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PETITIONED PUBLIC HEALTH ASSESSMENT

GAF BUILDING MATERIALS CORPORATION
MILLIS, NORFOLK COUNTY, MASSACHUSETTS


SUMMARY

GAF Building Materials Manufacturing Corporation has manufactured asphalt roofing materials since 1967 in a mill located at 60 Curve Street in Millis, Massachusetts. The original mill complex was constructed in 1891 and has been used for several industrial purposes such as metal work, beverage bottling, and asphalt roofing material and insulation manufacturing. The primary focus of public concern regarding the environmental and health implications of this industry is the possible migration of fugitive air emissions and groundwater contamination off-site. This public health assessment is an evaluation of existing environmental data, both on- and off-site, and community health concerns related to GAF plant in Millis to determine possible human health impact.

A review of environmental data showed that the fugitive air emissions from GAF are primarily made up of crushed limestone, a raw material used in shingle production. Other air emissions from GAF consist of combustion related particulate matter. Natural gas is used as a combustion fuel for the on-site asphalt boilers, asphalt storage tanks, and thermal oxidizer. Air modeling data, based on GAF stack emissions, show hydrocarbon (or combustion products) particulate matter to be 35 times below the National Ambient Air Quality Standard (NAAQS). The air modeling data also showed volatile organic compounds 100 to 1000 times less (depending on the chemical) than the Environmental Protection Agency's health-based comparison values. The Agency for Toxic Substances and Disease Registry (ATSDR) concluded there is not a threat to human health from combustion related emissions released from GAF.

The on-site soil does not pose a threat to human health based on the low levels of contaminants detected in the soil. Environmental sampling activities indicate significant groundwater contamination on-site. The groundwater contains elevated levels of several metals and fuel oil related chemicals. This contamination does not pose a threat to human health because there is no human consumption or contact with this groundwater and the contamination is confined on-site. ATSDR determined that GAF is presently categorized as a No Apparent Health Hazard based on the low levels of soil and air contamination and the lack of human exposure to groundwater.


PURPOSE AND HEALTH ISSUES

GAF Building Materials Manufacturing Corporation (GAF) has been in operation since 1967 at 60 Curve Street Millis, Massachusetts. The Agency for Toxic Substances and Disease Registry (ATSDR) was petitioned by a local citizens group to evaluate the potential public health impact of possible contaminants from GAF migrating off-site [1]. Community members suspect that GAF emissions are associated with respiratory illnesses, various cancers in Millis, and the contamination of municipal groundwater wells with industrial solvents. The purpose of this public health assessment is to identify potential human exposures related to GAF by evaluating existing on- and off-site environmental data, community health concerns, and to recommend appropriate public health follow-up activities.

Site Background

GAF Building Materials Corporation has been manufacturing roofing materials, specifically asphalt shingles, at the Millis plant since 1967. The original mill complex was constructed in 1891 on 11.8 acres. It has been used for several industrial purposes since construction, such as metal work, bottling, as well as roofing materials manufacturing. GAF is privately owned and operated in an area of mixed residential, commercial, and industrial zones. A map with the location and demographics of GAF is located in Appendix A. In the past, GAF was considered to be located in a rural community. However, since the early 1900s several single and multiple residential dwellings have been built adjacent to the site with the closest being less than 100 feet from the GAF property boundary. There are other industrial facilities abutting GAF property including Ann and Hope Corporation (a bottling company) and Rangaine Corporation (television table manufacturing). The GAF plant is surrounded by a partial stone and chain link fence and maintains 24 hour security control of site access. The only entrance road to GAF is along a merging of two residential access roads (Curve and Union Streets). Heavy truck traffic to GAF has been a subject of community opposition regarding the noise, safety, and inconvenience.

There are extensive records on file at the Massachusetts Department of Environmental Protection (MADEP) detailing fuel related releases, environmental clean up, and sampling activities occurring at GAF. In 1989, MADEP initiated a preliminary site investigation of GAF to evaluate all releases of petroleum or hazardous materials from the Millis plant since the removal of an underground storage tank (UST) earlier that year. GAF has one remaining UST on-site that has been closed in place. There are also five aboveground asphalt storage tanks on-site which sit on concrete berms.

As a result of the preliminary investigation, several shallow and deep groundwater monitoring wells were installed on-site to characterize the suspected groundwater contamination. Soil samples were collected from the drill borings of these monitoring wells [2][3]. All environmental sampling was performed in accordance with standardized methods from the Environmental Protection Agency (EPA) or American Society for Testing of Materials (ASTM) [2][3].

There are extensive environmental monitoring data available for groundwater and soil at the GAF facility. Results of ATSDR's evaluation of the environmental monitoring are presented in the Discussion section of this document.


COMMUNITY HEALTH CONCERNS

Specific health concerns expressed by Millis residents were about the possible releases of toxic fumes, gases, and smoke from GAF contributing to respiratory illnesses and increased cancer incidence. Fugitive emissions, such as dust particles, were also mentioned as possible respiratory irritants. The community was concerned that asbestos-matted shingles were manufactured at the Millis plant in the past. However, historical records indicate that asbestos containing products were never manufactured by GAF, or the previous owners (Ruberoid), at the Millis plant [4][5]. Asbestos containing concrete siding was previously distributed from this plant, but was manufactured elsewhere [4][5].

Other community concerns were decreasing property values as a direct result of living adjacent to GAF. The area surrounding GAF is zoned both industrial and residential making the high volume of GAF truck traffic a safety issue to community residents. The community also stated that excessive manufacturing and truck traffic noise levels were a nuisance. ATSDR has sent a copy of this Public Health Assessment to the Massachusetts Highway Department director as a notation of public complaint about the traffic congestion and concern regarding pedestrian safety.


DEMOGRAPHICS

There are 4,248 people living within a one mile radius of GAF (Appendix A) [6]. The population is 99% white, and 1% is black, Hispanic, Asian or another race. Of the total population, 12% are under age 6 years old and 10% are age 65 years and older. In 1990 there were 1,090 females of reproductive age (15-44 years) in the area.


DISCUSSION

A. Methods

The following sections contain an evaluation of the environmental data available for GAF. In preparing this evaluation, ATSDR uses established methodologies for determining how people may be exposed to potential contamination related to GAF and what harmful effects, if any, may result from such exposure. Chemical exposure pathways (or routes of physical contact with chemicals) that ATSDR evaluates are ingestion, inhalation, and skin contact. ATSDR uses comparison values (CVs), which are screening tools used to evaluate environmental data that are relevant to the exposure pathways. Comparison values are concentrations of contaminants that are considered safe levels of exposure. Chemicals detected below CVs are not likely to represent a health concern; chemicals that are detected above CVs require a more detailed evaluation of site specific exposure conditions. For a complete discussion of these criteria (quality assurance considerations, human exposure pathway analyses, ATSDR's health comparison values, and the methods of selecting contaminants above comparison values), refer to Appendix B.

B. Extent of Contamination

Air

Air emissions from asphalt roofing industry consist primarily of particulate matter and to a lesser extent, volatile organic compounds (VOCs) [7]. Air emissions originating from GAF (either fugitive or stack emissions) disperse to surrounding air depending on local meteorologic conditions. Effective stack heights and exhaust velocity influence the dispersion of emissions. Wind direction and speed and dilution also affect human exposure levels of air emissions. To assess the significance of site air emissions on public health, ATSDR evaluates the locations of potentially exposed people with source emissions.

Notices of noncompliance were sent to GAF from the Massachusetts Department of Environmental Quality Engineering (now the Massachusetts Department of Environmental Protection) in 1987 regarding the release of dust from a lack, or improper maintenance, of air pollution control equipment [8]. GAF agreed to resolve these Notices of Noncompliance by:

  • Paying stipulated penalties
  • Converting its thermal oxidizer (or incinerator) from burning fuel oil to burning natural gas (a cleaner burning fuel)
  • Testing stack emissions for combustion products
  • Controlling the dust emissions by installing fume and dust collection devices
  • Closing one of the two thermal oxidizers

Other measures GAF has taken to minimize odors were installing odor reduction devices on the asphalt trucks and installing steam exhaust extensions to reduce odors. However, there are still local and state records detailing community complaints of odors and fugitive emissions (dust) coming from GAF. According to GAF officials, the fugitive dust emissions are primarily made up of limestone. Crushed limestone is a raw material used in the manufacturing process of roofing shingles. To minimize possible fugitive emissions, GAF installed fume and dust collection devices throughout the shingle manufacturing process. GAF also placed four continuous video cameras around the facility to monitor limestone dust build-up in areas not visible, such as roofs and unloading areas, to alert GAF staff of possible build-up and subsequent off-site fugitive emissions.

Currently, the MADEP has permitted GAF to release certain quantities of particulate matter, carbon monoxide, nitrous oxides, volatile organic compounds (VOCs), and sulfur dioxide from fuel oil combustion in the past and natural gas combustion in the present. Although ambient air sampling has not been required by MADEP to be conducted in the vicinity of GAF, MADEP did request a modeling analysis of the incinerator stack dispersion of emissions in 1990. Air modeling was performed using particulate matter emissions to estimate how fuel oil and natural gas burning products (or the black-sooty material seen coming from stacks) would be diluted and dispersed through ambient air around GAF. The on-site thermal oxidizer is used to burn asphalt particulate fumes during the manufacturing process [9]. Air modeling is based on stack emission samples (the amount of particulate matter detected directly in the exhaust stream from a stack) and the atmospheric conditions around GAF (typical wind direction and speed). ATSDR generally prefers to verify modeling data with ambient air sampling results, however, ambient air data are not available on or near GAF property. Results from the air modeling are described below:

Particulate Matter
Based on the estimations of current manufacturing conditions using natural gas, the particulate matter with diameters smaller than 10 micrometers (PM10) being emitted from stacks is 0.0045 milligrams per cubic meter (mg/m3), or about 35 times less than the current National Ambient Air Quality Standard (NAAQS) for PM10 (which is 0.15 mg/m3) averaged over a 24 hour period [10]. Before the conversion to natural gas in 1991, the PM10 level for past fuel oil combustion was 15 times below the PM10 air standard. Based on the modeling information available, there is not a threat to human health from hydrocarbon particulate matter in manufacturing emissions at GAF.

Volatile Organic Compounds (VOCs)
VOC emissions from GAF were also modeled to determine how they are dispersed in ambient air and their impact on air quality. The Environmental Protection Agency (EPA) determined that VOCs emitted from asphalt roofing manufacturers are primarily made up of anthracene, pyrene, and fluoranthene [11]. Based on the estimations of current manufacturing conditions using natural gas, the VOCs being emitted from stacks are 0.001 mg/m3 [12]. This ambient air concentration is approximately 100-1000 times less the EPA's health-based comparison values for anthracene, pyrene, and fluoranthene (1.1 mg/m3, 0.11 mg/m3, and 0.15 mg/m3, respectively) [13]. Based on the modeling information available, there is not a threat to human health from VOCs in manufacturing emissions at GAF.

Soil

In 1989 to 1991, subsurface soil samples (5 to 105 feet deep) were collected in approximately 23 on-site locations to characterize the extent of contamination. Samples were analyzed for volatile organic compounds (VOCs) and inorganic compounds. All of the chemicals analyzed were detected below ATSDR comparison values [14]. Soil samples were also collected from stockpiled oil contaminated soil on-site. These soil piles were stockpiled during the removal of the UST in January 1989. Low levels of carbon tetrachloride and trichloroethylene were detected in the soil stock piles, however, these contaminants were also at levels below ATSDR comparison values. Carbon tetrachloride and trichloroethylene were not detected in subsurface soils at GAF. The contaminated stockpiled soil was removed and properly disposed of in May of 1989 [17]. Soil sampling results are located in Appendix C, Table 1. Based on the soil sampling results, ATSDR concluded that the contaminants detected in on-site soils were not at levels of public health concern.

Groundwater

Groundwater elevation data and well gauging information indicate a northeast groundwater flow direction toward the Charles River [2]. The average depth to groundwater at GAF is approximately 8.5 feet. ATSDR reviewed groundwater data from each monitoring well to determine if GAF has had an impact on the groundwater. The nearest municipal well is located approximately 1/3 mile hydrogeologically downgradient from GAF. All private wells located within ½ mile of GAF were hydrogeologically upgradient and would not be impacted by site activities [3].

Monitoring Wells
There have been several fuel oil spills at GAF that are documented by MADEP. Between 1990 and 1993, 23 groundwater monitoring wells were installed on-site at depths ranging from approximately 5 to 120 feet to monitor the impact of the fuel oil spills and the leaking UST. GAF installed a groundwater remediation system in 1991 which presently continues to remove floating oil compounds from two on-site groundwater wells that are associated with No. 2 fuel oil contamination [15]. All 23 wells are for monitoring purposes only and are not used as potable water sources. GAF employees are supplied public drinking water by the Town of Millis municipal water system. There are a total of 16 to 27 groundwater samples taken twice a year from the monitoring wells on-site. These samples are analyzed for total petroleum hydrocarbons (TPH), priority pollutant metals, and organic compounds according to EPA standard methods. ATSDR evaluated the contaminants detected in the groundwater. There were several contaminants in the monitoring wells above ATSDR's comparison values (Appendix C, Table 2). However, based on groundwater monitoring results, the groundwater contamination at GAF has been contained on-site and shows no indication of migrating off-site or potential for human exposure [16]. The semi-annual groundwater monitoring plan would indicate signs of future migration off GAF property boundaries, if it were to occur. Since there is no human exposure associated with the on-site groundwater contamination, ATSDR concludes there is no past or current public health threat associated with the on-site groundwater contamination.

Municipal Wells

The majority of Millis residents are supplied drinking water from the Town of Millis municipal water wells which are located approximately a ½ mile downgradient of GAF. This municipality is regulated under the Safe Drinking Water Act which requires the MADEP to monitor for organic, inorganic, synthetic organic, and radiological components in the groundwater at least annually and in some cases, quarterly. This monitoring regime would detect groundwater contamination of the municipal wells migrating from any potential source and would notify the municipality and MADEP of the need for immediate groundwater treatment [16].

The municipal water system entails four wells that are approximately 60 feet deep [16]. Municipal water wells #1 and 2 are located 1/3 mile northeast, or hydrogeologically downgradient, of GAF were closed in 1983 in response to the detection of several VOCs (carbon tetrachloride, tetrachloroethylene, and trichloroethylene) [17]. The source of the VOC contamination has not been identified by MADEP [16]. The public wells went back on-line to service the public in July 1998 and are being treated for VOCs via air stripping (a type of filtering process) [16]. Since there were past detections of VOCs in these two wells above state and federal drinking water guidelines, wells #1 and 2 are tested for VOCs quarterly to ensure safe drinking water quality. To this date, water quality from all four wells in the Town of Millis municipal water system has met federal drinking water standards [16]. The groundwater contamination found at GAF does not threaten the potable water quality at the Town of Millis municipal water system in the past or currently because GAF related contamination is confined on-site. However, municipal wells #1 and 2 could potentially be impacted in the future if GAF related groundwater contaminants began migrating downgradient off-site. However, this is unlikely since the groundwater contamination is being remediated and monitored. Also, the quarterly sampling regime taking place at the municipal wells would detect this potential impact and the air stripper treatment system would volatilize and filter the groundwater contaminants. ATSDR concludes there is no current threat to the Town of Millis municipal system water quality from GAF related groundwater contamination.

Private Wells

Records available at the Millis Health Department showed seven private wells located within ½ mile of GAF. Each of these wells is hydrogeologically upgradient from GAF and would not be impacted if site related groundwater contaminants migrated off-site [17]. The closest private well to GAF is 300 yards away, owned and operated by the Ann and Hope Company, a bottled spring water company. This privately owned commercial well has been tapped and used by several beverage companies to sell "spring water" [18]. Trichloroethylene (TCE) has been detected periodically in this well since 1993 and required a carbon filter treatment system to remove TCE at the groundwater tap. Current TCE and other VOC levels are below state and federal drinking water standards [17]. Ann and Hope Company is also located hydrogeologically upgradient (or the opposite flow of groundwater) to GAF, therefore, manufacturing practices at GAF would not have an impact on the water quality of this private well. However, since TCE was detected in this commercial private well, other private well owners in the area using well water as a potable water source should test their private well water for VOCs.

ATSDR concludes that there is no threat to private wells from GAF since groundwater contamination has been confined on-site (within GAF property boundaries). There is also no past threat to the identified private wells from GAF manufacturing activities since these private wells are located hydrogeologically upgradient from GAF. However, private well owners should test their well water for VOCs since TCE was detected in the Ann and Hope Company well water from an unknown source.

C. ATSDR Child Health Initiative

Children are at greater risk than adults from certain kinds of exposure to hazardous substances emitted from waste sites and emergency events. They are more likely to be exposed for several reasons; children play outside more often than adults, increasing the likelihood that they will come into contact with chemicals in the environment. Since they are shorter than adults, they breathe more dust, soil, and heavy vapors close to the ground. Children are also smaller, resulting in higher doses of chemical exposure per body weight. The developing body systems of children can sustain damage if toxic exposures occur during certain growth stages.

Many children live in the town of Millis and in areas adjacent to GAF. Even though these children do not have access to the site, ATSDR closely reviewed possible exposure situations to children while evaluating this site. ATSDR also used the Environmental Media Evaluation Guidelines (EMEG) for children, who are considered the most sensitive segment of the population. ATSDR did not identify any chemical contaminants at levels of health concern to children.

D. Health Outcome Data

Residents of Millis expressed concern that potential exposures from industrial activities at GAF would result in an increased incidence in cancer in the community. ATSDR reviewed available cancer data that were provided by the Massachusetts Department of Public Health and obtained from the Massachusetts Cancer Registry.

Cancer Data
Many state and local health agencies collect data on the number of people who have been diagnosed with cancer each year and classify these cancer cases into different categories such as lung, skin, liver, breast, prostate, colon, and so forth, defined by the type of cell in the body that is affected. Depending on the type of data available, the rate of specific cancers can be determined for certain populations within a state, an entire state population, or the entire United States population. The Massachusetts Cancer Registry has collected information on all reported new cancer cases diagnosed in the state, since 1982. Cancer "incidence" is the number of newly diagnosed cases of cancer during a particular time period, usually in years. This number is compared to the number of cases that occur in a larger, more stable population (in the case of Massachusetts, the statewide population) designated as "normal" or average. ATSDR reviewed health statistics from a publication prepared by the Massachusetts Department of Public Health entitled Cancer Incidence in Massachusetts 1987-1994: City and Town Supplement [19]. Based on the data reviewed, ATSDR provides the following summary:

The MADPH calculated the age adjusted cancer incidence rates for 22 cancer types by sex for each city/town [20]. In other words, the observed number of new cases of a particular type of cancer that was reported to have occurred in the residents from 1987-1994 was compared to the statewide average age-adjusted incidence rate for the same time period. The MADPH reported an increase (that was statistically significant) in the rate of lung, colon (or colorectal), and skin (or melanoma) cancer in the town of Millis when compared to rates for the state. Females had a higher rate of skin cancer, while males had a higher rate of colon cancer.

Cancer is a complex disease (or group of diseases) that often involves multiple "risk" factors, such as environment, lifestyle (smoking, drinking, diet, etc.), and family history. The report defines their limitations and biases in that they did not account for any of these "risk" factors. Furthermore, apparent increases or decreases in cancer incidence over time may reflect changes in diagnostic methods or case reporting rather than true changes in cancer incidence. Analyzing cancer patterns by city or town may be arbitrary and an inexact way of assessing the relationship between geographic location and cancer. For example, the city or town recorded on the death certificate, or in the Massachusetts Cancer Registry, may not be where the person resided most of his or her life. However, cancer patterns in certain towns or cities may help in defining areas to target for further health care strategies. Since specific environmental exposures and other health risk factors are not known, ATSDR cannot conclude any association between contaminants from any source (including GAF) and the incidence or mortality of cancer in Millis, Massachusetts. Detailed information on the causes and prevention of lung, colon, and skin cancer is provided in Appendix D.

E. Physical Hazards

GAF Building Materials Manufacturing Corporation in Millis is an active industrial facility that is not accessible to trespassers. There were no physical hazards noted by ATSDR staff members during the site visit or in the site file at MADEP.


CONCLUSIONS

  1. The air emissions from GAF do not currently pose a threat to public health based on the levels of particulate matter and VOCs released from the stacks and their predicted dispersion into ambient air. ATSDR generally prefers to verify modeling data with ambient air sampling results, however, no ambient air sampling has taken place on or near GAF property.

  2. The on-site soil at GAF is not a public health threat based on the levels of contaminants detected during sampling.

  3. ATSDR concluded there were no site related air emissions at levels of health concern based on modeling data. While the MADPH report (1987-94) identified an increase in colon, lung, and skin cancer in the Millis community, an association between respiratory illnesses or increased cancer incidences to GAF air emissions could not be established. Further information on these types of cancers is located in Appendix D.

  4. The municipal water quality has not been impacted from the GAF groundwater contamination because the contaminants are confined within GAF property boundaries.

  5. Private well water quality has not been impacted from the GAF groundwater contamination because the contaminants are confined within GAF property boundaries.

ATSDR uses one of five conclusion categories to summarize our findings of the site. These categories are: 1) Urgent Public Health Hazard, 2) Public Health Hazard, 3) Indeterminate Health Hazard, 4) No Apparent Public Health Hazard, and 5) No Public Health Hazard. A category is selected from site specific conditions such as the degree of public health hazard based on the presence and duration of human exposure, contaminant concentration, the nature of toxic effects associated with site related contaminants, presence of physical hazards, and community health concerns. Based on these criteria, ATSDR determined there is No Apparent Public Health Hazard from GAF emissions based on low levels of contaminants found at the site, the confined on-site groundwater contamination, and the lack of human exposure with the contaminated groundwater.


RECOMMENDATIONS

Based upon the conclusions and information reviewed, ATSDR makes the following recommendations:

  1. Maintain proper air pollution control equipment and control fugitive emission build-up at GAF.

  2. Maintain noise reduction equipment at GAF.

  3. Continue monitoring groundwater at GAF as recommended by MADEP to ensure early detection of potential contaminant migration off-site.

  4. Continue to monitor the downgradient municipal wells quarterly to ensure early detection of potential contamination.

  5. Private well owners should have their well water tested for volatile organic compounds since trichloroethylene was detected in the Ann and Hope Company well water from an unknown source.

PUBLIC HEALTH ACTION PLAN

The actions described in this section are designed to ensure that this public health assessment identifies public health hazards and provides a plan of action to mitigate and prevent adverse health effects resulting from exposure to hazardous substances in the environment.

Actions Completed:

  1. GAF has completed these emission control measures:

    • Converted thermal oxidizers, asphalt boilers, and oil burners from fuel oil to natural gas
    • Installed fume and dust collection devices for the limestone filler heating system
    • Upgraded dust collection systems
    • Installed four continuous video cameras to monitor dust emissions
    • Upgraded the fume collection system and enclosed the asphalt coating process
    • Installed odor reduction devices on asphalt trucks
    • Installed extensions to the steam stacks for odor reduction
    • Upgraded wastewater treatment system
    • Installed sound baffle walls and insulation around process blowers
    • Installed a groundwater remediation system

  2. ATSDR has evaluated all existing environmental data pertaining to GAF as a basis for this Public Health Assessment.

  3. ATSDR provided health educational material on colon, lung, and skin cancer located in Appendix D of this PHA.

Actions Ongoing:

  1. The Massachusetts Department of Environmental Protection requires annual, and in some cases quarterly (depending on the chemical tested for), groundwater monitoring of all municipal water supplies. Under the authority of the Safe Drinking Water Act, EPA regulates all chemicals in the municipal water supply of Millis.

  2. ARCADIS Geraghty & Miller are monitoring groundwater twice a year at GAF to detect potential migration of contaminants. The results are submitted to MADEP and placed in the Millis Public Library for public review.

Actions Planned:

  1. GAF staff will continue to answer any questions and provide public information regarding manufacturing emissions, environmental monitoring, and remedial actions.

  2. ATSDR will review additional environmental data if site conditions change.

PREPARERS OF REPORT

Kimberly K. Chapman, MSEH
Environmental Health Scientist
ATSDR/DHAC/EICB/PRS

Gregory M. Zarus, MS
Atmospheric Scientist
ATSDR/DHAC/EICB/EI

Adele Childress, PhD, MSPH
Environmental Health Scientist
ATSDR/DHAC/EICB/PRS


Reviewers of Report:

Donald Joe, PE
Section Chief
ATSDR/DHAC/EICB/PRS

John E. Abraham, PhD
Branch Chief
ATSDR/DHAC/EICB


Review and Approval of This Public Health Assessment for GAF Building Materials

Concurrence:

Environmental Health Scientist, PRS, EICB, DHAC

Senior Environmental Health Scientist, PRS, EICB, DHAC

Section Chief, PRS, EICB, DHAC

Branch Chief, EICB, DHAC


REFERENCES CITED

  1. Letter from Petitioner to ATSDR. June 16, 1997.

  2. Groundwater Technology, Inc. February 19, 1990. Phase I - Limited Site Investigation, Massachusetts Contingency Plan, GAF Building Materials Corporation. MADEP Case # 3-1419. Norwood, MA 02062.

  3. Groundwater Technology, Inc. November 7, 1990. Addendum to Phase I - Limited Site Investigation, Massachusetts Contingency Plan, GAF Building Materials Corporation. MADEP Case # 3-1419. Norwood, MA 02062.

  4. Seventy-fifth Anniversary of the Incorporation of the Town of Millis, Massachusetts. May 27-30 1960.

  5. Letter from Nelson D. Johnson of GAF Materials Corporation to Kimberly K. Chapman of ATSDR. April 1, 1998.

  6. United States Bureau of the Census. 1990. Census of Population and Housing: Summary Tape File 1B. U.S. Department of Commerce.

  7. U.S. Environmental Protection Agency. January 1995. Office of Air Quality and Planning Standards. Mineral Products Industry: Asphalt Roofing (11.2).

  8. Notice of Noncompliance. August 6, 1987. The Commonwealth of Massachusetts, Department of Environmental Quality Engineering. Woburn, MA 01801.

  9. ATSDR Official Record of Activity. October 14, 1998. Incoming phone call with David Horton of GAF.

  10. Gradient Corporation. 1992. Review of GAF Materials Corporation: Environmental Conditions Relating to Air Emissions. Cambridge, MA.

  11. U.S. Environmental Protection Agency. September +1987. Locating and Estimating Air Emissions from Sources of Polycyclic Organic Matter (POM). Office of Air Quality Planning and Standards. Research Triangle Park, NC.

  12. Gradient Corporation. November 1998. Screening Air Quality Assessment for Organic Air Emissions for GAF Building Materials Corporation, Millis, Massachusetts. Cambridge, MA.

  13. U.S. Environmental Protection Agency. October 1997. Region III Risk-Based Comparison Table. Philadelphia, PA.

  14. Groundwater Technology Inc. February 28, 1990. Phase I Limited Site Investigation Massachusetts Contingency Plan, GAF Building Materials Corporation. MADEP Case #3-1419. Norwood, MA 02062.

  15. Letter from Nelson D. Johnson of GAF Materials Corporation to Kimberly K. Chapman of ATSDR. October 5, 1998.

  16. ATSDR Official Record of Activity. September 21, 1998. Incoming phone call with Erving Preist of the Town of Millis Public Works.

  17. Groundwater Technology, Inc. November 11, 1991. Phase II - Comprehensive Site Assessment Report, GAF Material Corporation. MADEP Site # 3-1419. Norwood, MA 02062.

  18. Talbot, D. December 16, 1996. Bottled water flows from troubled well. Boston Herald.

  19. Massachusetts Cancer Registry. Cancer Incidence in Massachusetts 1987-1994: City and Town Supplement. Boston, MA.

  20. Massachusetts Department of Public Health. Cancer Incidence in Massachusetts 1987-1994: City and Town Supplement. Boston, MA 02108-4619.


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