PETITIONED PUBLIC HEALTH ASSESSMENT
E.I. DU PONT DE NEMOURS
POMPTON LAKES, PASSAIC COUNTY, NEW JERSEY
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.
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.
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
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

Figure 4. Mercury Fulminate Area Sampling Locations

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