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PETITIONED PUBLIC HEALTH ASSESSMENT

E.I. DU PONT DE NEMOURS
POMPTON LAKES, PASSAIC COUNTY, NEW JERSEY


CONCLUSIONS

1. The E.I. Du Pont, Pompton Lake Works Site is a public health hazard because of human exposure to contaminants in soil, sediment, surface water, groundwater and fish in the Acid Brook area. Remedial efforts currently underway are designed to reduce or eliminate the public health hazard.

2. There are or have been completed exposure pathways via ingestion of elevated levels of lead and mercury in Acid Brook Area soils and sediments. Future exposures are possible until remediation is completed. Ingestion of lead and mercury at levels found in soils at this site could result in reduced kidney function, gastrointestinal problems, neurological, reproductive, and hematological effects.

3. There have been completed past exposure pathways, via ingestion, to elevated levels of metals and solvents in Acid Brook Area private wells. Future exposures are possible if residents use their private well water for drinking water. Past ingestion exposures to solvents at levels found in private well water could adversely influence the normal function of the liver, kidney, central nervous system and skin. In addition, there is a low to moderate increased risk of cancer if long-term ingestion of contaminated well water occurred.

4. Workers and trespassers may have been exposed to mercury and other metals found in soils and surface water on PLW property via ingestion. Exposure to mercury and other contamination on PLW property could result in reduced kidney function, gastrointestinal problems, neurological, reproductive, and hematological effects. However, exposures are unlikely since workers currently have a health and safety plan for remediation, and access to the PLW property is monitored continuously.

5. Potential pathways of exposure to lead- and mercury-contaminated house dust existed via ingestion and inhalation. Lead and mercury found at high levels in outdoor soils may have migrated indoors.

6. Environmental monitoring data from Pompton Lakes, Wanaque River, and Pequannok River indicate that exposures to chemical contamination in these surface waters via ingestion does not present a public health hazard.

7. Vegetable tissue sampling data from vegetables grown in the Acid Brook Area indicate that consumption of these vegetable does not present a public health hazard. Residents are advised to clean vegetables thoroughly before consumption.

8. Off-site air monitoring data indicate that lead in the air is not at elevated levels.

9. Fish tissue sampling results from fish taken from Acid Brook, Wanaque River, Pequannok River, and Pompton Lake indicate that consumption of fish from Acid Brook and Wanaque River may present a public health hazard. Data on fish caught from the Pequannok River and Pompton Lake do not indicate a public health hazard.

10. Monitoring data for the municipal water supply for Pompton Lakes indicate that use and consumption of municipal water do not present a public health hazard.

11. A plume of groundwater contamination exists under the PLW property and extends into residential areas. Contaminated groundwater beneath PLW and Acid Brook is not hydrogeologically connected to groundwater used for the municipal water supply. It is unlikely that the plume of contamination will effect the municipal water supply.

12. The primary sources of Acid Brook Area lead and mercury contamination still exist on the PLW property. Interim remediation of those areas is sufficient to curb future migration of contamination to the Acid Brook Area. PLW plans full remediation of the PLW property.

13. The health outcome data provided on medical testing are inadequate to evaluate the relationship of environmental contamination to body burden of lead and mercury from the site, particularly in children.

14. The health outcome data on learning disabilities are inadequate to evaluate the relationship between lead and mercury exposure and neurological health effects.


RECOMMENDATIONS

A. Recommendations and the Health Activities Recommendations Panel (HARP) Statement

Cease/Reduce Exposure Recommendations

1. Maintain existing health advisories for Acid Brook, Wanaque River, and Pompton Lake until monitoring data indicate that exposures to soils, surface water, and fish are not a public health threat. Maintain restricted access to areas currently or awaiting remediation.

2. Ensure that all private wells downgradient of PLW are not being used as a source of drinking water, and that alternative water supplies have been provided.

3. Continue to maintain and enforce access restriction to PLW property until remediation is completed. Continue to encourage workers at PLW to comply with health and safety plan.

Site and Exposure Characterization Recommendations

1. Continue to monitor groundwater at and downgradient of PLW.

2. Conduct a community health investigation (including exposure histories and medical histories) for Acid Brook Residents to better evaluate possible health outcomes. A community health investigation is a medical or epidemiologic evaluation of descriptive health information about a population in order to evaluate and determine health concerns and to assess the likelihood that those concerns may be linked to exposure to hazardous substances.

HARP Statement

In accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 as amended, ATSDR and the State of New Jersey evaluated the E. I. Du Pont Site for appropriate health follow-up activities. ATSDR's HARP offers the following recommendations:

The data and information developed in the E.I. Du Pont Petitioned Public Health Assessment have been evaluated by the Health Activities Recommendation Panel for appropriate public health actions. Exposures to contaminants from E.I. Du Pont via contact with groundwater and soil (as discussed in this document), pose a public health threat and indicate the need for several follow-up actions. First, a community health investigation is recommended to evaluate health concerns and their linkage to exposure to lead and mercury contaminated soils. The investigation may include neurobehavioral testing of children. Second, the panel recommends a case series to evaluate the health status of those few residents who consumed contaminated groundwater. Third, the exposed population and their local health care providers may need assistance in understanding the public health implications of exposure to soil and groundwater contamination. Therefore, the panel recommends conducting community health and health professions education as health follow-up actions. Finally, the panel will inform the ATSDR Trichloroethylene Subregistry that residents have consumed groundwater contaminated with this chemical and should be considered for the Subregistry.

B. Public Health Actions

The Public Health Action Plan (PHAP) for the E.I. Du Pont site contains a description of actions to be taken by ATSDR and/or NJDOH at and in the vicinity of the site subsequent to the completion of this public health assessment. The purpose of the PHAP is to ensure that this public health assessment not only identifies public health hazards, but provides a plan of action designed to mitigate and prevent adverse human health effects resulting from exposure to hazardous substances in the environment. Included is a commitment on the part of ATSDR/NJDOH to follow up on this plan to ensure that it is implemented.

Actions Undertaken

E.I. Du Pont had offered biomonitoring of urine and blood for lead and mercury content for residents during remediation. Some community members have utilized this service. Some limitations exist when using this information as a measure of exposure as discussed in the public health implication section.

ATSDR has conducted community health education informally during past site visits and community meetings. ATSDR has been available to meet with concerned community members, and has addressed their questions as thoroughly as possible during these meetings.

ATSDR had also conducted health professions education in December, 1991 in response to a previous health consultation. Local health professionals were provided information about lead and mercury exposure.

ATSDR has conducted a public meeting and public availability session in June, 1993 as part of the public comment review process. NJDEPE and Du Pont also participated in the public availability meeting.

ATSDR contacted those homeowners in June, 1993, who may have consumed groundwater with chlorinated solvents south of Du Pont, but these homeowners did not desire any follow-up activities at this time.

Actions Planned

  1. NJDOH will conduct additional health professions education for local health care providers as needed.


  2. NJDOH is planning to conduct an exposure study for residents of the Acid Brook Area. The Acid Brook Area community will be notified as part of the planning process of the investigation.


  3. NJDOH will continue providing community health education as needed and in conjunction with other public health activities.


  4. ATSDR will coordinate with NJDOH to help address other public health issues as needed or if new data become available. Please contact Arthur Block, ATSDR Region II Representative at (212)264-7662 or Lynelle Neufer, ATSDR Environmental Health Scientist at (404)639-0600 for any additional concerns or questions regarding public health issues at this site.

PREPARERS OF REPORT

Environmental Assessor:

Lynelle Neufer, RN MPH
Environmental Health Scientist
Community Health Branch

Health Assessors:

Ronald J. Dutton, PhD
Toxicologist
Community Health Branch

Rosaline Dhara, RN MPH MA
Epidemiologist
Community Health Branch

ATSDR Regional Representative:

Arthur Block
Public Health Advisor
Region II


REFERENCES

  1. United States Geological Survey. Wanaque and Pompton Plains 7.5 Minute Series Topographic Quadrangle Maps, photorevised 1971.


  2. Agency for Toxic Substances and Disease Registry. Health Consultation: E.I. Du Pont De Nemours. April 22, 1991.


  3. Dunn Geoscience Corporation. Remedial Action Work Plan for Pompton Lakes Works Acid Brook Cleanup, Revision No. 2. July 1991.


  4. E.I. Du Pont. Background Information Du Pont Pompton Lakes Works. No Date.


  5. ACID BROOK AND WANAQUE RIVER - HEALTH ADVISORY by R. Assante, Administrator, Borough of Pompton Lakes and L. E. Woods, Plant Manager, Du Pont Pompton Lakes Works, date unknown.


  6. Letter, April 1, 1991, New Jersey Department of Public Health, to Dr. Barry Johnson, Assistant Administrator, Agency for Toxic Substances and Disease Registry.


  7. Census of the Population and Housing, 1980: New Jersey/prepared by the Bureau of the Census. Washington: The Bureau of the Census, 1980.


  8. E.I. Du Pont. Demographic Data on Du Pont's Acid Brook Area. Author and date unknown.


  9. Dunn Geoscience Corporation. Summary of Environmental Data for the Acid Brook Corridor, Pompton Lakes, New Jersey. December 1990.


  10. Dunn Geoscience Corporation. Remedial Investigation Work Plan, Vol. 3, Pompton Lakes Works, E. I. Du Pont de Nemours & Company, Inc. Pompton Lakes, New Jersey. Revision III. November 1989.


  11. National Climatic Data Center. Comparative Climatic Data for the United States Through 1990. 1990.


  12. Superfund Record of Communication, from resident to ATSDR Regional Representative, January 27, 1991.


  13. Letter, February 14, 1991, mayor, Borough of Pompton Lakes, to Commissioner, New Jersey Department of Public Health.


  14. Letter, February 14, 1991, Mayor, Borough of Pompton Lakes, to New Jersey Governor James Florio.


  15. Trip Report, February 26, 1991, Du Pont Pompton Lakes Works, Environmental Health Scientist, ATSDR, to Bob Williams, director, DHAC, ATSDR.


  16. Agency for Toxic Substances and Disease Registry. Public Health Assessment Guidance Manual. Agency for Toxic Substances and Disease Registry, March 1992; Department of Health and Human Services (Public Health Service).


  17. Agency for Toxic Substances and Disease Registry. Analysis Paper: Impact on Public Health of Lead - Contaminated Soil at Superfund Sites, October 1991; Department of Health and Human Services (Public Health Service).


  18. Conoco Environmental Geoscience. Isochores & Boring Locations Map for Acid Brook, 0 inch depth. February 20, 1991.


  19. Hazardous Substance Database, National Library of Medicine, Washington, D.C., July 1992.


  20. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Arsenic. Atlanta: ATSDR, February 1992.


  21. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Cadmium. Atlanta: ATSDR, February 1992.


  22. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Copper. Atlanta: ATSDR, December 1990.


  23. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Lead. Atlanta: ATSDR, June 1990.


  24. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Manganese. Atlanta: ATSDR, February 1991.


  25. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Mercury. Atlanta: ATSDR, December 1989.


  26. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Trichloroehtylene. Atlanta: ATSDR, October 1989.


  27. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Tetrachloroethylene. Atlanta: ATSDR, January 1990.


  28. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Cis, Trans, 1,2-Dichloroethene. Atlanta: ATSDR, December 1990.


  29. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Vinyl Chloride. Atlanta: ATSDR, August 1989.


  30. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Zinc. Atlanta: ATSDR, December 1989.


  31. Thorton, et al. Lead Exposure in Young Children From Dust and Soil in the United Kingdom. Environmental Health Perspectives. November 1989.


  32. Centers For Disease Control. Preventing Lead Poisoning in Young Children. October 1991; Department of Health and Human Services (Public Health Services).


  33. Agency for Toxic Substances and Disease Registry. The Nature and Extent of Lead Poisoning in Children. July 1988.


  34. Census of Population and Housing, 1990: Summary Tape File 1 (New Jersey) machine-readable data files prepared by the Bureau of the Census. Washington: The Bureau of the Census, 1991.


  35. Enesco Incorporated. Summary Result Packages for E.I. Du Pont De Nemours & Company, Inc., for projects 007959, 007172, 008025. August 1990.


  36. CH2M Hill. Interim Response Action Work Plan Mercury Fulminate Site (SWMUs 74, 75, and 76) Du Pont Pompton Lakes Works Pompton Lakes, New Jersey. February 25, 1992.


  37. Trip Report, April 1992, Acid Brook Area, Environmental Health Scientist, ATSDR to Bob Williams, Director, DHAC, ATSDR.


  38. Official Files of Municipal Utilities Authority. Borough of Pompton Lakes, New Jersey. 1985-92.


  39. Michael Gochveld, M.D., University of Medicine and Dentistry New Jersey: Summary of Blood and Urine Lead Levels in Pompton Lakes Residents. February 12, 1992.


  40. Michael Gochfeld, M.D., University of Medicine and Dentistry New Jersey: Summary of Blood and Urine Mercury Levels in Pompton Lakes Residents. February 12, 1992.


  41. Agency for Toxic Substances and Disease Registry Record of Communication. Official file on E. I. Du Pont Petitioned Public Health Assessment. September 22, 1992.


  42. New Jersey Department of Protection and Energy. Memo to Mr. Arthur Block, ATSDR Senior Region II Representative. March 4, 1993.


  43. Du Pont Chemicals. Memo to Mr. Arthur Block, ATSDR Senior Region II Representative. March 3, 1993.


  44. Du Pont Chemicals. Memo to Lydia Ogden-Askew, Community Involvement Liaison. July 2, 1993.


  45. NJDEPE. Memo to Arthur Block, ATSDR Senior Region II Representative. July 7, 1993.


  46. Agency for Toxic Substances and Disease Registry Record of Communication. Official file on E. I. Du Pont Petitioned Public Health Assessment. September 9, 1993.

APPENDIX A - FIGURES

USGS Map
Figure 1. USGS Map

Acid Brook Area
Figure 2. Acid Brook Area

Census Block Groups
Figure 3. Census Block Groups

Mercury Fulminate Area Sampling Locations
Figure 4. Mercury Fulminate Area Sampling Locations

Well Location Map: Dupont, Residential, Municipal
Figure 5. Well Location Map: Dupont, Residential, Municipal


APPENDIX B - TABLES

TABLE 1: CONTAMINANTS IN ON-SITE SOILS AND SEDIMENTS (1992)
CONTAMINANT MAXIMUM
CONCENTRATION (mg/kg)
COMPAR.
VALUE
(mg/kg)
0 - 6" 18 - 24" 36 - 42" 72 - 78"
lead 1790 1450 271 77.6 na
mercury 5930 1520 1880 2500 na

key:

na - not available
nd - not detected
nr - not reported
nt - not tested


TABLE 2: CONTAMINANTS IN ON-SITE SURFACE WATER (1989)
CONTAMINANT MAXIMUM
CONCENTRATION (mg/L)
COMPAR.
VALUE
(mg/L)
REFERENCE COMPAR.
VALUE
EXCEEDED?
LAGOON SHOOTING
POND
PLANT
STREAM
ammonia nd nd 0.13 3 EMEG No
barium 0.093 nd nd 0.7 RfD No
chloroform nd nd 0.455 *2 EMEG (acute) No
chromium 0.06 nd nd 0.1 MCLG No
copper 5.92 nd 0.035 1.3 MCLG Yes
1,2-DCA 0.00339 nd nd *0.05 EMEG (acute) No
trans-1,2-DCE 0.0448 nd 0.00236 0.1 LTHA No
iron 38.7 nd nd 0.3 MCL Yes
lead 0.7 8000 0.0094     Yes
maganese 1.25 0.038 nd 1 RfD Yes
mercury 0.0009 nd nd     na
methylene chloride 0.0224 0.127 0.723 0.0047 CREG Yes
nitrate 0.00025 nd 0.7 16 RfD No
selenium nd 50 nd 0.03 EMEG Yes
1,1,1-TCA nd nd 1.17 0.2 LTHA Yes
TCE nd nd 0.00416 *1 EMEG (inter) No
trichloroflouromethan nd 0.034 0.0349 3 RfD No
vinyl chloride 0.0111 nd nd 0.0002 EMEG Yes
zinc 7.95 nd nd 2.1 LTHA Yes

key:

na - no value available
nd - contaminant not detected
nr - not reported
nt - not tested
* derived comparison values based on acute or intermediate MRLs


TABLE 3: CONTAMINANTS IN OFF-SITE SOILS (1991)
CONTAMINANT MAXIMUM
CONCENTRATION (mg/kg)
COMPAR.
VALUE
(mg/kg)
REFERENCE COMPAR.
VALUE
EXCEEDED?
RESIDENTIAL
GARDENS
YARDS ACID
BROOK
SOIL
barium 419 nr 6860 3500 RfD Yes
copper 95 nr 25400     na
cyanide * 690 nt nt 1000 RfD No
lead 4120 62000 119000     na
mercury 6.4 540 8060 15 RfD Yes
selenium * 1.6 nr 100 150 EMEG No
zinc 623 nr 17000     na

* cyanide and selnium do exceed comparison values for the pica child. See discussion in Pathways Section.


TABLE 4: CONTAMINANTS IN OFF-SITE SURFACE WATER (1990)
CONTAMINANT MAXIMUM CONCENTRATION (mg/L) COMPAR. VALUE (mg/L) REFERENCE COMPAR. VALUE EXCEEDED?
ACID BROOK POMPTON LAKE WANAQUE RIVER
barium 0.044 0.079 0.01 0.7 RfD No
copper 0.094 0.018 nd 1.3 MCLG No
lead 0.054 0.012 0.007     na
mercury 0.0067 nd 0.0002     na
zinc 0.075 0.062 0.035 2.1 LTHA No

key:

na - not available
nd - not detected
nr - not reported
nt - not tested


TABLE 5A: CONTAMINANTS IN ON-SITE GROUNDWATER (1985 - 1986)
CONTAMINANT MAXIMUM CONCENTRATION (mg/l) COMPAR. VALUE (mg/l) REFERENCE COMPAR. VALUE EXCEEDED?
ALL WELLS PRIVATE WELL #1
arsenic 0.011 nd 0.003 RfD Yes
barium 0.062 0.02 0.7 RfD No
cadmium 0.29 nd 0.002 CREG Yes
chlorobenzene 0.0217 nd 0.2 RfD No
chloroethane 0.0211 0.021     na
chromium 0.007 0.005 0.1 MCLG No
1,1-DCA 0.0547 0.0547     na
1,1-DCE 0.253 0.253 0.000058 CREG Yes
trans-1,2-DCE 0.4 0.4 0.1 LTHA Yes
lead 0.008 0.002     na
manganese 0.48 0.18 1 RfD No
methylene chloride 0.026 0.0038 0.0047 CREG Yes
nitrate 0.00311 nd 16 RfD No
selenium 0.002 nd 0.03 EMEG No
tetrachloroethylene 0.408 0.408 0.0007 CREG Yes
toluene 0.0233 nd 1 LTHA No
1,1,1-TCA 3.72 3.72 0.2 LTHA Yes
TCE 0.167 0.167 0.005 MCL Yes
vinyl cloride 0.565 0.565 0.0002 EMEG Yes
zinc 1.6 0.41 2.1 LTHA No

key:

na - not available
nd - not detected
nr - not reported
nt - not tested


TABLE 5B: CHARACTERIZATION OF SOLVENT CONTAMINATION AMONG 28 PRIVATE WELLS (1985 - 1986) AND OFF-SITE MONITORING WELLS (1990)
CONTAMINANT DETECTION FREQUENCY FREQUENCY OVER HEALTH COMPARISON VALUE COMPAR. VALUE (mg/l) REFERENCE CONTAMINANT FOUND IN OFF-SITE MONITORING WELL (1990)
chlorobenzene 1/28 na 0.2 RfD nd
chloroethane 1/28 na     Yes
1,1-DCA 1/28 na     Yes
1,1-DCE 2/28 2/28 0.000058 CREG Yes
trans-1,2-DCE 5/28 2/28 0.1 LTHA nd
methylene chloride 8/28 7/28 0.0047 CREG Yes
tetrachloroethylene 15/28 15/28 0.0007 CREG Yes
toluene 1/28 1/28 1 LTHA Yes
1,1,1-TCA 16/28 1/28 0.2 LTHA Yes
TCE 10/28 8/28 0.005 MCL Yes
vinyl cloride 1/28 1/28 0.0002 EMEG Yes

key:

na - not available
nd - not detected
nr - not reported
nt - not tested


TABLE 6: CONTAMINANTS IN OFF-SITE GARDEN VEGETABLES (1990)
CONTAMINANT MAXIMUM CONCENTRATION (mg/l)
DARK GREEN VEGETABLES TOMATOES COMPAR. VALUE
barium 3.7 3.7 na
copper 1.6 2.4 na
zinc 9.2 7.9 na

key:

na - not available
nd - not detected
nr - not reported
nt - not tested


TABLE 7: CONTAMINANTS IN OFF-SITE FISH TISSUE (1990)
(no comparison values available)
CONTAMINANT MAXIMUM CONCENTRATION (mg/kg)
ACID BROOK WANAQUE RIVER POMPTON LAKE PEQUANNOK RIVER
barium 2.3 4.7 9.4 1.7
cadmium nt 0.084 0.031 0.4
chromium nt 0.62 0.49 0.26
copper 6 19.1 6.1 2.2
4,4-DDE nt nd 0.034 nt
heptachlor nt nd 0.2 nt
lead 2.3 0.94 2.1 12.1
lindane nt nd 0.039 nt
mercury 1.3 1.3 1 0.52
PCBs nt 0.36 0.41 nt
selenium 1.2 0.62 0.68 0.43
dioxins nt 0.00000151 2.00E-06 nt
zinc 23.3 33.3 0.027 31.8

key:

na - not available
nd - not detected
nr - not reported
nt - not tested


TABLE 8: CONTAMINANTS IN OFF-SITE AMBIENT AIR (1990)
CONTAMINANT MAXIMUM CONCENTRATION (mg/m^3) COMPARISON VALUE (mg/m^3) REFERENCE COMPARISON VALUE EXCEEDED?
barium 0.000059 0.0005 CRFC No
copper 0.00381 0.2 REL No
lead 0.000668 0.05 NAAQS No
zinc 0.00251     na

key:

na - not available
nd - not detected
nr - not reported
nt - not tested


TABLE 9: E.I. DUPONT PATHWAYS SUMMARY
COMPLETED PATHWAYS
Pathway: RESIDENTIAL SOIL PRIVATE WELL PRIVATE WELL
Source: Du Pont Du Pont Du Pont
Environmental Medium: soil groundwater groundwater
Exposure Point: residential yards private wells private wells
Exposure Route: ingestion ingestion dermal absorbtion inhalation
Receptor Population: children, adults private well users private well users
Exposure Duration: chronic chronic chronic
Time Period: past, present past past
Contaminants of Concern: lead, mercury, barium, copper, zinc arsenic, cadmium, chloroethane, 1,1-DCA, 1,1-DCE, trans-1,2-DCE, iron, manganese, methylene chloride, PCE, 1,1,1-TCA, TCE, vinyl chloride chlorinated solvents
Estimated number of exposed currently: Adults: 331 (8)
Children: 87 (8)
2 private wells (10)
Approx. 5 people
28 private wells (10)
Approx. 70 people

Pathway: ACID BROOK SOIL ACID BROOK GARDEN SOIL
Source: Du Pont Du Pont Du Pont
Environmental Medium: soil/sediments surface water garden soil
Exposure Point: soil at banks of Acid Brook Acid Brook residential gardens
Exposure Route: ingestion ingestion ingestion
Receptor Population: children children children, adults
Exposure Duration: acute acute acute
Time Period: past, present past, present past, present
Contaminants of Concern: barium, copper, lead, mercury, zinc lead, mercury lead, copper, zinc
Estimated number of exposed currently: Unknown Unknown Approx. 10 people (9)

Pathway: FISH VEGETABLE
Source: Du Pont garden soils
Environmental Medium: food chain, fish food chain, vegetables
Exposure Point: Acid Brook, Pompton Lake, Wanaque River residential gardens
Exposure Route: ingestion ingestion
Receptor Population: consumers consumers
Exposure Duration: chronic seasonal
Time Period: past, present, future past, present, future
Contaminants of Concern: mercury, heavy metals, pesticides barium, copper, zinc
Estimated number of exposed currently: Unknown Approx. 10 people (9)


POTENTIAL PATHWAYS
Pathway: INDOOR DUST PLW SURFACE WATER PLW SOIL
Source: contaminated residential soils Du Pont Du Pont
Environmental Medium: indoor dust surface water soil
Exposure Point: residential homes Shooting Pond, lagoons, Plant Stream mercury fulminate area
Exposure Route: ingestion/inhalation ingestion, dermal ingestion
Receptor Population: children, adults children, workers children, workers
Exposure Duration: chronic acute, intermediate acute, intermediate
Time Period: past, present, future past, present past, present
Contaminants of Concern: lead, mercury, barium, copper, zinc copper, iron, lead, manganese, methylene chloride, selenium, 1,1,1-TCA, vinyl chloride, zinc mercury, lead
Estimated number of exposed currently: Up to 418 people (8) Unknown Unknown


ELIMINATED PATHWAYS
Pathway: SURFACE WATER AIR MUNICIPAL WATER
Source: Du Pont wind erosion of contaminated soils unknown
Environmental Medium: surface water air groundwater
Exposure Point: Pompton Lakes, Wanaque River residential areas municipal water supply
Exposure Route: ingestion inhalation ingestion
Receptor Population: children adults, children children, adults
Exposure Duration: acute chronic chronic
Time Period: past, present, future past, present, future past, present, future
Contaminants of Concern: * * *

Pathway: MONITORING WELLS
Source: Du Pont
Environmental Medium: groundwater
Exposure Point: on-site monitoring wells
Exposure Route: --
Receptor Population: --
Exposure Duration: --
Time Period: --
Contaminants of Concern: solvents and metals

* no contaminants of concern were identified


APPENDIX C - COMPARISON VALUES

Comparison values for ATSDR public health assessments are contaminant concentrations in specific media that are used to select contaminants for further evaluation. The values provide guidelines used to estimate a dose at which health effects might be observed. Comparison values used in the Environmental Contamination and Other Hazards and in the Public Health Implications sections of this public health assessment are listed and described below.

CREG = Cancer Risk Evaluation Guides
DWEL = Drinking Water Equivalent Level (µg/L)
EMEG = Environmental Media Evaluation Guides
MCL = Maximum Contaminant Level (µg/L)
MCLG = Maximum Contaminant Level Goal (µg/L)
MRL = Minimal Risk Level (mg/kg/day)
IMRL = Intermediate Risk Level
CMRL = Chronic Risk Level
PEL = Permissible Exposure Limit (mg/m3)
REL = Recommended Exposure Limit (mg/m3)
RfD = Reference Dose (mg/kg/day)
RfC = Reference Concentration (mg/m3)
ppm = milligrams per liter (mg/L water)
          milligrams per kilogram (mg/kg soil)
ppb = micrograms per liter (µg/L water)
          micrograms per kilogram (µg/kg soil)
kg = kilogram
mg = milligram
µg = microgram
pg = picogram
L = liter
m3 = meters cubed
NAAQS = National Ambient Air Quality Standards

Cancer Risk Evaluation Guides (CREGs) are estimated contaminant concentrations that would be expected to cause no more than one excess cancer in a million (10E-6) persons exposed over a lifetime. CREGs are calculated from EPA's cancer slope factors.

The drinking water equivalent level (DWEL) is a lifetime exposure level specific for drinking water (assuming that all exposure is from that medium) at which adverse, noncarcinogenic health effects would not be expected to occur.

Environmental Media Evaluation Guides (EMEGs) are based on ATSDR minimal risk levels (MRLs) and they factor in body weight and ingestion rates.

Maximum Contaminant Levels (MCLs) represent contaminant concentrations that EPA deems protective of public health (considering the availability and economics of water treatment technology) over a lifetime (70 years) at an exposure rate of two liters of water per day (for an adult).

Maximum Contaminant Level Goals (MCLGs) are drinking water health goals set at levels at which no known or anticipated adverse effect on the health of persons occurs, and which allow an adequate margin of safety. Such levels consider the possible impact of synergistic effects, long-term and multi-stage exposures, and the existence of more susceptible groups in the population. When there is no safe threshold for a contaminant, the MCLG should be set at zero.

A Minimal Risk Level (MRL) is an estimate of human exposure to a chemical (in mg/kg/day) that is likely to be without an appreciable risk of deleterious but noncarcinogenic effects (noncarcinogenic) over a specified duration of exposure. MRLs are based on human and animal studies and are reported for acute (< 14 days), intermediate (15-364 days), and chronic (> 365 days) exposures. MRLs are published in ATSDR's Toxicological Profiles for specific chemicals.

The Occupational Safety and Health Administration's Permissible Exposure Limit (PEL) in air is an 8-hour, time-weighted average developed for the workplace. The level may be exceeded, but the sum of the exposure levels averaged over eight hours must not exceed the limit. The National Institute for Occupational Safety and Health recommends exposure limits (RELs) for the workplace. RELs are based on time-weighted average (TWA) concentrations for up to a 10-hour workday during a 40-hour work-week.

EPA's Reference Dose (RfD) and Reference Concentration (RfC) are estimates of the daily exposure to a contaminant that is unlikely to cause adverse health effects. However, RfDs and RfCs do not consider carcinogenic effects.

The Clean Air Act of 1990 established National Ambient Air Quality Standards (NAAQS) for six criteria pollutants. Concentrations exceeding NAAQS in ambient air may endanger public health.

EPA classifies the carcinogenic potential of contaminants based on the weight-of-evidence of toxicological data. There are five classes of carcinogenicity as shown below:

A. Carcinogenic in humans
B. Probably carcinogen in humans
C. Possibly carcinogenic in humans
D. Not classifiable as to human carcinogenicity
E. Evidence of noncarcinogenicity in humans

Further, the B1 classification is based on sufficient human evidence, while the B2 classification is based on sufficient animal evidence, but insufficient human evidence.

COMPARISON VALUE REFERENCES

  1. Agency for Toxic Substances and Disease Registry. Health Assessment Guidance Manual. Atlanta: ATSDR, October 1990.


  2. National Institute of Safety and Health. Pocket Guide to Chemical Hazards. Washington D.C.: Department of Health Human Services, June 1990.


  3. Environmental Protection Agency. Intergrated Risk Information System.

APPENDIX D - E.I. DU PONT SITE HISTORY

SITE HISTORY - E.I. DUPONT POMPTON LAKES WORKS
Date Event
1802 E.I. Dupont found by Eleuthere Irenee Du Pont.
1886 H. Julius Smith builds spark-fired blasting cap (filled with mercury fulminate) plant one-half mile from PLW entrance.

Dam build across Wanaque River creating Lake Inez.
1888 American Manufacturing and Supply Company, Ltd. built black powder mill on present Du Pont PLW site.
1891 Black powder mill sold to Metallic Cap Manufacturing Company, who dismantled the mill and built a plant to load caps.
1894 American Smokeless Powder company purchased land from H. Julius Smith and built a smokeless powder plant (known as the Haskell Plant) on the west side of Lake Inez.
1898 Haskell Plant purchased by Laflin & Rand.

Explosion at Haskell Plant and severly damaged.

Laflin & Rand purchased additional land from Smith and built a new plant having a daily capacity of 6000 pounds (lb) of smokeless powder and 1000 lb of gun cotton.
1902 Du Pont acquires control of Laflin & Rand Powder Company.

Electric Exploder company (owned by Du Pont) began operations at the newly constructed plant on the west side of Lake Inez.
1906 James Macbeth and Company cap plant moved to Pompton Lakes from Jamaica, New York, and became part of Du Pont's Electic Exploder Company. The consolidation resulted in plant emplotment of 155 workers and production of 35,000 E.B. caps per day.
1907 Du Pont acquired Metallic Cap Manufacturing Co. and property (now the center of the PLW site.)
1908 Du Pont purchased Smith Electric Fuse Co. and moved plant equipment to the Electric Exploder Co. plant on the west site of Lake Inez. This became known as Du Pont Fuse Works.

The old Metallic Cap Manufacturing Co. plant became the Du Pont works.
1917 Du Pont produces huge quantities of powder for World War I Allies. Work force at Cap and Fuse works increases to 7500 employees.
November, 1918 Production capacity:

1.5 MM ordinary blasting caps,
60 M electric blasting caps,
4.5 M lb of mercury fulminate,
200 M detonating fuses,
40 M boosters,
100 M primers,
100 M tracer and incendiary bullets, and
An unknown quantity of hand rifle grenades.

Housing boom occurs, many homeowners converted residences to rooming houses for workers. Du Pont built a dormitory colony (near the current site of Pompton Lakes High School).
1926 Du Pont discountinued operations on the west side of Lake Inez and consolidated with the current plant site on the east side of the lake.
1928 A lead azide plant was built at PLW site.
1930 Production at the lead azide plant began.
1938 Innovations in production methods occurred, when plastic wire insulation was introduced and replaced cotton insulation.
1939 The first plastic extruder was introduced at PLW.
1941 World War II increased employment to more than 3000. Activities included production of massive quantities of E.B. caps, all types of military detonators and fuses, rocket igniters, and pull-wite detonators.
1950 Du Pont introduced the Auto Loader.
1951 Du Pont introduced copper wire tinning.
1952 The first E.B. cap assembly machine began operations on a production basis.
1953 Pompton Lakes Process Laboratory (PLDL) was established.
1954 The AM Building was completed.
1962 The Delay Loader became operational.
1963 The metal cladding facilities started operations.
1965 Coin Clad production began.
1978 Plantwide conversion from mechanical relay to solid-state programmable controllers was initiated.
1980 Detaline system facilities and the new powerhouse began operations.
April 29, 1983 New Jersey Department of Environmental Protection (NJDEP) requires Du Pont to implement a hydrogeologic investigation of the site to assess the impact of waste disposal areas on the quality of groundwater at the site and to submit a report on the findings of the investigation.
July 19, 1984 Du Pont submitted Ground Water Assessment Report. The report concluded that groundwater on site was contaminated with heavy metals and volatile organic chemicals (VOC) and may be migrating off site in a southerly direction.
January 4, 1985 NJDEP required Du Point to conduct a supplementary hydrogeologic investigation.
June 26, 1986 Du Pont submits the supplementary hydrogeologic investigation report. Based on this report NJDEP concluded that Du Pont had discharged pollutants in violation of the New Jersey Water Pollution Control Act (NJWPCA).
1987 Du Pont sold the commercial Explosives Business to Canadian Investment Capital, Ltd., (CIC) including certain equipment associated with manufacture of explosives.

Du Pont continues to produce detonators on contract for CIC.
July 16, 1987 CIC signed letters of intent with E.I. Du Pont de Nemours & Co. and Du Pont Canada Ltd. to acquire Du Pont's industrial explosives businesses in Canada and the United States. These two businesses combined to form Explosives Technologies International (ETI).
September, 1988 Du Pont entered into an Administrative Consent Order (ACO) to conduct the necessary RI/FS studies for the PLW site.

A public meeting was held to present Du Pont's plans for remediation.
November 7, 1988 Use of the Shooting Pond for the destruction of waste detonators was discontinued.
March, 1989 Du Pont submitted a Remedial Investigation Work Plan (RIWP) to NJDEP that presented proposed methods to investigate contamination at PLW.
April 12, 1989 ETI announced the termination of the contract with Du Pont for production of commercial detonators, resulting in a phase-down of operations at PLW.
May 15, 1989 Public hearing conducted. Du Pont states plans to locate off-site monitoring wells and take borings for soil characterization. Also, they planned to take water samples from private wells located between the southern plant boundary and Pompton Lake.
August, 1989 Layoffs began; work force of 220 workers reduced 60%.
October, 1989 Du Pont installs monitoring wells off site. Du Pont paid to connect homeowners to municipal water systems where tests indicated the wells were contaminated.
November, 1989 NJDEP approved Du Pont's RIWP.
July 5, 1990 Resource Conservation and Recovery Act permit issued by NJDEPE for five areas at PLW. These included those used for storing and burning wastes.
August 24, 1994 EPA ordered corrective actions at all waste management operations throughout the site under the Hazardous Substance and Waste Amendment Regulations.


APPENDIX E - RESPONSES TO PUBLIC COMMENTS

ATSDR received many comments on the Public Release of this Public Health Assessment. Several of the comments have been addressed by making changes or additions in the public health assessment text or tables. Some of the comments were related to issues other than health, such as real estate issues. Other issues that would be better answered by another agency such as NJDEPE have been referred to these agencies. The remaining questions and comments have been addressed by ATSDR separately in this Appendix.

Comment: Is there some environmental cause possibly related to cases of children with autism among families where the mother grew up in the Acid Brook Area?
Response: To date, no linkage has been established between autism and any environmental contaminant, and there are no experimental data available because there is no animal model for autism. Lead is one contaminant at this site which is associated with subtle (subclinical) effects on neuropsychologic behavior. The reported effects of low level exposure to lead do not; however, include autism. Furthermore, the neurochemistry of lead intoxication is inconsistent with that of autism. While the most consistent biochemical finding in autism has been elevated blood levels of serotonin, it has been shown in lead-exposed rats that levels of serotonin actually decrease.

Comment: Could these health effects be related to exposure to contaminated soils in our yards or private wells?

hypertension
uterine/ovarian tumors
pituitary tumor
endocrine problems
leg swelling
dizziness
chest pain
numbness in extremities
urine incontinence
arteriosclerosis
heart attack
kidney stones
glaucoma
hemorrhoids
stomach ulcers
fatigue
sinus trouble
eye irritation
cancer (e.g. breast, brain, prostate, lung, liver)
neurological problems
diarrhea
stomach aches
peripheral neuropathy
renal tumor
"shadow on liver" (x-ray report)
enlarged kidney (hydronephrosis?)
fibrocystic breast disease
above normal mercury level
insomnia
short-term memory loss
endometriosis
bladder infections
Crone's disease
hiatal hernia
respiratory problems

Response: The listed health effects by themselves are not specific for any particular chemical exposure. Many are subjective complaints (e.g., dizziness, fatigue, stomach aches, insomnia, short-term memory loss) that can be early signs of poisoning (see the Public Health Implications Section), but are usually caused by something else. The results of blood and urine screening in this neighborhood did not indicate current lead and mercury toxicity in the individuals tested.
           In regards to cancer, some of the contaminants identified in private yards or wells near this site (i.e., lead, TCE, PCE, DCE, and vinyl chloride) have caused cancer in laboratory animals, but the results of human studies have been generally negative (with the exception of vinyl chloride). With some of these contaminants (i.e., lead, TCE, and PCE) the induction of cancers in experimental animals has occurred only at extremely high (i.e., cytotoxic) doses and/or has involved species-specific mechanisms that are considered irrelevant to humans. In other cases (e.g., DCE), the results of most animal cancer studies have been statistically insignificant and have shown no dose-effect relationship. By contrast, vinyl chloride, which was found in the off-site shallow aquifer, is a known carcinogen in humans as well as in animals. In humans, however, vinyl chloride-induced cancer (i.e., angiosarcoma of the liver) has occurred almost exclusively as a result of the heaviest occupational exposures (i.e., in cleaners of vinyl chloride reactor vessels in polymerization plants). Unfortunately, there is still very little information about the possible carcinogenic effects of long-term exposure to these chlorinated solvents in combination or at low levels.
           While there is no conclusive evidence of existing health problems attributable to environmental contamination at this site, the possibility of future problems should be still avoided. Prudence would dictate (a) not using any contaminated well as a drinking water supply, and (b) not allowing children to play in areas known to be contaminated with high levels of lead or mercury.

Comment: Other areas of the town should be checked, including Hill Court and West Lenox Ave, since the [Wanaque] river flooded these areas twice.
Response: When soil sampling around Acid Brook and Wanaque River was first conducted, the samplers began at the edge of the river and brook and moved outward until lead and mercury soil levels were similar to background levels. In this way, they hoped to capture the areas where flooding and possible contamination had occurred, and where lead and mercury were above expected levels. It may be possible that, even though an area flooded, the flooding had either diluted the contamination, or was insufficient to transport contamination, so soil lead and mercury levels were not elevated in areas that had been flooded previously. However, ATSDR did report the concern about flooded areas not being tested to NJDEPE for further investigation.

Comment: What are the public health implications of a basement dust level of 2010 ppm [lead]?
Response: To evaluate this concern, it is important to consider not only the level of lead in the basement, but also the level of exposure to basement dust. For instance, if this basement is or was used frequently as a play area for a young child (1 to 6 years old), this level of lead is very much a concern, and your family physician should be consulted about a blood lead test. Children are particularly susceptible to lead. Although lead is not absorbed through the skin, children ingest small quantities of dust from playing. This area should be properly remediated to prevent further exposure. If this basement is used for storage only and is not used as a living area, then this level of lead in the basement was unlikely to be a problem. Please see the Public Health Implications Section for more information about the health implications of lead exposure.

Comment: Concerned that kids play right next to clean up [areas] and people living right next door to clean up [areas].
Response: This Public Health Assessment advises minimizing exposure to soil and dust contaminated with high levels of either lead and/or mercury. Children who play right next to or on areas being remediated may have increased exposure to lead and mercury, and may be at risk for injury from heavy equipment that may be in the area. For these reasons, children should be discouraged from playing near remediation sites, as well as areas awaiting remediation.
           If children have been playing in these areas, some simple interventions may reduce exposure, such as assuring that the child washes their hands and face before eating, brushing dirt and dust off or changing clothes, leaving shoes outside to avoid tracking dirt inside the house, etc. If children have been playing in these areas on a daily basis, you may want to consult your child's family physician for a blood lead and urine mercury test.
           Lead or mercury contaminated dust is also a pathway of exposure. Du Pont reports using several methods to reduce dust generation at remediation sites. The CDC Guide to Preventing Lead Contamination in Children recommends cleaning with detergents high in phosphate to assure removal of lead-contaminated dust from homes. There are also inexpensive instant lead testing kits for testing whether surfaces may be contaminated with lead. These two interventions will help identify and minimize indoor lead exposures quickly. ATSDR staff have also reported this concern about dust generation to NJDEPE.

Comment: Dust accumulated in house duct work: is this dust contaminated? Can the dust be removed without harm to the residents or the contractor? Will the contractor remove the dust without being advised of possible dangers?
Response: First, testing of house duct work is needed to determine whether it is contaminated. Again, instant lead testing kits are available.
          Second, if lead or mercury is present in duct work dust, the Department of Housing and Urban Development have specific guidelines for when remediation is needed, and for safety guidelines for workers involved in this remediation.

Comment: Lead accumulation in the bone marrow--Exactly under what stressful or traumatic conditions can it be released into the bloodstream? Could I endanger someone else by being a blood donor? Am I endangering myself since the blood will come from the bone marrow to replenish my system?
Response: Lead accumulates in the bone proper, not in the bone marrow. In adults, about 94% of the total body burden of lead is sequestered in bone where it has an elimination half-life of 20 years or more. Thus, accumulation of lead in bone tissue is a protective mechanism that keeps lead levels low in the soft tissues (e.g., liver, kidney, blood, brain, and nerves) where lead exerts its toxic effects. Any condition that promotes demineralization of bone (e.g., pregnancy, sudden weight loss, old age, and osteoporosis) will increase blood lead levels and, hence, the potential for toxic effects.
          Unless your blood lead levels are significantly above normal, it is probably safe for you to give blood, since your blood would only be replacing the blood (and blood lead) lost by the person receiving your blood. Blood banks do not routinely test donor blood for lead or other environmental contaminants; they are primarily concerned about infectious disease agents and drugs. If you are still concerned, you should have your doctor determine your blood lead level and tell you whether or not you should give blood.

Comment: What quality assurance was done to ensure that Du Pont's medical tests were accurate? Did your office do any verification of these tests?
Response: Du Pont's medical tests were conducted through the University of Medicine and Dentistry of New Jersey (UMDNJ) and Roche Laboratories. ATSDR has assumed that this university and lab used proper protocol in testing blood and urine for lead and mercury. However, ATSDR did need to verify the blood mercury test results with UMDNJ staff, because there was confusion about the units (ug/L) used in reporting these results. The blood mercury units have since been verified with UMDNJ and there are some significant changes to the Health Outcome Data Evaluation Section. Please see this section for further information about blood and urine screening results.

Comment: Why did the Du Pont Dr. say you were o.k. if you were over 2.9 blood mercury when the NJDOH says 2.9 is high?
Response: This question also highlights the confusion surrounding the units used in interpreting the results of the blood mercury screening. I am not sure by your question if the value of 2.9 was expressed in units of ug/dL or ug/L. If the result was 2.9 ug/L, then that is the same as 0.29 ug/dL, and that is a safe result and also the average of all the test results from the Acid Brook Area residents. If the result was 2.9 ug/dL, then this is an elevated level and indicates the need for repeat testing and follow-up, especially if the urine mercury level was also elevated. There has been some confusion regarding units used in blood mercury result interpretation in the past and, there may have been some misinterpretation, (see the Health Outcome Data Evaluation for more description of the blood mercury results).

Comment: What impact could soil lead contamination have on our water supply? ATSDR's analysis of the impact of the lead in our soil should also include the impact of the lead in our water supply.
Response: Lead in soil normally does not tend to rapidly migrate to groundwater, but rather, stays bound to soil for many years. Even though there was high levels of lead in surface soil in the Acid Brook Area, it is unlikely that the lead contamination has significantly affected off-site groundwater quality in the past. In fact, groundwater under PLW showed the only elevated lead levels, and only trace amounts of lead have been found in private wells off-site. Unfortunately, this propensity for lead to bind with soil has also resulted in the high accumulation of lead found in soil in the Acid Brook Area.
          However, several other contaminants have affected private well water off-site. These are chlorinated solvents, which do not bind to soil well, and do tend to migrate rapidly to groundwater from land surfaces. Because the presence of elevated levels of chlorinated solvents have been detected in off-site private wells, these wells should not be used as a drinking water supply, (see the Pathway Analysis and Public Health Implications Section for more information).

Comment: If the aquifer drainage area is Pompton Lake and it has been draining into here for years, what section of the lake does it drain in? How many people have been contaminated by eating fish and swimming and swallowing lake water since 1906?
Response: As discussed above, the chlorinated solvents that have contaminated the groundwater have completely different properties than other hazardous substances, such as mercury and lead. Chlorinated solvents tend to evaporate from open water bodies, like Pompton Lake or swimming pools. The reason they tend to accumulate in groundwater is because groundwater is underground and in a closed space. Also, even if low levels of chlorinated solvents are in surface water, they do not tend to accumulate in fish. Therefore, it is not surprising that the data from Pompton Lake and Pompton Lake fish do not indicate elevated levels of chlorinated solvents, even though the nearby aquifer did. For these reasons, exposures to chlorinated solvents from swimming in Pompton Lake or eating fish in the past are probably minimal.
          However, there is signs recommending against consuming fish from Pompton Lake. One reason was because mercury was detected in the fish above the FDA level for mercury. The source of the mercury may be from Acid Brook, since elevated levels were found in the sediments throughout the length of the brook, (see the Pathways Analyses Section for more information).

Comment: The EPA has set forth guidelines by which you can estimate a person's blood lead level by the amount of lead that is in the air, water and soil. Why did the ATSDR make no effort to use this formula to verify the clinical results?
Response: The technique EPA uses to estimate blood lead levels by levels in air, water, and soil is called modeling. Modeling is used in the absence of clinical or monitoring results. Sometimes, modeling is the next best tool to actual results for making decisions, but it is, again, only an estimation. Actual results supercedes any modeling data. In fact, actual results are sometimes used to verify estimated results, but modeling is rarely ever used to verify actual results.

Comment: Where is your health study you have promised for three years?
Response: ATSDR began the petitioned public health assessment process in 1991. At that time, ATSDR was not sure if a health study would be useful at this site, so would not have committed to a health study at this time. One of the purposes of the public health assessment is to assess all the available data from involved agencies and community members, and evaluate whether a health study and/or other interventions would be appropriate. This public health assessment has recommended a health study, and ATSDR has funded NJDOH to conduct the study. This study will be much more specific than the public health assessment and will probably take several years, (see the Recommendations for more information).

Comment: If this report has been in the works for more than 2 years, why is there still no information on birth defects and cancer figures from the registry?
Response: Health outcome data are often the most difficult data to retrieve and analyze at many sites. ATSDR has now received this health data for the public health assessment. NJDOH will also be conducting a health study, and that will be much more focused then simply reviewing available health statistics from the state. However, ATSDR will work with NJDOH in incorporating this data into their health study activities as needed.

Comment: We were told clean up would be 250 ppm lead and 14 ppm for mercury. Since lead standards have been dropped to 100 ppm do all the "cleaned up" areas have to be redone?
Response: No, the areas that were "cleaned up" actually had soil replaced. The new soil is clean fill, and is virtually free of lead and mercury.
          It should be noted that NJDEPE proposed 100 ppm as the new clean-up level for lead. This proposed change is not final, (see the Community Health Concerns Evaluation Section for more information on the lead clean-up level issue).

Comment: Won't the Acid Brook be a completed exposure pathway until Du Pont cleans up all 600 acres?
Response: Cleaning up the Acid Brook Area (see Figure 1 in Appendix A) should prevent future exposures to lead and mercury contaminated soils, even if clean-up of the PLW site is not entirely complete until after the Acid Brook Area is finished. One reason is that interim remediation efforts have curbed migration of lead and mercury from the PLW site to the Acid Brook Area. Secondly, although lead and mercury contamination may temporarily remain at PLW, PLW is restricted and residents should not be going on site.

Comment: The report, in several places, used language that confuses two separate concepts -- whether an exposure pathway exists and whether individual exposure actually occurred or is occurring. We understand that ATSDR has simply concluded that an exposure pathway exists that creates the opportunity for exposure.
Response: ATSDR's conclusion is not simply that an exposure pathway exists that creates the opportunity for exposure. ATSDR concluded both that plausible exposure pathways exists and that exposures have actually occurred. The basis for concluding that a plausible exposure pathway exists is based on environmental data. ATSDR ultimately concluded that exposures have actually occurred based on observations during site visits to the Acid Brook Area, and numerous interactions with community members including meetings, phone conversations, letters, surveys, and comments to this public health assessment. Please see the Background and Pathway Analyses Sections for more information.

Comment: This report improperly characterizes the Pompton Lakes Works Site as a public health hazard [because]...actual exposure has not been demonstrated,... and [there is] not any demonstrated connection between site contamination and adverse health outcomes.
Response: It is ATSDR's opinion that our conclusion (this site was a past public health hazard, and will remain a public health hazard until off-site remediation is complete) is not improper. The public health hazard categorization has two criteria: 1) Evidence exists that exposures have occurred, are occurring, or are likely to occur in the future; and 2) the estimated exposures are to a substance or substances at concentrations in the environment that, upon long-term exposures, can cause adverse health effects to any segment of the receptor population. ATSDR believes both these criteria were met, (see the Pathway Analysis and Public Health Implications Sections).
          An additional consideration, that community-specific health outcome data indicate that the site has had an adverse impact on human health, is not required but may be included. ATSDR did not have data to fulfill this additional consideration; however, ATSDR recommended a health study which will be conducted through NJDOH. This study will help evaluate possible adverse impacts on human health in this community.

Comment: The report uses maximum contaminant values inappropriately--the report uses without qualification maximum concentration values.
Response: In regards to use of maximum contaminant values, the public health assessment follows guidelines as stated in the Public Health Assessment Guidance Manual.

"To determine whether a contaminant is a contaminant of concern, the maximum media concentration should be compared to an appropriate health assessment comparison value".

          Using maximimum concentrations allows for a conservative analysis of the environmental data, which is in the interest of protecting public health. ATSDR also believes that the public has a right to know what health effects may be associated with exposure to the maximum concentrations of hazardous substances in their environment. However, the report does not only report the maximum concentrations, and does qualify maximum concentrations on several occasions. A distribution table of lead and mercury in surface soil and a discussion of trends is in the Environmental Contamination and Other Hazards Section, and see also discussions in the Pathway Analysis Section, the Public Health Implications Section, and Table 5B in Appendix B.

Comment: The ATSDR Guidance Manual requires comparison values to determine whether a contaminant is of concern...the reports failure to use any comparison values taints all of its conclusions about possible health risks of lead and mercury in soils and surface water.
Response: The Public Health Assessment Guidance Manual does not state that comparison values are required for determining whether a contaminant is of concern, in fact it clearly states just the opposite.

"To determine whether a contaminant is a contaminant of concern, the maximum media concentration should be compared to an appropriate health assessment comparison value. If the maximum medium concentration exceeds a comparison value, the contaminant should be selected for further evaluation. If a comparison value is not available, the contaminant should be selected [as a contaminant of concern]."

Also, Table 5.2 in the Public Health Assessment Guidance Manual clearly outlines when to list a contaminant as a contaminant of concern.

          It is ATSDR's opinion that our conclusions about possible health risks of lead and mercury in soils and surface water are appropriate. Although comparison values were not available for these contaminants, ATSDR qualitatively discussed the public health implications of exposure at length in the Public Health Implications Section. This discussion was based on information in the Toxicological Profiles for Lead and Mercury (23, 25).

If any community members have any additional questions or concerns regarding public health issues at this site, please feel free to call ATSDR staff Lynelle Neufer at (404) 639-0600 or Artie Block at (212) 264-7662.

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