The following section 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:
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch
E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
The following section 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:
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch
E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
APPENIDIX 5 PUBLIC COMMENTS--RESPONSIVENESS SUMMARY
The Public Comment section for the OSL site contains the public
comments received during the public comment period in July 1993 and
their respective response.
PUBLIC COMMENTS RECEIVED FROM A LOCATION IN SOUTHINGTON, CT
COMMENT NO. 1.
According to the Public Health Assessment the boundaries of the
landfill are not clearly defined. If this is so, then why
aren't more tests being done to determine the boundaries?
RESPONSE TO COMMENT NO.1.
Since the writing of this document, information has been
reviewed by the CT DPHAS and the CT DEP. The CT DPHAS and the
CT DEP have determined that the northern, eastern and southern
boundaries of site have been defined by the EPA RI/FS
consultants ESE. At the present time there is still a question
as to the western boundary of the landfill.
COMMENT NO.2.
Why hasn't more testing of the wetlands around Black Pond been
done? Even though the water in the pond has tested relatively
clean, what about the silt that flows out with the water and
stays after the pond water recedes? More testing of the silt
from the pond and the wetlands on the northeast side of the
pond needs to be done. We live at number 61 Rejean Road and
many times have had Black Pond overflow into our back yard,
sometimes as close as ten feet from our home. Testing has not
been done in any of the back yards of the homes that get
overflow from the pond? Why? We would like to know if there is
anything there.
RESPONSE TO COMMENT NO. 2.
Based on the data we have evaluated from Black Pond which
includes, surface water, sediments and fish, we do not have any
evidence that exposure to the overflow from the pond onto your
backyards will cause an adverse health effect.
In response to your concern, the CT DPHAS is planning to sample
the surface water overflow and surface soil in the area of your
property where water from Black Pond overflows.
COMMENT NO. 3.
Why are so many of the towns wells contaminated? Our family
drank the water from well number five for approximately two
years. How are we and all the other people who drank from these
wells going to be monitored for any illnesses in the future?
What recourse do we have?
RESPONSE TO COMMENT NO. 3.
Waste disposal activities account for the contamination of the
four Southington town wells that have been contaminated through
time. The source of contamination for wells number 4 and 6 is
Solvents Recovery Services of New England. Allegedly, there
are several sources that contributed to the contamination of
town well number five. These include the OSL Landfill and
other industrial facilities near the well. Well 2 was
contaminated by the disposal of dry cleaner waste.
In response to your question on monitoring people for
illnesses, the CT DPHAS has educated physicians in Southington
about the environmental history of the Town of Southington
including the contamination of these four wells. This
physicians education program is designed to alert physicians
that exposures have occurred and that citizens are concerned
for their health.
COMMENT NO. 4.
Why did the Town of Southington allow homes and businesses to
be built on a landfill where it was known that hazardous waste
was dumped? How could the Town of Southington allow plans for
a residential area to be made and have those plans on paper
years before the landfill was closed?
RESPONSE TO COMMENT NO. 4.
The CT DPHAS does not know the answer to this comment. This
question should be directed to the Town Manager's office of
Southington.
PUBLIC COMMENTS RECEIVED FROM A LOCATION IN PLANTSVILLE CT.
COMMENT NO. 1.
Considering my location next to R.V. & Son, I feel more testing
on my property should be done for gases and contaminants.
RESPONSE TO COMMENT NO. 1.
The CT DPHAS and the ATSDR feel that adequate testing was done
on-site to characterize the potential for you as a resident to
be exposed to site contaminants. The CT DPHAS has reviewed the
surface soil data, indoor air, drinking water and methane data
that was available and did not find evidence that your family
would be in danger of being exposed to contaminants from the
site.
COMMENT NO. 2.
I feel my property lacks adequate subsurface testing for gases
and contaminants. Due to my location how does EPA justify that
adequate testing was conducted in order to collect data for the
Health Risk Assessment report.
RESPONSE TO COMMENT NO.2.
The CT DPHAS cannot answer this question because it concerns
the EPA Risk Assessment which is different from the ATSDR
Public Health Assessment. This question should be addressed to
the EPA Region I office for a response.
The CT DPHAS feels that adequate testing was done on your
property in order to assess the potential for exposures to
occur at the present time. The CT DPHAS was concerned with
surface soils, soil gas, indoor air, drinking water, and
surface water from Black Pond. A review of the data from the
above mentioned sources did not indicate that you or your
family are being exposed to any contaminants. However, we are
concerned about the methane levels that were detected in your
backyard, and your home will be monitored regularly by the
Southington Fire Department.
COMMENT NO. 3
What information did the EPA use in order to establish quality
guidelines for VOCs in our well water? B) How can the EPA be
sure the guidelines are at a safe level for consuming? (pg. 19)
RESPONSE TO COMMENT NO. 3.
These guidelines developed by the EPA are protective of public
health. All these quality guidelines developed by the EPA are
based on animal toxicity studies and they represent the highest
concentration of a chemical that a person can be exposed to
over a 70 year lifetime without causing a health problem.
COMMENT NO. 4.
How does our site compare to other sites in the way of
contamination and how it effects our health? What site was used
in your study to compare with ours?
RESPONSE TO COMMENT NO. 4.
As per our review of the available data from several sites in
Connecticut the OSL site in comparison to other Superfund sites
in the Connecticut is more contaminated than some and less
contaminated than others. The CT DPHAS and the ATSDR did not
use other sites for comparison in our analysis of the
contamination on the OSL site. Each Superfund site that we
investigate is assessed individually. The one element that all
the Superfund sites have in common is contaminated ground water
problems.
This is the first time that the CT DPHAS has dealt with the
problem of methane migrating into the indoor air. However,
when the CT DPHAS, the ATSDR, and the EPA became aware of the
presence of potentially dangerous levels of methane at the
site, experts that had dealt with other landfills and methane
hazards in the U.S. were consulted.
PUBLIC COMMENTS RECEIVED FROM A SECOND LOCATION IN PLANTSVILLE, CT.
As long standing residents of Southington CT, we have many concerns
(past, present and future) regarding our health. My husband, ____
has been a Southington resident for over 40 years. I have a
daughter, _______, who is seven years old.
COMMENT NO. 1.
Our past concerns stem from contaminated drinking water,
inhalation of smoke contaminated with toxic waste, and of toxic
gases that we may have been exposed to from the Old Southington
Landfill. We may have been exposed to contaminated water while
bathing, gardening, swimming, or washing the car. We have been
exposed to smoke, gases, and dust emitted from the landfill.
Many chemicals at Old Southington Landfill are cancer causing
others cause heart, lung, kidney or liver diseases. Still
others attack the respiratory, central nervous, or blood
systems. Residents of Southington have been exposed to all of
them from Old Southington Landfill. Our family and many of our
immediate neighbors suffer from dizziness, severe headaches,
respiratory ailments, cancer, leukemia, numbness of
extremities, high blood pressure, fatigue, abdominal pain, and
others too numerous to mention. All of our health problems can
be attributed to exposure to toxins at the Old Southington
Landfill by inhalation, ingestion, or contact.
RESPONSE TO COMMENT NO. 1.
It is true that some of the chemicals that were detected at the
OSL site and in the public water wells have been found to cause
heart, lung, kidney, and liver diseases in animal studies but
at levels greater than those found at the site. In the
Toxicologic Evaluation section each compound that was
identified as a potential concern was assessed with respect to
the potential for this contaminant to cause a health problems
to humans. We did not find any evidence that the contaminants
from the site could be causing the illness you describe above.
However, we feel that your family and immediate friends should
consult with a local physician or an occupational health
clinic. Occupational health clinics specialize in exposures to
chemicals that are found in the workplace as well as in the
local environment. The CT DPHAS has consulted with physicians
in Southington and with the Occupational Medicine Program at
the University of Connecticut Health Center in Farmington
concerning the history of the OSL site.
COMMENT NO. 2.
Our present health concerns are more personal. Our home is on
the northern border of the old Southington Landfill. We live
approximately forty feet away from a toxic waste Superfund site
that is on the National Priority List. Everyday we acknowledge
that our family is exposed to life threatening chemicals, soil
gases and landfill leachate. Some chemicals even in small
amounts, are deadly.
RESPONSE TO COMMENT NO. 2.
The CT DPHAS and the ATSDR have reviewed the available data and
have found no evidence that you and your family are being
exposed to substances that could cause you harm. If we felt
that there could be a possibility that this was true, we would
have contacted you immediately. If we felt that residents were
exposed to a life threatening situation, the CT DPHAS, the EPA
and the ATSDR would have taken the necessary actions and
evacuated the residents.
COMMENT NO. 3.
Methane gas is a major concern. Every time we hear a siren or
see a fire truck in the street we panic. Have the levels of
methane reached dangerous? Are we going to be evacuated?
Methane migration has been detected in the southern areas of
the landfill. Has any of the methane from the northern areas
of the landfill migrated? Has it moved to our property? Did
it carry any unknown gases or VOCs? Is methane building up in
small enclosed areas -- causing an explosion danger? Are safe?
RESPONSE TO COMMENT NO. 3.
Methane was detected indoors in the floor cracks of three non-
residential buildings on the OSL site at levels that could pose
a fire and explosion hazard. However, methane has not been
detected indoors in any of the northern residential homes on
the OSL site. The Southington Fire Department inspects and
monitors the homes located on the landfill every day and has
not identified methane inside any of the homes to date.
Methane has been detected in methane wells installed in the
backyards of homes that are on the OSL site. These wells are
monitored regularly.
At the present time we do not have any information to indicate
that methane and other potentially toxic gases are migrating
into your homes. However, the Southington Fire Department has
offered to come and test the homes of residents who are
concerned about the presence of combustible gases in their homes.
COMMENT NO. 4.
High levels of VOCs and PAHs are in the soil. Elevated levels
of Toluene, TCE, and other VOCs have been detected in indoor
air samples at dangerous levels. The VOCs found in the samples
cause dizziness and headaches. Is this the cause of our
daughters unexplained chronic dizziness? Why hasn't the air
been tested inside of the homes bordering the landfill?
RESPONSE TO COMMENT NO. 4.
Elevated levels of toluene, TCE, and other VOCs have not been
found in any of the homes. The levels of VOCs found in indoor
air samples were below health comparison values and therefore,
exposure to these are unlikely to cause health problems.
Because there is no evidence that toxic gases or vapors are
migrating substances into the homes located on the landfill,
the CT DPHAS does not feel there is cause for concern in the
homes bordering the landfill.
COMMENT NO. 5.
Chemicals causing adverse dermal effect to patients with
preexisting skin conditions are in the soil. Mixtures of
pyrene with other PAHs including benzo(a)pyrene and
fluoroanthene cause skin cancer. Is my husband at risk?
RESPONSE TO COMMENT NO. 5.
The CT DPHAS does not believe that your husband is at risk of
being exposed to subsurface soil contaminated with PAHs from
the OSL site. There is no evidence that your home is on the
landfill.
As discussed in the Toxicologic Implications Section, those
persons involved in excavations and/or diggings on the site
could be at risk of exposure to PAHs, and high levels of VOCs.
The PAHs were identified at 4 foot depths on the OSL site.
COMMENT NO. 6.
Lead and mercury have been detected in ground water. Although
contamination levels are relatively low - as parents we are
concerned about long term exposure to mercury which can cause
permanent brain damage.
RESPONSE TO COMMENT NO. 6
The lead and mercury identified in Town well number five is
believed to be the result of laboratory error. The lead and
mercury were only detected in laboratory analysis in a sampling
round. Because subsequent sampling did not detect the presence
of lead or mercury, the CT DPHAS does not believe that Town
well number five was contaminated with lead or mercury.
COMMENT NO. 7.
Our future concerns center around recommended remediation of
Old Southington Landfill.
When the houses and factories that are situated on solid waste,
methane, or VOC pockets are destroyed, how will the
contamination be contained?
COMMENT NO. 8.
When the vegetation is uprooted, how will the contaminated soil
and dust be prevented from becoming air born?
COMMENT NO.9.
How will methane gas and other contaminants be contained and
prevented from migrating?
COMMENT NO. 10.
Will an impermeable clay wall be installed to surround
subsurface contamination?
COMMENT NO. 11.
Will sewer and utility lines be removed (not capped) to insure
that gases and other contamination will not follow them and
pollute the entire neighborhood?
COMMENT NO. 12.
Can mixed chemicals, PCBs and VOCs ignite or explode when
exposed to oxygen?
COMMENT NO. 13.
When a clay cap is placed over the landfill will pressure cause
methane or other toxic waste to spread or redistribute? How
will this be prevented?
COMMENT NO. 14.
How and how often will the quality of air, soil, and water be
monitored during clean up?
COMMENT NO. 15.
Different chemicals and gases travel through different avenues,
air - soil - water, will monitors be installed outside of the
landfill current boundary to insure public safety?
COMMENT NO. 16.
When our child sees the EPA employees in their space suits,
what reassurance can we give her that she is absolutely not in
danger?
COMMENT NO. 17.
We live less than 40 feet away from the Old Southington
Landfill. In 1984 this site was placed on the EPA National
Priority List as one of the worst toxic waste sites in the
U.S.. When clean up of this site begins, I want guarantees
Guarantees ... that my family and friends will be safe during
clean up.
COMMENT NO. 18.
Guarantees ... that our lives will proceed as normal and not be
disrupted because of landfill activities.
COMMENT NO. 19.
Guarantees ... that we will be able to enjoy outdoor activities
without worry.
COMMENT NO. 20.
Guarantees ... that we will be able to leave our windows open
and not be assaulted with contamination.
COMMENT NO. 21.
Guarantees ... that future migration of gases, VOCs, PCBs, and
landfill waste will not endanger us.
COMMENT NO. 22.
Guarantees ... that the water we drink is safe that the air we
breath is not contaminated that the soil beneath our feet is
not killing us.
COMMENT NO. 23.
I want to know beyond a shadow of doubt that our lives and
health will not be diminished because we live on the border of
a U.S. EPA Superfund Toxic Waste Site.
COMMENT NO. 24.
Our concerns and anxieties are genuine. We are apprehensive
about our future. Our physical and mental health is uncertain.
Our daily lives have been and will continue to be disrupted by
landfill activities. Questions remain unanswered.
The CT DPHAS and the ATSDR cannot comment on the hazards of the
prospective remediation plan or methods without reviewing the
EPA specific plan. The CT DPHAS recommends that concerned
residents like yourself review the Remediation plan when it is
made available for public comment and that you submit written
comments to the EPA and the CT DEP. The EPA Remediation plan
will be made available for your review at the Southington
Public Library. In addition, there will be several meetings
concerning the remediation of the site that you should attend.
The EPA RI/FS workers are required by law to wear health and
safety equipment and clothing while they are on the site
performing any sampling, investigative or remediation work. If
the EPA identified a potential hazard, local residents and
workers would be notified and evacuated if necessary.
COMMENT NO. 25.
The CT DPHAS has provided Southington residents with a health
assessment that is factual and understandable. Along with the
CT DEP, your combined efforts have overcame obstacles and have
provided residents with information that is vital for our
understanding of this public disaster. Recognizing that the
State of Connecticut Agencies willingly provide information
when Federal and Local Governments are reluctant to do so, is
a great comfort and deserving of Southington's residents
gratitude. The knowledge that both the CT DPHAS and the CT DEP
are safe-guarding people from harm is sincerely appreciated.
RESPONSE TO COMMENT NO. 25.
The CT DPHAS thanks you for submitting comments on the Draft
Public Health Assessment for Old Southington Landfill. If you
require further information or clarification on the information
presented here or other issues concerning the site, please do
not hesitate to contact us. We are here to serve you.
PUBLIC COMMENTS RECEIVED JULY 28, 1993 FROM PEPE & HAZARD LAW
OFFICES, GOODWIN SQUARE, HARTFORD, CT.
GENERAL COMMENTS
The CT DPHAS and the ATSDR have conducted an evaluation of the
human health risks and hazards presented by contamination
associated with the Site. As noted in the Draft Public Health
Assessment (Draft PHA), the purpose of this evaluation "is to
determine whether adverse health effects are possible and to
recommend actions to reduce or prevent possible health effects."
Given the stated purpose of the Draft PHA, we believe that the
Draft PHA as currently written has fallen short of the mark for a
number of reasons as set forth below.
GENERAL COMMENT NO 1.
* First, the Draft PHA has reviewed only selective data gathered
over the years at the site. The Draft PHA has failed to
include the most recent results of investigations at the Site,
including the risk assessment and actions taken at the Site.
These facts are critical in evaluation and presenting potential
risks to nearby residences and businesses. Additionally, many
of the facts reported are not correct. While there is
available a large amount of information regarding the Site,
much incorrect information has been reported and is repeated in
the PHA. We would be willing to assist ATSDR in identifying
and correcting such factual errors.
RESPONSE TO GENERAL COMMENT NO.1
The Draft PHA was reviewed by the EPA and the CT DEP before it
went out for public comment. The CT DPHAS and the ATSDR rely
on the EPA and the CT DEP for their comments and review of the
available data. At that time neither agency commented that the
information that was included in the Draft PHA was incorrect.
The CT DPHAS agrees that more recent data was not included in
the Draft PHA before it went out for Public comment. However,
this data does not change our assessment and conclusions of the
site that it is a public health hazard. This conclusion is
based on past exposures to VOC contaminated drinking water from
town well number five and the present physical hazards
associated with the methane contamination of indoor air in
commercial facilities. The CT DPHAS and the ATSDR are
conducting a study to try and reconstruct the dose of VOCs
Southington residents may have received from contaminated
drinking water with respect to the geographic location of their
residence.
GENERAL COMMENT NO. 2.
* Second, the Draft PHA is misleading in its presentation of
current potential risks posed by the Site, by intermixing and
emphasizing historic risks to groundwater town-wide, which have
long since ceased with discussions as to current and future
risks. The fact that there may have been potential risks due
to drinking groundwater in the past is an insufficient reason
to classify the site as a current public health risk.
RESPONSE TO COMMENTS NO. 2
What you are discussing above is the purpose of a risk assessment
which is different than the purpose of an ATSDR Public Health
Assessment. The following is a comparison of these two different
assessment documents.
The ATSDR Public Health Assessment is qualitative, and uses
environmental and health outcome data and community health
concerns as the primary sources of information. For the most
part the health assessment is site-specific unless another
source of exposure is identified near the site that may have or
could impact the local community.
The EPA risk assessment is quantitative, compound oriented,
site specific and uses environmental contamination data.
The ATSDR Public Health Assessment weighs medical and public
health perspectives to assess health hazards. It is concerned
with past, current, and future exposures.
The EPA Risk Assessment uses statistical and/or biologic models
to calculate numerical estimates of health risks. In addition,
it deals with hypothetical populations and pathways. It is
concerned with current and future exposures.
The ATSDR Public Health Assessment is used to evaluate human
health impacts and to identify public health interventions.
The EPA Risk Assessment is used to facilitate remediations or
other risk management actions.
The ATSDR Public Health Assessment may identify populations for
which further health actions or studies are indicated.
The EPA Risk Assessment may lead to the selection of particular
remediation measures at a site.
The EPA Risk Assessment bears regulatory weight of authority.
The PHA may lead to the issuance of a Public Health Advisory.
GENERAL COMMENT NO. 3.
* A related problem is the inclusion in the Draft PHA for the
Site of a discussion of the area wide cancer studies which
sprang from the SRSNE Site. The discussion of those studies is
confusing and likely to mislead the public as to the nature of
potential risks posed by the Old Southington Superfund Site.
This is compounded by the fragmented discussion which should
clearly point out that the findings of those studies have not
determined whether any elevated cancer incurrences are present
which are attributable to conditions which may have
historically existed. To the extent the ATSDR deems these
matters to be of interest to the public, the discussion should
be appended to the PHA for the Site and merely referenced
within the PHA.
RESPONSE TO GENERAL COMMENT NO. 3.
Although the cancer cluster investigation was initiated because
of concern with the Solvents Recovery Services of New England
(SRSNE) site, the cancer cases analyzed in this study were from
the entire town of Southington. In addition, the CT DPHAS was
evaluating the Old Southington Landfill site at the same time
as the SRSNE site. Therefore, since the entire town was
evaluated it was included in this public health assessment.
GENERAL COMMENT NO. 4.
* Fourth, the draft PHA fails to clearly characterize the nature
and results of combustible gas investigations at the Site and
the efforts undertaken by the parties to assess and prevent
potential impacts. The Draft PHA should clearly differentiate
between the residence on the Site where numerous sampling
events have shown no potential impacts. The Draft PHA should
clearly differentiate between the residences on the Site, where
numerous sampling events have shown not potential problems to
exist, from the commercial buildings where actions have been
taken to ensure the monitoring and prevention of problems which
may occur. In addition, the Draft PHA does not describe the
actions taken in cooperation with the CT DEP, the CT DPHAS, the
EPA, and the Fire Department to monitor combustible gas, take
immediate measures in response, and install monitors and
venting systems for the long term.
RESPONSE TO GENERAL COMMENT NO. 4
The CT DPHAS and the ATSDR feel that the information is clearly
presented with respect to what has been identified on
residential and commercial properties. The ATSDR Public Health
Assessment is concerned with past, current, and future
exposures. The Draft PHA doesdescribe the actions taken by the EPA, the CT DEP, the Southington Fire Department, the ATSDR
and the CT DPHAS in sections B. ON-SITE CONTAMINATION and in
Public Health Action Plan.
COMMENT NO. 5.
* Finally, the Draft PHA should be rewritten in a less
inflammatory style. Merely reporting statements and rumors
about potential risks has no place in this report.
Nonscientific assertions as to stress, etc. and the need for
counseling are simply not based upon factors of the Site, are
misleading to the public and are unnecessarily inflammatory.
RESPONSE TO COMMENT NO. 5
In reviewing your comments it is quite clear that you are
unfamiliar with the health assessment process and most
importantly its mission. The health concerns and statements of
residents are not interpreted as "rumors".
Addressing the health questions of the residents associated
with the site is central to the overall mission of the ATSDR
and to the purposes of the Draft PHA. The health concerns will
vary from site to site. In addition, addressing the health
concerns of the community including stress, is crucial if the
health assessment is to satisfy its purpose of helping the
public and health professionals understand all the risks posed
by a site. The CT DPHAS has observed an unusually high amount
of stress in several communities living near Superfund sites in
Connecticut and recognizes that stress can effect the quality
of family life.
COMMENT NO. 6
Of the most critical importance, however, is the fact that the
essential findings of the Draft PHA that the Site is a public
health risk is based simply upon two conclusions: 1) historic
risks due to contaminated groundwater; and 2) potential risks
to businesses from combustible gas. Although the Draft PHA
arrives at these conclusions, they are not clearly presented.
As a result, the PHA is likely to cause unnecessary confusion
and anxiety on the part of the public rather than to serve its
primary function of guiding future response activities at the
Site. Furthermore, the first conclusion cited in support of
the findings of the Draft PHA provide no basis for that
finding. While there may have been in the past potential risks
due to contaminated supply wells, this risk no longer exists
and is not relevant to the stated purpose for the PHA
evaluation. Finally, with respect to the combustible gas
issue, the facts as to the Site, measures taken and monitoring
underway do not support these issues as a sufficient basis for
the Draft PHA finding.
RESPONSE TO GENERAL COMMENT NO. 6
Please see response to GENERAL COMMENT numbers 1 and 2 above.
SPECIFIC COMMENTS
SPECIFIC COMMENT NO. 1, BACKGROUND, PAGE 2, PAR. A, PAR. 2
The statement that "the extent of the landfill's boundaries are
not established and have not been fully defined" is incorrect.
Through the performance of the RI/FS, especially during the
Post-Screening Field Investigations (PSFI), the boundaries of
the landfill have been fully defined. The findings resulting
from these extensive field investigations are consistent with
information collected from the review of historical records,
review of aerial photographs, and interviews. Attached as
Exhibit I hereto is a letter to the EPA Remedial Project
Manager setting forth in detail the bases for such findings.
(See also Exhibit 2, EPA letter and attachments, dated June 18,
1992.)
SPECIFIC COMMENT NO. 2
The PSFI were completed in two tasks: Task I was completed in
December of 1991, and Task 2 was completed in late 1992, early
1993. The PSFI included several programs designed to provide
additional information relative to the extent of refuse across
the Site: delineation of the landfill boundary along the west
side of Black Pond; further delineation of the southern
boundary of the landfill; and further delineation of the
northern boundary of the landfill.
Based upon the installation of borings and chemical analysis of
soils, across the Study during Task I investigations, findings
were presented in the Task I Report (submitted March 26, 1992,
as revised May 22, 1992) which differentiate the northern
portion of the Study Site (wood debris characteristic of a
"stump dump") from the southern portion (refuse characteristics
of a municipal landfill). Further, the northernmost extent of
the wood debris in the northern portion of the Site was
confirmed to lie just south of Rejean Road.
Based upon the installation of borings and chemical analysis of
soils across the southern portion of the Site, during Task 2
investigations, findings were presented in the draft Remedial
Investigation Report which clearly define the extent of refuse
along the southern and southeasterly boundaries of the
landfill. Likewise, hand auger investigations along the
western side of Black Pond delineated the extent of refuse
encroachment along the shore of the Pond.
RESPONSE TO SPECIFIC COMMENTS NO 1 AND 2.
Your comments on the landfill boundaries were incorporated into
the health assessment. However, in discussions with the CT
DEP, there is still some controversy as to the southern limits
of the landfill.
SPECIFIC COMMENT NO. 3, PAGE 2, PAR. 6
With respect to the statement concerning open burning, we
believe that the reference overstates the known occurrence of
such activities. The Draft PHA should state instead that there
are certain reports of open burning at the landfill prior to
1964, but such activities appear to have been sporadic over
that period of time.
In addition, this paragraph is misleading in its
characterization of the volumes and nature of wastes received
at the landfill. The Draft PHA states that approximately 2.5
million gallons of solvent were disposed of at the Site. While
it is alleged that Solvents Recovery Services of New England
(SRS) took approximately one million gallons of solvent
contaminated wastewater to the landfill, analyses of these
wastewater streams indicated that the natural percent of
solvent ranged somewhere between 8 percent and 22 percent. As
SRS was in the business of recycling and selling solvents, it
is not likely it would have disposed of pure solvent. The
Ecology and Environment report (Field Investigations of
Uncontrolled Hazardous Waste Sites: FIT Project, December 29,
1980) suggests approximately 2.7 million gallons of solvent
contaminated waste, not solvent waste. If ATSDR has additional
information correctly indicating the amount of solvent disposed
of, we would appreciate reviewing that information to determine
how it may impact the RI/FS.
RESPONSE TO COMMENT 3
As previously stated above in the general comments, the CT DEP
and the EPA reviewed this document previously prior to it going
out for public comment and neither agency questioned this
information. It is unknown how much waste was disposed of at
the landfill. In addition, the CT DPHAS personally interviewed
an employee of the OSL landfill and the owner of Solomon
Casket. Both reported that waste burning was commonly performed
during the operation of the landfill. They also reported that
spontaneous chemical fires also occurred.
Your comment on the waste disposed of by SRS was addressed.
SPECIFIC COMMENT NO 4, PAGE 3, PAR. 2
This statement should be changed to read:
Since the time the landfill was covered and closed, and
portions were subsequently subdivided, further remediation has
not taken place. An RI/FS is being conducted at the Site,
after which the EPA will determine the appropriate remedial
measures to be taken based upon the extensive studies and the
feasibility of remedial options.
RESPONSE TO SPECIFIC COMMENT 4
The CT DPHAS does not see any reason to change this paragraph
as it will not be adding any new information.
SPECIFIC COMMENT NO 5, PAGE 4 (B, PAR 4)
We take issue with the statements made regarding the presence
of seepage of landfill leachate. During the course of he
various investigations conducted to date, no evidence of seeps
has been observed. What has been observed, however, is the
presence of surface water runoff from existing industrial
activities.
RESPONSE TO COMMENT NO 5.
On several occasions the CT DPHAS has observed and photographed
what appears to be leachate seeps and not surface water runoff
from the commercial facilities.
COMMENT NO. 6. PAGE 4 (B, PAR. 4)
The Draft PHA states incorrectly that the areas north of the
Rejean Road are believed to have been all wetlands prior to the
construction of the existing subdivision. Based on aerial
photographs, subdivision plans, and Town road construction
drawings, the area directly north of the site was a wooded
hill, but this was significantly northeast of the site.
RESPONSE TO COMMENT NO. 6.
To respond to your comment, which concerns page 3, paragraph 2,
the CT DPHAS is referring to the residential area immediately
north of Rejean Road. This correction was included in the
health assessment.
COMMENT NO. 7 page 4-5 (B, Par. 5)
The statements made regarding combustible gases present an
incomplete history of investigations undertaken by the agencies
and the parties, as well as fail to detail the activities
undertaken by the agencies and the parties, as well as fail to
detail the activities undertaken to monitor and respond to
concerns in the past and on a continuing basis.
The Draft PHA should detail the fact that immediate steps were
undertaken to seal floor cracks in the Parks and Recreation
Building. Furthermore, an additional combustible gas indicator
(CGI) has been placed in that building and an existing passive
venting system was modified in June of 1992. In addition, a CGI
has been placed in the three buildings at Southington Metal
Fabricators and a passive venting system installed in two of
the buildings which had detectable amounts of combustible
gases. Finally, ESE, DPHAS, OSHA, and DEP have made available
to workers, etc., the results of data collected with respect to
those buildings, as well as information on appropriate
precautions.
RESPONSE TO COMMENT NO. 7 pages 4-5(B, Par. 5)
The Draft PHA doesdescribe the actions taken and planned by
the EPA, the CT DEP, the Southington Fire Department, the
ATSDR, and the CT DPHAS in B. ON-SITE CONTAMINATION and in the
PUBLIC HEALTH ACTION PLAN sections. However, in this, the
final version of the PHA, we have included those actions taken
during the health assessment process by the various agencies
and the Southington Fire Department in the BACKGROUND section.
SPECIFIC COMMENT NO. 8, D. Health Outcome Data, Page 6
We believe that the rationale for inclusion of the cancer study
data arising out of the SRSNE Site is unsupported. The
inclusion of this lengthy discussion is confusing and
misleading to the public. This discussion should clearly note
the results of the studies to date which do not show any
correlation to this Site or any site for that matter.
We would suggest that the final PHA include such discussion
only as an appendix to the PHA for Site. While certainly of
interest to the public, its inclusion within the body of a
site-specific PHA is misleading and unnecessarily alarmist.
RESPONSE TO COMMENT NO. 8, D. Health Outcome Data, Page 6
Although the cancer cluster investigation was initiated because
of concern with the Solvents Recovery Services of New England
(SRSNE) site, the cancer cases analyzed in this study were from
the entire town of Southington. In addition, the CT DPHAS was
evaluating the Old Southington Landfill site at the same time
as the SRSNE site. Therefore, since the entire town was
evaluated it was included in this public health assessment.
COMMENT NO. 9, COMMUNITY CONCERNS
The Draft PHA should present a complete picture of the efforts
undertaken to address community concerns. The Draft PHA should
state that the EPA and the ATSDR held a public meeting in
August of 1992 to provided information to the public on site
conditions. In addition, the CT DEP, the EPA, and the parties'
Project Technical Coordinator have met twice with residents and
concerned citizens to discuss these concerns. Finally, data
from monitoring in commercial and residential structures has
been made available to owners of and workers within tested
buildings, as well as information provided on appropriate
precautions.
RESPONSE TO COMMENT NO. 9 COMMUNITY CONCERNS
The Draft PHA presents community health concerns and those
actions that were taken to address these concerns. For those
actions taken to address community concerns please refer to the
PUBLIC HEALTH IMPLICATIONS, section C. Community Health
Concerns Evaluation
. Those specific actions taken by the
various agencies and the Southington Fire Department to address
citizen's concerns are discussed in this section.
See "General Comments" with respect to our concerns that the
PHA was based upon selective review of data and incomplete
consideration of activities conducted to date.
The Draft PHA was reviewed by the EPA and the CT DEP before it
went out for public comment. The CT DPHAS and the ATSDR rely
on the EPA and the CT DEP for their comments and review of the
available data. At that time neither agency commented that the
information that was included in the Draft PHA was incorrect.
The CT DPHAS agrees that more recent data was not included in
the Draft PHA before it went out for Public comment. However,
this data does not change our conclusions that the OSL site is
a Public Health Hazard.
COMMENT NO. 11, PAGE 8, PAR. 2
This statement as to the reason for indoor air sampling is
incomplete and incorrect. This statement should be rewritten
as follows:
In addition, sampling for combustible gas in indoor air has and
is being conducted as follow-up to citizen complaints, and as
part of routine monitoring by Respondents, the CT DEP, the EPA
and the OSHA. Continued sampling is being conducted in
commercial buildings where elevated levels of combustible gas
have previously been detected and measures taken. In addition,
continued monitoring has been and continues to be performed in
the residences. Both are being performed pursuant to a
monitoring plan submitted to the CT DEP on June 26, 1992, and
memorialized in an agreement with the CT DEP on August 15,
1992.
RESPONSE TO COMMENT NO. 11
The CT DPHAS disagrees with your comment. Firstly, our review
of the Southington Fire Department logs in November of 1993
indicate that continued sampling is not being conducted in all
commercial buildings where elevated levels of combustible gas
have been previously detected. According to the Southington
Fire Department Record for the month of November 1993, the
Southington Metal Fabricators buildings was no longer being
monitored as per ESE's request. The CT DPHAS contacted the CT
DEP with respect to this matter. In addition, the extent of
the methane problem at the site was discovered as a result of
information received by the CT DPHAS during site visits and a
public availability session that occurred in November of 1991.
COMMENT NO. 12, TOXIC INVENTORY, PAGE 9
This paragraph should make clear that the TRI would not serve
to identify all facilities which may have contributed to
contamination near the Site. It should be noted that
considerable information regarding potential site and site
vicinity contributors has been provided to the CT DEP and the
EPA. In addition, information in DEP files demonstrates that
other potential sources (i.e. Lori Corp.) may be responsible
for historic ground water problems.
RESPONSE TO COMMENT NO. 12
Your comment was incorporated in the PHA.
COMMENT NO. 13, B. ON-SITE, PAGES 9-16
The Draft PHA concludes that there is no current health threat
from contaminants which may be present as a result of the
landfill, except for the potential physical hazard associated
with combustible gas. This overall conclusion should be more
clearly stated within the report. The RI/FS activities have,
and through the remedial alternative selection process will,
address contaminants present at the site and direct the steps
necessary to continue to assure that the site does not pose a
threat to human health.
This paragraph should further state the full facts regarding
measures taken (e.g. passive venting) and monitoring underway.
(See pages 2, 5 and of these comments). In addition, it should
be noted that combustible gas readings within the commercial
buildings have not indicated any significant problems.
The measures that have been taken to mitigate the methane
problem in the commercial facilities on the landfill is
discussed in the B. ON-SITE CONTAMINATION, Indoor Air section.
Mitigation measures are addressed targeted towards the movement
of soil gas into a building. Consequently, this is an indoor
air issue.
The CT DPHAS and the ATSDR disagree with your comment that the
combustible gas readings within the commercial buildings have
not indicated a significant problem. The identification of
combustible gases in the interior of a building is cause for
concern. In addition, the potential exists for toxic gases to
migrate into the buildings and contaminate the indoor air.
COMMENT NO. 15, PAGE 14, PAR.2
The reason for the presence of combustible gas outside of the
two residential properties has not been fully determined.
However, the statement that this presence is a result of
migration from the southern portion of the Site is incorrect
and contrary to the field data collected. A large number of
combustible gas measurements have been taken in the soil gas
across the northern portion of the Site. These measurements
clearly show an absence of combustible gas across most of the
northern portion, especially between the southern portion and
the two residential properties. Additionally, measurements
were taken from soil gas along the natural gas line utility
trench, which runs parallel to Old Turnpike Road along the
entire Site. These measurements clearly show an absence of
combustible gas across most of the northern portion, especially
between the southern portion and the two residential
properties. Likewise, measurements taken from soil gas along
the entire Site have demonstrated the lack of migration along
this potential pathway. These data refute the notion that the
combustible gas present at the two isolated locations is the
result of migration from southern portion.
RESPONSE TO COMMENT NO. 15, PAGE 14, PAR. 2
The paragraph offers two interpretations of the potential
source of methane in the residential yards. The paragraph
reads as follows: "This suggests that either methane is
migrating from the southern areas of the landfill or is being
generated naturally from buried organic materials."
Since the CT DPHAS and the ATSDR are not 100 percent convinced
that the methane is not migrating north from the southern
portions of the landfill. In addition, in order for us to
protect public health we have to be conservative in our
interpretations of the pathways of contaminant migration.
COMMENT NO. 16, INDOOR AIR, PAGE 14-16
This discussion should clearly differentiate between results at
residences and those at businesses. The Draft PHA discussion
is misleading as to the significance and location of any
concerns. The Draft PHA should indicate that the EPA performed
GC/MS at the residences twice and the results did not show any
problem from those analyses, which included combustible gases.
RESPONSE TO COMMENT NO. 16, INDOOR AIR, PAGE 14-16.
This information is already discussed in the health assessment.
On page 17, the discussion concerns off-site ground water
monitoring wells. Your comment was incorporated in the Ground
Water - Public Well and Ground Water - Private Wells sections.
COMMENT NO. 18, SURFACE WATER, PAGE 20, PAR. 3
This paragraph improperly implies that compounds detected in
the Quinnipiac River are site related. Numerous studies at the
Quinnipiac River have shown the river to have been impacted by
many sources upstream of the Site.
The CT DPHAS knows that there are many sources in Southington
that may have impacted the Quinnipiac River.
This paragraph reports what contaminants were identified in the
Quinnipiac River in the vicinity of the OSL site by the RI/FS
consultants.
COMMENT NO. 19, PHYSICAL AND OTHER HAZARDS PAGE 22-23
We believe that this section as presented relies upon selective
review of data and an incomplete history of activities
conducted to date. As such, it presents a biased and
misleading characterization of such matters. This discussion
should be balanced to reflect measures taken and monitoring
underway. (See General Comments).
RESPONSE TO COMMENT NO. 19, PHYSICAL AND OTHER HAZARDS PAGE 22-23
This section represents the concerns of state and federal
health and regulatory agencies over the methane contamination
problem on the OSL site. The CT DPHAS and the ATSDR believe
the identification of combustible levels of methane are cause
for concern. Indeed it is because state and federal regulatory
and health agencies believe that the presence of methane at the
OSL site poses a potential physical hazard that continuous
monitoring is occurring and engineering controls have been
installed.
COMMENT NO. 20, PATHWAYS ANALYSES PAGE 24, PAR. 2
This section should be rewritten to reflect the fact that this
potential exposure pathway was historic in nature. (See
General Comments). In addition, the record does not clearly
show that site-related contamination was responsible for this
risk.
RESPONSE TO COMMENT NO. 20, PATHWAYS ANALYSES PAGE 24, PAR 3.
The discussion of this completed exposure pathway clearly
states that the exposure occurred in the past and as such will
not be changed.
COMMENT NO. 21, PAGE 24, PAR 3.
As noted in our General Comments, this discussion with respect
to Town wells 2, 4, and 6 is inappropriate in this site
specific PHA and is confusing and misleading to the public.
RESPONSE TO COMMENT NO. 21, PAGE 24, PAR 3.
As part of the health assessment process all sources of
exposure that are identified during our investigations of
Superfund sites in a specific town are presented in this
document. In addition, the CT DPHAS and the ATSDR are
conducting a dose reconstruction study to assess the exposures
that residents in Southington received from the Town's
historically contaminated water supply.
It is the purpose of the health assessment process to assess
past, current, and potential future exposures.
COMMENT NO. 22, INDOOR AIR, PAGE 24
This statement should be rewritten as follows: "Employees...may
have received...
as written, this statement is speculative and biased. The
paragraph should reflect the fact that no adverse health
effects are likely since methane is merely an asphyxiant, and
should not speculate on "other unknown gases." Based upon
numerous analyses by the EPA, combustible or other gases in the
indoor air at the buildings at the site.
RESPONSE TO COMMENT NO. 22, INDOOR AIR, PAGE 24
This statement is based on health effects that have been
reported by several employees interviewed by the CT DPHAS. As
such employees have become ill from the migration of gases into
there working environment and the exposure occurred.
COMMENT NO. 23, SOIL PATHWAY, PAGE 25
It should be noted that PAHs do not "readily evaporate."
RESPONSE TO COMMENT NO. 23, SOIL PATHWAY, PAGE 25
Your comment is noted and a correction was made to the sentence
in question.
COMMENT NO. 24, PAGE 26
With respect to statements regarding landfill leachate see page
5 of these comments.
RESPONSE TO COMMENT NO. 24, PAGE 26
Please refer to RESPONSE TO COMMENT NO. 5.
COMMENT NO. 25, AMBIENT-AIR PAGE 26
This discussion is speculative and inflammatory. As stated
above, the reports of open burning are not conclusive but
rather indicate such activities occurred on a sporadic basis.
The relevance of such historic allegations is unclear when the
purpose of this PHA is to determine possible current and future
risks associated with the Site and to recommend measures to
address such risks.
RESPONSE TO COMMENT NO. 25, AMBIENT-AIR PAGE 26
Again, your comment indicates that you don't understand the
health assessment process. The purpose of the public health
assessment is to determine all possible past, current, and
future risks associated with the site.
The CT DPHAS interviewed persons that worked in the landfill
when it was in operation and residents who had businesses
during this time. The CT DPHAS and the ATSDR have no reason to
doubt eye- witness accounts of landfill activities from the
community. Information received from the community is
necessary for us to assess past exposures and at times can be
more helpful to us in getting the historic exposure history
than state and federal records.
COMMENT NO. 26, COMBUSTIBLE GAS PAGE 27, PAR. 2
This statement should clarify that residences have been tested
and no significant levels found. As written, homes and
businesses are inappropriately grouped together. See General
Comments above.
RESPONSE TO COMMENT NO. 26, COMBUSTIBLE GAS PAGE 27, PAR. 2
The CT DPHAS and the ATSDR feel that the information is clearly
presented with respect to what has been identified on
residential and commercial properties. Additional information
was added to this paragraph which discusses the high levels of
combustible gases detected in the backyards of two residential
properties.
COMMENT NO. 27, TCA AND TCE, PAGES 27 -28
The Draft PHA should clarify the distinction between residences
and businesses and the results of previous investigations. The
PHA should not compare commercial business indoor air results
with TEAM Study residential results. In addition, it should be
noted that the TCE carcinogenicity assessment has been
withdrawn from IRIS.
COMMENT NO. 28, TOLUENE AND BENZENE, PAGE 29 SEE COMMENT ABOVE
RESPONSE TO COMMENTS NO. 27, TCA AND TCE, PAGES 27-28 AND NO. 28,
TOLUENE AND BENZENE, PAGE 29
TCE, TCA, toluene, and benzene were identified in indoor air in
residential homes at levels above what would be expected based
on the results of the EPA TEAM study but below health
comparison values. The Draft PHA does not compare the TEAM
study results with the commercial facilities' indoor air
results.
COMMENT NO. 29, LEAD/MERCURY, PAGE 31, PAR.2
As stated in our General Comments, the inclusion of this
discussion in a site specific PHA is inappropriate, confusing
an misleading to the public, and inflammatory.
RESPONSE TO COMMENT NO. 29, LEAD/MERCURY
Lead and mercury were detected in 1976 in three public water
wells in Southington including well number five. The detection
of lead and mercury in town production wells 4, 5, and 6 is
information that the Southington Town residents are aware of,
and as such, despite the fact that the CT DPHAS believes that
the presence of these compounds was due to sampling or
laboratory error, it must be discussed in the health assessment
to clear up any misconceptions. As a rule the CT DPHAS is not
in the business of holding back information from the public.
COMMENT NO. 30, CONCLUSIONS, INTRODUCTORY PARAGRAPH (SEE COMMENTS
ON PAGE 3 OF THESE COMMENTS).
This conclusion should state that Southington residents "may
have been exposed...". This conclusion should indicate that
other sources of site vicinity and area wide ground water
problems are likely.
RESPONSE TO COMMENT NO 30, CONCLUSIONs, PAGE 38, # 1.
The CT DPHAS obtained sufficient evidence from its review of
the Southington Water Department files to conclude that people
drank water that was contaminated. The Old Southington
Landfill was placed on the National Priority List and is a
Superfund Site because it contributed to the contamination of
well number five.
This conclusion should also state that based upon numerous
analyses by the EPA, the CT DEP, the CT DPHAS, and ESE,
combustible gases are not posing a threat to the residences.
RESPONSE TO COMMENT 31, PAGE 38, #2
Although the ongoing monitoring, and wall monitors have not
detected the presence of combustible gases to date, combustible
gases have been identified in residential backyards. In
addition, there is evidence of subsidence in the homes which
could potentially create cracks in the foundation creating a
potential methane migration pathway. It is because the EPA,
the CT DEP, and the CT DPHAS feel that combustible gases could
pose a threat to the residences that monitoring is required
under a state order.
COMMENT NO. 32, PAGE 38, #3
Conclusion should state that PCBs were only found in isolated subsurface samples.
RESPONSE TO NO. 32, PAGE 38, # 3
The CT DPHAS sees no reason to change the wording in this
conclusion. Since sampling was not performed underneath any of
the building structures, stating that PCBs were only found in
isolated subsurface samples is misleading.
COMMENT NO. 33, PAGE 38, #5
As stated in our General Comments, these nonscientific
assertions are inappropriate for a PHA and are misleading and
inflammatory. While we appreciate the frustration which often
accompanies the Superfund process, a frustration we also feel.
These statements have no place in a document such as this.
RESPONSE TO COMMENT NO. 33, PAGE 38, #5
See response to GENERAL COMMENT NO 5.
COMMENT NO. 34, PAGE 38, #6
See previous discussion. Where the conclusions show no link to
the Site, nor any demonstrated impact to the Town, they should
not be part of this specific PHA.
RESPONSE TO COMMENT NO 34, PAGE 38, #6
See response to GENERAL COMMENT NO. 3.
COMMENT NO. 35, PAGE 39, #1
This recommendation should state that, pursuant to the
monitoring plan submitted to the CT DEP and the EPA and
memorialized in an agreement with DEP, combustible gases
continue to be monitored and results submitted to the CT DEP.
In addition, the EPA has performed monitoring in the
residences. Finally, this recommendation should note that
results of such investigations have shown no combustible gas
impact on the four residences.
RESPONSE TO COMMENT NO. 35, PAGE 39, #1
Continuous monitoring of all of the three affected facilities
has not been ongoing. The CT DPHAS review of the Southington
Fire Department files indicates that no monitoring was
performed at the Southington Metal Fabricators Buildings in
November of 1991 as per your request. The CT DPHAS contacted
EPA and the CT DEP to address this matter. In addition,
combustible gases have been identified in the backyards of
residences. Although the level of combustible gases is below
the lower explosive level (LEL), the CT DPHAS, the CT DEP, the
EPA, and the ATSDR still feel that there is cause for concern.
This concern is based on the fact that the homes are now
showing signs of subsidence which could create cracks in the
foundations potentially creating gas migration pathways.
COMMENT NO. 36, PAGE 39, #3
Stress-See General Comments
RESPONSE TO COMMENT NO. 36, PAGE 39, # 4
See response GENERAL COMMENT NO. 3.
COMMENT NO. 37
As stated in our General Comments, landfill boundaries have
been fully delineated. Moreover, the draft RI/FS submitted to
the EPA characterizes the nature and extent of groundwater
contamination.
RESPONSE TO COMMENT NO. 37
Your comments on the landfill boundaries were incorporated into
the health assessment. However, in discussions with the CT
DEP, there is still some controversy as to the southern limits
of the landfill. However, this recommendation will not be
changed. The CT DPHAS and the ATSDR still feel that the
Southington Community should be informed as to the extent and
degree of overburden and bedrock contamination within and
emanating from the landfill. Perhaps these questions will be
answered in future public meetings that are planned to discuss
the proposed remedial designs.
COMMENT NO. 38, PUBLIC HEALTH ACTION PLAN, PAGE 40, #1
It should be stated in addition that both the Fire Department
and ESE have been and continue to monitor conditions in the
commercial buildings onsite and take any measures found
necessary.
RESPONSE TO COMMENT NO. 38, PUBLIC HEALTH ACTION PLAN, PAGE 40, #1
Part of your comment was incorporated in number 11 of the
Public Health Action Plan. However, continuous monitoring of
the three affected commercial facilities has not been
occurring. The CT DPHAS review of the Southington Fire
Department files indicates that monitoring was ordered stopped
in November at the Southington Metal Fabricators Buildings as
per your request. The CT DPHAS contacted the EPA and the CT
DEP to look into this matter.
COMMENT NO. 39, PAGE 40, #2
This statement should clarify that no adverse effects were
indicated based upon the results of this assessment by the CT
DEP.
RESPONSE TO COMMENT NO. 39, PAGE 40, #2
Your comment was addressed in the PHA.
COMMENT NO. 40, PAGE 40, #3
This statement should state that the results showed no
contamination in the tap water.
RESPONSE TO COMMENT NO. 40, PAGE 40, #3
Your comment was addressed in the PHA.
COMMENT NO. 41, PAGE 40, #6
This paragraph should state that this action has been
implemented pursuant to the monitoring plan submitted to the CT
DEP and the EPA and memorialized in an agreement with the CT
DEP.
RESPONSE TO NO. 41, PAGE 40, #6
Your comment was incorporated in the Public Health Action Plan
(PHAP). However, in November of 1993, the CT DPHAS was
informed by the Southington Fire Department that the
Southington Metal Fabricators facility was not to be monitored
anymore. This facility continues to be a concern to the CT
DPHAS with respect to the presence of combustible gases and
should continue to be monitored.
COMMENT NO. 42, PAGE 40, #9
The PHA should reflect the fact that the RI/FS has completed an
investigation of surface soils and that the risk assessment has
determined that surface soils do not present an unacceptable
risk.
RESPONSE TO NO. 42, PAGE 40, #9
Your comment was addressed in the health assessment. Although
we agree with the risk assessments determination, our
conclusions as to the health risk involved are based on the CT
DPHAS and the ATSDR assessment of the soil and not the results
of the EPA risk assessment. As previously stated the EPA Risk
Assessment and the ATSDR PHA are two separate documents with
different purposes.
COMMENT 43, PAGE 40, # 10
For reasons set forth on pages 3 and 4 of these comments, the
Site boundaries have been delineated.
RESPONSE TO COMMENT 43, PAGE 40, # 10
See previous response.
COMMENT NO. 44, PAGE 40, #11
This paragraph should state in addition that the residences are
being monitored on a bimonthly basis.
RESPONSE TO COMMENT 44, PAGE 40, # 11
This information was incorporated into the PHA.
COMMENT NO. 45
Once again, we appreciate the opportunity to provide comments
on the Draft PHA. As stated above we believe that the PHA
should reflect the most current data available on site
conditions and potential impacts. We believe that the PHA
should be redrafted to focus on the presentation of potential
current and future site-specific risks in a clear,
understandable and unbiased fashion.
RESPONSE TO COMMENT NO. 45
The most recent data does not change our conclusions concerning
the site. The CT DPHAS and the ATSDR have categorized this
site as a public health hazard based on past exposures to VOC
contaminated drinking water from town well number five and the
physical hazards associated with the methane contamination of
indoor air. Please refer to our previous discussions
concerning the differences between a Risk Assessment and a
Public Health Assessment.
The CT DPHAS and the ATSDR thank you for submitting comments on the
OSL PHA.
