PUBLIC HEALTH ASSESSMENT
EGG HARBOR TOWNSHIP, ATLANTIC COUNTY, NEW JERSEY
This response summary represents those comments and reactions to the Public Health Assessment for the Delilah Road Landfill site received by the New Jersey Department of Health during the public comment period which occurred from March 28, 1994 through April 29, 1994. In some cases similar commentary was received from various sources, while other concerns were expressed by individuals or groups. Comments and concerns have been grouped by content where possible and are followed by the consequent response.
Comments were received from a representative of the responsible parties (RPs). The comments expressed general concurrence with the conclusions of the Health Assessment, but did offer input with regard to the three specific issues listed below.
The RP representative expressed a lack of understanding as to why the DRL site would be considered for inclusion into the ATSDR benzene subregistry.
Benzene occurred in two potable wells associated with the DRL site above the ATSDR comparison value for the compound (1.2 ppb; CREG). Although site data do not conclusively demonstrate the source of the benzene is the DRL site, it is the policy of the ATSDR and the NJDOH to consider the public health implications of all contaminants found in the potable wells. As stated in the Toxicological Evaluation sub-section of the Public Health Implications section of the Health Assessment, calculated exposure doses were not at levels where non-carcinogenic adverse health outcomes were likely, and consequently, there resulted no apparent excess lifetime cancer risk. The decision by the ATSDR HARP committee to consider the DRL site for inclusion into the benzene subregistry was not based upon site management issues, but as a means to follow-up individuals known to have been exposed to the compound at levels exceeding ATSDR comparison values.
The RP representative expressed the opinion that the presence of mercury in potable wells is not site-related, and community concerns regarding this issue should be directed to another source.
The Remedial Investigation report (1) was cited by the RP representative as stating the DRL site was not the likely source of mercury contamination in the potable wells. Groundwater mercury data were not presented in the RI/FS; data were rejected because holding times were exceeded. Thus it was not possible to definitively conclude the origin of mercury in groundwater. Notwithstanding the origin of the mercury detected in the potable wells, it is the policy of the ATSDR and the NJDOH to evaluate all contaminants found in excess of ATSDR comparison values. The Health Assessment has been amended to reflect the possibility that the presence of mercury in potable wells may not be site related (see Conclusions).
The RP representative expressed an opinion that the institutional controls specified in the Record Of Decision for the DRL site would serve to interrupt any potential exposure pathways and adequately protect the public health.
The ATSDR and the NJDOH concur (as stated in the Conclusions section of the Health Assessment) that the remedial activities and institutional controls specified in the ROD, when implemented, are consistent with protection of the public health.