120-2,200 | 4 |
| 1,2-dichlorobenzene | 28-400 | 4 |
| 1,4-dichlorobenzene | 24-420 | 4 |
| 1,2,3-trichlorobenzene | 14-180 | 3 |
| 1,2,4-trichlorobenzene | 35-650 | 4 |
| 1,2,3,4-tetrachlorobenzene | 340-420 | 3 |
| 1,2,4,5-tetrachlorobenzene | 65-74 | 3 |
| hexachlorobenzene | 15 | 1 |
| alpha-hexachlorocyclohexane | 210-700 | 3 |
| beta-hexachlorocyclohexane | 30-150 | 5 |
| gamma-hexachlorocyclohexane | 13-1,400 | 3 |
| delta-hexachlorocyclohexane | 800-4,500 | 3 |
| 2,5-dichloroaniline | 580 | 1 |
| 3,4-dichloroaniline | ND | 0 |
| phenol | 25-28 | 3 |
| 2-chlorophenol | 12-54 | 3 |
| 4-chlorophenol | 27-240 | 3 |
| 2,4-dichlorophenol | 75-97 | 2 |
| 2,5-dichlorophenol | 75-97 | 2 |
| 2,4,5-trichlorophenol | 72-1,300 | 3 |
| 2,4,6-trichlorophenol | 240 | 1 |
| 2-chlorobenzoic acid | 130 | 1 |
| 3-chlorobenzoic acid | ND | 0 |
| 4-chlorobenzoic acid | 100 | 1 |
| phosphorus (dissolved) | 100 | 1 |
| mercury | 2.3-31.3 | 2 |
| arsenic | ND | 0 |
| total organic halide (TOX) | 130-10,000 | 5 |
| total kjeldahl nitrogen (TKN) | 1,800-4,700 | 5 |
| total organic carbon (TOC) | 80,000-180,000 | 5 |
ND - not detected
STORM SEWER SEDIMENT ANALYTICAL RESULTS
(from 2 samples)
(all values in milligrams per kilogram (mg/kg) dry weight).
| Parameter | Range of Concentration | Typical Background Range** |
| SITE SPECIFIC INDICATORS | ||
| 1,2-dichlorobenzene | 810/710 | NDT |
| 1,4-dichlorobenzene | 220/170 | NDT |
| 2-monochlorotoluene | 570/510 | NDT |
| 4-monochlorotoluene | 400/350 | NDT |
| 2,4-dichlorophenol | ND/ND* | NDT |
| 2,5-dichlorophenol | ND/ND | NDT |
| hexachlorobenzene | 490/530 | NDT |
| alpha-hexachlorocyclohexane | 350/400 | NDT |
| beta-hexachlorocyclohexane | 11/9.5 | NDT |
| delta-hexachlorocyclohexane | 84/78 | NDT |
| gamma-hexachlorocyclohexane | 89/93 | <0.01-0.1 |
| pentachlorobenzene | 3,500/5,100 | NDT |
| 1,2,3,4-tetrachlorobenzene | 21,000/22,000 | NDT |
| 1,2,4,5-tetrachlorobenzene | 1,600/1,600 | NDT |
| 1,2,3-trichlorobenzene | 890/930 | NDT |
| 1,2,4-trichlorobenzene | 3,000/4,900 | NDT |
| 2,4,5-trichlorophenol | ND/ND | NDT |
| 2,4,6-trichlorophenol | ND/ND | NDT |
| mercury | 36/24 | 0.01-3.4 |
ND - not detected
NDT - not determined
*Detection limit at 1.0 mg/kg dry
**References: ATSDR, 1989; Shacklette and Boerngen, 1984.
102ND STREET LANDFILL
STORM SEWER INFILTRATION
AQUEOUS ANALYTICAL RESULTS
(all concentrations in micrograms per liter)
| SITE SPECIFIC INDICATORS (SSI) | UPGRADIENT OF SITE | CONCENTRATION RANGES IN SEWER LINE | CONCENTRATION AT THE OUTFALL |
| benzene | ND | ND | ND/ND |
| toluene | ND | ND | ND/ND |
| monochlorobenzene | ND | ND | 330/260 |
| 2-monochlorotoluene | ND | ND | 28/23 |
| 4-monochlorotoluene | ND | ND-7 | 15/13 |
| 1,2-dichlorobenzene | ND | ND | 32/40 |
| 1,4-dichlorobenzene | ND | ND | 110/140 |
| 1,2,3-trichlorobenzene | ND | ND | 46/55 |
| 1,2,4-trichlorobenzene | ND | 23-25 | 280/280 |
| 1,2,3,4-tetrachlorobenzene | ND | 13-14 | 300/230 |
| 1,2,4,5-tetrachlorobenzene | ND | ND | 32/33 |
| hexachlorobenzene | ND | ND | ND/ND |
| alpha-hexachlorocyclohexane | ND | ND | 75/71 |
| beta-hexachlorocyclohexane | ND | ND | ND/ND |
| gamma-hexachlorocyclohexane | ND | ND | 33/37 |
| delta-hexachlorocyclohexane | ND | ND | 130/130 |
| 2,5-dichloroaniline | ND | ND | ND/ND |
| 3,4-dichloroaniline | ND | ND | ND/ND |
| phenol | ND | ND | 64/76 |
| 2-chlorophenol | ND | ND | ND/ND |
| 4-chlorophenol | ND | ND | 26/39 |
| 2,4-dichlorophenol | ND | ND | ND/ND |
| 2,5-dichlorophenol | ND | ND | ND/ND |
| 2,4,5-trichlorophenol | ND | ND | ND/ND |
| 2,4,6-trichlorophenol | ND | ND | ND/ND |
| 2-chlorobenzoic acid | ND | ND | ND/ND |
| 3-chlorobenzoic acid | ND | ND | ND/ND |
| 4-chlorobenzoic acid | ND | ND | ND/ND |
| total SSI | ND | 39-43 | 1501/1427 |
| soluble phosphorus | 860 | ND-270 | 67/65 |
| mercury | ND | ND | 0.41/0.49 |
| arsenic | ND | ND-0.41 | ND/ND |
ND - not detected
102ND STREET LANDFILL
NIAGARA RIVER
SURFACE SEDIMENTS
(all values in milligrams per kilogram)
| Parameter | Concentration Range (Excluding Highest Sample, C-75) | Frequency of Detects (out of 87) | Highest Sample (C-75) | Typical Background Range** | Comparison Value*** | Source**** |
| 2-monochlorotoluene | ND | 1 | 1.47 | NDT | 1,000 | EPA RfD |
| 4-monochlorotoluene | 0.15 | 2 | 1.55 | NDT | -- | |
| 1,2-dichlorobenzene | 0.11 | 2 | 1.19 | NDT | 4,500 | EPA RfD |
| 1,4-dichlorobenzene | 0.103-0.649 | 12 | 13.2 | NDT | 30 | EPA CPF |
| 1,2,3-trichlorobenzene | ND | 1 | 19.7 | NDT | -- | |
| 1,2,4-trichlorobenzene | 0.128-0.358 | 3 | 295.0 | NDT | 500 | EPA RfD |
| 1,2,3,4-tetrachlorobenzene | 0.196 | 2 | 454.0 | NDT | -- | |
| *1,2,4,5-tetrachlorobenzene | 0.108-0.799 | 5 | 153.0 | NDT | 15 | EPA RfD |
| *pentachlorobenzene | 0.176 | 2 | 147.0 | NDT | 40 | EPA RfD |
| *hexachlorobenzene | 0.14-0.236 | 4 | 10.1 | NDT | 0.44 | ATSDR CREG |
| *alpha-hexachlorocyclohexane | 0.1-4077.0 | 6 | 2550.0 | NDT | 0.11 | EPA CPF |
| *beta-hexachlorocyclohexane | 0.173-15.3 | 8 | 310.0 | NDT | 0.71 | EPA CPF |
| delta-hexachlorocyclohexane | 0.21-9.79 | 3 | 11.3 | NDT | -- | |
| *gamma-hexachlorocyclohexane | 0.843-55.4 | 3 | 6.82 | 0.01-0.1 | 0.45 | EPA CPF |
| 2,4-dichlorophenol | 0.137-0.208 | 2 | ND | NDT | 150 | EPA RfD |
| 2,5-dichlorophenol | 0.109 | 1 | ND | NDT | -- | |
| 2,4,5-trichlorophenol | 0.367 | 1 | ND | NDT | 5,000 | EPA RfD |
| 2,4,6-trichlorophenol | 4.3 | 2 | 6.45 | NDT | 65 | EPA CPF |
| *mercury | 0.108-10.2 | 67 (out of 91) | 200 | 0.01-3.4 | 15 | EPA RfD |
ND - not detected
NDT - Not determined
*Contaminant selected for further evaluation.
**References: ATSDR, 1989; Shacklette and Boerngen, 1984
***These values are for a nonresidential setting and assume a lifetime exposure through incidental ingestion of soil.
****ATSDR CREG = ATSDR Cancer Risk Evaluation Guide
EPA CPF = EPA Cancer Potency Factor
EPA RfD = EPA Risk Reference Dose
102nd Street Landfill
Off-Site Surface Soil
(all values in milligrams per kilogram)
| Parameter | Griffon Park | Along Buffalo Avenue | East of Site | Typical Background Range** | Comparison Value*** | Source**** | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| Concentration Range | Frequency of Detection (out of 35) | Concentration Range | Frequency of Detection (out of 47) | Concentration Range | Frequency of Detection (out of 23) | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| 2-monochlorotoluene | ND | 0 | 0.127-0.881 | 3 | ND | 0 | NDT | 57 | NYS RfG
| 4-monochlorotoluene | 0.129-1.43 | 2 | 0.113-0.917 | 6 | 0.228 | 1 | NDT | --
| 1,2-dichlorobenzene | 0.137-1.57 | 2 | 0.198-5.81 | 5 | 0.102-0.12 | 2 | NDT | 324 | NYS RfG
| *1,4-dichlorobenzene | 0.103-0.43 | 5 | 0.118-4.28 | 13 | 0.127-0.164 | 2 | NDT | 0.4 | NYS CREG
| 1,2,3,-trichlorobenzene | ND | 0 | 0.108-0.859 | 3 | ND | 0 | NDT | --
| 1,2,4-trichlorobenzene | ND | 0 | 0.114-0.404 | 15 | ND | 0 | NDT | 152 | NYS RfG
| 1,2,3,4-tetrachlorobenzene | 0.128 | 1 | 0.105-11.3 | 14 | ND | 0 | NDT | --
| 1,2,4,5-tetrachlorobenzene | 0.103 | 1 | 0.105-4.88 | 16 | ND | 0 | NDT | 4.2 | NYS RfG
| pentachlorobenzene | 0.118 | 1 | 0.101-0.736 | 5 | ND | 0 | NDT | 21 | NYS RfG
| *hexachlorobenzene | ND | 0 | 0.117-9.51 | 18 | ND | 0 | NDT | 0.004 | NYS CREG
| *alpha-hexachlorocyclohexane | 0.266-1.26 | 2 | 0.109-4.57 | 18 | 0.114-0.46 | 4 | NDT | 0.003 | NYS CREG
| *beta-hexachlorocyclohexane | 0.230 | 1 | 0.179-7.88 | 25 | 0.109-2.8 | 14 | NDT | 0.02 | NYS CREG
| *delta-hexachlorocyclohexane | ND | 0 | 0.15-1.65 | 3 | ND | 0 | NDT | --
| *gamma-hexachlorocyclohexane | 0.185 | 1 | 0.113-1.21 | 4 | ND | 0 | 0.01-0.1 | 0.006 | NYS CREG
| 2,4-dichlorophenol | ND | 0 | 0.115-0.546 | 6 | ND | 0 | NDT | 4.3 | NYS RfG
| 2,5-dichlorophenol | ND | 0 | ND | 0 | ND | 0 | NDT | --
| 2,4,5-trichlorophenol | 0.253 | 1 | 0.132 | 1 | ND | 0 | NDT | 421 | NYS RfG
| 2,4,6-trichlorophenol | ND | 0 | ND | 0 | ND | 0 | NDT | 1.5 | NYS CREG
| *mercury | 0.13-4.76 | 39 (of 42) | 0.11-9.29 | 45 (of 50) | 0.153-5.08 | 22 | 0.01-3.4 | 1.6 | EPA RfD
| | ||||||||||
ND - not detected
NDT - not determined
*Contaminant selected for further evaluation.
**References: ATSDR, 1989; Shacklette and Boerngen, 1984
***These values are for a residential setting and assume a lifetime exposure through incidental ingestion of soil and homegrown vegetables.
****NYS CREG = New York State Cancer Risk Evaluation Guideline
NYS RfG = New York State Risk Reference Guideline
EPA RfD = EPA Risk Reference Dose
Toxic Release Inventory (TRI)
(all values in pounds per year)
| Facility Chemical | Air Release Stack Plus Fugitive |
| Carborundum Abrasives | |
| formaldehyde | 2-20 |
| pseudocumene (trimethylbenzenes) | 57,759 |
| phenol | 937 |
| zinc compounds | 2-20 |
Niacet | |
| methanol | 517,500 |
| chloracetic acid | 501-1,009 |
| phenol | 22-898 |
| hydrochloric acid | 22-898 |
| chlorine | 22-898 |
| glycols | 22-898 |
| Energy from Waste Facility | |
| *hydrochloric acid | 4,560,014 |
| sulfuric acid | 0 |
| chlorine | 0 |
*Contaminant anticipated to exceed 1 microgram per cubic meter within 1/2 mile from the 102nd Street Landfill site.
This Appendix was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:
To evaluate the potential health risks from contaminants of concern associated with the 102nd Street Landfill site, the New York State Department of Health assessed the risks for cancer and noncancer health effects.
Increased cancer risks were estimated by using site-specific information on exposure levels for the contaminant of concern and interpreting them using cancer potency estimates derived for that contaminant by the US EPA or, in some cases, by the NYS DOH. The following qualitative ranking of cancer risk estimates, developed by the NYS DOH, was then used to rank the risk from very low to very high. For example, if the qualitative descriptor was "low", then the excess lifetime cancer risk from that exposure is in the range of greater than one per million to less than one per ten thousand. Other qualitative descriptors are listed below:
| Excess Lifetime Cancer Risk | |
| Risk Ratio | Qualitative Descriptor |
| equal to or less than one per million | very low |
| greater than one per million to less than one per ten thousand | low |
| one per ten thousand to less than one per thousand | moderate |
| one per thousand to less than one per ten | high |
| equal to or greater than one per ten | very high |
An estimated increased excess lifetime cancer risk is not a specific estimate of expected cancers. Rather, it is a plausible upper bound estimate of the probability that a person may develop cancer sometime in his or her lifetime following exposure to that contaminant (i.e., there is only about a 5 percent chance that the risk of a response is greater than the estimated value).
There is insufficient knowledge of cancer mechanisms to decide if there exists a level of exposure to a cancer-causing agent below which there is no risk of getting cancer, namely, a threshold level. Therefore, every exposure, no matter how low, to a cancer-causing compound is assumed to be associated with some increased risk. As the dose of a carcinogen decreases, the chance of developing cancer decreases, but each exposure is accompanied by some increased risk.
There is no general consensus within the scientific or regulatory communities on what level of estimated excess cancer risk is acceptable. Some have recommended the use of the relatively conservative excess lifetime cancer risk level of one in one million because of the uncertainties in our scientific knowledge about the mechanism of cancer. Others feel that risks that are lower or higher may be acceptable, depending on scientific, economic and social factors. An increased lifetime cancer risk of one in one million or less is generally considered an insignificant increase in cancer risk.
For noncarcinogenic health risks, the contaminant intake was estimated using exposure assumptions for the site conditions. This dose was then compared to a risk reference dose (estimated daily intake of a chemical that is likely to be without an appreciable risk of health effects) developed by the US EPA, ATSDR and/or NYS DOH. The resulting ratio was then compared to the following qualitative scale of health risk:
| Qualitative Descriptions for Noncarcinogenic Health Risks | |
| Ratio of Estimated Contaminant Intake to Risk Reference Dose | Qualitative Descriptor |
| equal to or less than the risk reference dose | minimal |
| greater than one to five times the risk reference dose | low |
| greater than five to ten times the risk reference dose | moderate |
| greater than ten times the risk reference dose | high |
Noncarcinogenic effects unlike carcinogenic effects are believed to have a threshold, that is, a dose below which adverse effects will not occur. As a result, the current practice is to identify, usually from animal toxicology experiments, a no-observed-effect-level (NOEL). This is the experimental exposure level in animals at which no adverse toxic effect is observed. The NOEL is then divided by an uncertainty factor to yield the risk reference dose. The uncertainty factor is a number which reflects the degree of uncertainty that exists when experimental animal data are extrapolated to the general human population. The magnitude of the uncertainty factor takes into consideration various factors such as sensitive subpopulations (for example, children or the elderly), extrapolation from animals to humans, and the incompleteness of available data. Thus, the risk reference dose is not expected to cause health effects because it is selected to be much lower than dosages that do not cause adverse health effects in laboratory animals.
The measure used to describe the potential for noncancer health effects to occur in an individual
is expressed as a ratio of estimated contaminant intake to the risk reference dose. If exposure to
the contaminant exceeds the risk reference dose, there may be concern for potential noncancer
health effects because the margin of protection is less than that afforded by the reference dose.
As a rule, the greater the ratio of the estimated contaminant intake to the risk reference dose, the
greater the level of concern. A ratio equal to or less than one is generally considered an
insignificant (minimal) increase in risk.
This summary was prepared to respond the public's comments and questions on the 102nd Street Landfill draft Public Health Assessment (PHA). The public was invited to review this document during the public comment period which ran from July 8, 1993 to August 13, 1993. However, because of requests for copies of the draft PHA toward the end of the comment period by the public, the comment period was extended until mid-September. Some comments have been consolidated or grouped together to incorporate similar concerns. If you have any questions about this responsiveness summary, contact the Health Liaison Program at the toll-free number 1-800-458-1158, extension 402.
PUBLIC COMMENT
Only one comment was received from the public, as follows:
Comment
A sign should be posted at the public docks at Griffon Park to inform the public about contamination from 102nd Street Landfill and the chances of getting skin reactions if launching boats into the water.
Response
Contaminated sediments from the 102nd Street Landfill are close to the shoreline and do not extend very far beyond the western property line of the landfill. Therefore, people launching boats from the docks at Griffon Park are unlikely to be exposed to contamination from the 102nd Street Landfill.
COMMENTS FROM THE US ENVIRONMENTAL PROTECTION AGENCY
Comment #1
When referring to children at Griffon Park being exposed to contamination, it is not clear whether this contamination is due to migration of surface contamination from the site or contamination unrelated to the 102nd Street site.
Response #1
The data evaluated in this Public Health Assessment were gathered during the remedial investigation (RI) of the 102nd Street Landfill. There may be contamination at Griffon Park from sources other than the 102nd Street Landfill; however, the 102nd Street Landfill is a source of contaminants in soil at Griffon Park. These contaminants were identified during the RI and are summarized in Table 11 of this public health assessment. To assess possible health impacts to the community, total exposures must be evaluated, even if contamination is from more than one source.
Comment #2
There is no acknowledgement of the Record of Decision (ROD) or its contents.
Response #2
The ROD has been added to the References and a discussion of the elements of the ROD has been incorporated in the text (Background Section).
Comment #3
Heavily contaminated sediments are going to be placed inside the slurry wall, thereby eliminating the need to excavate and incinerate.
Response #3
All references to incineration of sediments have been revised in the text.
Comment #4
Groundwater will only be recovered and treated to maintain an inward gradient across the slurry wall.
Response #4
The text has been revised to reflect that the purpose of groundwater recovery is to maintain an inward gradient across the slurry wall.
COMMENTS RECEIVED FROM OCCIDENTAL CHEMICAL CORPORATION AND OLIN CHEMICALS CORPORATION
Comment #1
OxyChem does not agree with the statement on page 2 of the Summary that "Exposures to site-related chemicals could cause an increased risk of cancer. Other health related problems associated with the site contaminants are neurological, liver and kidney effects." This disagreement is based on the EPA/State approved Baseline Risk Assessments, Final Report (Sirrine, July 1990) which stated "The PHA determined that neither the individual exposure routes nor the cumulative effects of the site present any significant risks to health under current conditions."
Response #1
The comment implies that the EPA/State agreed with the conclusions of the OxyChem/Olin baseline risk assessment (Sirrine, 1990). On the contrary, both agencies disagreed with some of the assumptions and the conclusions of the risk assessment. Subsequently, OxyChem/Olin was required to incorporate EPA's Baseline Risk Assessment summary into the Feasibility Study (Sirrine, 1990). As discussed in Chapter 3 and Section 7 of the feasibility study, the EPA risk assessment used conservative but reasonable assumptions to evaluate "reasonable maximum exposures" and concluded that significant health risks could be associated with exposure to site-related contaminants. A significant human health risk was defined as one in one million incremental increase in the chance of getting cancer. Additional information on how health risks were evaluated and qualified in the Public Health Assessment has been included in Appendix D.
Comment #2
Descriptions of Olin's and OCC's wastes are incorrect and should be revised. The correct information can be found in the Consent Order for the Remedial Investigation/Feasibility Study.
Response #2
The text has been revised. I have grouped OCC and Olin waste together since this site is considered one site and knowing who disposed of which wastes isn't important for the discussions of potential public health exposures.
Comment #3
Please revise the last paragraph of Section B of the Background section to reflect that the NYS DOH health advisory on fish is based upon PCBs, which is not a contaminant at the 102nd Street Landfill.
Response #3
The text has been revised to reflect that the fish advisory has been developed based upon concern for chemicals which bioaccumulate in fish. The specific sources of these chemicals can not always be identified.
Comment #4
There are many sources for chemicals that have bioaccumulated in fish caught in the Niagara River or Lake Ontario. It is not appropriate to reference only 102nd Street Landfill when it is only one of many sites that generate this concern. Analysis of fish from the upper Niagara River for organochlorines will not provide data specific to discharges from the site due to the migratory nature of fish and the presence of other organochlorine sources along the upper Niagara River.
Response #4
The Public Health Assessment states that 102nd Street is not the sole contributor of contamination to the Niagara River. It also states that the current fish advisory is based upon PCB data, which is not a chemical of concern at 102nd Street Landfill. We agree that organochlorine analyses of fish caught in the upper Niagara River will not give specific data on the impact of the landfill's discharges on fish. However, 102nd Street does contribute to the total chemical loadings to the Niagara River. Discharges from the site, combined with loadings from other sources could result in persons being exposed to contamination in fish at levels of public health concern. The Public Health Assessment evaluates total exposures to contamination at a specific exposure point and may include both site-related and non-site-related contamination.
Comment #5
The last paragraph of the Background section, section B stating "fish from the Niagara River and Lake Ontario have been monitored extensively..." conflicts with the previous paragraph which recommends further sampling and with the Pathway Analysis, section A, Fish, which states that "There are no analytical data for site specific compounds in fish from the Upper Niagara River...".
Response #5
The word "extensively" has been removed. Many more fish from the lower Niagara River and especially Lake Ontario have been analyzed than from the upper Niagara River. The fish are analyzed for only a few chemicals and not most of the site-related chemicals.
Comment #6
It should be noted in the Public Health Implications section, subsection A, Toxicological Evaluation, item 3 that there is a Health Advisory on fish in place in order to protect human health.
Response #6
The Health Advisory on eating fish caught in the Upper Niagara River has been mentioned in several places in the Public Health Assessment. This section discusses potential health effects that might occur from exposure to site related contamination through various pathways. Since we do not have site-specific fish data, we did not include the discussion of the Health Advisory in this section.
Comment #7
The off-site soil sampling included analysis for 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) and total TCDD. No other analyses for dioxin isomers or chlorinated dibenzofurans were performed.
Response #7
The text has been revised to reflect these corrections.
Comment #8
The site has be fenced along Buffalo Avenue and on the western side of the site since commencement of landfilling, in the early 1940's, thus restricting access on those sides and exposure to on-site soils.
Response #8
This information has been included in the revised text. However, if access to the site was not restricted on all the land bound sides of the site, then access to the site by the public could have been possible and the past exposure scenario remains correct. Furthermore, due to the maintenance and condition of this fence, it may not have been an effective barrier at all times.
Comment #9
Why has the public health hazard been described as "indeterminate" when the exposures were characterized and evaluated in the "Baseline Risk Assessment - Final Report" prepared by Sirrine Environmental Consultants in July 1990 which was approved by the EPA/State including the NYS DOH. As stated in the Sirrine report, "The PHA determined that neither the individual exposure routes nor the cumulative effects of the site present any significant risks to human health under current conditions."
Response #9
The Public Health Assessment evaluates both known (i.e., completed) and potential human exposure scenarios for the past, current, and future. Human exposure pathways are considered complete if there is an identified source of contamination, an environmental media which has been contaminated from the source, an exposure point for humans, a route of human exposure (i.e., ingestion, inhalation),and an identified receptor population. If one or more of these factors does not exist, then it may be considered as a potential pathway. Specific guidelines have been developed by ATSDR to determine public health hazards that a site poses. Based on the information reviewed during development of the PHA, the site currently poses an indeterminate public health hazard because it is unknown to what extent persons may be exposed to surface soils off-site. Additionally, there is a potential for direct contact with or incidental ingestion of contaminated surface water, and contact with sediments or off-site surface soils. The major public health concern is ingestion of fish caught in the Niagara River or Lake Ontario that have bioaccumulated contaminants from the 102nd Street Landfill. However, there are inadequate data to assess the public health significance of past, present and potential exposures to site contaminants in fish. In addition, the comment implies that the EPA/State agreed with the conclusions of the OxyChem/Olin baseline risk assessment (Sirrine, 1990). Please refer to the response to comment #1 for a discussion of this issue.
Comment #10
Inhalation or ingestion of airborne soil particulates is unlikely. Such exposure is potentially possible during remedial activities. However, appropriate measures to control fugitive dust emissions will be implemented during the performance of remedial activities.
Response #10
We agree that dust is unlikely to be generated under current site conditions. However, in the past this was a possible exposure route. The text has been revised to clarify that exposure to contaminated dusts and particulates may have occurred in the past.
Comment #11
Remediation of the area north of Buffalo Avenue was completed in November 1993. The subject item should be revised accordingly.
Response #11
This was incorporated in the Public Health Assessment.
Comment #12
Sediment "hot spots" are not going to be excavated and incinerated. They will be contained in place.
Response #12
The text was revised accordingly.
Comment #13
On page 7, 4th full paragraph - Why is there concern related to surface water discharges to the north or west of the site?
Response #13
This section relates observations made during a site visit. These are observations made by the staff person who conducted the visit and is considered as part of the historical record for the site. The exposure pathway analysis section discusses known potential human exposure routes of concern.
Comment #14
Page 10, 1st full paragraph, last sentence - Sediment sampling and analyses have shown that the contamination is limited to within 300 feet of the shoreline and the sediments of the Little River have not been impacted.
Response #14
This section is titled "Public Health Concerns" and discusses concerns that have been expressed by the public that may or may not have been address previously. Concern about dredging of the Little River has been addressed in the Record of Decision and in this Public Health Assessment.
Comment #15
The site is not the only source of chemicals present in soils, groundwater, sewer water, and sediments of the Niagara River.
In addition, for many years the swale to the east was an open cesspool which discharged directly to the River. The origin of the sewage was the trailer park to the northeast. The periodic damming of the discharge by natural wave action at the river shore created a stagnant, open sewer which was the most significant health hazard at or near the site. The potential for disease pathogens in the untreated, raw sewage and the many chemicals discharged in average household effluent specifically contributed to the sediment and surface water problems at the site.
Response #15
The text has been revised, where appropriate, to clarify that sources other than the 102nd Street site are contributing to contamination of the Niagara River.
The discharge from the ditch east of the site may have contributed to contamination in the Niagara River. However, household effluent is unlikely to contribute greater chemicals contamination than the site. Therefore, this point will be mentioned, but not evaluated in this Public health Assessment.
Comment #16
The correct name for the "Energy Furnace" is "Energy from Waste" (EFW). The current owner is American Ref-Fuel.
Response #16
The text has been revised.
Comment #17
Air data were collected during the Remedial Investigation activities (a "worst case" situation) and did not show a problem. The data should be reviewed and the subject paragraph revised accordingly.
Response #17
Air was not specifically sampled as part of the Remedial Investigation. Air was monitored as part of the health and safety activities. The purpose of this type of air monitoring is to warn of any potential releases of site contamination so that corrective action can be taken. The "worst case" situation would have been expected to have occurred during dumping activities at the site.
Comment #18
Prior to initiating any remedial activities, a Health and Safety Plan (HASP) will be in place to minimize the release of chemicals during the implementation of remedial activities at the site. Therefore, impacts during the performance of remedial activities will be negligible.
Response #18
A discussion of the past and proposed remedial measures to minimize public exposures to site contaminants is given in the Background section of this document. As part of the selected remedial action, a Health and Safety Plan will be in place to minimize exposure to site contaminants by remedial workers and nearby residents, as mentioned in the Pathways section of this document.
Comment #19
The off-site soil survey performed during the site RI showed that the chemical presence in Griffon Park due to the site did not extend into the playing area of the two baseball diamonds. Since the chemical presence did not extend onto the baseball diamonds, the potential for dermal contact by the baseball participants would have been minimal. In addition, the area which has shown chemical presence was and is heavily vegetated and it is unlikely that exposure to dust particulates occurred. This is supported by the Public Health Implications section which states in item 4 of Section A, "past exposures to these chemicals by the Little League baseball participants and other park users at the highest concentrations found in the park's soil would pose a minimal health risk".
Response #19
We agree that site contaminants were not found in most of the samples collected in the area of the baseball diamonds. However, from the diagrams provided in the RI, some site-related contaminants were found in the area of the baseball diamonds. Since most of the samples collected from the baseball diamonds have not contained site-related contaminants, the discussion of human exposure via this pathway will be changed from a completed pathway to a potential pathway for past exposure to site-related contamination.
Comment #20
The area north of Buffalo Avenue is on the NYS DOH "not habitable" list and the Love Canal Area Revitalization Agency's (LCARA's) current plans are to convert this area into an open area. There are no plans to re-habit the area. Conversion to an open area will not occur until remedial activities are completed. Olin has control of the house immediately east of the site through a 99 year lease. It has been vacant for several years.
Response #20
These points are noted and the text has been revised where appropriate.
Comment #21
The statement of the Toxicological Evaluation section, item 2, that "exposures...would pose a minimal health risk to (persons exposed to surface soils at Griffon Park)" should be incorporated into the Conclusions section, item 2(c).
Response #21
The text will be revised accordingly. The Toxicological Evaluation section will be used to revise all relevant conclusions.
Comment #22
OxyChem and Olin should be placed on the mailing list for the annual follow-ups to the Public Health Assessment.
Response #22
OxyChem and Olin will be placed on the appropriate mailing lists.
