PUBLIC HEALTH ASSESSMENT
RAYMARK INDUSTRIES
STRATFORD, FAIRFIELD COUNTY, CONNECTICUT
APPENDIX A
SITE MAP
APPENDIX B
ATSDR PUBLIC HEALTH ADVISORY, MAY 1993
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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
APPENDIX C
INTERAGENCY COMMUNICATION PLAN
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Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch,
E-56
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APPENDIX D
GIS MAPS
Contaminant Levels of Health Concern
Population 5 Years of Age and Younger
APPENDIX E
HEALTH CONSULTATION
FISH AND SHELLFISH
SUBSISTENCE FISHING MEMO
PRESS RELEASE-FISH DATA
FACT SHEETS-PONDS
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Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch,
E-56
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APPENDIX F
HEALTH CONSULTATION
PRIVATE WELL SURVEY
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Division of Health Assessment and Consultation
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E-56
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APPENDIX G
CITIZEN QUESTION AND ANSWERS
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E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
APPENDIX H
FACT SHEETS NEIGHBORHOOD FORUMS
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Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch,
E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
APPENDIX I
STRATFORD ENVIRONMENTAL UPDATES
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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
APPENDIX J
PUBLIC HEALTH CODE/PRIVATE WELLS
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Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch,
E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
APPENDIX K
HEALTH CONSULTATION
BLOOD LEAD SCREENING
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Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch,
E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
APPENDIX L
HEALTH CONSULTATION
CANCER INCIDENCE
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Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch,
E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
APPENDIX M
MEMO-BIRTH DEFECTS
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Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch,
E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
APPENDIX N
RESPONSE TO PUBLIC COMMENT
The following lists all of the public comments received on the Public Health Assessment during the public comment period that ran from August 21st through October 6th.
Comment #1: CTDPH and ATSDR found an excessive rate for mesothelioma which is generally acknowledged to be indicative of asbestos exposure. However, this rate was based on Stratford as a whole and not residents who lived near or worked at the Raymark facility. The 16 reported cases should be investigated further to see how many of them may be Raymark-related. While it is true that this epidemiological study did not find statistically significantly higher cancer incidence (except to bladder cancer) this could be simply that the Raymark effects are "diluted" in the larger all-of-Stratford database. The justification for ignoring the statistically significant higher incidence of cancers among persons less than 25 years of age because "no one type of cancer was more common" will be less than reassuring to the residents of Stratford. There is clearly still a need for more detailed epidemiological studies of cancer incidence.
In September of 1993, CTDPH and ATSDR recommended: "Cohorts of individuals who may have had higher exposure to the waste should be considered for more extensive follow-up." As was shown by the epidemiology discussed above, this is vitally important to the community, but no discussions were included that indicate this work has been started, yet alone completed.
Response: Page 10 of the Public Health Assessment specifically outlines the follow-up health studies that will be done using Geographic Information Systems. As indicated in the Public Health Assessment, this additional analysis will allow us to further explore the association between proximity to waste and cancer risk as opposed to the first analysis which looked at Stratford as a whole. In addition, page 9 of the document discusses the evaluation of Stratford residents with waste present in their yards and Public Works employees, two cohorts that were evaluated because they represented cohorts that may have experienced more significant exposures.
Comment #2: It is unfortunate to have to point out to CTDPH and ATSDR that, despite the tone of their document, the potential serious exposures associated with off-site Raymark contaminated soil will not automatically disappear when these affected soils are redeposited on another in-town property. These soils are currently inadequately and illegally stored at the Raymark Facility. Not only does this represent a health hazard to those who must work on site, but also the surrounding community may be impacted by the dust or inadequate site security. The "space-age" foam used to cover the wastes may even encourage inquisitive trespassing!
Response: The Public Health Assessment clearly states that excavated soil does pose a potential health threat to workers at the facility (p. 41), residents living near the facility (p. 42) and trespassers (p. 42). The CT DPH have and continue to work very closely with EPA to assure that 1.) temporary piles are covered in such a manner as to prevent any soil from becoming airborne, and 2.) that on-site activities are occurring in such a manner as to prevent the spread of contamination off-site. These commitments are clearly outlined in Conclusion #1 and Recommendation #2 of the Public Health Assessment. In addition, perimeter air monitoring is being done at the site on a daily basis to ensure that contamination is not migrating off-site at levels of health concern.
Comment #3a: The Public Health Assessment neglects to mention that EPA in their April 1995 Proposed Cleanup Plan state that they will "begin additional studies to further evaluate the groundwater contamination...to identify potential groundwater cleanup options in the future, if necessary." The Public Health Assessment also failed to address the potential impacts of groundwater or LNAPL vapors which may be discharging into the basements of homeowners or businesses.
Response: The Public Health Assessment does identify the groundwater contamination and the potential for volatilization into confined spaces as a potential exposure pathway (pg 42.) In addition, Conclusion #5 states that additional information regarding groundwater migration, extent of contamination and potential for off-gassing needs to be gathered. Recommendation #4 outlines these same issues and as part of the Public Health Action Plan, we commit to reviewing that additional data.
Comment #3b: The potential health problems associated with solvents were not mentioned nor was the ability of solvents to mobilize otherwise relatively immobile compounds in the sub-surface. Since the purpose of the well survey was to locate and test private wells in order to evaluate potential health impacts, it is inconsistent for agencies responsible for protecting public health not to collect and analyze groundwater from these wells to state that since public water is available, no one should ever access this contaminated groundwater for potable purposes.
Would the CT DPH further explain what actions it now plans to take in terms of these wells specifically, 1) if testing has been undertaken, and what results were obtained, 2) if well permits were granted whether they will now be revoked, 3) if permits were not granted, what action will be taken, 4) what warnings CT DPH has provided or will provide to the homeowners relating to this well water and 5) the technical and regulatory basis for their statement on p. 44 that "These wells are not located near the Raymark facility or other waste locations." In particular, how does "less than one mile" equate to "not near?"
Response: Appendix F of the Public Health Assessment outlines the well survey methodology, the findings and the follow-up activities. The purpose of the survey was to 1.) identify wells within 0.5 miles of a known Raymark waste site, and 2.) sample any wells within 0.5 miles of a site. As stated, a total of 15 addresses were identified as having an active private water supply well. Of these, none were located within 0.5 miles, six were located within one mile but greater than 0.5 miles two were located one to two miles from a site and seven were located 2.5 to 3.5 miles from any known waste site. Of the six private wells located between 0.5 and one mile, four were near Wooster School, one was near the Lordship area and 1 was near the Raymark facility but upgradient from the site.
The local health department followed up with the fifteen private wells and encouraged testing.
In initiating the private well survey, the agencies were most interested in determining if private wells existed near the Raymark facility. Unlike the other off-site waste locations where soil contamination is not adversely impacting groundwater, the groundwater at the facility is grossly contaminated and stated as such on page 19 of the Public Health Assessment.
Comment #4: No discussion is given of the potential adverse health impacts (other than eating shellfish) of the high levels of PCBs (greater than 10 ppm) found in Ferry Creek sediments. Since this was predominantly PCB-1268 (an unusual aroclor associated with Raymark wastes), it is related to the Raymark facility. No discussion was given of whether these sediments might be exposed at low tide or might otherwise impact local residents.
Response: Data available for Ferry Creek, at the time the document was written, was insufficient to evaluate the potential risks associated with direct contact with sediments. We are committed to evaluating this data.
Comment #5: I am concerned about the reports in the news media involving the study of cancer rates in Stratford. To only study the data of the Town of Stratford gives a misleading result. The only way to have an accurate picture of where Stratford truly stands is to study the health data from surrounding towns (Trumbull, Bridgeport, Shelton, Milford) as well. We do not live in a vacuum. While Raymark was indeed a polluter, it also is not isolated. This entire region, for example, is affected by air pollution from New York City. If it was found that surrounding towns also had a slightly elevated number of bladder cancer incidents or the rare form of lung cancer then perhaps the problem(if there is indeed a problem) is a regional one-not something that is unique to Stratford.
Response: The cancer incidence study in Stratford was initiated for two specific and focused reasons: 1.) determine if Stratford had experienced a higher than expected rate of cancers over the study time period and 2.) respond to citizens concerns regarding whether certain cancers had occurred more in Stratford residents. Both of these questions were raised in light of the Raymark environmental contamination in the town. The most significant limitation of this type of cancer analysis is it does not show cause and effect or tell us what caused the differences in cancer rates.
Cancer is not one disease but many diseases with different causative factors. While hereditary, dietary and environmental agents may increase an individuals risk of cancer, certain characteristics of a population of people also change the risk of disease in that group. Age, race, ethnicity and socioeconomic status all contribute to cancer risk in a population. Because of this, we compare Stratford to the State as opposed to comparing it to surrounding towns. We know than the population characteristics of Bridgeport, Trumbull or Shelton are very different than the population characteristics of Stratford. When we compare Stratford to the State the differences in population characteristics are less dramatic and provide for a better comparison.
