KEYSTONE METAL FINISHERS INCORPORATED (FORMER)
SECAUCUS, HUDSON COUNTY, NEW JERSEY
This Public Health Consultation has been prepared in response to a petition that wassubmitted to the Agency for Toxic Substances and Disease Registry (ATSDR) on October 4, 2000. The petitioner is concerned about possible exposure of nearby residents to chemicals that were usedat the former Keystone Metal Finishers, Inc. (KMF) facility located in Secaucus (Hudson County),New Jersey. From about 1947 through 1991, KMF operated as an electroplating business, utilizingpriority pollutant metals, acids, and volatile solvents. Chemicals and process equipment on the KMFproperty were removed by the USEPA in 1991-1992. On-site structures were demolished in 1994,when the property was legally transferred to the Town of Secaucus. The former KMF site is nowa public park.
No data are available regarding contamination of the soils or groundwater at the KMF siteand surrounding properties before 1986. On-site soils that had contained elevated concentrationsof metals (cadmium, chromium, nickel, and lead) and chlorinated solvents were removed in 1996. While it is possible that there may have been direct contact with, or inhalation/ingestion of, thesesoils on site property prior to 1991 when access to the site ceased, any exposure to site contaminantsis likely to have been minimal. There is no evidence that any contaminated soils were transportedbeyond the KMF boundary to the surrounding community.
A shallow ground water plume of trichloroethylene (TCE) and tetrachloroethylene(perchloroethylene) (PCE) extends from the former site, located at the intersection of HumboldtStreet and Raydol Avenue, about 600 feet (two blocks) north to Golden Avenue and Minnie PlaceSouth. However, since there are no potable wells in the vicinity of KMF, ingestion of contaminatedgroundwater may be eliminated as a completed exposure pathway. Several nearby irrigation wellswere identified, but these have been sealed, and there is no evidence of these wells having been used as a potable water supply.
Low concentrations (below health-based comparison values for drinking water) of PCE andcis-1,2-dichloroethylene were found in water samples taken from basement sumps in five nearbyresidences. No contaminants were detected in indoor air at the five residences. There is no evidencethat inhalation of indoor airborne volatile organic chemicals (VOCs) from residential sumps is acompleted exposure pathway under current conditions. Nevertheless, until the ground water VOCplume is remediated, the potential exists for exposure by inhalation to VOCs that may volatilize andenter nearby houses through basement sumps.
TCE and PCE have been (and are currently) present in the ground water at levels of publichealth concern. However, there is no evidence that any significant exposure to these chemicals hasoccurred, therefore, the public health hazard category is "No Public Health Hazard".
The New Jersey Department of Health and Senior Services (NJDHSS), under a cooperativeagreement with the federal Agency for Toxic Substances and Disease Registry (ATSDR), has beenpetitioned to evaluate the potential for exposures to chemicals that may be associated with the(former) Keystone Metal Finishers (KMF) site, located in Secaucus (Hudson County), New Jersey. This Health Consultation will (1) review and summarize the known environmental data for thefacility, and (2) address community health concerns regarding potential past, present, and futureexposure to contaminated soils and groundwater from the KMF site. The results of recent indoor air testing of several nearby homes will also be reviewed.
The Keystone Metal Finishers facility (40 47' 14'' North, 74 3' 39" West) was anelectroplating plant located on a 1.3 acre parcel ofland (Block 93, adjacent Lots 1 and 21) at theintersection of Humboldt Street and Raydol Avenuein Secaucus (Hudson County), New Jersey (see inset). The site contained a one-story brick warehouse andloading dock. Other structures on the propertyincluded a garage and storage shed. A 1,500 gallonabove ground tank that had apparently containedtrichloroethylene was adjacent to the warehouseloading dock. A 2,000 gallon underground storagetank for fuel oil was near the northeast corner of thewarehouse building. The property is located in aresidential area. The nearest residence wasapproximately 50 feet from the former facility. Aschool, hospital, retail stores, professional buildings,a municipal building, and a shopping center arelocated within one mile of the former site (see Figure1). In 1993, approximately 6,100 persons livedwithin one mile of the site (NJDEP, 1993).
The property is presently being used as anopen space park named Fountain Park. The two lotshave been completely re-landscaped, so very little vegetation from the former KMF site remains. The site was backfilled with imported fill, and then re-graded and seeded. The surface grade levelof the former site was raised by about 1 to 4 feet above the surrounding area. The park consists ofa large landscaped lawn, several garden settings, and planted trees. A well-defined drainage ditch(swale) meanders through the park in a southwest-northeast direction along the eastern portion ofthe site to collect surface water runoff. There is a small area of man-made herbaceous wetlandsrunning along a fence line on the eastern border of the park. Sewer and sanitary sewer systems arelocated beneath Humboldt Street adjacent to the former site.
Keystone Metal Finishers operated from 1947 to 1960 as a metal plating facility. In the1950s, the Town of Secaucus was involved in litigation with the owner of the property in an attemptto ban the operation of the plating facility in a residential area. The litigation was not successful, butapparently a settlement was reached whereby the facility could continue to operate as it was, i.e., ina non-conforming use, but that it could not expand. The large lot on the Humboldt Street side, i.e.,Block 93, Lot 1, was re-zoned as residential, and the property could only be utilized for housing inthe future (see Figure 2).
In 1960, ownership of the property changed, and the site activities were modified to includeanodizing, tin-nickel plating, and electroless nickel plating. These processes utilized: sulfuric, hydrochloric, and nitric acids; caustic soda; cyanides; volatile organic chemicals (VOCs), including trichloroethylene (TCE), and perchloroethylene (PCE); and metals, including tin, nickel, cadmium,and chromium. The factory remained in operation with a decline in business until June 1991.
In 1986, an environmental investigation of the KMF site was conducted that showedcontamination of on-site soils and shallow groundwater. Three shallow monitoring wells (MW1,MW2, and MW3) were installed on site property as part of the site evaluation (GM, 1987).
In 1990, KMF was cited by NJDEP under the provisions of New Jersey Pollutant DischargeElimination System (NJPDES) for excessive industrial discharge of cadmium and nickel to the waste water treatment plant, i.e., sanitary sewer system, operated by the Secaucus Municipal UtilityAuthority.
In 1991, the owner was issued eight summonses by the Secaucus Health Department forfailure to maintain the property. The Town of Secaucus was in the process of foreclosure due tofailure to pay property taxes when the owner died in June 1991. The property was entered byrepresentatives of the Secaucus Health Department and the New Jersey Department ofEnvironmental Protection (NJDEP), who identified potential environmental and health hazards thatwere associated with the improper on-site storage of process chemicals. Due to the hazardoussituation, the United States Environmental Protection Agency (USEPA) was notified, and a chain-link fence that surrounded the property was installed.
In September 1991, representatives of the Hudson Regional Health Commission (HRHC),NJDEP, and USEPA conducted a detailed inspection of the KMF site. There had apparently beenlittle on-site activity for several years, and the property was in a state of disrepair. The dilapidatedbuilding contained approximately 15 process vats that held rain water and plating solutions (HRHC,1991a). The building also contained 35 - 40 drums (including a 30 gallon drum of sodium cyanide),a number of carboys (including a 5 gallon container of cadmium fluoroborate), and other smallcontainers. A variety of chemicals, including acids (sulfuric, phosphoric, and hydrochloric), andmetals (copper cyanide, nickel chloride, tin chloride) were found in the building. The soil basement,which initially could not be accessed since it was flooded, held additional containers. Two aboveground storage tanks (one of which had apparently previously contained trichloroethylene) werelocated near the building. An underground storage tank that contained fuel oil was found in frontof the main building.
Removal actions commenced in September 1991, and, by September 1992, all chemicals andassociated process equipment had been removed from the site. The removal actions are documentedin a series of 16 Pollutant Reports (USEPA, 1992) that describe the nature of the contaminants thatwere found on-site. The underground storage tank, which contained approximately 1,200 gallonsof fuel oil, was emptied in 1992. USEPA turned over control of the former KMF site to the Townof Secaucus in September 1992.
In April 1994, after receiving funding from the USEPA, the Town of Secaucus continuedremedial activities at the site, including abatement of asbestos-containing materials on the boiler andassociated piping, removing the 1,500 gallon underground storage tank, and demolishing all on-sitestructures. In December 1994, the Superior Court of New Jersey, Chancery Division, HudsonCounty, officially turned over title for the property to the Town of Secaucus.
In 1996, PMK Group was contracted by the Town of Secaucus to delineate the extent ofcontamination of the soils in the former main processing area. Approximately 110 cubic yards ofPCE-contaminated soils, and about 390 cubic yards of metals-contaminated soils were removed inOctober 1996.
In 1998, the property of the former KMF site was turned into a municipal open space park(Fountain Park).
A chronology of significant events related to the former Keystone Metal Finishers plant siteis given in Table 1.
In 1991, the USEPA requested that the ATSDR develop a long-term health risk assessmentfor the residences surrounding the site. In a verbal consultation dated November 1, 1991, followedby a written consultation (ATSDR, 1992), ATSDR concluded that the site was a fire and explosionthreat, i.e., incompatible chemicals (cyanides, acids and bases) were stored together in an unsecuredbuilding, and an imminent health threat, i.e., the site was unfenced. ATSDR recommended thataccess to the site be restricted, that all hazardous materials be removed, that the extent of migrationof contaminants be delineated, and that the existence of any potable wells in the area be determined. ATSDR also recommended that the extent of on- and off-site contamination be better characterized. This evaluation was based on the inventory of materials on site at the time, on the analysis ofgroundwater sampling in 1986, and on the preliminary results of two residential basement sumpwater samples obtained in September 1991 (ATSDR, 1992).
No other health assessment activities have been conducted by ATSDR at the (former)Keystone Metal Finishers site.
Local residents are concerned about possible exposure to site contaminants (including metalsand chlorinated solvents) during the period before the site underwent removal actions in 1991. Residents are also concerned about exposure to the plume of chlorinated solvents that currentlyexists in the ground water beneath the property and extends beyond site boundaries. There is alsoconcern about cancer and other possible health effects that may result from exposure to site-relatedchemicals. In addition to possible direct contact with, and ingestion of, contaminants, exposure tothese chemicals could occur through inhalation of VOCs that may have volatilized into residencesthrough basement sumps. These concerns led to a petition to ATSDR for a Public HealthConsultation to evaluate the potential for exposure.
In order to fully evaluate community concerns, a site visit to the KMF site was conductedby representatives of the NJDHSS and ATSDR on March 27, 2001. A meeting with the petitionerand local residents was also held to gather information and discuss public health concerns and health assessment procedures.
Several sampling episodes were conducted between 1986 and 2000 to determine thecontaminants that were present on and beneath the KMF site. Cadmium, chromium, lead, and nickelhad been used in the various metal plating processes, and chlorinated VOCs, including TCE andPCE, were used as solvents and degreasers. The concentrations of contaminants that were found inthe samples will be described, and potential human exposure pathways will be evaluated. Table 2presents the current guidelines and cleanup standards for the chemicals that have been identified atthe site.
On-Site Shallow Soil and Groundwater - 1986
Contamination of soils on, and shallow groundwater beneath, the KMF property has beenknown since March 1986, when an environmental firm was retained by the owner of KMF toevaluate the KMF facility. The principal objectives of the investigation were to: (1) develop anassessment of soil and ground water quality conditions at shallow depths underlying the site; and(2) develop recommendations for areas of possible environmental concern (GM, 1987).
In the course of the investigation it was noted that three deep wells had been installed on-site to provide water for site operations. These wells were apparently sampled several times in the1950s, but the results of the analyses are not known. However, since the wells were drilled to thedeep rock aquifer (about 300 feet below surface level), they were not believed to be relevant to thequality of the shallow ground water. During the 1986 investigation, one of the supply wells, locatedinside the main building, was found not to be in service. The other two wells were located, but notsampled at that time.
In October 1986, three shallow (16-18 feet deep) monitoring wells were installed tocharacterize the ground water beneath the site, i.e., MW1, representing the "background" locationat the southeast corner of the site; MW2, located near the underground storage tank at the front ofthe building; and MW3, located near the above ground storage tank and loading dock at the rear ofthe building (GM, 1987). The water table was found to be from 0 to 3.5 feet below the groundsurface. Concentrations of Total Petroleum Hydrocarbons (TPHC) taken by organic vapor analyzer(OVA) during the drilling were 0-20, 0-15, and 0-60 ppm, for MW1, MW2, and MW3, respectively. Aqueous samples taken from MW3 on November 21, 1986 were found to contain 40 ppb cyanide,200 ppb fluoride, 1,400 ppb PCE, 47 ppb TCE, 53 ppb trans-1,2-dichloroethylene, and 12 ppb vinylchloride. The concentration of total chromium (Cr) in MW3 was 195 ppb (hexavalent-Cr was 186ppb). Apparently, no other priority metals were analyzed at that time. As shown in Table 3, theconcentrations of PCE, TCE, and total chromium in MW3 exceeded current ATSDR ComparisonValues (CVs). (See Appendix A for a description of ATSDR Comparison Values.) Theconcentrations of PCE in MW1, and PCE and TCE in MW2 also exceeded current CVs.
Twelve shallow soil boring samples were taken on site property in October and November1986 during the investigation. Analysis showed elevated concentrations of several contaminants asfollow (maximum value): cadmium (58 ppm), chromium (total 4,300 ppm, hexavalent 560 ppm),nickel (5,200 ppm), cyanides (120 ppm), PCE (7,200 ppm), and PCBs (147 ppm) (see Table 4). Themaximum concentrations were found in a sample taken from soils within the footprint of thebuilding. The concentrations of cadmium, total chromium, lead, and nickel that were found inseveral of the samples exceed NJDEP Soil Cleanup Criteria and current ATSDR CVs.
Soil and Ground Water Sampling 1991-1992
In September 1991, at the time of the initial site investigation, sumps in two residences acrossthe street from the former KMF site (one each on Raydol Avenue and Humboldt Street) weresampled and analyzed for metals, cyanide, and chlorinated VOCs. No VOCs were detected in eithersample. Low levels of chromium, copper, and zinc were found in the Raydol Avenue sample (seeTable 5). Arsenic (65 ppb), lead (41.5 ppb), and cyanide (43 ppb) were also found in the same sump. Only chromium (22 ppb) and zinc (52 ppb) were found in the Humboldt Street sample (HRHC,1991b).
In December 1991, during Phase 2 of the removal actions, USEPA's Technical AssistanceTeam (TAT) sampled on-site soils and groundwater for metals and VOCs. The soil was found tocontain elevated levels of cadmium, chromium, and lead. The ground water samples revealedconcentrations of cadmium, chromium, lead, nickel, and TCE in excess of NJDEP cleanupguidelines.
In March 1992, the USEPA TAT conducted soil screening for polychlorinated biphenyls(PCBs) near three on-site ground level transformers. All test results were negative.
In May 1992, the USEPA TAT collected seven wood floor samples and two samples ofstanding water in the basement of the KMF building. The wood samples were analyzed for ToxicityCharacteristic Leaching Procedure (TCLP) chemicals and cyanide, and the water samples wereanalyzed for metals, cyanide, and VOCs. The sample results revealed contamination of the woodflooring with barium, cadmium, chromium, lead, nickel, silver, zinc, and cyanide. The standingwater results revealed contamination with arsenic, barium, cadmium, chromium, copper, lead, nickel,zinc, TCE, PCE, and cis 1,2-dichloroethylene.
In December 1992, the TAT sampled two of the previously installed on-site monitoringwells, and found concentrations of cadmium, chromium, lead, nickel, and tetrachloroethylene (PCE)in excess of NJDEP Groundwater Quality Standards. Four on-site soil samples were taken at the rearof the facility, one of which showed chromium (valence not indicated) to be present at 595 ppm (NJDEP, 1993).
NJDEP Preliminary Assessment - 1993
In April 1993, the New Jersey Department of Environmental Protection (NJDEP) conducteda Preliminary Assessment of the site (NJDEP, 1993). The report summarized the data that weregathered during the 1986 on-site investigation, the data from USEPA, the TAT, and their contractors,and NJDEP's characterization of the wells that existed within four miles of the site. The reportconcluded that additional sampling would be required to adequately characterize the site conditions,and recommended that an investigation be conducted under the provisions of the ComprehensiveEnvironmental Response, Compensation, and Liability Act (CERCLA), i.e., Superfund.
On-Site Soils and Shallow Groundwater - 1995
In 1995, an investigation of the soils in the vicinity of the former KMF structure wasconducted by the PMK Group, Inc., under contract to the Town of Secaucus. Forty-nine soil boringswere analyzed for priority pollutant metals, and it was found that NJDEP Soil Cleanup Criteria hadbeen exceeded. In addition, the 1986 MW2 (MW1 and MW3 had been destroyed during demolitionof the building in 1994), was analyzed for VOCs and pollutant metals, but the analyzedconcentrations did not exceed Groundwater Quality Standards criteria (PMK, 1998).
Delineation of Soil and Groundwater Contamination - 1996 - 1998
In February 1996, PMK Group expanded the search for contaminated soils in the vicinity ofthe former KMF building. Thirty-nine soil borings were taken, and samples were taken fromselected depths within each of the borings. Nine of the exploratory soil borings were taken in theimmediate vicinity of the former dry well and at the locations of the previously identified PCE-contaminated soils. Seven soil samples were analyzed for PCE. Laboratory analysis showed thatsix of the thirty-nine soil boring samples (at about 6-7 feet below grade) contained cadmium(maximum concentration 5.4 ppm) at concentrations that were above NJDEP's Residential DirectContact Soil Cleanup Criteria (RDCSCC), which was 1 ppm at the time, but has since been revisedto 39 ppm. Other targeted priority pollutant metals were below applicable RDCSCC. Elevatedconcentrations of nickel and chromium were found in the soils within the footprint of the formerbuilding. During the investigation a previously unknown dry well was located within the buildingthat was contaminated with PCE, with a maximum concentration 1,200 ppm (PMK, 1998).
As a result of the soil contamination investigation, three new on-site monitoring wells (MW1,MW2, and MW3) were installed (screened from just below the clay layer, at about 10 feet, to depthsof 18-19 feet) in January 1997 and tested for VOCs. In addition, twelve Hydropunch™ (HP) testexplorations were made in May 1997 to delineate the extent of the plume of TCE and PCE in thegroundwater (PMK, 1998). PCE was found in HP4 (intersection of Raydol Avenue and HumboldtStreet) at 2,000 ppb, and TCE was found in HP9 (at southeast corner of site) at 88 ppb. In addition,1,2-DCE was found at HP9 at 140 ppb.
As a result of the soil and groundwater investigation, ground water characterization wasextended to further delineate on- and adjacent off-site contamination. In June 1998, PMK installedfive additional monitoring wells (MW4 through MW8), two piezometers, and one air sparging wellon and in the vicinity of the property. MW4 and MW5 were located on-site, and MW6 throughMW8 were off-site. The air sparging well (AS1) and the piezometers (PZ1 and PZ2) were installedwithin the on-site source area. In October 1999, three additional monitoring wells were installed,with MW9 onsite, and MW10 and MW11 offsite along the main axis of the groundwater plume (see Figure 2).
Residential Soil Gas, Sump, and Irrigation Wells - 1999
In 1999, PMK performed a series of investigations to evaluate possible off-site migration ofsoil and ground water contaminants. Sump pits, soil, irrigation wells, and groundwater at nearbyresidences were sampled to delineate the extent of the off-site chlorinated solvents plume (PMK,2000a). PMK also performed a subsurface investigation along the storm sewer pipeline that runsbeneath Humboldt Street along the northern site boundary. Test borings were also taken near thestorm drain sections on Raydol and Golden Avenues.
A shallow soil excavation, i.e., the installation of a porch foundation, was sampled onHumboldt Avenue across the street from the KMF site in June 1999. No VOCs were detected.
In June 1999, four test pits (from 4 to 8 feet below the surface) were dug on HumboldtAvenue along the northern boundary of the former KMF site in conjunction with the plannedimprovement of the storm sewer line by the Town of Secaucus. PCE, TCE, and 1,2-DCE werefound in excess of the NJDEP Impact to Groundwater Soil Cleanup Criteria (IGWSCC) in the testpit closest to the former KMF site (TP2; depth 4.5 -5 feet).
In July 1999, sump water was sampled and analyzed from 15 residential properties near theformer KMF site. Chloroform and bromodichloromethane were found in two of the sumps atconcentrations that exceed NJDEP Groundwater Quality Criteria (but not ATSDR CV). MTBE wasalso found at low levels in several of the sumps. However, these chemicals are not related to thechlorinated solvent plume from KMF.
Soils from 17 residential properties near the former KMF site were sampled at 2-2.5 and 11-12feet below the surface in August, 1999. No VOCs were found in excess of the NJDEP IGWSCC.
In August 1999, four previously unknown private irrigation wells located on Golden Avenueand Minnie Place South were analyzed for VOCs. PCE and TCE were found in excess of NJDEPGroundwater Quality Criteria or ATSDR CV in one of the wells on Golden Avenue. Low levels ofMTBE (in three wells, maximum 8.2 ppb) and cis1,2- dichloroethylene (one well, 1.7 ppb) were alsofound. The wells were sealed and abandoned in January 2000.
In October 1999 and January 2000, test borings were taken at six locations along the stormsewer near the storm water pump house on the west end of Golden Avenue and Raydol Avenue. PCEwas identified in four of the test borings at levels above the NJDEP Groundwater Quality Criteria and ATSDR CV.
Delineation of Ground Water Contamination Plume - 2000
In January 2000, the groundwater plume in the vicinity of the former KMF site was delineatedby sampling the eleven on- and off-site monitoring wells and the air sparging well. The results of thissampling episode, presented in Table 6, show concentrations up to 8,404 ppb total VOCs (TVOC)(maximum at the former location of the KMF building). Figures 3 and 4, respectively, show that PCEand TCE were found at concentrations above the New Jersey Groundwater Quality Criteria underresidential properties as far as about 600 feet to the north of the site. The samples were not analyzedfor metals.
Residential Indoor Air and Sump Water - October 2000
In September 2000, PMK identified approximately 40 properties that were determined to bepotential locations for sampling of ground water in basement sumps, and indoor air (PMK, 2000b). In October 2000, indoor air and water in basement sumps were sampled and analyzed for VOCs infive residences near the former site property that were considered most likely to be contaminated. As shown in Table 7, low levels of PCE (1 residence sump) and 1,2-DCE (two residence sumps) werefound. As shown in Table 8, no VOCs were found in the air in any of the sampled residences (PMK,2000c)
To determine whether residents near the former Keystone Metal Finishers site were, are, ormay be exposed to contaminants which may have emanated from the former KMF site, the ATSDRand the NJDHSS evaluate the five environmental and human components which are necessary tocomplete an exposure pathway. The five elements of a completed exposure pathway are: (1) a sourceof contamination; (2) transport of the contaminant through an environmental medium; (3) a pointof human exposure; (4) a route of human exposure; and (5) a receptor, i.e., exposed, population.
The ATSDR and the NJDHSS categorize exposure pathways into three groups: (1) completedpathways, that is, those in which it is likely that some persons in the receptor population wereexposed, are being exposed, or will be exposed; (2) potential pathways, that is, those in whichexposure might have occurred, may be occurring , or may yet occur; and (3) eliminated pathways, thatis, those which can be eliminated from consideration because one of the five elements is missing andwill never be present, or in which no contaminants of concern can be identified. Completed orpotential pathways may be interrupted by remedial actions or public health intervention.
Groundwater in the Vicinity of the KMF Site
The Brunswick Formation, a mixture of shale, sandstone, argillite and conglomerate,comprises the geologic formation that provides groundwater in this area of northern New Jersey. Water yields are almost exclusively from cracks in the rocks of the formation. The water is generallyfree to move in any direction and seek a level determined by local factors affecting charge andrecharge. The water table beneath the former KMF site, located about 2 miles from the HackensackRiver to the northwest and about 4 miles from the Hudson River to the southeast, is very shallow,typically from zero to three feet below the surface. The so-called Meadowlands, a large swampy areain this part of New Jersey, is located about one mile to the south of the KMF site. Bedrock is about ten to forty feet below existing surface grade.
Ground water in the vicinity of the site is not used for public potable water supply. Instead,United Water Company supplies potable water to Secaucus from surface water sources that areoutside the city, including Oradell Reservoir in Wanaque, and Woodcliff Lake Reservoir in NewYork (PMK, 2000c). According to NJDEP, no public supply wells exist within four miles of the site(NJDEP, 1993).
A survey conducted by NJDEP in 1993 revealed that there were approximately twentyindustrial or irrigation wells located between two and four miles from the site. The majority of thesewells were screened in the deep rock aquifer from 200 to 500 feet below the surface (NJDEP, 1993).
The records of the NJDEP Bureau of Water Allocation indicated that, as of 2000, nine wells,all of which were between 150 and 312 feet deep, were located within one mile of the site, includingfour industrial wells (three of which were located on the KMF site), three domestic wells, onecommercial well, and one unidentified well (PMK, 2000c). Two of the commercial/industrial wellswere in service as of 2000.
Since that time, four additional, unpermitted residential irrigation wells were identified withinone mile of the site; these wells were sampled (one showed PCE and TCE at concentrations abovethe Groundwater Quality Criteria), and they were sealed and abandoned in January 2000.
Several human exposure pathways are, have been, or may be possible in the vicinity of theKMF site during and since its operation. These include: (1) ingestion of contaminated groundwater;(2) direct contact with, or inhalation/ingestion of, contaminated surface soils; and (3) inhalation ofVOCs from contaminated ground water that volatilizes and enters residences through indoor sumps.
No data are available regarding contamination of the soils or groundwater at the KMF site andsurrounding properties before 1986. As a result, it is not possible to determine whether there has beenany prior exposure to any chemicals on the site. However, since all potable water is supplied fromsources outside the area, ingestion of contaminated groundwater may be eliminated as a completedexposure pathway in the present.
Analyses of on-site surface soils showed that elevated concentrations of cadmium, chromium,lead, and nickel were present on site property in 1986 (these were primarily found within the footprintof the KMF building). Access to site property was restricted in 1991, so the potential for exposureto contaminated soils ceased then. The contaminated on-site soils were removed in October, 1996,and the property was then backfilled with one to four feet of clean backfill, and landscaped. Whileit is possible that there may have been direct contact with, or inhalation and/or ingestion of, surface soils on site property prior to 1991, exposure to site contaminants in soils is unlikely. There is noevidence that contaminated soils were transported beyond the original site boundaries.
One exposure pathway, i.e., the inhalation of VOCs that volatilized from contaminatedgroundwater in an indoor sump, presents the potential for a completed exposure pathway in the future. Sampling (see Tables 7 and 8) showed that no VOCs were present in the indoor air of the fiveresidences that were tested in November 2000. Very low concentrations of PCE and cis 1,2-DCE (atthe limit of detection) were found in two residential sumps along Humboldt Avenue and GoldenPlace. However, neither chemical was detected in the basement or living space of any of the fiveresidences. Nevertheless, it is possible, although unlikely, that, if left unremediated, the levels ofTCE and PCE currently found in the shallow groundwater plume (shown in Figures 3 and 4) mightvolatilize and diffuse into indoor air in the basements of residences.
As discussed above, exposure to the contaminants that have been found in the vicinity of theformer KMF site, namely TCE and PCE, is unlikely. None of the operating wells in the vicinity ofthe former KMF site are used to supply potable water. The unpermitted irrigation wells that wereidentified at several residences near the site have been sealed. Sampling of water from indoor sumpshas shown very low concentrations of VOCs; no TCE or PCE were found in the indoor air of anyof the five nearby residences that were sampled. Nevertheless, it is possible that, when the water tableis high and water enters residences through basement sumps, VOCs could volatilize and diffusethroughout the residences. If so, exposure to these chemicals might occur through inhalation.
TCE is a nonflammable, colorless liquid at room temperature, and it has a somewhat sweetodor and a sweet, burning taste. It is a solvent that is commonly used as a degreaser for metals. PCEis also a nonflammable liquid at room temperature, and has a sharp sweet odor. It is widely used todry clean fabrics and in metal degreasing operations. Both TCE and PCE are used in a variety ofconsumer products, such as paints and glues (TCE), and cleaners, lubricants, and spot removers(PCE).
The toxicologies of TCE and PCE have been summarized by ATSDR (ATSDR, 1997a;ATSDR 1997b). Epidemiological studies of occupationally-exposed workers suggest an associationbetween long-term inhalation exposure to high levels of TCE and increased risk of liver and biliarytract cancer and non-Hodgkin's lymphoma (IARC, 1995; ATSDR, 1997a). Increased risks ofesophageal cancer, cervical cancer, and non-Hodgkin's lymphoma have been observed in workersexposed to high levels of PCE.(IARC, 1995; ATSDR, 1997b). As noted in Table 2, the health-basedComparison Values and carcinogenic categories of TCE and PCE are currently under review byATSDR. However, there is no evidence of exposure to either contaminant. Neither of these specieswas found in the indoor air of the tested residences in the vicinity of the former KMF site. Consequently, any potential adverse health effects, such as on the central nervous system or cancer, are not likely to have occurred.
A draft of this (former) Keystone Metal Finishers Public Health Consultation was releasedfor public comment during the period from November 6 to December 6, 2002. No comments were received.
The NJDHSS and ATSDR have concluded that, as discussed below, there is currently NoPublic Health Hazard to residents in the vicinity of the former Keystone Metal Finishers site. (SeeAppendix B for the definitions of ATSDR Public Health Hazard categories.) This health hazardcategory has been selected because there is no evidence of a completed human exposure pathway. However, this health assessment hazard category may be re-evaluated and/or changed if furtherinformation becomes available, particularly from additional sampling of indoor air and sumps.
Based on the data that have been gathered through sampling and analysis of shallow soils and groundwater on and near the former KMF site, it may be concluded that:
- Exposure to metals and VOCs that may have been transported from theKMF site to nearby residences in the past is unlikely to have occurred at levels ofpublic health concern;
- There is currently no pathway that would lead to human exposure tometals in soils on the KMF site property. Access to surface soils on the property thatwere contaminated with metals was terminated in 1991, and the soils were removedin October 1996. One to four feet of clean soils were subsequently imported to coverthe original KMF site property. The property has been re-zoned, landscaped, andturned into a public open space park (Fountain Park). There is no evidence ofcontaminated soils having been transported beyond the original site boundaries;
- Based on recent (1999-2000) analyses of on- and off-site monitoringwells, it has been shown that chlorinated VOCs have migrated to the north from theformer KMF site. PCE and TCE are currently present at levels of public healthconcern in shallow groundwater (less than 20 feet) beneath approximately 17residences located on Irving Place, Humboldt Street, Golden Avenue, and MinniePlace South. However, there is no evidence of any human exposure; and
- Analyses of groundwater in residential sumps in 1999-2000 show lowconcentrations of chlorinated VOCs (at the limit of detection, below NJDEPGroundwater Quality Criteria and ATSDR CVs). No target VOCs were found in theindoor air of the tested residences. Although the potential exists for a completedexposure pathway, there is no evidence that inhalation of indoor airborne VOCs fromresidential sumps is a completed pathway under current conditions.
Since a plume of TCE and PCE currently exists in the shallow groundwater on and near theformer KMF site (now Fountain Park), it is recommended that no potable wells be permitted in thevicinity of the former KMF site property.
Sampling of residences along Irving Place, Humboldt Avenue, Golden Avenue, and MilliePlace South should be conducted for chlorinated VOCs, specifically PCE, TCE, chloroform, 1,2-DCE, and VC, under conditions when the water table is high, i.e., when residential basements mayflood, to determine the extent of potential VOC volatilization. In addition, the existing former supply well on the site property should also be sampled and analyzed for VOCs.
The Public Health Action Plan (PHAP) for the former Keystone Metal Finishers site containsdescriptions of the actions to be taken by ATSDR and/or NJDHSS at or in the vicinity of the site. Thepurpose of a PHAP is to ensure that a Health Assessment/Consultation not only identifies publichealth hazards, but provides a plan of action designed to mitigate and prevent adverse human healtheffects resulting from exposure to hazardous substances in the environment. The environmentalsampling data and remedial activities that have been conducted have been evaluated within thecontext of human exposure pathways and other relevant public health factors. Included is acommitment on the part of ATSDR and NJDHSS to monitor this plan to ensure that the plan isimplemented. ATSDR will provide follow-up to this PHAP, outlining the actions which have beencompleted, and those actions in progress, as needed. The public health actions to be implemented byATSDR/NJDHSS are as follows:
A site visit and meeting with concerned residents was held to discuss and assess communityconcerns.
- ATSDR and NJDHSS will evaluate the results of any additional sampling episodes.
- NJDHSS will provide a copy of this document to all concerned residents in the vicinityof the former KMF site.
- NJDHSS will provide a Citizen's Guide to all who are interested in the KMF site.
- ATSDR and NJDHSS will coordinate as deemed necessary with the appropriateenvironmental agencies to develop plans to implement the recommendations contained in thisdocument.
This Health Consultation was prepared by the New Jersey Department of Health and SeniorServices (NJDHSS) under a cooperative agreement with the Agency for Toxic Substances andDisease Registry (ATSDR). It has been produced in accordance with approved methodology and procedures existing at the time the Health Consultation was begun.
Gregory V. Ulirsch
Technical Project Officer
Superfund Site Assessment Branch (SSAB)
Division of Health Assessment and Consultation (DHAC)
The Division of Health Assessment and Consultation, ATSDR, has reviewed this Health Consultation and concurs with its findings.
Lisa C. Hayes
for Roberta Erlwein
Chief, SPS, SSAB, DHAC
Preparer of Report:
Bruce E. Wilcomb, Ph.D.
Health Assessment Project
Hazardous Site Health Evaluation Program
Consumer and Environmental Health Services
New Jersey Department of Health and Senior Services
ATSDR Regional Representative:
Regional Representative, Region II
Office of the Assistant Administrator
ATSDR Technical Project Officer:
Gregory V. Ulirsch
Technical Project Officer
Superfund Site Assessment Branch (SSAB)
Division of Health Assessment and Consultation (DHAC)
Any questions concerning this document should be directed to:
Health Assessment Project Manager
Consumer and Environmental Health Services
New Jersey Department of Health and Senior Services
3635 Quakerbridge Road
PO Box 369
Trenton, NJ 08625-0369
ATSDR, 1992. ATSDR Record of Activity, Subject: Keystone Metals Refinishing, January 6, 1992
ATSDR, 1997a. Toxicological Profile for Trichloroethylene (Update), ATSDR, September 1997
ATSDR, 1997b. Toxicological Profile for Tetrachloroethylene (Perchloroethylene) (Update),ATSDR, September 1997
GM, 1987. Assessment of Soil and Shallow Ground Water Conditions at the Keystone MetalFinishers, Inc. Facility in Secaucus (Draft), New Jersey, Geraghty & Miller, February 1987
HRHC, 1991a. Site Visit Report, Keystone Metal Finishers (NJDEPE Case Number 91-09-09-0956),Hudson Regional Health Commission (HRHC Case Number 91-09-09-S-16), September 9, 1991
HRHC, 1991b. Groundwater Sampling from Residential Sumps near Keystone 9/27/91, HudsonRegional Health Commission, September 27, 1991
IARC, 1995. IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. Dry Cleaning,Some Chlorinated Solvents, and Other Industrial Chemicals, Volume 63, World Health Organization,International Agency for Research on Cancer, Lyon, France
NJDEP, 1993. Preliminary Assessment Report for Keystone Metal Finishers, Inc, NJDEP Bureauof Field Operations, April 21, 1993
PMK, 1998. Remedial Investigation/Action Report, Former Keystone Metal Finishers Facility, 22Raydol Avenue, Secaucus, New Jersey, PMK Group, Inc., July 1998
PMK, 2000a. Remedial Investigation/Remedial Action Workplan Report (RI/RAW), Former KeystoneMetal Finishers Facility, 22 Raydol Avenue, Secaucus, NJ, Volumes 1 and 2, from PMK Group, toTown of Secaucus, NJ, July 6, 2000
PMK, 2000b. Letter, RE: Additional Remedial Investigation Receptor Evaluation and Sampling atResidences, Former Keystone Metal Finishers Facility, from PMK Group, to Town of Secaucus,New Jersey, September 5, 2000
PMK, 2000c. Letter, RE: Air and Sump Water Analytical Results -- Residences, Former KeystoneMetal Finishers Facility, from PMK Group, to Town of Secaucus, NJ, November 22, 2000
USEPA, 1992. USEPA Pollution Reports (16 reports), Keystone Metal Finishers, Secaucus, HudsonCounty, New Jersey, USEPA Region 2, dated November 15, 1991 through September 22, 1992
ATSDR's Comparison Values are media-specific concentrations that are considered to be "safe"under default conditions of exposure. They are used as screening values in the preliminary identification ofsite-specific chemical substances that the health assessor has selected for further evaluation of potential healtheffects.
Generally, a chemical is selected for evaluation because its maximum concentration in air, water, orsoil at the site exceeds one of ATSDR's Comparison Values. However, it cannot be emphasized stronglyenough that Comparison Values are not thresholds of toxicity. While concentrations at or below the relevantcomparison value may reasonably be considered safe, it does not automatically follow that any environmentalconcentration that exceeds a Comparison Value would be expected to produce adverse health effects. Indeed,the whole purpose behind highly conservative, health-based standards and guidelines is to enable healthprofessionals to recognize and resolve potential public health problems before they become actual healthhazards. The probability that adverse health outcomes will actually occur as a result of exposure toenvironmental contaminants depends on site-specific conditions and individual lifestyle and genetic factorsthat affect the route, magnitude, and duration of actual exposure, and not solely on environmentalconcentrations.
Screening values based on non-cancer effects are generally based on the level at which no healthadverse health effects (or the lowest level associated with health effects) found in animal or (less often)human studies, and include a cumulative margin of safety (variously called safety factors, uncertainty factors,and modifying factors) that typically range from 10-fold to 1,000-fold or more. By contrast, cancer-basedscreening values are usually derived by linear extrapolation with statistical models from animal data obtainedat high exposure doses, because human cancer incidence data for very low levels of exposure are rarelyavailable. Cancer risk estimates are intended to represent the upper limit of risk, based on the available data.
Listed and described below are the types of comparison values that the ATSDR and the NJDHSS usedin this Public Health Consultation:
Cancer Risk Evaluation Guides (CREGs) are estimated concentrations of contaminants in an environmentalmedium (such as drinking water) that are expected to cause no more than one excess cancer case for everymillion persons who are continuously exposed to the concentration for an entire lifetime (equaling a risk of1 x 10-6). These concentrations are calculated from the USEPA's cancer slope factors, which indicate therelative potency of carcinogenic chemicals. Only chemicals that are known or suspected of beingcarcinogenic have CREG Comparison values.
Environmental Media Evaluation Guides (EMEGs) and Reference Dose Media Evaluation Guides(RMEGs) are estimates of chemical concentrations in an environmental medium (such as drinking water) thatare not likely to cause an appreciable risk of deleterious, non-cancer health effects, for fixed durations ofexposure. These guides may be developed for special sub-populations such as children. EMEGs are basedon ATSDR's Minimal Risk Level (MRL) while RMEGs are based on the USEPA's Reference Dose (RfD).
Other health-based guides may also be used as Comparison Values, including drinking water Maximum Contaminant Levels (MCLs) established by the USEPA or the NJDEP.
|Category / Definition||Data Sufficiency||Criteria|
|A. Urgent Public Health Hazard |
This category is used for sites where short-term exposures (< 1 yr) to hazardous substances or conditions could result in adverse health effects that require rapid intervention.
|This determination represents a professional judgement based on critical data which ATSDR has judged sufficient to support a decision. This does not necessarily imply that the available data are complete; in some cases additional data may be required to confirm or further support the decision made.||Evaluation of available relevant information* indicates that site-specific conditions or likely exposures have had, are having, or are likely to have in the future, an adverse impact on human health that requires immediate action or intervention. Such site-specific conditions or exposures may include the presence of serious physical or safety hazards.|
|B. Public Health Hazard |
This category is used for sites that pose a public health hazard due to the existence of long-term exposures (> 1 yr) to hazardous substance or conditions that could result in adverse health effects.
|This determination represents a professional judgement based on critical data which ATSDR has judged sufficient to support a decision. This does not necessarily imply that the available data are complete; in some cases additional data may be required to confirm or further support the decision made.||Evaluation of available relevant information* suggests that, under site-specific conditions of exposure, long-term exposures to site-specific contaminants (including radionuclides) have had, are having, or are likely to have in the future, an adverse impact on human health that requires one or more public health interventions. Such site-specific exposures may include the presence of serious physical or safety hazards.|
|C. Indeterminate Public Health Hazard |
This category is used for sites in which "critical" data are insufficient with regard to extent of exposure and/or toxicologic properties at estimated exposure levels.
|This determination represents a professional judgement that critical data are missing and ATSDR has judged the data are insufficient to support a decision. This does not necessarily imply all data are incomplete; but that some additional data are required to support a decision.||The health assessor must determine, using professional judgement, the "criticality" of such data and the likelihood that the data can be obtained and will be obtained in a timely manner. Where some data are available, even limited data, the health assessor is encouraged to the extent possible to select other hazard categories and to support their decision with clear narrative that explains the limits of the data and the rationale for the decision.|
|D. No Apparent Public Health Hazard |
This category is used for sites where human exposure to contaminated media may be occurring, may have occurred in the past, and/or may occur in the future, but the exposure is not expected to cause any adverse health effects.
|This determination represents a professional judgement based on critical data which ATSDR considers sufficient to support a decision. This does not necessarily imply that the available data are complete; in some cases additional data may be required to confirm or further support the decision made.||Evaluation of available relevant information* indicates that, under site-specific conditions of exposure, exposures to site-specific contaminants in the past, present, or future are not likely to result in any adverse impact on human health.|
|E: No Public Health Hazard |
This category is used for sites that, because of the absence of exposure, do NOT pose a public health hazard.
|Sufficient evidence indicates that no human exposures to contaminated media have occurred, none are now occurring, and none are likely to occur in the future|
* Such as environmental and demographic data; health outcome data; exposure data; community health concerns information; toxicologic,medical, and epidemiologic data; monitoring and management plans.
|1947-1991||Operation of Keystone Metal Finishing plant as nickel plating facility|
|1960||Modification of site processes to include anodizing, and tin-nickel and electroless nickel plating|
|1987||"Assessment of Soil and Shallow Groundwater Conditions at the Keystone Metal Finishers, Inc. Facility" published by Geraghty & Miller|
|September 1991-September 1992||Removal actions by USEPA. Removal of hazardous materials and identification of on-site soil and groundwater contamination. Site turned over to Town of Secaucus|
|April 1993||Preliminary Assessment Report issued by NJDEP|
|September 1994||Memorandum of Agreement (MOA) approved by NJDEP for soil investigation and remediation of the site.|
|December 1994||Title for site turned over to Town of Secaucus by Superior Court of New Jersey Chancery Division for Hudson County|
|May 1995||Site Investigation Report issued by PMK|
|October 1995||MOA amended to include additional investigation and remedial action activities|
|November 1995||NJDEP approved scope of work for site investigation submitted with Hazardous Site Remediation Fund (HSRF) application|
|May-October 1996||Soil excavation and off-site disposal with post-excavation soil sampling and analysis to address metal and chlorinated solvent contamination source area|
|January 1997||Groundwater investigation including well installation, groundwater sampling and analysis|
|August 1997||HSDRF application submitted to NJDEP|
|February 1998||New Jersey Economic Development Authority (NJEDA) and NJDEP approved HSDRF grant|
|June 1998||Soil and groundwater investigation to delineate on-site and adjacent off-site contamination. 11 monitoring wells installed|
|July 1998||Remedial Investigation/Soil Action Report issued. Sampling and analysis of all existing wells|
|September 1998||NJDEP approved Remedial Investigation/Action Report|
|June 1999||Soil and groundwater investigation prior to rehabilitation of adjacent storm sewer system|
|June 1999-January 2000||PMK sample and analysis of sump pits, soil, groundwater, and irrigation wells at nearby residences|
|August 1999-October 1999||Addition groundwater investigation to delineate off-site extent of chlorinated solvents plume|
|September 1999-March 2000||Soil and groundwater investigation to assess if storm sewer pipe is acting a preferential migration pathway for PCE plume|
|January 2000||Groundwater sampling of all wells. Four residential irrigation wells abandoned|
|March 2000||On-site drainage swale and nearby sump pit sampled|
|August 2000||Request to ATSDR for Petitioned Health Assessment|
|October 2000||Sampling of indoor air and sump pits in 5 residences|
|Contaminant||NJDEP Groundwater Quality Standard (ppb)||Potable Water MCL (ppb)||ATSDR child,adult |
Drinking Water CV (ppb)
|NJDEP Residential Soil (ppm)||ATSDR |
Soil CV (ppm)
|Perchloroethylene (PCE)||1||1NJ||100*, 400*, UR||1(IGWSCC) 4(RDCSCC)||500, 7000RMEG|
|Trichloroethylene (TCE)||1||1NJ||UR||1(IGWSCCS) 23(RDCSCC)||UR|
|cis 1,2-dichloroethylene (1,2DCE)||10||70MCL||3000, 10000||1(IGWSCC) 79(RDCSCC)||600, 20000*|
|trans 1,2-dichloroethylene(1,2-DCE)||100||100MCL||2000, 7000||50(IGWSCC) 1000(RDCSCC)||400, 10000*|
|Vinyl chloride (VC)||5||2MCL||0.2, 0.7, 0.02CREG||2(RDCSCC) 10(IGWSCC)||1, 10, 0.3CREG|
|Cadmium (Cd)||10||5MCL||2, 7||39(RDCSCC)||10, 100|
|Nickel (Ni)||100||100LTHA||100LTHA||250(RDCSCC)||1000, 10000RMEG|
|Cyanide (CN)||200||200MCL||200LTHA||1100(RDCSCC)||1000, 10000RMEG|
IGWSCC - Impact on Ground Water Soil Cleanup Criteria
RDCSCC - Residential Direct Contact Soil Cleanup Criteria
NJ - New Jersey A280 Criteria
AL - Action Level
MCL - Maximum Contaminant Level
CREG - Cancer Risk Evaluation Guide
* - intermediate RMEG
CV - Comparison Value
RMEG - Reference dose Media Evaluation guide
UR - Under review
LTHA - Long Term Health Advisory
|Total Petroleum Hydrocarbons (TPHC)||ND(<0.21)||ND(<0.21)||ND(<0.22)||NE|
|Nitrogen (as ammonia)||ND (<0.05)||ND (<0.05)||0.43||NE|
|Nitrogen (as nitrate)||0.99||1.7||27||10|
|Total Dissolved Solids (TDS)||356||427||517||NE|
|Vinyl chloride||ND||ND||0.012||0.0002, 0.00002 CREG|
|Trichloroethylene (TCE)||ND||8||0.047||0.001 UR|
|Tetrachloroethylene (PCE)||6||110||1.400||0.0004 UR|
|Chromium (total)||NS||NS||0.195||0.1 LTHA|
BOLD - Exceeds Comparison Values
CV - Comparison Value
NE -- Not Established
ND - Not Detected
NS - Not Sampled
UR - Under Review
LTHA - Longer Term Health Advisory
CREG - Cancer Risk Evaluation Guide
|Contaminant||A-1||A-2||B||C||D-1||D-2||D-3||D-4||E||F-1||F-2||G||Soil Cleanup Criteria||ATSDR CV|
|Chromium (total) (ppm)||49||31||26||39||110||4300||280||32||150||35||19||37||100||NE|
|Chromium (hexavalent) (ppm)||<2||<2||<2||<2||<2||560||<2||<2||21||<2||<2||2.6||NE||200*|
|t-1,2 dichloroethylene (ppb)||ND||19||ND||10||7||ND||ND||ND||ND||ND||ND||ND||NE||400*|
BOLD - exceeds soil cleanup criteria
CV - Comparison Value
ND - Not Detected
NA - Not Analyzed
NE - Not Established
PCB - Polychlorinated biphenyls
* child Reference Media Evaluation Guide
CREG - Cancer Risk Evaluation Guide
|Metal||Sample A||Sample B||Drinking Water Standard||Proposed GQS|
BOLD - exceeds Drinking Water Standard or Ground Water Standard
GQS - Ground Water Quality Standard
ND - Not Detected
NE - Not Established
BOLD - Exceeds Groundwater Quality Criteria
* Generic Groundwater Quality Criteria
ND - Not Detected
DEP - New jersey Department of Environmental Protection
EB - Ethyl benzene
TCFM - Trichlorofluoromethane
VC - Vinyl chloride
t-DCE - trans- 1,2-Dichloroethylene
c-DCE - cis-1,2-Dichloroethylene
MTBE - methyl t-butyl ether
CFM - Chloroform
PCE - perchloroethylene (tetrachloroethylene)
TVOC - Total Volatile Organic Compounds
|Vinyl chloride (VC)||ND||ND||ND||ND||ND||0.6||5||0.03CREG|
ND - Not Detected
MDL - Minimum Detection Level
GQC - Groundwater Quality Criteria
CREG - Cancer Risk Evaluation Guide
NJ - New Jersey A-280 Criteria
|Detection Limit (ppbv)|| |
ATSDR MRL (ppbv)
ppbv - parts per billion by volume
PCE - Perchloroethylene (tetrachloroethylene)
TCE - Trichloroethylene
c-DCE - cis-1,2-Dichloroethylene
t-DCE - trans-1,2-Dichloroethylene
VC - Vinyl chloride
ND - Not Detected
NE - Not Established
MRL - Minimal Risk Level