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1. ATSDR > Public Health Assessments & Consultations

PRELIMINARY PUBLIC HEALTH ASSESSMENT

SPECTRON INCORPORATED
(a/k/a GALAXY INCORPORATED)
ELKTON, CECIL COUNTY, MARYLAND

APPENDICES

APPENDIX A

Figure 1. Cecil County Spectron
Galaxy Superfund Site


Figure 2. Cecil County Spectron
Galaxy Superfund Site

APPENDIX B

TABLES

Table 1
Maximum Contaminant Levels in On-Site Monitoring Wells (µg/L)

¹All Comparison values are described on pages 11-12.

Table 1 (continued)
Maximum Contaminant Levels in On-Site Monitoring Wells (µg/L)

¹ All comparison values are described on pages 11-12.

Table 2A
Maximum Contaminant Levels Measured
in Off-site Air (µg/m³)
(May, June 1970)

1. All comparison values are described on pages 11-12.
   
   
2. Concentrations of these contaminants were estimated as they could not be precisely determined with the instruments utilized.
   
   
3. Values are provided for 1,1,2,2-tetrachloroethane and 1,1,1,2-tetrachloroethane.

Table 2B
Mean and Range of Contaminant
Concentrations in Off-site Air Samples (µg/m³)
(August, 1976 - January, 1977)

1. Values shown include the mean concentration for all samples in which contaminant was detected and the range for all samples in the units µg/m³.
   
   
2. Refers to the number of sampling days on which the contaminant was detected out of the total number of sampling days [total = site 1 (16 days); site 2 (40 days)]
   
   
3. All comparison values are described on pages 11-12.
   
   
4. Not detected.

Table 2C
24-Hour Average Concentrations of Contaminants
Detected in Off-Site Air Samples
(July-August 1984)

Contaminant	Average Concentration and Range (µg/m3)	Comparison Value1 (µg/m3)
Benzene	7.3 4.5 - 11.5	0.1 (CREG)
Methylene chloride	1,240 36.8 - 7,578	2 (CREG)
Tetrachloroethylene (PCE)	35.3 0.6 - 135	2 (CREG)
Toluene	158 14.2 - 1,015	400 (RfC)
1,1,1-Trichloroethane	271 0.5 - 2,158	1,632 (EMEG)

1. All comparison values are described on pages 11-12.

Table 2D

Range of Average Annual Concentrations of Contaminants Measured at 3 Off-Site Air
Monitoring Stations (1987, 1988, 1989)

¹Station 1 (N) was located about 250 ft. northeast of the site, Station 2 (KR) about 500 ft south of the site, and Station 3 (Shelton) about 1,500 ft. to the north.

²Annual average concentrations for 1993 at a monitoring station in an industrial area of Baltimore City (for comparison purposes).

³ All comparison values are described on pages 11-12.

⁴ Data not available.

⁵ Not detected.

Table 3

Maximum Contaminant Levels in Off-Site Residential Wells¹

¹These maximum concentrations are from residential well sampling conducted in 1992 (9). The findings are uncertain because no VOCs were detected in samples which were split and analyzed by a different laboratory; no contaminants were detected in 1993 follow-up samples.

²In residential well sampling conducted in February 1993 and November 1993, no contaminants were present above detection limits (5 ppb).

³J = Analyte present but reported value may not be accurate or precise.

⁴CV = comparison value.

⁵All comparison values are described on pages 11-12.

Table 4

Range of Contaminant Concentrations Detected in
Little Elk Creek Water Samples (µg/L)
(1979,1980)

¹The minimum and maximum concentrations from four sampling dates: 11/21/79, 12/7/79, 12/18/79, 1/3/80.

²The concentration measured in samples from this station collected on 1/14/80.

Table 5

Maximum Contaminant Levels in Off-site Creek Samples (1989-1991)
(µg/L)

¹Creek samples were collected a short distance from the site.

²ND = not detected

³NA = not analyzed

* = estimated value

Table 6

Maximum Contaminant Levels in Seep Samples (1989-1991)
(µg/L)

¹Seep samples were collected from the stream bank, adjacent to the site

* estimated value

Table 7

Maximum Contaminant Levels in Groundwater Immediately below
Little Elk Creek¹

¹Samples were taken using piezometers.

²NA = not analyzed.

³ND = not detected.

APPENDIX C

Summary of Little Elk Creek Valley Cancer
Mortality Study (1963-1976)

Observed¹and expected Cancer deaths for Providence Valley residents
from January 1, 1967 through June 30, 1976,
with standard mortality ratios and associated 95% Confidence Limits

¹Observed cancer deaths were obtained by death certificate surveillance and include only those occurring to individuals residing in the Valley at the time of the death. The specific cause of death was that recorded on the death certificate.

ICDA
200 (Lymphosarcoma, reticulum cell sarcoma)
201-209 (All other neoplasms of lymphatic and hematopoietic tissue)

³Observed deaths/expected deaths.

⁴Poisson probability of observing X number of deaths or more due to chance alone.

from: Final report on studies conducted in Little Elk Creek Valley during 1974 - 1976. Maryland Department of Health and Mental Hygiene. 1977.

APPENDIX D

Written Public Comments on the Public Comment Draft Public Health Assessment for the Spectron/Galaxy Site and MDE Responses

Following are written comments on the Spectron/Galaxy Public Health Assessment received by MDE during the public comment period: September 24, 1995, through November 25, 1995. Comments within quotation marks are as submitted, while the absence of quotation marks indicates that the comments have been paraphrased or summarized by MDE. Comments are presented in the chronological order they were received by MDE. A set of comments refers to those submitted together in one letter.

1) The following are the 1st set of comments received.

Comment: The resident of Little Elk Valley was recently diagnosed with chronic myeloid leukemia after living in the area since 1974 and felt strongly that proximity to the Spectron/Galaxy site (now and while the facility was in operation) contributed to the resident's illness.

MDE response: It is not possible to state with certainty whether or not this illness is related to exposure to contaminants from the site. There is a "background rate" of leukemia among people living in Maryland and the United States, and most cases cannot be attributed to a specific cause. Leukemia is a relatively rare disease, with an overall annual incidence rate (number of newly diagnosed cases per year) in the total U.S. population during 1987-1991 of approximately 10 cases per 100,000 people. The annual incidence rate of chronic myeloid leukemia among the total U.S. population during this same period was 1.3 cases per 100,000 people.

One of the contaminants detected at an elevated concentration in off-site air in 1970 and again in 1976/77 was benzene. Epidemiologic studies have shown a higher rate of acute myelogenous leukemia among some groups of adults who were occupationally exposed to benzene on a regular basis. A recently completed study has also identified a possible association between benzene exposure and other forms of leukemia. The cancer mortality study of Providence Valley residents that was completed in 1977 did not identify a significantly elevated excess of deaths from leukemia during the study period (1967-1976). A young child who lived close to the site did die from acute leukemia during this period; however, the interpretation of this child's illness with respect to exposure to chemicals from the Spectron/Galaxy facility is complicated by the fact that the child had Down's Syndrome. Children with this condition are at an approximately twenty times greater risk of developing leukemia than those without it. This does not rule out chemical exposure as a possible contributing factor in the development of leukemia in this child. We are hopeful that our update of the original cancer mortality study of valley residents will identify any additional cases of leukemia mortality that have occurred among area residents following completion of that study in 1976 and will also shed light on any association with the Spectron/Galaxy site.

Current chemical emissions from the Spectron/Galaxy site are not expected to pose a health risk to area residents. Air sampling conducted on residential properties near the site in August, 1995 did not identify any elevated levels of airborne contaminants. Twenty-one residential wells located near the site were sampled in September 1995. Low levels of site-related chemicals were detected in the water sample from one well; however, the chemicals were present in concentrations well below drinking water standards and would not be expected to cause illness in people who may have been exposed to it. A carbon filter was placed on this well in January 1996 as a precaution.

Comment: "It is my hope that future research will include more detailed medical research and not simply cancer mortality rates. While this Public Health Assessment does a good job of informing the public of Off- and On-Site Contaminants related to the site, it lacks with respect to the Health Outcome Data."

MDE Response: It is true that cancer death rates are not a very sensitive endpoint of the potential health impact of chemical exposures. Cancer mortality was originally examined by the Little Elk Creek Valley Task Force because of public concern at the time which focused on a possible increased rate of cancer among area residents. There is also a plausible link between exposure to some of the contaminants originating from the Spectron/Galaxy facility and an increase in the risk of developing some forms of cancer. During the time period when people were exposed to higher concentrations of airborne chemicals from the site it would have been possible to look at other health endpoints in exposed residents, such as pregnancy outcomes and symptom patterns. A study that looked at these types of endpoints (i.e., that could indicate the effects of ongoing exposures) would not be appropriate to conduct now because there is information indicating that there are currently no exposures to contaminants at levels of public health concern.

We believe that it is useful to update the original cancer mortality study of Providence Valley residents. There is a "latency period" or lag time between exposure to a cancer causing agent (e.g., radiation, carcinogenic chemicals) and the subsequent development of cancer. If there have been any cancer deaths caused by past site-related exposures, a follow-up to the original study might identify some of these cases. This is not as simple an exercise as it might appear. Cecil County residents with serious illnesses often use hospitals in Delaware, which makes it necessary to search records from that state as well as Maryland. Also, some people who were exposed to elevated levels of site-related contaminants in the past have moved from the area, and it may not be possible identify these individuals.

Comment: "I also find it appalling that "no conclusions can be made regarding the impact of site-related contaminants on the health of exposed individuals" according to your evaluation of the available health outcome data. It is obvious to most of the residents of the Little Elk Creek Valley that the emissions from the Spectron/Galaxy Site have had significant effects on the overall health of the Valley."

MDE response: The statement that the commenter quotes from the health assessment document refers to the fact that the cancer mortality rates for Cecil County that are provided in the document cannot be used to draw conclusions about the impact of the site on exposed residents. As stated in the document, this information is provided because we believed that it may be of interest to the reader. Cancer mortality rates for the population of Cecil County as a whole cannot be used to indicate whether or not there is an elevated cancer mortality among a small subpopulation of people living within the County (i.e., residents of Providence Valley).

Comment: "With a continued effort, I am confident that a total assessment of the public health concerns related to the Spectron/Galaxy Site can be obtained."

MDE response: The Department is hopeful that we will be made aware of the health concerns that residents of Providence Valley have with respect to the Spectron/Galaxy Superfund site so that we can address them. The Cecil County Health Department (CCHD) has recently completed a survey of the residents of Providence Valley in order to assess their information needs related to the Spectron/Galaxy site. We hope to work with the CCHD in addressing the concerns of residents.

2) The following are the second set of comments received.

Comment: "It appears from the report that the lab tests are reporting inconsistent results. Wouldn't it be advisable to have several more independent labs repeat these tests and then average out the results? If no further testing is done, a doubt remains in my mind as to whether the site is truly safe."

MDE response: The comment refers to the discussion in the health assessment document of the results of residential well sampling that was conducted near the Spectron/Galaxy site in 1992 and 1993. In November 1992 EPA sampled wells from 20 residences located in the vicinity of the site. MDE "split" some of these samples with EPA and sent them to a different laboratory for analysis. Two different volatile organic chemicals (VOCs) were detected in some of the samples collected by EPA, whereas none were found in the samples that were collected by MDE from these same wells.

The detection of chemicals in samples that were analyzed by one laboratory but not in the samples analyzed by a different laboratory may be a reflection of the difficulty associated with accurately measuring very low concentrations of chemicals in water. The levels of chemicals detected in these samples were near the lower limit of the detection level for the laboratory instruments. The discrepancy might result from the differences in the capabilities of the 2 laboratories to analyze low contaminant level samples. The chemicals detected in the November 1992 well samples were not common laboratory contaminants and have also been detected in the contaminated groundwater at the Spectron site. In this case, it was assumed that the contaminants were actually present in the well samples, and as a precautionary measure, the residents were supplied with bottled water. Additional sampling of eight of the wells was conducted in February 1993 and no contamination was detected.

Laboratories which analyze samples from sites such as Spectron, which are on EPA's National Priorities List (NPL), must be certified by EPA. The laboratories must comply with strict quality control procedures during the handling and analysis of samples, and this must be well documented. When there is a question about the validity of a finding (such as the case discussed above), an additional sample is usually collected and analyzed instead of "averaging" different values for the same sample.

It may appear that there is "conflict of interest" in allowing this sampling to be conducted by a company hired by the RP group. This is common practice at Superfund hazardous waste sites, and the Department considers the results to be reliable. The sampling is conducted under EPA supervision, and the laboratory that analyzes the samples must be certified by EPA. The samples are also subjected to a strict "chain-of-custody" protocol from the point at which they are collected to the laboratory at which they are analyzed.

More recent testing involved the sampling of 21 residential wells near the Spectron site in September 1995. As noted above in the response to the first set of comments, low levels of site-related chemicals were detected in the water sample from one well; however, the chemicals were present in concentrations well below drinking water standards and would not be expected to cause illness in people who may have been exposed to them (a carbon filter has been placed on this well as a precaution). Site-related contaminants were not detected in the remaining 20 wells. All twenty-one wells will continue to be monitored at a frequency of twice per year.

Comment: The site is an eyesore and everything should be removed. Suggested uses of the site in order of priority include:

1) Restore the area to woods and/or green space; 2) Build a year-round staffed playground and swimming pool for local residents; and 3) Build a fish hatchery to stock Little Elk Creek so that Cecil Co. residents can fish in the stream.

MDE response: The structures that are currently on the site will be eventually removed during clean-up of the site. The first priority is to take some action to prevent contaminants from continuing to enter Little Elk Creek. The RP group is currently working with EPA and MDE in developing a plan of action. There is no easy solution to this situation. Contaminants are entering the creek through contaminated groundwater located under the creek and through some pockets of pure chemical that have collected under the creek.

Once this action is completed a plan for the long-term restoration of the site will be developed. There are contaminated soils under the site. The decision may be reached to leave some of these soils in place because they do not pose a hazard and digging them up could cause a greater health threat as a result of the release of chemicals into the air during the process. A common approach in such situations is to "cap" a site with an impervious material (such as polyethylene covered with clay) and then cover this with soil on which grass is grown. It is unlikely that any new structures will be built on the site.

3) The following are the third set of comments received.

Comment: The commenter lives south of the site near Little Elk Creek and has lived there for 35 years. He commented that "For many years we tolerated the air-borne emissions from the plant, but as time went on the odors became worse. Many times with the cooler, heavier air we spent sleepless nights. Headaches, burning eyes, fatigue and short tempers were the norm."

MDE response: Based on written reports, it appears that some of the worst odors occurred during still evenings. A meteorologist who was consulted by members of the committee that conducted an environmental review of the Spectron/Galaxy site noted that conditions in the valley would sometimes exist that would tend to keep airborne pollutants from being disbursed. An example of such a condition is referred to as an inversion. Inversions occur when cooler air would settle in the valley with warmer air above it, a situation that would tend to trap any airborne contaminants. The highest concentrations of airborne chemicals measured near the site were detected near the bank of Little Elk Creek on a still evening. The symptoms that the commenter reports are consistent with symptoms that would be expected from exposure to elevated levels of some of the solvents detected in the air near the facility.

Comment: The commenter notes that although the federal Clean Air Act did not exist at the time when high exposures occurred, a regulation that was enforced by the Maryland Department of Health and Mental Hygiene (DHMH) should have applied. Among other things, this law prohibited "...unreasonable interference with the proper enjoyment of the property of others by reason of the emission of odors."

MDE response: The DHMH did take Galaxy Chemical Company to court in 1970 under the law that the commenter refers to, and the company was ordered to take corrective actions. This law appears to have been difficult to enforce because it requires a subjective interpretation of the degree of offensiveness of a given odor, or the State had to show with "reasonable certainty" that emissions would be injurious to human health.

Comment: "It appears to me that the damage to our health can have long term effects. I personally have had many blood problems... Two of my neighbors and friends have died of cancer recently."

MDE response: It is possible that sufficiently high exposure to some of the chemicals emitted by the Spectron/Galaxy facility could have long-term effects on the health of exposed individuals. Aspects of chemical exposure which determine whether or not a person's health might be affected include the amount of a chemical to which a person is exposed (i.e., the concentration of a chemical in the air) and the total length of the exposure. It appears that the highest levels of chemicals in the air near the Spectron/Galaxy facility occurred during the use of an on-site evaporation lagoon which was eliminated in 1970, with some periods of elevated levels in the 1970s. People have different degrees of susceptibility to chemical exposures depending on factors such as age, the presence of any preexisting medical conditions, and genetic make-up.

One chemical that was measured at elevated levels in the air near the Spectron/Galaxy site that can have adverse effects on the blood is benzene. One condition that has been detected in some workers who were overexposed to the chemical is a reduction in the different elements of the blood (e.g., red and white blood cells). As noted in a response to a previously listed comment, high occupational exposure to benzene has been associated with increased risk of developing acute myelogenous leukemia, a type of cancer which involves an overproduction of white blood cells.

Unfortunately, cancer is a relatively common disease. About one in three people alive today will develop cancer, and currently about one out of every five deaths in the U.S. is from cancer. Important known causes of cancer include cigarette smoking and heavy alcohol consumption, with diet also thought to be a potentially important causal factor for some forms of cancer. Chemical exposure is thought to be an important factor in a relatively small fraction of cancers. Determining whether or not chemicals from the Spectron/Galaxy facility have caused an increased cancer rate in exposed area residents involves looking at the total number of cases in the defined population (e.g. Providence Valley residents during 1960s-70s), the types of cancers which are observed, possible confounding factors associated with cancer (such as tobacco use, etc.) and the geographic pattern of cancer cases. The Department is planning to follow up on the original cancer mortality study which was completed in 1977.

Comment: "I guess what bothers me most is that our Health Departments should have been educated on the short and long term effects of the recycled chemicals."

MDE Response: Today's knowledge of the short-term health effects from exposure to the industrial solvents that were emitted from the Spectron/Galaxy facility has been developed through scientists observations of workers frequently exposed to relatively high concentrations of these chemicals on the job. Knowledge of long term effects has been more difficult to obtain because it requires studying large groups of people who were exposed to the chemicals of interest. The stricter environmental laws created in the 1970s and 1980s to protect human health and the environment from the effects of chemical exposure were in response to our increasing knowledge of these chemicals.

There is still much to be learned about the possible health effects from exposure to mixtures of chemicals such as those that were released from the Spectron/Galaxy facility.

4) The following are the fourth set of comments received.

Comment: "Nineteen years ago the little Elk Creek Valley Study recommended that further study be done to assess the health hazards caused by Spectron/Galaxy. Nothing was done. The current Public Health Assessment of the Spectron Galaxy Superfund site leads me to strongly recommend that further health studies be conducted in both Providence Valley and within half a mile of this severely contaminated site."

MDE response: The authors of the cancer mortality study, which included the Maryland Department of Health and Mental Hygiene and other local scientists, recommended that surveillance of cancer mortality in Providence Valley be continued. They recommended that this surveillance should include deaths from all cancers and specifically recommended that it include cancers of the blood forming and lymphatic tissues (including leukemia and lymphomas). Based on the records that the Department has located, it appears that the follow up of cancer deaths was continued for 2-3 years following completion of the original study. The Department is planning to update the original cancer mortality study, starting from the point at which the original study finished its review of records (June 30, 1976).

The Department does not believe there are currently any exposures to contaminants entering the air or surface water from the Spectron/Galaxy site that represent a health concern. For this reason we do not believe that there is any reason to conduct a study that would look for evidence of health effects from current exposures.

Comment: The commenter would like to see sampling of Little Elk Creek in the vicinity of Leeds Rd. so that she would know whether or not it was safe for her children to play in the creek.

MDE response: Based on the results of both past and recent sampling of Little Elk Creek, there would be no risk to children who were in contact with creek water in the vicinity of Leeds Rd., approximately 3 miles downstream from the site. The contaminants entering the creek near the site are volatile and tend to move from the water to air; thus, VOC levels 3 miles downstream are expected to be undetectable or present at trace levels.

Water from Little Elk Creek was sampled in September 1995. One sample was collected upstream of the site, with the other three samples collected downstream of the site, at distances of approximately 100, 300, and 2,000 feet downstream from the bridge on Providence Road (approximately 3 miles upstream from Leeds Road). Twenty-one different volatile organic compounds (VOCs) were detected in the sample collected 100 feet downstream, with a total concentration of 395 micrograms per liter (parts per billion or ppb); 20 VOCs were detected at 200 ft. (total concentration = 366 ppb); and 15 VOCs were detected at 2,000 ft. downstream (total concentration = 55 ppb). This large drop of approximately 85% in total VOC concentration at the farthest downstream station, with six VOCs no longer detectable when compared to the closest sample, is explained by the fact that these chemicals are volatile and are released into the air as they travel downstream.

A similar pattern of reduction in the concentration of VOCs in Little Elk Creek was observed in creek samples that were collected in 1979/1980 (see Appendix B, Table 4). One sample was collected at the intersection of Childs Road and Little Elk Creek, about 3 miles downstream from the site. As predicted, there was a large drop in VOC concentrations at this station as compared to the closest upstream station (about 1,500 feet downstream of the site), with 6 of 10 VOCs no longer detectable. Based on the 1995 sampling, the current concentrations of most VOCs (when measured at comparable points in the stream) appear to be considerably lower than in 1979/1980, and VOC concentrations at the Leeds Road/Childs Road section of the stream (about 3 miles downstream of the Providence Road Bridge) would be proportionately lower.

A plan has been approved by EPA and MDE for the RP group to sample Little Elk Creek on a semi-annual basis. The next round of sampling is scheduled for March 27-29, 1996. During this round, a water sample will be collected approximately 3,000 feet downstream of the Providence Road Bridge (approximately 2 miles upstream from Leeds Road) in order to further document the reduction of contaminant concentrations in the creek downstream from the site.

5) The following are the fifth set of comments received.

Comment: "Justice has not been achieved in this case. The collaborative efforts of all parties involved have not achieved closure. I am not only appalled at the evidence of damage done to the land, air, waters and people and animals, BUT, the damage to public confidence in Government to protect us is an even more insidious erosion."

MDE response: The Department understands the commenter's frustration with the perceived inadequacy of the regulatory agencies to, in this case, protect human health and the environment from damage. A review of this site's history does show, however, that local and state regulatory agencies used the laws that were available at the time to address problems caused by the operating facility. The applicable laws in the 1960s and early 1970s appear weak in retrospect, but reflected the limited state of scientific knowledge regarding potential adverse health and environmental effects resulting from chemical discharges into the environment. The early laws also put the burden on government agencies to show that discharges could be injurious to human health or the environment, or unreasonably interfere with the proper enjoyment of property. The following are examples of early government actions:

Date	Action
March, 1969	The Cecil County Health Department filed a complaint against the company, but the Court decided in favor of the company due to "insufficient evidence."
1970	MD Department of Health and Mental Hygiene filed suit against Galaxy Chemical Co. to stop the company from emitting harmful levels of chemicals beyond its borders. The Court found in favor of the Health Department, and ordered the company to take corrective action. The plant was ordered closed by the Court in 1971 for failure to take corrective actions, and was only allowed to reopen following the completion of these actions.

Numerous actions have been taken since the early 1970s; unfortunately, there remains residual contamination of the soil and groundwater at and near the site. Remediation of the site is being carried out under the Comprehensive Environmental Response, Compensation, and Liability act of 1980 (CERCLA or Superfund), with EPA the primary agency overseeing clean up. The Superfund process is slow and methodical; however, the Department is confident that it will result in a satisfactory clean up of the site.

Current laws strictly regulate the use and disposal of potentially hazardous chemicals such that the hazardous activities which occurred at Spectron/Galaxy during 1960s and early 70s would not be allowed to take place today.

6) The following are the sixth set of comments received.

Comment: The commenter wrote that it was difficult to comment on the public health assessment (PHA) document because of its many flaws, which the commenter listed as the document's want of purpose, lack of stated Authorization, lack of References, and lack of clearly set forth Conclusions and Recommendations (the commenter notes that the latter are "buried on pages 46 through 49"). The commenter further noted that although "References" are listed in the Table of Contents, the References were not used to verify statements in the document, and that what was provided was merely a Bibliography. The commenter therefore suggests that the Department not mislead the public into believing that all the statements regarding the bases for conclusions and recommendations are "thoroughly grounded in fact from fully researched references."

MDE response: Regarding purpose and authorization, the PHA was prepared by the Maryland Department of the Environment under a cooperative agreement with the federal Agency for Toxic Substances and Disease Registry (ATSDR). The ATSDR is an agency of the U.S. Public Health Service that was established by Congress in 1980 under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund). Since 1986, ATSDR has been required by law to conduct a public health assessment of each of the sites on the U.S. EPA's National Priorities List (NPL or Superfund). Because of the cooperative agreement with ATSDR, MDE has the responsibility to conduct public health assessments of NPL sites in Maryland. MDE conducts health assessments according to procedures specified in ATSDR's "Public Health Assessment Guidance Manual, March, 1992".

A public health assessment is defined in the Federal Register (vol. 55, p. 5136, Feb. 13, 1990) as "...the evaluation of data and information on the release of hazardous substances into the environment in order to assess any current or future impact on public health, develop health advisories or other recommendations, and identify studies or actions needed to evaluate and mitigate or prevent human health effects." A health assessment is also required to seek out and respond to community health concerns and review relevant health data. The Department will be sure to include information on authorization and purpose in future "public comment drafts" of public health assessments.

The Department disagrees with the commenter that Conclusions and Recommendations are not clearly set forth. We believe that they are clearly stated and documented in the body of the health assessment document. In order to increase their visibility, the recommendations have been summarized in the Summary section, which is the first section of the document.

The Department disagrees with the commenter's assertion that references were not used to verify statements in the document. Specific references are cited in the text as numbers in parentheses, and are numbered consecutively in the order in which they appear. The numbers correspond to the documents (listed under "References") in which the information supporting the preceding text is contained. This method is specified in ATSDR's "Public Health Assessment Guidance Manual" and is commonly used in scientific publications. The commenter may be confusing this scientific style with the method commonly used in the humanities which incorporates the use of footnotes (see for example, K.L. Turabian. A Manual for Writers of Term Papers, Theses, and Dissertations. 5th ed. The University of Chicago Press).

Comment: "Because all "available information" (p. 46, paragraph 1) was obviously not involved here, the entire report lacks objectivity and balance. It is therefore a dangerous report, not because it is flawed, but because it could lead to a wasting and misdirection of the state's health care resources in the future. Therefore, my first recommendation is that the report be done again by an independent group whose future employment does not depend on the conclusions and recommendations produced in the report." The commenter continues that the independent group should make use of additional information that includes Court transcripts and "independent environmental risk assessments done throughout the years."

MDE response: The Department disagrees with the assertion that the document lacks objectivity and balance, and that as a result, it could lead to a misdirection of heath care resources. Discussion and conclusions regarding the potential health risk posed by chemicals that were emitted from the facility during its operation and from the site following closure of the facility are based on available environmental sampling data. These data were interpreted using the current state of scientific knowledge on the potential effects posed by human exposure to the substances at the concentrations detected in the environment. Information provided by agencies such as ATSDR and EPA was used to assist in this interpretation. The future employment of the MDE employees involved in the completion of the health assessment is in no way affected by the conclusions and recommendations that are produced in the document.

The Department is confident that the PHA represents a thorough review of relevant information on the site and former facility, as indicated by a review of the references. Because of the past litigation involving the companies that occupied the site, the Department is in possession of a large volume of site-related materials, including Court transcripts, company files, etc. It was both impossible and unnecessary to review all of this information in the process of completing the PHA on the Spectron/Galaxy site. The public is encouraged to bring to the Department's attention any information that would result in the modification of any the conclusions or recommendations contained in the document.

The Department does not agree that any funds spent on additional site-related activities would be wasted or misdirected. We believe that any future expenditures for activities that address any of the recommendations contained in the document represent legitimate expenditures addressing important public health issues.

Comment: on Conclusion No. 1... "The times in the past when any level [of] airborne contaminants caused concern was in the late 1960's and early 1970's before Spectron, Inc. was organized. Thereafter air monitoring by the State's own Air Management Administration found no evidence of any 'urgent public health hazard for some exposed area residents'." "Coordination of MDE and EPA did not result in closure of the facility. Judge Kaplan of the Baltimore City Circuit Court shut Spectron down at the insistence of the MDE because Spectron could not set aside large amounts of money for closure demanded by Ronald Nelson of the Waste Management Division in case it was shut down. Before shut down, Spectron was in compliance with all laws and regulations."

MDE response: The Department has amended this conclusion to indicate the time frame that the description "urgent public health hazard" was referring to (i.e., at certain times during the 1960s and early 1970s). The categorization of airborne chemical concentrations as representing an "urgent public health hazard" during this period is based on the application of ATSDR definitions to airborne concentrations measured in 1970 (see Table 2A). Although there are no records of air monitoring conducted near the site in the 1960s, the Department believes that the results of the 1970 monitoring probably reflect conditions that at times existed during the 1960s.

Comment: on Conclusion No. 3... "There is no substance to the implication in this conclusion that off-site air contamination put area residents at risk." The commenter indicates that a former director of MDE's Air Management Administration stated that off-site air monitoring indicated that the air was "as good as any Maryland suburb." He further states that continuous off-site air monitoring conducted in 1987-1989 showed the air to be "free of contaminants."

MDE response: The Department believes that airborne concentrations of some constituents were sufficiently elevated during the 1960s and occasionally in the 1970s to put some area residents at increased risk of suffering adverse health effects. Important factors which contribute to this conclusion (in addition to the toxicity of individual contaminants), include the proximity of residences, the topography of the area, the presence of susceptible subpopulations, and the fact that people were exposed to a mixture of contaminants. Airborne concentrations of some chemicals (e.g., methylene chloride) were measured as recently as 1984 at levels exceeding current public health guidelines for ambient air.

We now have more data on "background levels" of VOCs such as those emitted during the operation of Spectron. The continuous monitoring of air in the vicinity of Spectron during the period of 1987-1989 revealed the presence of some contaminants in annual average concentrations exceeding those measured at an air sampling station in an industrial part of Baltimore in 1993. It is likely that the chemical concentrations measured in 1987-1989 were greater than those that would have been detected in most suburban air at the time, being unlikely that some of the substances would have even been detected in most suburban air. As is apparent from the measured concentrations of constituents that the air was certainly not "free of contaminants."

Comment: on Conclusion No. 4... "It would appear from this discussion that the residential wells sampled in 1992 were free of any contamination and that any follow-up to be done should be an evaluation of the lab that found contaminants that "may have been due to inadvertent contamination of water samples during handling and analysis"."

MDE response: It is not unusual for discrepancies to exist when split samples are analyzed for low level contamination. Factors suggesting that the findings could be indicative of actual contamination include the fact that the detected substances are present in high concentrations in the groundwater under the site and the fact that these chemicals are not common laboratory contaminants. Because of the potential for contaminants to migrate to residential wells near the site, the Department believes that it is important that the closest residential wells be monitored on a regular basis. A group of 21 wells have been identified which will be sampled by a contractor for the Responsible Party group on a semi-annual basis.

Comment: on Recommendation No. 1... "Why conduct soil gas monitoring if no present air contamination hazard exists?"

MDE response: This recommendation is based on the fact that chemicals can migrate through the pore spaces in soil, and in the process could enter the basements of nearby homes. This phenomenon sometimes occurs in structures located near landfills. Upon more careful evaluation of the topography of the area and the presence of Little Elk Creek, the Department considers it very unlikely that soil gases could pose a significant hazard to homes located adjacent to the site. The Department has removed this recommendation from the final document.

Comment: on Recommendation No. 4 (No. 3 in final document)... "What exposed and potentially exposed people? How exposed? Air? Water?"

MDE response: This refers to past and current residents of Providence Valley who were exposed to site-related contaminants from any exposure pathway and have questions related to these exposures. The vast majority of people would have been exposed to airborne chemicals.

Comment: on Recommendation No. 6 (Note: This recommendation was misnumbered in the public comment draft PHA; it should have been labeled as No. 5. This change has been made in the final document.)... "The same difficulties still exist. Too small a population, too result oriented. Even the results of the Love Canal epidemiology revealed no health effects, including cancer."

MDE response: Environmental epidemiology studies often result in negative findings, not necessarily because there is no "effect" from the exposure of interest (although this would be true in some cases), but because many studies of this type do not have the statistical power to identify a moderate effect, such as a doubling of the rate of a specific cancer. If the cancers of concern are relatively rare, the chances of observing an effect are increased. Some of the cancer mortality cases identified in the original study were diagnosed with relatively rare cancers in a category (i.e., lymphomas) that has been associated with solvent exposure, and these cases appeared to cluster near the site.

The Department believes that follow-up of the original cancer mortality study is warranted. The use of scientifically valid methods to conduct a follow-up study should address any concern that it would be "result-oriented."

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