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PETITIONED PUBLIC HEALTH ASSESSMENT

MORSE CUTTING TOOLS
NEW BEDFORD, BRISTOL COUNTY, MASSACHUSETTS


APPENDIX A -- FIGURES

Morse Cutting Tools Site Location
Figure 1. Morse Cutting Tools Site Location

Morse Cutting Tools Site Plan
Figure 2. Morse Cutting Tools Site Plan

Morse Cutting Tools Intro Map
Figure 3. Morse Cutting Tools Intro Map

Underground Storage Tank and Catch Basin Removal
Figure 4. Underground Storage Tank and Catch Basin Removal

Sampling Location Map
Figure 5. Sampling Location Map


APPENDIX B -- PAST RESPONSE ACTIONS

Past Response Actions (1987 to 1998):

Date

Response Action

1987 Morse Cutting Tools facility discontinued manufacturing activities.
1990 Morse Cutting Tools facility assets were prepared for auction.
June 27, 1990 The Massachusetts Department of Environmental Protection (MADEP) Hazardous Waste Division inspected the facility to determine its status relative to compliance with Resource Conservation and Recovery Act (RCRA) regulations. MADEP noted that Morse Cutting Tools was in the process of closing out the operation and dissembling and/or removing the production equipment.
July 18, 1990 The MADEP issued a Notice of Noncompliance pursuant to RCRA regulations for improper labeling and storing of hazardous wastes on the site.
November 1, 1990 Harborline Engineering, Inc., released a Phase I report that included a visual inspection of the site, a review of local and state records, installation and sampling of groundwater monitoring wells, electronic soil screening, and laboratory analysis. The report concluded there was a substantial quantity of separate free product on the water table directly adjacent to the site (MW-2), and there was evidence of a release of oil and/or hazardous material from the site. The report stated that these site conditions may constitute an imminent hazard.
1991 The current site owner, 163 Pleasant Street Corporation, filed for Chapter 7 bankruptcy.
March 5, 1991 Asea Brown Boveri Environmental Services, Inc. (ABB-ES) completed an assessment of the free phase petroleum product at the site and determined that the free product is localized, not migrating rapidly, and could be relatively thin as compared with the thickness observed in the monitoring wells.
April - May, 1991 MADEP requested further investigation to confirm ABB-ES' findings. In response, ABB-ES excavated a 29-foot long test trench on Purchase Street approximately 10 feet downgradient of MW-2. ABB-ES found that visual evidence clearly indicated that free product had not migrated to the trench. ABB-ES reported that they believe that the presence of oil on the water table at the site does not pose an imminent or substantial hazard to public health and safety.
February 1992 The New Bedford Fire Department (NBFD) entered the facility to assess water damage from a broken sprinkler system pipe and noted the presence of hazardous substances. The NBFD immediately notified MADEP.
February 5, 1992 The bankruptcy trustee for the 163 Pleasant Street Corporation filed a "Notice of Intention to Abandon Property".
February 27, 1992 A MADEP, Southeast Regional Office (SERO), site inspection identified numerous potential hazards and hazardous substances stored on-site that could potentially cause exposure to nearby human populations, including the threat of fire or explosion.
March 3, 1992 Personnel from the EPA, the RCRA Emergency Response Group at MADEP-SERO, the NBFD, and consultants Roy F. Weston, Inc., conducted a site inspection and assessment sampling effort, including an air monitoring survey, as a part of a "Removal Program Preliminary Assessment/Site Investigation". Several areas of concern were identified, including haphazard storage of chemicals and waste products like cyanide, oil, solvents, acids and asbestos in drums.
March 26, 1992 Hazardous waste warning signs were posted at the facility.
April 13, 1992 The New Bedford City Council held a public meeting to inform the residents of New Bedford about an upcoming removal action at the Morse Cutting Tools site. The EPA on-scene coordinator and representatives from MADEP were available to answer community questions and discuss concerns.
April - June, 1992 The EPA conducted a removal action at the site. This involved inventorying, staging, bulking, sampling, and transportation of various containerized wastes. The material was sent to disposal facilities or it was removed for recycling or reuse. Asbestos-containing materials reportedly remained on-site, as did various miscellaneous drums, vats, furnaces, and the like.
1996 The City of New Bedford erected a padlocked chain-link fence around the perimeter of the site to prevent unauthorized access.
The MADEP secured an absorbent pad/plywood barrier to a portion of the East Building wall in response to the cutting oil "weeps" through the masonry wall from EPA Tank #1.
1997 During 1997, initial remedial response actions were undertaken by the city of New Bedford and Haley & Aldrich, Inc. immediately prior to and during demolition of the buildings.
November 5, 1997 A draft "Immediate Response Action (IRA) Plan" dated September 9, 1997, was presented for public review and comment at a public meeting.
February 27, 1998 The final IRA Plan was submitted, which incorporated comments as appropriate, from the public review and comment period.
April 24, 1998 Franklin Environmental Services (Franklin) obtained precharacterization samples of material contained in a tank and within a catch basin at the site.
May 5-13, 1998 Franklin pumped out, exposed, cleaned, and removed two 10,000-gallon bare steel, #6 fuel oil underground storage tanks (USTs). Franklin also removed associated below-grade piping, brick, and mortar manway access structures, and a concrete catch basin/oil water separator. Below-grade soils that showed black staining and a faint petroleum odor were excavated. An additional 960 gallons of groundwater that contained small, emulsified droplets of oil and discolored foam were removed by tanker truck during soil excavation.
May 1998 Franklin conducted passive soil gas screening, confirmatory soil sampling, exploratory soil boring sampling, and groundwater sampling in conjunction with the UST removal.
June 10, 1998 Tank bottom sludge and oily debris removed from the USTs and catch basin were contained in thirteen 55-gallon drums and transported off-site.
June 22, 1998 The oil-impacted soil was transported for off-site, cold asphalt batch recycling.
August 11-13, 1998 Six test borings were completed to assess the lateral and vertical extent of the free product in the vicinity of MW-2.
August 26, 118 Groundwater samples were collected from existing and newly installed wells.
October 1998 Soil cuttings from recent test borings were placed in a total of four 55-gallon drums for off-site disposal.
A draft "Scope of Work Phase II - Comprehensive Site Assessment" was submitted for public review/comment.
December 1998 A final "Scope of Work Phase II - Comprehensive Site Assessment" was released.
Previous actions were compiled directly from the following sources: ABB-ES, 1991a; ABB-ES, 1991b; EPA, 1992; Haley & Aldrich, Inc., 1997b; Haley & Aldrich, Inc., 1998b; Haley & Aldrich, Inc., 1998c; Haley & Aldrich, Inc., 1998d; Haley & Aldrich, Inc., 1998e; Harborline Engineering, Inc., 1990.

Notes:

ABB-ES Asea Brown Boveri Environmental Services, Inc.
EPA Environmental Protection Agency
IRA Immediate Response Action
MADEP Massachusetts Department of Environmental Protection
NBFD New Bedford Fire Department
RCRA Resource Conservation and Recovery Act
SERO Southeast Regional Office
USTs Underground Storage Tanks


APPENDIX C -- TABLES

Table 1: Exposure Pathways

Pathway Name Exposure Pathway Elements Time Frame
Source Media Point of Exposure Route of Exposure Exposed Population
Completed Exposure Pathways
Air Morse Tools Indoor Air Off-site (nearby homes) Inhalation Residents Past;
Current;
Future
Potential Exposure Pathways
Groundwater Morse Tools Groundwater On-site;
Off-site
Dermal;
Ingestion;
Inhalation
Residents Future
Soil Morse Tools Subsurface Soil On-site Dermal Workers Past
Asbestos Containing Materials Morse Tools Asbestos Containing Materials On-site Dermal;
Inhalation
Workers; Trespassers Past
Paint Chips Morse Tools Paint Chips On-site Incidental Ingestion;
Dermal
Workers; Trespassers Past
Water Morse Tools Tank Water On-site Dermal Workers Past
Debris Morse Tools Miscellaneous Debris On-site Dermal Workers; Trespassers Past
Tank and Catch Basin Material Morse Tools Tank and Catch Basin Material On-site Dermal Workers Past
Soil Unknown Subsurface Soil Off-site Dermal Residents; Workers Current; Future
Air Unknown Indoor Air Off-site (St. James Place) Inhalation Residents Future
Eliminated Exposure Pathways
Groundwater Morse Tools Groundwater On-site;
Off-site
None None Past;
Current
Soil Morse Tools Surface Soil On-site None None Current
Air Unknown Indoor Air Off-site (St. James Place) None None Current
Lead Dust Unknown Dust Off-site (property that was deleaded) None None Current


Table 2: On-site Groundwater Sampling

Contaminant Concentration Range (µg/L) Location/Year of Maximum Comparison Value (µg/L)
Acenaphthene 0.4; 0.5 B210-OW/1999 6,000 IEMEG (child)
20,000 IEMEG (adult)
Acetone 6.0 - 38 B203-OW/1999 20,000 IEMEG (child)
70,000 IEMEG (adult)
Anthracene 0.1 - 110 Compositea/1990 100,000 IEMEG (child)
400,000 IEMEG (adult)
Arsenic 10 B214-OW/1999 0.02 CREG
50 MCL
3 IEMEG (child)
Barium 340 - 12,000 B214-OW/1999 700 RMEG (child)
2,000 MCL
Benzene 1; 4 B217-OW/1999 1 CREG
5 MCL
Bromodichloromethane 2 B203-OW/1999 0.6 CREG
200 Chronic EMEG (child)
700 Chronic EMEG (adult)
2-Butanone 10 B217-OW/1999 6,000 RMEG (child)
20,000 RMEG (adult)
Chloroform 2.2 - 30 B203-OW/1999 6 CREG
100 Chronic EMEG (child)
Chloromethane 1 B217-OW/1999 3 LTHA
400 CLHA
Cyanide, total 20 B210-OW/1999 200 RMEG (child)
200 MCL
1,2-Dichloroethane 6.6; 132 MW-5/1990 0.4 CREG
5 MCL
2,000 IEMEG (child)
cis-1,2-Dichloroethylene 0.8 - 170,000 B214-OW/1999 3,000 IEMEG (child)
70 MCL
trans-1,2-Dichloroethylene 0.51 MW-4/1997 2,000 IEMEG (child)
100 MCL
Fluoranthene 0.3; 0.5 B210-OW/1999 4,000 IEMEG (child)
10,000 IEMEG (adult)
Fluorene 0.4 - 190 Composite/1990 4,000 IEMEG (child)
10,000 IEMEG (adult)
Lead 3 B211-OW/1999 15 EPA Action Level
2-Methylnaphthalene 0.1 - 8 J Composite/1990 None
Methyl tert-butyl ether 1.2 MW-2/1997 3,000 IEMEG (child)
10,000 IEMEG (adult)
Napthalene 0.9 - 15 B206-OW/1999 200 IEMEG (child)
700 IEMEG (adult)
Phenanthrene 0.9; 92 Composite/1990 None
Pyrene 0.2 - 22 Composite/1990 300 RMEG (child)
1,000 RMEG (adult)
Selenium 2 (2 detections) B106-OW/1998 50 Chronic EMEG (child)
200 Chronic EMEG (adult)
Tetrachloroethylene 5 (2 detections) B208R-OW/1999 0.7 CREG
5 MCL
100 RMEG (child)
Toluene 0.6 - 2 B217-OW/1999 200 IEMEG (child)
700 IEMEG (adult)
Trichloroethene 0.7 - 33,000 B214-OW/1999 3 CREG
5 MCL
1,2,4-Trimethylbenzene 0.83 - 20 B210-OW/1999 12 RBC (n)
1,3,5-Trimethylbenzene 1 (2 detections) B217-OW/1999 12 RBC (n)
Vinyl Chloride 1.6 - 930 B212R-OW/1999 0.2 EMEG (child)
0.7 EMEG (adult)
2 MCL
Xylenes, mixture 0.75; 1.6 B217-OW/1999 2,000 IEMEG (child)
10,000 MCL
Sources: Haley & Aldrich, 1997a; Haley & Aldrich, Inc., 1998d; Haley & Aldrich, Inc., 1999a; Harborline Engineering, Inc., 1990.

a "Composite" refers to a sample containing groundwater from 5 wells.

Table Notes:

CLHA = Child longer term health advisory
CREG = Cancer risk evaluation guide
EMEG = Environmental media evaluation guide
IEMEG = Intermediate environmental media evaluation guide
J = Estimated value
LTHA = Lifetime health advisory
MCL = Maximum contaminant level
RBC (n) = Risk-based concentration (noncancer)
RMEG = Reference dose media evaluation guide
µg/L = micrograms per Liter


Table 3: On-site Subsurface Soil Sampling Results

Contaminant Concentration Range (mg/kg) Location/Depth of Maximum Comparison Value (mg/kg)
Acenaphthene 0.039 J - 2.3 B210/2-6 ft 400,000 IEMEG (adult)
Acetone 0.012 - 0.160 B105/4.0-6.0 ft 1,000,000 IEMEG (adult)
Anthracene 0.098 J - 6.9 B213R/2-7.5 ft 7,000 IEMEG (adult)
Arsenic 0.94 - 15 B207/0.5-4 ft 200 Chronic EMEG (adult)
Barium 5.5 - 120 TP-1/4.3-5.5 ft 50,000 IEMEG (adult)
Benzo(a)anthracene 0.042 J - 8.2 B210/2-6 ft 0.87 RBC (c)
Benzo(a)pyrene 0.041 J - 7.5 B213R/2-7.5 ft 0.1 CREG
Benzo(b)flouranthene 0.046 J - 9.1 B210/2-6 ft 0.87 RBC (c)
Benzo(g,h,i)perylene 0.052 J - 5.7 B210/2-6 ft None
Benzo(k)flouranthene 0.041 J - 5.5 B210/2-6 ft 0.87 RBC (c)
2-Butanone 0.007 - 0.045 B105/4.0-6.0 ft 400,000 RMEG (adult)
n-Butylbenzene 0.016 TP-8/4.4-7 ft 780 RBC (n)
Cadmium 0.35; 0.45 Stockpile#1/NA 100 Chronic EMEG (adult)
Carbon disulfide 0.001 J - 0.018 B101/4.0-5.5 ft 70,000 RMEG (adult)
Chromium 3.0 - 22 B201/0-4 ft 2,000a RMEG (adult)
Chrysene 0.044 J - 8.6 B210/2-6 ft 87 RBC (c)
Cyanide, total 11 B216/0.5-4 ft 10,000 RMEG (adult)
Dibenzo(a,h)anthracene 0.6 - 1.7 B210/2-6 ft 0.87 RBC (c)
1,1-Dichloroethane 0.003 J B105/4.0-6.0 ft 7,800 RBC (n)
cis-1,2-Dichloroethylene 0.001 J - 80 B214/4.5-6.5 ft 200,000 IEMEG (adult)
trans-1,2-Dichloroethene 0.001 J - 0.010 J B105/4.0-6.0 ft 100,000 IEMEG (adult)
Ethyl benzene 0.001 J B101/4.0-5.5 ft 70,000 RMEG (adult)
Fluoranthene 0.08 J - 20 B210/2-6 ft 300,000 IEMEG (adult)
Fluorene 0.46 - 14 B213R/2-7.5 ft 300,000 IEMEG (adult)
2-Hexanone 0.004 J B101/4.0-5.5 ft 3,100 RBC (n)
Indeno(1,2,3-cd)pyrene 0.06 J - 5 B210/2-6 ft 0.87 RBC (c)
4-Isopropyltoluene 0.013 TP-8/4.4-7 ft 7,800 RBC (n)
Lead 8.7 - 670 B207/0.5-4 ft 400b EPA Interim Soil Guidance
Mercury 0.073 - 0.21 TP-1/4.3-5.5 ft 7.8 RBC (n)
2-Methylnaphthalene 0.073 J; 0.4 SP-1/2.5-4.5 ft 1,600 RBC (n)
Naphthalene 0.15 - 0.6 B217/4-6 ft 10,000 IEMEG (adult)
PCBs (Aroclor 1260) 0.12 B214/2-6.5 0.4 CREG
Phenanthrene 0.047 J - 41 B213R/2-7.5 ft None
n-Propylbenzene 0.17 J B217/4-6 ft 0.78 RBC (n)
Pyrene 0.038 J - 15 B210/4-6 ft 20,000 RMEG (adult)
Silver 3.2 B101/12.5-13.0 ft 4,000 RMEG (adult)
Tetrachloroethene 0.001 J B101/4.0-5.5 ft 7,000 RMEG (adult)
Trichloroethene 0.003 J - 40 B214/4.5-6.5 ft 60 CREG
1,2,4-Trimethylbenzene 0.032 - 4.7 B214/4.5-6.5 ft 3,900 RBC (n)
1,3,5-Trimethylbenzene 0.012 - 0.59 B217/4-6 ft 3,900 RBC (n)
Vinyl Chloride 0.009 - 0.052 B105/4.0-6.0 ft 10 Chronic EMEG (adult)
Xylenes, mixture 0.002 J - 0.19 J B217/4-6 ft 1,000,000 IEMEG (adult)
Sources: Haley & Aldrich, Inc., 1998b; Haley & Aldrich, Inc., 1998d; Haley & Aldrich, Inc., 1999a.

a Comparison value provided is for hexavalent chromium.
b Comparison value provided is based on the EPA 'Revised Interim Soil Lead Guidance for CERCLA sites and RCRA Corrective Action Facilities' (Directive 9355.4-12) 1994.

Table Notes:

CREG = Cancer risk evaluation guide
EMEG = Environmental media evaluation guide
ft = Feet
IEMEG = Intermediate environmental media evaluation guide
mg/kg = Milligram per kilogram
J = Estimated value
NA = Not applicable
PCBs = Polychlorinated biphenyls
RBC (c) = Risk-based concentration (cancer)
RBC (n) = Risk-based concentration (noncancer)
RMEG = Reference dose media evaluation guide


Table 4: Concrete Tank Water Sample

Contaminant Concentration (ppb) Comparison Valuea (ppb)
Chloroform 1 J 4,000 IEMEG (adult)
Copper 30 1,300 MCLG
Zinc 84 10,000 IEMEG (adult)
Source: New Bedford DPW, 1997.
Sample Date: June 20, 1997.

a Comparison values listed in this table are for drinking water.

Table Acronyms:

IEMEG = Intermediate environmental media evaluation guide
J = Estimated value
MCLG = Maximum contaminant level goal
ppb = parts per billion


Table 5: Wood Pile Debris Sampling

Contaminant Concentration (ppm) Comparison Valuea(ppm)
Acenaphthene 5.2 30,000 IEMEG (child)
400,000 IEMEG (adult)
Anthracene 13 500,000 IEMEG (child)
7,000,000 IEMEG (adult)
Benzo(a)anthracene 24 0.87 RBC (c)
Benzo(a)pryene 17 0.1 CREG
Benzo(b)flouranthene 17 0.87 RBC (c)
Benzo(g,h,i)perylene 7.1 None
Benzo(k)flouranthene 15 0.87 RBC (c)
Chrysene 21 87 RBC (c)
Flouranthene 63 20,000 IEMEG (child)
300,000 IEMEG (adult)
Flourene 6.3 20,000 IEMEG (child)
300,000 IEMEG (adult)
Indeno(1,2,3-cd)pyrene 7.3 0.87 RBC (c)
Naphthalene 5 1,000 IEMEG (child)
10,000 IEMEG (adult)
Phenanthrene 56 None
Pyrene 53 2,000 RMEG (child)
20,000 RMEG (adult)
Arsenic 8.2 20 Chronic EMEG (child)
200 Chronic EMEG (adult)
Barium 720 4,000 RMEG (child)
50,000 RMEG (adult)
Cadmium 3.8 10 Chronic EMEG (child)
100 Chronic EMEG (adult)
Chromium 130 200b RMEG (child)
2,000b RMEG (adult)
Lead 840 400c EPA Interim Soil Guidance
Mercury 1.5 7.8 RBC (n)
Silver 3.4 300 RMEG (child)
4,000 RMEG (adult)
Aroclor 1242 2.3 0.32 RBC (c)
Source: MADPH, 1997; New Bedford DOH, 1997b.
Sampling Date:November 4, 1997

a Comparison values listed in this table are for the soil medium.
b Comparison value provided is for hexavalent chromium.
c Comparison value provided is based on the EPA 'Revised Interim Soil Lead Guidance for CERCLA sites and RCRA Corrective Action Facilities' (Directive 9355.4-12) 1994.

Table Acronyms:

CREG = Cancer risk evaluation guide
EMEG = Environmental media evaluation guide
EPA = Environmental protection agency
IEMEG = Intermediate environmental media evaluation guide
ppm = parts per million
RBC (c) = Risk-based concentration (cancer)
RBC (n) = Risk-based concentration (noncancer)
RMEG = Reference dose media evaluation guide


Table 6: Construction and Demolition Debris Sampling

Contaminant Concentration Range (ppm) Comparison Valuea (ppm)
Chloroform 0.002 500 Chronic EMEG (child)
7,000 Chronic EMEG (adult)
Methylene Chloride 0.009 3,000 Chronic EMEG (child)
40,000 Chronic EMEG (adult)
PCBs 0.596 - 26.4 0.4 CREG
TPHs 1,219 None
Source: CGK, 1998.
Sampling Dates: November 17, 1997 and January 15, 1998.

a Comparison values listed in this table are for the soil medium.

Table Acronyms:

CREG = Cancer risk evaluation guide
EMEG = Environmental media evaluation guide
PCBs = Polychlorinated biphenyls
ppm = parts per million
TPHs = Total petroleum hydrocarbons


Table 7: Underground Storage Tank and Catch Basin Material Sampling

Compound UST Material Concentration (mg/kg) Catch Basin Material Concentration (mg/kg) Comparison Valuea (mg/kg)
n-Butylbenzene 13 ND None
Butylbenzyl phthalate ND 680 100,000 RMEG (adult)
Ethylbenzene 17 ND 70,000 RMEG (adult)
Naphthalene 1,300 54 10,000 IEMEG (adult)
Phenanthrene 690 ND None
Toluene 25 ND 10,000 IEMEG (adult)
TPH 54,000 260,000 None
1,2,4-Trimethylbenzene 91 15 None
1,3,5-Trimethylbenzene 27 ND None
o-Xylene 47 ND 100,000b IEMEG (adult)
m&p-Xylene 91 ND 100,000b IEMEG (adult)
Barium 12.8 81.5 50,000 RMEG (adult)
Cadmium 0.59 0.45 100 Chronic EMEG (adult)
Chromium 2.46 33.0 2,000c RMEG (adult)
Lead 62.1 19.2 400d EPA Interim Soil Guidance
Source: Haley & Aldrich, Inc., 1998b.
Sample Date: April 24, 1998.

a Comparison values listed in this table are for the soil medium.
b Comparison value provided is for total xylenes.
c Comparison value provided is for hexavalent chromium.
d Comparison value provided is based on the EPA 'Revised Interim Soil Lead Guidance for CERCLA sites and RCRA Corrective Action Facilities' (Directive 9355.4-12) 1994.

Table Acronyms:

EMEG = Environmental media evaluation guide
EPA = Environmental protection agency
IEMEG = Intermediate environmental media evaluation guide
mg/kg = Milligrams per kilogram
ND = Not detected above the reporting limit
RMEG = Reference dose media evaluation guide
TPH = Total petroleum hydrocarbons
UST = Underground storage tank


Table 8: Off-site Groundwater Sampling

Compound Concentration Range (µg/L) Location/Year of Maximum Comparison Value (µg/L)
Acetone 125; 130 MW-2/1993 20,000 IEMEG (child)
70,000 IEMEG (adult)
Benzene 1 B302-OW/1999 1 CREG
5 MCL
Bromodichloromethane 0.7 B315-OW/1999 0.6 CREG
200 Chronic EMEG (child)
700 Chronic EMEG (adult)
Chloroform 1 - 18 B309-OW/1999 6 CREG
100 Chronic EMEG (child)
Chloromethane 1 B221-OW/1999 3 LTHA
400 CLHA
cis-1,2-Dichloroethene 2 - 3,200 B219-OW/1999 70 MCL
3,000 IEMEG (child)
10,000 IEMEG (adult)
trans-1,2-Dichloroethene 4.8; 8 B218-OW/1999 100 MCL
2,000 IEMEG (child)
7,000 IEMEG (adult)
2-Methylnaphthalene 0.1 B218-OW/1999 120 RBC (n)
Trichloroethene 2 - 750 B222R-OW/1999 3 CREG
5 MCL
1,2,4-Trimethylbenzene 1 B311-OW/1999 12 RBC (n)
1,3,5-Trimethylbenzene 2 B311-OW/1999 12 RBC (n)
Toluene 1 B221-OW/1999 200 IEMEG (child)
700 IEMEG (adult)
Vinyl Chloride 0.5 - 890 B220R-OW/1999 0.2 Chronic EMEG (child)
0.7 Chronic EMEG (adult)
2 MCL
Xylenes, mixture 1 B221-OW/1999 2,000 IEMEG (child)
7,000 IEMEG (adult)
Barium 760; 4,900 MW-2/1993 700 RMEG (child)
2,000 RMEG (adult)
2,000 MCL
Cadmium 40; 200 MW-2/1993 2 Chronic EMEG (child)
7 Chronic EMEG (adult)
5 MCL
Chromium 350; 2,500 MW-2/1993 100 MCL
Lead 300; 1,800 MW-2/1993 15 EPA Action Level
Mercury 2 MW-2/1993 2a MCL
Silver 60 MW-2/1993 50 RMEG (child)
200 RMEG (adult)
Source: Haley & Aldrich, Inc., 1999a; Paragon, 1997.

a Comparison value provided is for inorganic mercury.

Table Acronyms:

CREG = Cancer risk evaluation guide
EMEG = Environmental media evaluation guide
EPA = Environmental protection agency
IEMEG = Intermediate environmental media evaluation guide
MCL = Maximum contaminant level
RBC (n) = Risk-based concentration (noncancer)
RMEG = Reference dose media evaluation guide
µg/L = micrograms per Liter


Table 9: Off-site Subsurface Soil Sampling Results

Contaminant Concentration Range (mg/kg) Location/Depth of Maximum Comparison Value (mg/kg)
Acetone 0.014; 0.037 B104/0.5-2.5 ft 100,000 IEMEG (child)
1,000,000 IEMEG (adult)
Benzene 0.001 J B104/0.5-2.5 ft 20 CREG
2-Butanone 0.007 B104/0.5-2.5 ft 30,000 RMEG (child)
400,000 RMEG (adult)
Chromium 1.3 B220/0.5-4 ft 200a RMEG (child)
2,000a RMEG (adult)
cis-1,2-Dichloroethylene 0.001 J - 0.018 B219/6-8 ft 20,000 IEMEG (child)
200,000 IEMEG (adult)
Xylenes, mixture 0.007 B104/0.5-2.5 ft 10,000 IEMEG (child)
100,000 IEMEG (adult)
Sources: Haley & Aldrich, Inc., 1998d; Haley & Aldrich, Inc., 1999a.

a Comparison value provided is for hexavalent chromium.

Table Notes:

CREG = Cancer risk evaluation guide
ft = Feet
IEMEG = Intermediate environmental media evaluation guide
mg/kg = Milligram per kilogram
J = Estimated value
NA = Not applicable
RMEG = Reference dose media evaluation guide


Table 10: Indoor Air Sampling

Compound

Indoor Concentration Range at St. James Placea (µg/m3)

Indoor Concentration Range at a nearby Residenceb (µg/m3)

Outdoor Concentration Rangec (µg/m3)

Comparison Value (µg/m3)

Acetone - 26; 76 18 - 52 30,900 Chronic EMEG (13,000 ppb)
Benzene 2.3; 2.6 0.84; 2.2 0.75; 1.2 0.1 CREG
13 IEMEG (4 ppb)
2-Butanone - 1.7; 3.4 3.7 - 5.1 1,000 RFC
Carbon Disulfide - 1.1; 1.4 1.4; 3.0 930 Chronic EMEG (300 ppb)
Carbon Tetrachloride Trace (0.75) ND ND 0.07 CREG
320 IEMEG (50 ppb)
Chloromethane 1.8; 2.0 2.4; 2.5 1.5 - 2.3 103 Chronic EMEG (50 ppb)
1,2-Dichlorobenzene - ND 3.7 150 RBC(n)
1,4-Dichlorobenzene - 1.3 ND 601 Chronic EMEG (100 ppb)
1,2-Dichloroethane ND 0.86; 1.5 1.7; 1.8 0.04 CREG
809 Chronic EMEG (200 ppb)
cis-1,2-Dichloroethene Trace (0.67);
Trace (0.51)
ND ND 37 RBC(n)
Dichlorodiflouromethane 3.6; 3.9 -d - 108 RBC(n)
Ethylbenzene 1.2; 1.4 3.2 3.9 870 IEMEG (200 ppb)
4-Ethyltoluene Trace (0.59) - - None
Freon 113 Trace (4.8); 32 - - None
2-Hexanone - ND 11; 12 5 RBC(n)
4-Methyl-2-pentanone - 16; 20 9.2 - 23 73 RBC(n)
Methyl Tertiary Butyl Ether 4.0; 4.7 7.7 0.77 - 1.3 2,500 Chronic EMEG (700 ppb)
Methylene Chloride 14; 19 0.81; 1.7 1.1 (2 detections) 3 CREG
104 IEMEG (30 ppb)
Styrene Trace (0.55);
Trace (0.64)
ND 0.96 - 1.4 60 Chronic EMEG
Tetrachloroethylene ND ND 1.3 (2 detections) 2 CREG
Toluene 5.6; 6.4 12; 24 2.8 - 13 3,800 Chronic EMEG (1,000 ppb)
1,1,1-Trichloroethane Trace (0.76);
Trace (0.81)
0.78 ND 3,800 IEMEG (700 ppb)
Trichlororethene Trace (0.58);
Trace (0.85)
ND ND 0.6 CREG
540 IEMEG (100 ppb)
Trichloroflouromethane 3.3; 4.2 3.1; 4.2 1.5 - 1.6 730 RBC(n)
1,2,4-Trimethylbezene 2.0; 2.1 - - 6.2 RBC(n)
1,3,5-Trimethylbenzene Trace (0.59) - - 6.2 RBC(n)
Vinyl Chloride ND 0.090; 0.13 0.10 - 0.17 77 IEMEG (30 ppb)
Xylenes 5.6; 6.9 0.84 - 10 e 1.3 - 28 e 3,040 IEMEG (100 ppb)
Source: Haley & Aldrich, 1999b; Paragon, 1997.

a The indoor samples were collected from the east and west stairwells.
b The indoor air samples were collected from the basement and kitchen.
c The outdoor air samples were collected from the northwest corner of the Morse site, 8th street, and outside the Livramento residence.
d Not reported.
e The maximum concentration was for xylenes, m-,p-.

Table Notes:

CREG = Cancer risk evaluation guide
EMEG = Environmental media evaluation guide
IEMEG = Intermediate environmental media evaluation guide
ND = Not detected
ppb = parts per billion
RBC (n) = Risk based concentration - noncancer
RFC = Reference concentration
RMEG = Reference dose media evaluation guide
µg/m3 = micrograms per cubic meter of air


APPENDIX D -- COMPARISON VALUES

ATSDR comparison values are media-specific concentrations that are considered to be safe under default conditions of exposure. They are used as screening values in the preliminary identification of site-specific "contaminants of concern". The latter term should not be misinterpreted as an implication of "hazard". As ATSDR uses the phrase, a "contaminant of concern" is merely a chemical substance detected at the site in question and selected by the health assessor for further evaluation of potential health effects. Generally, a chemical is selected as a "contaminant of concern" because its maximum concentration in air, water, or soil at the site exceeds one of ATSDR's comparison values.

However, it must be emphasized that comparison values are not thresholds of toxicity. While concentrations at or below the relevant comparison value may reasonably be considered safe, it does not automatically follow that any environmental concentration that exceeds a comparison value would be expected to produce adverse health effects. The whole purpose behind highly conservative, health-based standards and guidelines is to enable health professionals to recognize and resolve potential public health hazards before they can become actual public health consequences. Thus, comparison values are designed to be preventive, rather than predictive, of adverse health effects. The probability that such effects will actually occur depends, not on environmental concentrations alone, but on a unique combination of site-specific conditions and individual lifestyle and genetic factors that affect the route, magnitude, and duration of actual exposure.

Listed and described below are the various comparison values that ATSDR uses to select chemicals for further evaluation, as well as other non-ATSDR values that are sometimes used to put environmental concentrations into a meaningful frame of reference.

CREG = Cancer Risk Evaluation Guides
MRL = Minimal Risk Level
EMEG = Environmental Media Evaluation Guides
IEMEG = Intermediate Environmental Media Evaluation Guide
RMEG = Reference Dose Media Evaluation Guide
RfD = Reference Dose
RfC = Reference Dose Concentration
RBC = Risk-Based Concentration
DWEL = Drinking Water Equivalent Level
MCL = Maximum Contaminant Level
CLHA = Child Longer Term Health Advisory

Cancer Risk Evaluation Guides (CREGs) are estimated contaminant concentrations expected to cause no more than one excess cancer in a million persons exposed over a lifetime. CREGs are calculated from EPA's cancer slope factors, or cancer potency factors, using default values for exposure rates. However, neither CREGs nor CSFs can be used to make realistic predictions of cancer risk. The true risk is always unknown and may be as low as zero.

Minimal Risk Levels (MRL) are estimates of daily human exposure to a chemical (doses expressed in mg/kg/day) that are unlikely to be associated with any appreciable risk of deleterious noncancer effects over a specified duration of exposure. MRLs are calculated using data from 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 Toxicological Profiles for specific chemicals.

Environmental Media Evaluation Guides (EMEGs) are concentrations that are calculated from ATSDR minimal risk levels by factoring in default body weights and ingestion rates.

Intermediate Environmental Media Evaluation Guides (IEMEG) are calculated from ATSDR minimal risk levels; they factor in body weight and ingestion rates for intermediate exposures (those occurring for more than 14 days and less than 1 year).

Reference Dose Media Evaluation Guide (RMEG) is the concentration of a contaminant in air, water or soil that corresponds to EPA's RfD for that contaminant when default values for body weight and intake rates are taken into account.

EPA's Reference Dose (RfD) is an estimate of the daily exposure to a contaminant unlikely to cause noncarcinogenic adverse health effects. Like ATSDR's MRL, EPA's RfD is a dose expressed in mg/kg/day.

Reference Concentrations (RfC) is a concentration of a substance in air that EPA considers unlikely to cause noncancer adverse health effects over a lifetime of chronic exposure.

Risk-Based Concentrations (RBC) are media-specific concentrations derived by Region III of the Environmental Protection Agency Region III from RfDs, RfC's, or EPA's cancer slope factors. They represent concentrations of a contaminant in tap water, ambient air, fish, or soil (industrial or residential) that are considered unlikely to cause adverse health effects over a lifetime of chronic exposure. RBCs are based either on cancer ("c") or noncancer ("n") effects.

Drinking Water Equivalent Levels (DWEL) are based on EPA's oral RfD and represent corresponding concentrations of a substance in drinking water that are estimated to have negligible deleterious effects in humans at an intake rate of 2 L/day for life, assuming that drinking water is the sole source of exposure.

Maximum Contaminant Levels (MCLs) represent contaminant concentrations in drinking water 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 2 liters of water per day.

Child Longer Term Health Advisory (CLHA) represents the concentration of a substance in drinking water that would have no deleterious effect on a child exposed for up to 7 years.


APPENDIX E -- ATSDR METHODOLOGY

In public health assessments, ATSDR addresses the likelihood that exposure to contaminants at the maximum concentrations detected would result in adverse health effects. While the relative toxicity of a chemical is important, the response of the human body to a chemical exposure is determined by several additional factors, including the concentration (how much); the duration of exposure (how long); and the route of exposure (breathing, eating, drinking, or skin contact). Lifestyle factors (i.e., occupation and personal habits) have a major impact on the likelihood, magnitude, and duration of exposure. Individual characteristics such as age, sex, nutritional status, overall health, and genetic constitution affect how a human body absorbs, distributes, metabolizes, and eliminates a contaminant. A unique combination of all these factors will determine the individual's physiologic response to a chemical contaminant and any adverse health effects the individual may suffer as a result of the chemical exposure.

ATSDR has determined levels of chemicals that can reasonably (and conservatively) be regarded as harmless, based on the scientific data the agency has collected in its toxicological profiles. The resulting comparison values and health guidelines, which include ample safety factors to ensure protection of sensitive populations, are used to screen contaminant concentrations at a site and to select substances ("chemicals of concern") that warrant closer scrutiny by agency health assessors and toxicologists.

It is a point of key importance that ATSDR's (and EPA's) comparison values and health guidelines represent conservative levels of safety and not thresholds of toxicity. Thus, although concentrations at or below a comparison value may reasonably be considered safe, it does not automatically follow that any concentration above a comparison value will necessarily produce toxic effects. To the contrary, ATSDR's (and EPA's) comparison values are intentionally designed to be much lower, usually by orders of magnitude, than the corresponding no-effect levels (or lowest-effect levels) determined in laboratory studies. ATSDR uses comparison values (regardless of source) solely for the purpose of screening individual contaminants. In this highly conservative procedure, ATSDR considers that a compound warrants further evaluation if the highest single recorded concentration of that contaminant in the medium in question exceeds that compound's lowest available comparison value (e.g., cancer risk evaluation guides or other chronic exposure values) for the most sensitive, potentially exposed individuals (e.g., children or pica children). This highly conservative process results in the selection of many contaminants as "chemicals of concern" that will not, upon closer scrutiny, be judged to pose any hazard to human health. However, ATSDR judges it prudent to use a screen that "lets through" many harmless contaminants rather than one that overlooks even a single potential hazard to public health. Even those contaminants of concern that are ultimately labeled in the toxicologic evaluation as potential public health hazards are so identified solely on the basis of the maximum concentration detected. The reader should keep in mind the protectiveness of this approach when considering the potential health implications of ATSDR's evaluations.

Because a contaminant must first enter the body before it can produce any effect, adverse or otherwise, on the body, the toxicologic discussion in public health assessments focuses primarily on completed pathways of exposure, i.e., contaminants in media to which people are known, or are reasonably expected to have been exposed, such as water that may be used for drinking water and air in the breathing zone.

To determine whether people were, or continue to be, exposed to contaminants originating from a site, ATSDR evaluates the factors that lead to human exposure. These factors or elements include (1) a source of contamination, (2) transport through an environmental medium, (3) a point of exposure, (4) a route of human exposure, and (5) an exposed population. Exposure pathways fall into one of three categories:

  • Completed Exposure Pathway. ATSDR calls a pathway "complete" if it is certain that people are exposed to contaminated media. Completed pathways require that the five elements exist and indicate that exposure to the contaminant has occurred, is occurring, or will occur.

  • Potential Exposure Pathway. Potential pathways are those in which at least one of the five elements is missing but could exist. Potential pathways indicate that exposure to a contaminant could have occurred, could be occurring, or could occur in the future. Potential exposure pathways refer to those pathways where (1) exposure is documented, but there is not enough information available to determine whether the environmental medium is contaminated, or (2) an environmental medium has been documented as contaminated, but it is unknown whether people have been, or may be, exposed to the medium.

  • Eliminated Exposure Pathway. In an eliminated exposure pathway, at least one of the five elements is missing and will never be present. From a human health perspective, pathways can be eliminated from further consideration if ATSDR is able to show that (1) an environmental medium is not contaminated, or (2) no one is exposed to contaminated media.

Please refer back to the Discussion section of this public health assessment for ATSDR's evaluation of the Morse Cutting Tools site.


APPENDIX F -- GLOSSARY OF TERMS

Absorption
The process of taking in, as when a sponge takes up water. Chemicals can be absorbed through the skin into the bloodstream and then transported to other organs. Chemicals can also be absorbed into the bloodstream after breathing or swallowing.


Acute
Occurring over a short time, usually a few minutes or hours. For purposes of health assessment, ATSDR defines acute exposures as those lasting up to two weeks. An acute exposure can result in short- or long-term health effects.


Ambient
Surrounding. For example, ambient air is usually outdoor air (as opposed to indoor air).


Carcinogen
Any substance that may produce cancer.


Chronic
Occurring over a long period of time (more than 1 year).


Comparison Values
Estimated contaminant concentrations in specific media that are not likely to cause adverse health effects, given a standard daily ingestion rate and standard body weight. The comparison values are calculated from the scientific literature available on exposure and health effects.


Concentration
The amount of one substance dissolved or contained in a given amount of another. For example, sea water contains a higher concentration of salt than fresh water.


Contaminant
Any substance or material that enters a system (e.g., the environment, human body, food, etc.) where it is not normally found.


Dermal
Referring to the skin. Dermal absorption means absorption through the skin.


Dose
The amount of substance that actually enters the body over a specified period of time. Dose is expressed in terms of unit weight of chemical per unit body weight per unit of time, e.g., mg/kg/day.


Epidemiology
The study of the occurrence of disease in human populations and the factors associated with the frequency and distribution of that disease.


Exposure
Contact with a chemical by swallowing, breathing, or direct contact (such as through the skin or eyes). Exposure may be short term (acute) or long term (chronic).


Hazard
A possible source of danger or harm (i.e., in this context, adverse health effects).


Health Outcome Data
Information on the prevalence of death, disease or other health-related factors in the community. Such information may be derived from local, state, and national databases, medical records, tumor and disease registries, and health studies.


Indeterminate Public Health Hazard
A formal conclusion category that ATSDR reserves for sites at which, due to the unavailability of critical information, no determination can be made regarding the existence or non-existence of a potential threat to health in the community.


Ingestion
Swallowing (such as eating or drinking). Chemicals can get in or on food, drink, utensils, cigarettes, or hands, from which they can be ingested. After ingestion, chemicals can be absorbed into the blood and distributed throughout the body.


Inhalation
Breathing. Exposure may occur from inhaling contaminants, because the contaminants can be deposited in the lungs, taken into the blood, or both.


Media (Environmental)
Soil, water, air, plants, animals, or any other parts of the environment that can contain contaminants.


Petitioned Public Health Assessment
A public health assessment conducted at the request of a member of the public. When a petition is received, a team of environmental and health scientists is assigned to gather information to ascertain, using standard public health criteria, whether there is a reasonable basis for conducting a public health assessment. Once ATSDR confirms that a public health assessment is needed, the petitioned health assessment process is essentially the same as the public health assessment process.


Public Health Action
As used in ATSDR public health advisories, public health assessments, and health consultations, this term refers to activities designed to prevent exposures and/or to mitigate or prevent adverse health effects in populations living near hazardous waste sites or releases. These actions may include eliminating immediate exposures (e.g., by providing an alternative water supply), monitoring indicators of exposure in bodily fluids (e.g., blood and urine) to better assess exposure, and providing health education for health care providers and community members.


Public Health Hazard
A formal conclusion category that ATSDR reserves for sites at which chronic, long-term exposure (>1 year) to potentially hazardous contaminants may cause illness in the community.


Risk
The possibility of suffering harm. As regulatory agencies use the term, it usually refers to the hypothetical probability of suffering adverse health effects due to chemical exposure.


Route of Exposure
The way in which a person may contact a chemical substance. The primary routes of exposure are ingestion (as in eating or drinking), inhalation (as in breathing), and dermal or skin contact (as in bathing).


Toxicological Profile
An ATSDR reference document that identifies and reviews key, peer-reviewed literature describing the properties of a hazardous substances, the levels of significant exposure to that substance, and the associated acute, subacute (intermediate), and chronic health effects in laboratory animals and humans, where known. Toxicological Profiles also describe the experimental and/or epidemiological bases of ATSDR's existing comparison values for the substance, and identify knowledge gaps and research needs.

APPENDIX G -- PUBLIC COMMENTS

ATSDR released the Morse Cutting Tools public health assessment for public review and comment from September 28 through December 22, 1999. Upon receiving a request on December 21, 1999, to extend the public comment period, ATSDR extended the public comment period until March 1, 2000. Each comment received was logged and became part of the administrative record. This appendix contains both the comments received during the public comment period and ATSDR's response to those comments. The comments have been numbered and are in italic with the response directly below each comment.

Comment 1: What was done with the demolition materials that were buried on-site?

Response 1:
ATSDR reviewed site files and contacted the New Bedford Department of Public Works to gather information about buried demolition material (ATSDR, 2000). A large quantity of demolition material was originally buried on-site in the buildings' basements which did not meet the specifications of the demolition contract. These specifications directed that asphalt, brick, and concrete could be used as backfill as long as they were processed to pieces no greater than 6 inches in diameter. Also, the specifications directed that no wood debris could be used as backfill. Once it was noted that the backfill material did not meet specifications, portions of the site were dug out and the backfill material was removed. Once tested, this backfill material was sent to a landfill. These areas on-site were later filled with clean backfill (ATSDR, 2000; Haley & Aldrich, 1998e).

Comment 2: Could contamination from the site have entered the municipal water lines during demolition activities, thereby causing my family to experience skin problems (like burning sensations) when bathing?

Response 2:
ATSDR contacted the City of New Bedford Water Department to ask about pipe leaks (New Bedford Water Department, 1999). The water department researched pipe breaks in the area of the Morse site during demolition activities, i.e., from 1991 to the present. The only break close to the site was on South Sixth Street near Wing Street in August 1996. The free product (i.e., crude oil) contamination plume is near Purchase Street, which is on the opposite side of the site. No leaks have been reported along the Purchase Street pipe located adjacent to the Morse site from 1991 to the present. Therefore, ATSDR would not expect contamination from the site to be entering the municipal water lines or contributing to adverse health effects.

Comment 3:There is one aspect throughout the public health assessment that is speculative inasmuch as data supporting past completed air exposure pathways does not exist. Therefore, we would suggest that the document reflect only existing information known about the site. The following provide suggested changes:

3A) Section 1, 2nd paragraph, 2nd sentence: change the word "completed" to "potential".
3B) Section 1, 2nd paragraph, 3rd sentence: change the words "the extent to which" to "whether".
3C) Section 4.2.3, 1st paragraph, 3rd and 4th sentences: delete the sentences "However, given the types of manufacturing processes and the amount of chemicals used at the site during operations, and the close proximity of residences, it appears possible that residents were exposed to air contamination in the past. ATSDR, therefore, considers ambient air to represent a past completed exposure pathway."
3D) Section 4.2.3, 1st paragraph, 5th sentence: change the last sentence of this paragraph to "Without ambient air sampling data, it is not possible to conclude that past off-site air exposures occurred or contributed to reported respiratory ailments."
3E) Section 5, Response to first community concern, 1st paragraph, 2nd sentence: delete the sentence "Air contamination, in the form of dust, from site demolition activities would have been the main contributor to respiratory ailments at that time."
3F) Section 5, Response to first community concern, 2nd paragraph, 2nd sentence: delete sentence "Given the types of manufacturing processes and the amount of chemicals used at the site during operations, and the close proximity of residences, it appears possible that residents were exposed to air contamination in the past."
3G) Section 5, Response to first community concern, 2nd paragraph, 4th sentence: delete the words "of off-site air exposures."
3H) Appendix C, Table 1, Completed Exposure Pathways, Air: delete "Past" from the Time Frame column.

Response 3:
Ambient off-site air has been classified by ATSDR as a past completed exposure pathway. Numerous manufacturing activities that used a variety of volatile chemicals occurred on-site directly across the street from residences. While ATSDR recognizes that chemical-specific air sampling data are not available to verify that past air exposures did indeed occur, it is the agency's opinion that past air exposures were possible when the facility was operating. No changes to the main text of the document have been made.

Comment 4: ATSDR received comments on the December 1999 Morse Cutting Tools fact sheet. The comments were similar to Comment 3, i.e., that air data supporting past completed air exposure pathways does not exist so the fact sheet should be changed to reflect only existing information known about the site.

Response 4:
No changes were made to the fact sheet (refer to Response 3).

Comment 5: The report lists the petitioner as Congressman Barney Frank. The community readily acknowledges and is grateful for the support of the Congressman and his office but has indicated that the role of the residents deserves to be acknowledged as a starting point for the public health assessment.

Response 5:
Public health assessment activities at the Morse site began in response to Congressman Barney Frank's petition letter. However, learning what people in the area know about a site and what concerns they may have about its impact on their health is of particular importance to ATSDR. Responding to community health concerns is a major focus of the public health assessment process. ATSDR has added these statements to Section 2 (Purpose and Health Issues) to further define the role of the residents in the public health assessment process.

Comment 6: The ATSDR summary of the groundwater data states that "on-site groundwater contains contamination at levels of health concern for ingestion as drinking water". The ATSDR does not find a pathway of exposure - as there is no existing or planned reliance on the groundwater for drinking purposes - and concludes that this media is not of public health concern. Comments on the Interim Report on Phase II - Comprehensive Site Assessment are in agreement that the principal concern on-site is the contaminated groundwater (document provided by commentor).

Response 6:
The comments regarding groundwater that were submitted on the Phase II - Comprehensive Site Assessment focus on the need for additional groundwater sampling and analysis, and continued removal of oil from the groundwater surface. ATSDR has made similar recommendations with regard to groundwater in this public health assessment (i.e., continue monitoring groundwater contamination on- and off-site, and continue removing free product from on-site groundwater to prevent further off-site migration of groundwater contamination).

Comment 7: Based on these analyses the ATSDR concludes that the former Morse Cutting Tools site poses a past Indeterminate Public Health Hazard. This historical perception of risk is a matter of some concern to residents as the public record reflects.

Response 7:
ATSDR agrees that residents are concerned about historical issues related to the site. Several areas of this public health assessment note these concerns, such as Section 2 (Purpose and Health Issues) and Section 5 (Community Health Concerns). Unfortunately, environmental sampling data were not collected when the facility was operating. Therefore, ATSDR cannot comment on potential environmental hazards associated with the facility in the past (prior to 1990). However, the limited data collected during and after demolition activities do not indicate contaminants were released off-site into the environment at levels of health concern.

Comment 8: The ATSDR concludes that the former Morse Cutting Tools site currently poses No Apparent Public Health Hazard. The dynamic nature of the site interjects some uncertainty - especially with possible re-use scenarios still in development. Previous comments on a Response Action Outcome (RAO) (document provided by commentor) for the West Parcel of the site stated the need to provide a quantitative estimate of exposure and risk from eating produce grown on the site.

Response 8:
ATSDR public health assessments reflect an evaluation of available environmental data based on current information concerning site conditions. ATSDR is aware there are several possible re-use scenarios for this site. At this time, ATSDR does not see the need for estimating potential future exposures from eating garden produce grown on the site; however, if site conditions change considerably in the future, ATSDR will re-evaluate the environmental data, if requested, based on the new site conditions.



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