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PUBLIC HEALTH ASSESSMENT

BATAVIA LANDFILL
BATAVIA, GENESEE COUNTY, NEW YORK

APPENDIX A

Figure 1
Figure 1.

APPENDIX B

Table 1.

Batavia Landfill
Summary of Groundwater Data (On-Site Monitoring Wells)
Remedial Investigation
(All values in micrograms per liter)
(see Table 6 for Comparison Values)


Contaminant Concentration Range

Upper
Fill/Soil
Zone
Lower
Soil
Zone
Lower
Bedrock
Zone

*acetone ND-40 ND-2,300 ND-50
*arsenic ND-105 ND-90 ND-10
*barium ND-26,700 ND-824 ND-550
*benzene ND-24 ND-17 ND-1
*2-butanone ND-4 ND-13,000 ND-6
*chlorobenzene ND-25 ND ND-1
*chloroethane ND-170 ND-100 ND-96
chromium ND-14 ND-13 NA
*1,1-dichloroethane ND-200 ND-340 ND-20
*trans-1,2-dichloroethene ND-3 ND-160 ND
*ethylbenzene ND-140 ND-46 ND-1
*iron 456-28,800 ND-141,000 ND-3,110
*lead ND-28 ND-79.6 ND-20
*magnesium 20,000-661,000 31,500-459,000 70-96,300
*manganese 30-551 50-2,180 ND-240
*4-methyl-2-pentanone ND ND-360 ND
*4-methylphenol ND-7 ND-4,700 ND-5
*phenols, total ND ND-1,870 ND-70
*toluene ND-16 ND-1,900 ND-3
*1,1,1-trichloroethane ND-110 ND-60 ND
*trichloroethene ND-26 ND-99 ND
*vinyl chloride ND ND-480 ND
*xylenes, total ND-300 ND-130 ND-4


NA - not analyzed
ND - not detected

*Contaminant selected for further evaluation.

Source: Goldberg-Zoino Associates of New York, P.C. 1989. Batavia Landfill Site Draft Remedial Investigation Report.


Table 2.
Batavia Landfill
Summary of On-Site Subsurface Soil and Waste Data
Remedial Investigation
(All values in milligrams per kilogram)



Compound Concentration Range Typical Background Range** Comparison Value*** Source****

Subsurface Soil Contaminanta

*acetone 210 NA 2 EPA RfD
*2-butanone 45-1,700 NA 2.2 EPA HEAST
*chromium 42-3,200 10-40 250 EPA RfD
copper 31-410 <1-25 6,500 EPA RfD
*ethylbenzene 190-600 NA 200 EPA RfD
*lead 77-2,000 10-300 --
*toluene 6.6-5,100 NA 230 EPA RfD
xylenes, total 830-2,100 NA 4,620 EPA RfD

Waste Contaminantb

aluminum 13,300-248,000 7,000-100,000 --
*arsenic 20.2-164 10-20 15 EPA RfD
*barium 28,800 300-500 3,500 EPA RfD
cadmium 4.2-17.3 <0.5-1 10 ATSDR MRL
*chromium 101-313,000 10-40 250 EPA RfD
copper 76-1,010 <1-25 6,500 EPA RfD
iron 236-8,770 10,000-40,000 --
lead 8.6-94.7 10-300 --
manganese 444-1,850 500-3,000 7,000 EPA RfD
*magnesium 24,900-410,000 50-6,000 --
*methylene chloride 0.013-0.14 NA 0.07 EPA CPF
zinc 513-3,670 50-100 10,000 EPA RfD


NA - not available
aSubsurface soil at a depth of 4 feet or greater.
bWaste contaminants at a depth of greater than 3.5 feet except for barium which was found at a depth of 1 foot or greater.
*Contaminant selected for further evaluation.
**References: Clarke et al. (1985); Connor et al. (1957); Dragun (1988);
Frank et al. (1976); McGovern (1988); Shacklette and Boerngen (1984)
***Comparison values for volatile and semi-volatile organics are based on ingestion of soil and homegrown vegetables; comparison values for metals (inorganics) are based on ingestion of soil.
****ATSDR MRL = ATSDR Minimal Risk Level
     EPA RfD = EPA Reference Dose
     NYS CREG = New York State Cancer Risk Evaluation Guideline
     EPA HEAST = EPA Health effects Assessment Summary Tables

Source: Goldberg-Zoino Associates of New York, P.C. 1989. Batavia Landfill Site Draft Remedial Investigation Report.


Table 3.

Batavia Landfill
Summary of On-Site/Off-Site Surface Water Data
Remedial Investigation
(All values in micrograms per liter)
(see Table 6 for Comparison Values)


Surface Water Contaminant Concentration Range

On-Site Off-Site

*acetone ND ND-4,990
*barium 76-6,560 ND-21,700
*2-butanone ND 12,000
*cadmium NA 300
*chloroethane ND-58 ND-38
*chromium NA ND-212
*ethylbenzene ND 130
*iron NA 480-1,570,000
*lead ND-12 ND-3,720
*magnesium 19,100-63,600 18,500-348,000
*manganese 58-512 30-3,300
*methylene chloride ND-8 ND-5
*toluene ND ND-1,400
*1,1,1-trichloroethane ND ND-240
*xylenes, total ND ND-98
*zinc ND-65 ND-19,800

NA - not available
ND - not detected

*Contaminant selected for further evaluation.

Source: Goldberg-Zoino Associates of New York, P.C. 1989. Batavia Landfill Site Draft Remedial Investigation Report.


Table 4.

Batavia Landfill
Summary of On-Site/Off-Site Sediment Data
Remedial Investigation
(All values in milligrams per kilogram)


Sediment
Contaminant
Concentration Range

Typical
Background
Range**
Comparison
Value***
Source****
On-Site Off-Site

acetone ND-0.52 ND-2.3 NA 5,000 EPA RfD
aluminum 3.11-16,400 7,000-100,000 --
*arsenic ND-110 10-20 15 EPA RfD
*barium 87.2-1,270 34.2-5,200 300-500 3,500 EPA RfD
2-butanone ND-1.3 NA 2,500 EPA RfD
cadmium ND-14 0.5-<1 25 EPA RfD
*chromium 10.5-189 7.6-3200 10-40 250 EPA RfD
cyanide ND-7.1 NA 1,000 EPA RfD
iron 5,340-362,000 10,000-40,000 --
*lead 10.8-531 8.7-1,220 10-300 --
*magnesium 4,060-31,200 1,800-39,000 50-6,000 250,000 NYS RfG
manganese 196-665 102-2,410 500-3,000 7,000 EPA RfD
mercury ND-0.9 0.01-3.4 15 EPA RfD
phenols, total ND-5.3 NA 30,000 EPA RfD
toluene ND-0.066 NA 10,000 EPA RfD
zinc 59.4-1,460 24-1,730 50-100 10,000 EPA RfD

NA - not available
ND - not detected

*Contaminant selected for further evaluation.

**References: Clarke et al. (1985); Connor et al. (1957); Davis and Bennett (1983); Dragun (1988); Frank et al. (1976); McGovern (1988); Shacklette and Boerngen (1984)

***Comparison value for noncancer risk determined for a 10 kilogram child who ingests 200milligrams soil per day.

****NYS RfG = New York State Risk Reference Guideline
     EPA RfD = EPA Risk Reference Dose

Source: Goldberg-Zoino Associates of New York, P.C. 1989. Batavia Landfill Site Draft Remedial Investigation Report.


Table 5.

Batavia Landfill
Summary of Off-Site Groundwater Data
(All values in micrograms per liter)
(see Table 6 for comparison Values)


Groundwater Contaminant Concentration Range

Private Wells Trailer Park Well Municipal Well

1,1-dichloroethane ND-1.0 ND ND
*trans-1,2-dichloroethene ND-7.1 ND ND
*iron 230-3,230 750 1,250
*methylene chloride ND-10 ND ND
phenols, total NA 52 ND
tetrachloroethene ND-1.0 ND ND
*1,1,1-trichloroethane ND-240 ND ND
*trichloroethene ND-20 ND ND
*trichlorofluoromethane ND ND ND-11

NA - not analyzed
ND - not detected

*Contaminant selected for further evaluation.

Source: NYS DOH Project Files: Batavia Files, 1980-1993.


Table 6.

New York State and Federal Standards and Public Health Assessment Comparison Values forContaminants Found in Sources of Drinking Water.
(All values in micrograms per liter)


Compound New York State

U.S. EPA

Comparison
Value*
Source**
Groundwater Surface
Water
Drinking
Water
Drinking
Water

arsenic 25 50 50 50 11 EPA RfD
barium 1,000 2,000 1,000 2,000 2,000 EPA LTHA
cadmium 10 10 5 5 5 EPA LTHA
iron 300 300 300 300s -- --
lead 25 50 15*** 15*** -- --
magnesium 35,000g 35,000 -- -- 35,000 NYS RfG
manganese 300 300 300 50s 175 EPA RfD
mercury 2 2 2 2 2 EPA LTHA
acetone 50 -- 50 -- 700 EPA RfD
benzene 0.7 0.7 5 5 0.7 NYS CREG
2-butanone 50 50 50 -- 200 EPA LTHA
chlorobenzene 5 20 5 100 140 EPA RfD
chloroethane 5 -- 5 -- -- --
1,1-dichloroethane 5 5g 5 -- 700 EPA RfD
trans-1,2-dichloroethene 5 5g 5 100 100 EPA LTHA
ethyl benzene 5 5g 5 700;30ps 700 EPA LTHA
4-methyl-2-pentanone 50 50g 50 -- 350 EPA RfD
4-methyl phenol 1 1 50 -- 360 EPA RfD
methylene chloride 5 5g 5 5 4.7 ATSDR CREG
phenols, total 1 1 -- -- -- --
tetrachloroethene 5 0.7g 5 5 0.7 NYS CREG
toluene 5 5g 5 1,000;40ps 1,000 EPA LTHA
1,1,1-trichloroethane 5 5g 5 200 200 EPA LTHA
trichloroethene 5 3g 5 5 3 NYS CREG
trichlorofluoromethane 5 5g 5 -- 2,200 EPA RfD
vinyl chloride 2 0.3g 2 2 0.02 EPA CPF
xylenes 5n 5g,n 5n 10,000;20ps 10,000 EPA LTHA
zinc 300 300 5,000 5,000s 2,100 EPA LTHA
chromium 50 50 100 100 100 EPA LTHA

g = guidance
n = applies to each isomer separately unless isomers are analytically indistinguishable
p = proposed national primary drinking water standard
ps = proposed national secondary drinking water standard
s = national secondary drinking water standard

*Comparison value determined for a 70 kilogram adult who ingests 2 liters of water per day.

**ATSDR CREG = ATSDR Cancer Risk Evaluation Guide
   EPA LTHA = US EPA Drinking Water Lifetime Health Advisory
   EPA CPF = US EPA Cancer Potency Factor
   EPA RFD = US EPA Reference Dose
   NYS CREG = NYS Cancer Risk Evaluation Guideline
   NYS RfG = NYS Risk Reference Guideline

***The maximum contaminant level goal (MCLG) for lead is zero and the action level is 15 mcg/L at the tap.


APPENDIX C

This Appendix was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

    Agency for Toxic Substances and Disease Registry
    Division of Health Assessment and Consultation
    Attn: Chief, Program Evaluation, Records, and Information Services Branch,
    MS E-56
    1600 Clifton Road NE,
    Atlanta, Georgia 30333

APPENDIX D

This Appendix was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

    Agency for Toxic Substances and Disease Registry
    Division of Health Assessment and Consultation
    Attn: Chief, Program Evaluation, Records, and Information Services Branch,
    MS E-56
    1600 Clifton Road NE,
    Atlanta, Georgia 30333

APPENDIX E

This Appendix was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

    Agency for Toxic Substances and Disease Registry
    Division of Health Assessment and Consultation
    Attn: Chief, Program Evaluation, Records, and Information Services Branch,
    MS E-56
    1600 Clifton Road NE,
    Atlanta, Georgia 30333

APPENDIX F

PROCEDURE FOR EVALUATING POTENTIAL HEALTH RISKS FROM SITE-ASSOCIATED CONTAMINANTS OF CONCERN

To evaluate the potential health risks from contaminants of concern associated with the BataviaLandfill site, the New York State Department of Health assessed the risks for cancer andnoncancer health effects.

Increased cancer risks were estimated by using site-specific information on exposure levels forthe contaminant of concern and interpreting them using cancer potency estimates derived for thatcontaminant by the US EPA or, in some cases, by the NYS DOH. The following qualitativeranking of cancer risk estimates, developed by the NYS DOH, was then used to rank the riskfrom very low to very high. For example, if the qualitative descriptor was "low", then the excesslifetime cancer risk from that exposure is in the range of greater than one per million to less thanone per ten thousand. Other qualitative descriptors are listed below:

Excess Lifetime Cancer Risk
Risk Ratio Qualitative Descriptor
equal to or less than one per million very low
greater than one per million to less than one per ten thousand low
one per ten thousand to less than one per thousand moderate
one per thousand to less than one per ten high
equal to or greater than one per ten very high

An increased excess lifetime cancer risk is not a specific estimate of expected cancers. Rather, itis an estimate of the probability that a person may develop cancer sometime in his or her lifetimefollowing exposure to that contaminant.

There is insufficient knowledge of cancer mechanisms to decide if there exists a level ofexposure to a cancer-causing agent below which there is no risk of getting cancer, namely, athreshold level. Therefore, every exposure, no matter how low, to a cancer-causing compound isassumed to be associated with some increased risk. As the dose of a carcinogen decreases, thechance of developing cancer decreases, but each exposure is accompanied by some increasedrisk.

There is no general consensus within the scientific or regulatory communities on what level ofestimated excess cancer risk is acceptable. Some have recommended the use of the relativelyconservative excess lifetime cancer risk level of one in one million because of the uncertaintiesin our scientific knowledge about the mechanism of cancer. Others feel that risks that are loweror higher may be acceptable, depending on scientific, economic and social factors. An increasedlifetime cancer risk of one in one million or less is generally considered an insignificant increasein cancer risk.

For noncarcinogenic health risks, the contaminant intake was estimated using exposureassumptions for the site conditions. This dose was then compared to a risk reference dose(estimated daily intake of a chemical that is likely to be without an appreciable risk of healtheffects) developed by the US EPA, ATSDR and/or NYS DOH. The resulting ratio was thencompared to the following qualitative scale of health risk:

Qualitative Descriptions for
Noncarcinogenic Health Risks
Ratio of Estimated Contaminant
Intake to Risk Reference Dose
Qualitative
Descriptor
equal to or less than the risk reference dose minimal
greater than one to five times the risk reference dose low
greater than five to ten times the risk reference dose moderate
greater than ten times the risk reference dose high

Noncarcinogenic effects unlike carcinogenic effects are believed to have a threshold, that is, adose below which adverse effects will not occur. As a result, the current practice is to identify,usually from animal toxicology experiments, a no-observed-effect-level (NOEL). This is theexperimental exposure level in animals at which no adverse toxic effect is observed. The NOELis then divided by an uncertainty factor to yield the risk reference dose. The uncertainty factor isa number which reflects the degree of uncertainty that exists when experimental animal data areextrapolated to the general human population. The magnitude of the uncertainty factor takes intoconsideration various factors such as sensitive subpopulations (for example, children or theelderly), extrapolation from animals to humans, and the incompleteness of available data. Thus,the risk reference dose is not expected to cause health effects because it is selected to be muchlower than dosages that do not cause adverse health effects in laboratory animals.

The measure used to describe the potential for noncancer health effects to occur in an individualis expressed as a ratio of estimated contaminant intake to the risk reference dose. If exposure tothe contaminant exceeds the risk reference dose, there is concern for potential noncancer healtheffects. As a rule, the greater the ratio of the estimated contaminant intake to the risk referencedose, the greater the level of concern. A ratio equal to or less than one is generally considered aninsignificant (minimal) increase in risk.

APPENDIX G
SUMMARY OF PUBLIC REVIEW PERIOD CONCERNS

Batavia Landfill
Town of Batavia, Genesee County, New York

This responsiveness summary was prepared to address public concern on the Batavia Landfilldraft P

blic Health Assessment. The public was invited to review the draft document during the public review period which ran from April 12, 1993 to May 12, 1993 (extended to May 19, 1993). Eight sets of responses were received by the New York State Department of Health. Some comments were consolidated or grouped together to incorporate similar concerns raised by more than one person. If you have any questions about this responsiveness summary, contact the Health Liaison Program at the toll-free number 1-800-458-1158, extension 402.

COMMENTS RECEIVED FROM THE PUBLIC

Comment #1

We are appreciative of the work performed on behalf of the citizens of this community.

Response #1

Thank you.

Comment #2

Page 5, "R.E. Chapman Industries" should probably read "R.E. Chapin Industries".

Response #2

Revised.

Comment #3

Page 7, D - The report indicates the distance of the Village of Oakfield wells as 1.5 northwest ofthe landfill, yet the map in Figure 1 of Appendix A clearly shows that these wells are well withinone (1) mile of the landfill. Which is correct?

Response #3

The map of the Batavia Landfill has been revised (Appendix A). It shows both the propertyboundaries and the waste disposal location. The Village of Oakfield municipal wells are aboutone mile northwest of the waste disposal area. The report text has also been revised.

Comment #4

The background section presents facts that were known for years.

Response #4

The background section of the report is intended to provide a description, history and nature ofsite operations, a summary of community health concerns and regulatory involvement, acharacterization of populations near the site, land use and natural resources near the site, and anevaluation of health outcome data.

Comment #5

After reading the draft public health assessment and attending a meeting conducted by the EPA(Fall, 1992), I fear what may happen to the Village of Oakfield if our wells are found to becontaminated. We were told then that the test wells had not been tested since 1987, andpromised a full report by the spring of 1993. So far no report...worse yet, no testing.

Comment #5A

The Village of Oakfield is extremely concerned over the very lax position that the EPA is takingwith the monitoring of test wells between the Village of Oakfield Well Site and the landfill. Contaminants known to be found in the landfill were detected in our water source.

Comment #5B

Although there is no current threat to Village of Oakfield residents, this situation could change atany time. A single test could change all that. We cannot depend on the EPA to perform thetesting. The New York State Department of Health and Village of Oakfield will continue thesetests.

Responses #5, #5A and #5B

Although the municipal wells were reported to be contaminated with trichlorofluoromethane andtotal phenols in 1982, follow-up samples collected from the municipal wells have not beencontaminated. Monitoring wells BL-16R and BL-25R are located between the landfill and themunicipal wells. These monitoring wells were sampled in 1987 and in November 1992 and nocontamination was detected. A comprehensive groundwater monitoring system will be institutedas part of the final site remedy. In addition, routine monitoring of the municipal wells ismandated by New York State. The sampling results for the municipal wells are maintained onfile in NYS DOH office in Albany, New York. Those reports on the landfill investigation are indocument repositories in Batavia, New York at the Richmond Library, 19 Ross Street and theBatavia Town Hall, 4165 West Main Street Road.

Comment #6

I lived on Kelsey Road for 11 years and developed breast cancer in 1989. Cancer runs in myfamily, so I am not blaming water contamination, but could it have been a contributing factor? We are very concerned for people who live in that area. We have since moved.

Response #6

Water from this particular well was sampled by the NYS DOH in January 1992. Nocontaminants were detected. Based on this analytical data and the distance that the well is fromthe landfill, people at this location were unlikely to have been exposed to contaminants in thedrinking water.

Comment #7

Industrial wastes were buried at the landfill and at a nearby location that no one ever checked on. It was owned by a town councilman and was agricultural land. It may be hazardous to publichealth and may be in groundwater.

Comment #7A

If you really want to have a safe environment, check land behind old brick building on KelseyRoad.

Response #7 and #7A

Specific details and information about these disposal locations and nature of the wastes should beprovided to the New York State Department of Environmental Conservation (NYS DEC), UnitedStates Environmental Protection Agency (US EPA) and New York State Department of Health(NYS DOH) for appropriate follow-up. We have sent your comments to both agencies.

Comment #8

I believe that the ground is filled with contaminants.

Comment #8A

The Batavia Landfill site is still contaminated and needs to be cleaned up. This needs to be partof your recommendations.

Response #8 and #8A

Contaminants associated with the disposal of wastes at the landfill will be addressed as part ofthe final site remedy, following completion of the feasibility study (FS) for the site.

Comment #9

There is no control to prevent trespassing by the public.

Response #9

With the exception of a gate to restrict vehicular access, there are no other barriers to restrictaccess to the site. NYS DOH recommended in this document that public access to the landfill berestricted.

Comment #10

All wells in the area are supposedly contaminated to some extent.

Response #10

The NYS DOH collected off-site groundwater samples in May 1989, August 1991, October 1991and January 1992. Groundwater samples were collected from the Village of Oakfield municipalwells, two trailer parks and forty-five residential wells. No contaminants were found in either themunicipal wells or the wells at the two trailer parks. Those homeowners with contaminatedwells were notified and provided with information about the continued use of their water supply.

Comment #11

We are concerned with the potential contamination of the Village of Oakfield's wells, and theneed for a safe backup water supply. Your report states that there are no safe geological barriersthat will protect the Village Water Supply. It also states that several aquifers are alreadycontaminated in this area. We implore your support for a secondary source of Municipal Water.

Response #11

Although contaminants have been found in the on-site water bearing zones, we do not believethat a new source of drinking water for the Village of Oakfield is necessary at this time. Monitoring wells are between the plume and the Village wells. If contamination is detected,sufficient time is available to implement controls to minimize human exposure. We will alsoreevaluate the need for a backup supply if the monitoring wells become contaminated. Moreover, the groundwater plume may be remediated, negating the need for a backup supply.

Comment #12

What about the health of ARC workers working at the Batavia Landfill? What about their healthoutcome from exposure to toxic chemicals and methane gas?

Comment #12A

Close the Batavia Recycling Center at the landfill site.

Response #12 and #12A

The Batavia Recycling Center is in an area of the Batavia Landfill site where there was no wastedisposal. It is unlikely that normal use of the recycling center will result in exposure to sitecontaminants. The work performed by the Association of Retarded Citizens (ARC) does notinvolve activities in the areas of the Batavia landfill where the disposal of waste has occurred. Any use of the waste disposal area is unauthorized and the toxicological implications of theunauthorized use of the Batavia Landfill are provided in the Public Health Assessment.

Comment #13

The report indicates that plume migration of site contaminants to the Oakfield wells is possible. You do not take into account the interaction of geology and hydrology and the effect that shiftingof geological structures could have on speeding the contamination of Oakfield Municipal wells. You don't give an explanation why your current tests of the Oakfield wells fail to detectcontaminants that have been found in your earlier samples.

Response #13

Although contaminants have been found in the on-site water bearing zones, we do not believethat a new source of drinking water for the Village of Oakfield is necessary at this time. Monitoring wells are between the plume and the Village wells. If contamination is detected,sufficient time is available to implement controls to minimize human exposure. We will alsoreevaluate the need for a backup supply if the monitoring wells become contaminated. Moreover, the groundwater plume may be remediated, negating the need for a backup supply.

In response to contaminants found in off-site groundwater and to community concerns, a highpriority was given to the performance of an accelerated focused feasibility study that will extendpublic water to residents living near the landfill. This study was conducted by US EPA and itwas determined that public water should also be extended to the mobile home parks on PrattRoad. This interim remedial action will be protective of human health by eliminating exposuresto site contaminants in drinking water. The draft Public Health Assessment also addressed theVillage of Oakfield municipal wells and the conclusions and recommendations remainunchanged.

Based on the available information and data, a sample collected in 1982 from the Village ofOakfield municipal wells showed the presence of total phenols and trichlorofluoromethane. Follow-up samples collected from the municipal wells have not shown the presence of site-related contaminants. Therefore, the continued monitoring of the on-site monitoring wells andthe municipal wells that is recommended in this Public Health Assessment report remainsunchanged.

In 1982, a private consulting firm collected groundwater samples from the Village of Oakfieldmunicipal wells. Total phenols and trichlorofluoromethane were reported in those samples (referto Table 5 of Appendix B). There were no quality assurance or quality control (QA/QC)documents accompanying the sample results. Follow-up samples were collected from themunicipal wells using a proper QA/QC protocol, and no contaminants were found in thesesamples.

There is no indication that geological formations and related hydrology are changing andaffecting the migration of contaminants to the Oakfield wells. The earlier samples that showedthe presence of contaminants in the municipal wells were collected by a private consulting firm. There have been no contaminants found in any samples collected from the municipal wells by theNYS DOH. Although we can't explain the analytical results produced by the private consultingfirm, we assume that the data were valid and use the data in this document.

Comment #14

If we need something done to help people living here now, it seems it is already too late. It isjust a wait and see game.

Comment #14A

A filtering system on each well could solve the problem.

Comment #14B

I am disappointed that while you recommend that all homes near the landfill site be connected tothe Town of Batavia public water supply, you don't specifically address the mobile home parkresidents, and also ignore those citizens who depend on water from the Village of Oakfieldmunicipal wells in the same general area.

Comment #14C

City water should be brought in.

Comment #14D

In general, I think the report is thorough, and indicates that it is only a matter of time before thecontamination known to exist in the Galloway Swamp migrates to all wells taking groundwaterfrom the general area.

Comment #14E

Money is spent foolishly in many areas of government. City water is a necessity here.

Response #14, #14A, #14B, #14C, #14D and #14E

In response to contaminants found in off-site groundwater and to community concerns, a highpriority was given to completing a focused feasibility study on extending public water toresidents living near the landfill. This study was conducted by US EPA and stated that publicwater should also be extended to the mobile home parks on Pratt Road. This interim remedialaction will be protective of human health by eliminating exposures to site contaminants indrinking water. The health assessment recommends that the monitoring wells between the plumeand the Village of Oakwood municipal wells be monitored to detect contamination that mightimpact the village wells. If contamination is detected in the monitoring wells, additional actionscan be taken to protect the village wells.

Comment #15

The EPA doesn't have any answers for why the test wells were not being monitored on a regularbasis at the Batavia Landfill. This was very clear at the public hearing they held in Batavia, NewYork in September of 1992.

Comment #15A

The monitoring wells are not checked often enough.

Response #15 and #15A

Although the on-site monitoring wells were not sampled on a regular basis, the NYS DOH didcollect off-site groundwater samples on a regular basis to evaluate groundwater quality near thelandfill. Based on the data generated from the off-site groundwater samples, public water will beextended to residents living near the landfill. In addition, a comprehensive groundwatermonitoring system will be instituted as part of the final site remedy.

Comment #16

We need a new, clean water source - not Batavia City or creek water - and clean out that dumpnow!

Response #16

The City of Batavia municipal wells are 4.5 miles southeast of the landfill. Given the distanceand location of the municipal wells, they are unlikely to be contaminated by chemicals migratingfrom the landfill.

Comment #17

You recommend routine monitoring of the Village of Oakfield municipal water supply wells andyet do not recommend a frequency of testing. Following a test, exactly how long a time can beknow our water supply is safe before taking additional samples? Assuming you arerecommending testing on an accelerated schedule, I would like to know at what routinefrequency we can expect the New York State Department of health to take samples and reportback to us.

Response #17

The frequency of testing of the Village of Oakfield municipal wells is determined by New YorkState regulations. Also see Response #14.

Comment #18

I am not satisfied with your conclusion that we should wait until contaminants show up in testwells BL-19 and BL-25. There is no assurance that these wells are representative of theaquifer(s) that supply the Oakfield municipal wells, nor that they will even detect any plumemigration of contaminants.

Response #18

Based on monitoring well logs and the distribution of contaminants in groundwater at the site, allwater bearing zones are connected to form one heterogeneous aquifer. Monitoring wells BL-19and BL-25 are located between the landfill and the monitoring wells. Given their location andthe nature of the aquifer, these monitoring wells will provide an early warning of the migration ofcontaminants towards the municipal wells.

Comment #19

Because you cannot guarantee the safety of groundwater supplies originating from the generalarea of Galloway Swamp, your recommendations should include measures for finding newsources for drinking water for all affected residents, including the residents of Oakfield.

Response #19

In response to contaminants found in off-site groundwater and to community concerns, a highpriority was given to completing a focused feasibility study on extending public water toresidents living near the landfill. This study was conducted by US EPA and stated that publicwater should also be extended to the mobile home parks on Pratt Road. This interim remedialaction will be protective of human health by eliminating exposures to site contaminants indrinking water. The health assessment recommends that the monitoring wells between the plumeand the Village of Oakwood municipal wells be monitored to detect contamination that mightimpact the village wells. If contamination is detected in the monitoring wells, additional actionscan be taken to protect the village wells.

Based on monitoring well logs and the distribution of contaminants in groundwater at the site, allwater bearing zones are connected to form one heterogeneous aquifer. Monitoring wells BL-19and BL-25 are located betwen the landfill and the monitoring wells. Given their location and thenature of the aquifer, these monitoring wells will provide an early warning of the migration ofcontaminants towards the municipal wells.

Comment #20

It is my opinion (and that of others concerned with this problem) that there is only one sure wayto protect individuals from the landfill. If must be circled with pipelines so that all of us can beassured that our water is safe! It is my understanding that part of this is being done: water isbeing piped up Kelsey Road to the corner of Galloway and also down Pratt Road past the trailerpark. Now, to protect Oakfield's wells, we need to continue with the pipes west from the cornerof Kelsey/Galloway Road one mile to our water plant. We don't even have to use this. But weneed to be assured that if our wells go bad, we have a safe backup.

Comment #20A

We ask that the New York State Department of Health support the construction of a water linenorth of the New York State Thruway, as already proposed in the EPA plan. And then continuethis water main to the Village of Oakfield Water Filtration Site for a Secondary, EmergencySource of Water. This would be 1/2 to a mile west of the current EPA Proposal to provide waterto Kelsey Road residents north of the New York State Thruway.

Comment #20B

Please consider amending your findings to provide for a secondary municipal source of water forthe 2,000 residents served by our municipal water. This would only be an additional 1/2 to amile of additional cost. We implore your assistance.

Response #20, #20A and #20B

Although contaminants have been found in the on-site water bearing zones, we do not believethat a new source of drinking water for the Village of Oakfield is necessary at this time. Monitoring wells are between the plume and the Village wells. If contamination is detected,sufficient time is available to implement controls to minimize human exposure. We will alsoreevaluate the need for a backup supply if the monitoring wells become contaminated. Moreover, the groundwater plume may be remediated, negating the need for a backup supply.

In response to contaminants found in off-site groundwater and to community concerns, a highpriority was given to completing a focused feasibility study on extending public water toresidents living near the landfill. This study was conducted by US EPA and stated that publicwater should also be extended to the mobile home parks on Pratt Road. This interim remedialaction will be protective of human health by eliminating exposures to site contaminants indrinking water. The health assessment recommends that the monitoring wells between the plumeand the Village of Oakwood municipal wells be monitored to detect contamination that mightimpact the village wells. If contamination is detected in the monitoring wells, additional actionscan be taken to protect the village wells.

Based on monitoring well logs and the distribution of contaminants in groundwater at the site, allwater bearing zones are connected to form one heterogeneous aquifer. Monitoring wells BL-19and BL-25 are located betwen the landfill and the monitoring wells. Given their location and thenature of the aquifer, these monitoring wells will provide an early warning of the migration ofcontaminants towards the municipal wells.

Comment #21

Your findings are spelled out very clearly in your report. Clearly, when we compare your reportwith the EPA's there are many irregularities. The EPA report differs especially in the test results. If there are any contaminants at all that will put our residents at risk; this is of great concern to allof us on the Village of Oakfield Board of Trustees. Thank you for this opportunity.

Response #21

In 1984, the US EPA and NL Industries entered into an Administrative Order on Consent for theperformance of a remedial investigation (RI) and feasibility study (FS) at the Batavia Landfillsite. The RI report was prepared by Goldberg-Zoino Associates of New York, P.C. and revisedby GZA GeoEnvironmental of New York for NL Industries. Much of the data found in thedocument are from these reports. The off-site groundwater data from samples collected by NYSDOH in 1989-1992 at private wells are not found in the earlier RI report, but are in the NYSDOH project files in Albany, New York.

Comment #22

It is unfortunate that some industries in the Batavia area that also bear responsibility for thecontaminants buried there, are not being researched further. They should share the cost ofcorrective action.

Response #22

Records indicating the type, quantity, and location of wastes that were disposed at the landfillduring its twelve years of operation are limited. If further records exist to document that otherparties are responsible for past disposal of wastes at the landfill, then these records should beprovided to the US EPA and NYS DEC, for appropriate follow-up.

Additional review comments were received from the US EPA outside of the publiccomment period, as follows:

Comment #1

The conclusions and recommendations are not reflective of the risks described in the document. The health risks for people exposed to contaminants in off site groundwater are described as lowbut the conclusion is "the Batavia Landfill site is a public health hazard because users of privatewells near the site and the Village of Oakfield public water supply were exposed to sitecontaminants in their drinking water in the past."

Response #1

The ATSDR criteria for determining whether a site poses a public health hazard as a result oflong-term exposures to hazardous substances are:

    "Evidence exists that exposures have occurred, are occurring, or are likely to occur in the future;

    and

    the estimated exposures are to a substance or substances at concentrations in the environmentthat, upon long-term exposures (greater than 1 year), can cause adverse health effects to anysegment of the receptor population. The adverse health effect can be the result of eithercarcinogenic or noncarcinogenic toxicity from a chemical exposure. For a noncarcinogenic toxiceffect, the exposure exceeds a chronic MRL established in the ATSDR Toxicological Profiles orother comparable value;

    and/or

    community-specific health outcome data indicate that the site has had an adverse impact onhuman health that requires intervention."

For the Batavia Landfill, groundwater contamination has been detected off-site in privateresidential wells at levels exceeding New York State drinking water standards for public watersupplies. Lower level contamination (at or below standards) persists in at least fourteenresidential wells. The estimated increased cancer risk from past exposures to trichloroethene andmethylene chloride in drinking water exceeds the one in one million baseline cancer risk used toassist in categorizing sites.

    Past exposure to contaminated drinking water meets criteria for categorizing the Batavia Landfillsite as a public health hazard.

In addition, lead and chromium have been detected in off-site sediment at levels that couldpresent a high public health risk, particularly to children if they play in these areas. Theestimated potential exposures to both these metals exceed health risk criteria. Also, since nodeed restrictions exist for residential development, there is the possibility that future excavationcould bring contaminated soils and waste materials to the surface and make them available fordirect contact and uptake by homegrown vegetables/fruits. As noted in Table 2 of the PublicHealth Assessment, the concentrations of several organic and metal contaminants in on-site soiland waste materials exceed health assessment comparison values for soil in a residential setting.

Given this information and the criteria the Agency for Toxic Substances and Disease Registryuses for placing sites in categories, this site meets the criteia for a public health hazard.

Comment #2

EPA has just issued a Record of Decision for this site that calls for the extension of a waterline toprovide water to many of the homes near the landfill based on a quantitative risk assessment thatidentifies that the threat exists of contaminants migrating from the landfills to the wells to thesouth.

Response #2

So noted.

Comment #3

A single sampling event in 1982 of the Village of Oakfield municipal wells identifiedcontaminants in the public water supply. It is never stated in the report that there is no link of thepossible contamination of the Oakfield well to the Batavia Landfill site. The EPA does notbelieve that the Village of Oakfield wells have been impacted by the Batavia Landfill site.

Response #3

So noted.

The following is a summary of comments received from the ENVIRON Corporation:

Comment #1

In the toxicological evaluation of past exposures to volatile organic compounds (VOCs) and ironin drinking water, the report (section 1 of the Toxicological Evaluation) claims that pastexposures to methylene chloride and trichloroethene (magnitude unknown prior to 1982) couldresult in a "low" increased risk of developing cancer. NYS DOH has presented nodocumentation of this statement in the form of quantitative risk calculations, and no definition of"low risk". Theoretically, the presence of any non-zero concentration of methylene chloride ortrichloroethene would be accompanied by an incremental cancer risk; however, this in itself maynot be of sufficient magnitude to constitute a public health problem. Similarly, it is impossible toverify or interpret the qualitative statements regarding "low risks" of noncarcinogenic effectsfrom past exposures to VOCs, and "minimal risks" from past exposure to iron. The report alsostates that long-term exposure to 1,1,1-trichloroethane (the only substance exceeding NYSdrinking water standards in recent sampling of domestic wells) poses minimal risk of adversehealth effects. NYS DOH has not quantified the magnitude of risks from past or currentexposures.

Response #1

Although quantitative risk calculations are completed to estimate health risks, it is not the intentof the Public Health Assessment to provide detailed documentation. The increased cancer riskswere estimated for the Batavia Landfill site by using site-specific information on exposure levelsfor each contaminant of concern and interpreting the exposure using cancer potency estimatesderived by the US EPA or, in some cases, by the NYS DOH. The following qualitative rankingof cancer estimates, developed by the NYS DOH, was then used to rank the risk from very low tovery high. For example, if the qualitative descriptor was "low", then the excess lifetime cancerrisk from that exposure fell in the range of greater than one per million to less than one per tenthousand. Other qualitative descriptors are listed below:

Excess Lifetime Cancer Risk
Risk Ratio Qualitative Descriptor
equal to or less than one per million very low
greater than one per million to less than one per ten thousand low
one per ten thousand to less than one per thousand moderate
one per thousand to less than one per ten high
equal to or greater than one per ten very high

Contamination of a number of private wells near the Batavia Landfill site was first detected in1985. Prior to 1985, it is not known for how long or at what levels residents with private wellswere exposed to contaminants in their drinking water. Since 1989, one only sample taken from aprivate well contained VOCs at levels exceeding NYS DOH's drinking water standards. Sincethe Batavia Landfill site was opened in 1968, the estimated maximum period of time duringwhich the private wells were contaminated with VOCs at levels above drinking water standardsis about 21 years.

Both trichloroethene and methylene chloride have caused cancer in laboratory animals and arepotential human carcinogens. The estimated increased cancer risk for exposure to the highestlevel of trichloroethene (20 mcg/L) is in the low range (greater than one per million to less thanone per ten thousand) for exposure periods ranging from about 5 to 21 years. For exposure to thehighest level of methylene chloride (10 mcg/L), the estimated increased cancer risk falls in thelow range for exposure periods of about 16 years or more. The levels of these volatile organiccontaminants in residential private wells prior to 1985 are not known and could have been less orgreater than 20 mcg/L and 10 mcg/L for trichloroethene and methylene chloride, respectively.

For noncarcinogenic health risks, the contaminant intake was estimated using exposureassumptions for conditions at the Batavia Landfill site. This dose was then compared to a riskreference dose (estimated daily intake of a chemical that is likely to be without an appreciablerisk of health effects) developed by the US EPA, ATSDR and/or NYS DOH. The resulting ratiowas then compared to the following qualitative scale of health risk:

Qualitative Descriptions for
Noncarcinogenic Health Risks
Ratio of Estimated Contaminant
Intake to Risk Reference Dose
Qualitative
Descriptor
equal to or less than the risk reference dose minimal
greater than one to five times the risk reference dose low
greater than five to ten times the risk reference dose moderate
greater than ten times the risk reference dose high

As a rule, the greater the ratio of the estimated contaminant intake to the risk reference dose, thegreater the level of concern. A ratio equal to or less than one is considered a minimal increase inrisk.

For past exposures to each of the VOCs in private wells (trichloroethene, methylene chloride and1,1,1-trichloroethane), the ratio of the level of contaminant to the risk reference dose of thatcontaminant was less than one. Therefore the risk of noncarcinogenic effects from pastexposures to each of these contaminants is considered minimal. The risk for noncarcinogeniceffects from exposure to these VOCs, reported as low in the Public Health Assessment for theBatavia landfill site, has been corrected to indicate that it is minimal.

The health risk from past ingestion of iron at the highest levels found in drinking water (3,230mcg/L) was determined to be minimal. Although no risk reference dose has been derived foringestion of iron in drinking water, the clinical literature reports that ingestion of iron at dosesless than 20 mg/kg body weight is typically nontoxic. Consequently, a 70 kg adult who ingests 2liters of water per day could ingest water with about 200 times more iron (700,000 mcg of ironper liter) that found at the highest level in a private well without adverse health effects. Therefore, drinking water containing iron at a level of 3,200 mcg/L would be considered to posean insignificant (minimal) increase in risk. However, water containing iron at these levels isunlikely to be used for drinking since iron alters the taste of water.

Comment #2

The draft Public Health Assessment of the Batavia Landfill provides no basis for the State'sconclusion that "The site poses a public health hazard because of past and continuing exposuresto site contaminants in drinking water." Concentrations in the private domestic wells from themost recent round of sampling were all at or below NYS DOH drinking water standards; contraryto the NYS DOH conclusion, this does not suggest the existence of a public health hazard.

Response #2

The ATSDR criteria (ATSDR, 1992, Table 8.1) for determining whether a site poses a publichealth hazard as a result of long-term exposures to hazardous substances are:

    "Evidence exists that exposures have occurred, are occurring, or are likely to occur in the future;

    and

    the estimated exposures are to a substance or substances at concentrations in the environmentthat, upon long-term exposures (greater than 1 year), can cause adverse health effects to anysegment of the receptor population. The adverse health effect can be the result of eithercarcinogenic or noncarcinogenic toxicity from a chemical exposure. For a noncarcinogenic toxiceffect, the exposure exceeds a chronic MRL established in the ATSDR Toxicological Profiles orother comparable value;

    and/or

    community-specific health outcome data indicate that the site has had an adverse impact onhuman health that requires intervention."

For the Batavia Landfill, groundwater contamination has been detected off-site in privateresidential wells at levels exceeding New York State drinking water standards for public watersupplies. Lower level contamination (at or below standards) persists in at least fourteenresidential wells. The estimated increased cancer risk from past exposures to trichloroethene andmethylene chloride in drinking water exceeds the one in one million baseline cancer risk used toassist in categorizing sites.

    Past exposure to contaminated drinking water meets criteria for categorizing the Batavia Landfillsite as a public health hazard.

In addition, lead and chromium have been detected in off-site sediment at levels that couldpresent a high public health risk, particularly to children if they play in these areas. Theestimated potential exposures to both these metals exceed health risk criteria. Also, since nodeed restrictions exist for residential development, there is the possibility that future excavationcould bring contaminated soils and waste materials to the surface and make them available fordirect contact and uptake by homegrown vegetables/fruits. As noted in Table 2 of the PublicHealth Assessment, the concentrations of several organic and metal contaminants in on-site soiland waste materials exceed health assessment comparison values for soil in a residential setting.

Comment #3

Because no quantitative risk estimates are presented, it cannot be determined how the Statearrived at the qualitative potential future risk estimates for the on-site contaminants discussed insection 3 of the Toxicological Evaluation. There is no evidence in the report to indicate that theState actually determined the magnitude of risk (if any) to future off-site water consumers.

Response #3

As indicated in the previous response, quantitative risk assessment for contaminants from theBatavia Landfill site was completed. The potential health risks from contaminants of concern inon-site groundwater were estimated by assessing the risks for cancer and noncancer health effectsusing procedures and qualitative descriptors discussed in response to Comment #1. For example,potential chronic exposure to the highest levels of vinyl chloride and benzene by on-sitegroundwater plume migration and subsequent contamination of residential drinking watersupplies could pose a high (one per thousand to less than one per ten) and low (greater than oneper million to less than one per thousand) increased cancer risk for vinyl chloride and benzene,respectively.

Comment #4

Two separate firms specializing in hydrology [GZA GeoEnvironmental (GZA) and Leggett,Brashears & Graham (LBG)] have interpreted the data to indicate that the aquifers are notinterconnected and that overburden groundwater does not discharge to existing domestic wells,but rather to surface water in Galloway Swamp. The NYS DOH report does not mention thesetwo independent studies, giving the false impression that there is no question as to thehydrogeology of the Batavia site. Based on the GZA and LBG interpretation, the State has nobasis to assume that all contaminants identified in on-site monitoring wells pose a potentialfuture risk of contamination of the off-site domestic wells.

Response #4

GZA and LBG, consultants for the responsible parties, and the government agencies, US EPA,NYS DEC and NYS DOH, have reviewed the same hydrogeology data that are in the BataviaLandfill Site Remedial Investigation Report Final Draft, as prepared by GZA. The consultantsinterpretation of the hydrogeology at the site differs from that of the government agencies. However, the consultants have failed to demonstrate that a continuous confining layer existsthroughout the entire site which keeps each water-bearing zone separate and which prevents themigration of site contaminants between each water-bearing zone. The following statements areexcerpts from the US EPA final technical comments on the report and they summarize thegovernment agencies position on the site hydrogeology. "Based on well logs, discontinuouslayers of silt and clay, varying in thickness between 1 and 30 feet, are present in the northern andsouthern portions of the site. Because of the discontinuity of the low permeability lenses, theupper soil zones, the low permeability lenses and the lower soils should be considered as oneheterogeneous aquifer. The interconnectedness of the aquifer is demonstrated by the detection ofsite contaminants in samples from wells screened at all depths." The interpretation of sitehydrogeology in the public health assessment is based upon the above information.

Comment #5

The Site Visit section claims that the site is not fenced, but a gate was present which restrictedvehicular access to the site. The nearby residences evaluated by NYS DOH are located alongPratt Road and in order for these residents to trespass the site, they would have to perform thehighly unlikely action of crossing the Thruway on foot.

Response #5

An evaluation of all residences near the site included not only those located along Pratt Road,which is south of the site, but also those residences located along Kelsey Road, east of the siteand Galloway Road, north of the site. Although a gate restricts vehicular access to the site, itremains readily accessible to the general public. Since Kelsey Road crosses over the NYSThruway, the general public does not have to negotiate traffic on the Thruway, as this commentsuggests.

Comment #6

For those substances with the potential to migrate to off-site wells, use of on-site monitoring welldata alone will not provide accurate predictions of future off-site wells concentrations becauseattenuation may occur between the monitoring wells and the domestic wells.

Response #6

Although it is reasonable to expect attenuation to occur between on-site monitoring wells anddomestic drinking water wells, it is also possible that the levels of contaminants detected in theon-site monitoring wells were not the maximum levels that could have been found in on-sitegroundwater by additional monitoring. Consequently, it is not unreasonable to use the presenton-site groundwater monitoring data to calculate what the potential risks could be to users of off-site private and municipal drinking water supply wells contaminated from on-site groundwater byplume migration. This is the approach used to estimate cancer and noncancer risks frompotential exposures to contaminants found in groundwater at the Batavia Landfill site.

Comment #7

The State presents no evidence to suggest that the Batavia Landfill will be converted toresidential use, so the statement that "The waste materials would pose a higher increased risk ifthey were in a residential setting" is unwarranted.

Response #7

There are no deed restrictions that would prevent future residential development and it must,therefore, be included as a future possibility.

Comment #8

It is highly unlikely, given the remote nature of the site that nearby residents would trespass onthe site. Also, the highly contaminated areas are covered with at least one foot of soil and contactis, therefore, further unlikely.

Response #8

Further examination of the on-site soil data by the NYS DOH indicates that on-site soilcontaminant results were all subsurface (at least 3 to 4 feet in depth). Therefore, contact withthese contaminants by trespassers is highly unlikely. Appropriate revision of the text has beenmade in the potential exposure pathway subsection on soil and waste material and also in thetoxicological evaluation subsection (#4) entitled "potential ingestion, inhalation and dermalexposure to persons coming in contact with on-site soil and waste material".

Comment #9

With respect to potential future exposure to recreational users of the wetlands, the State has notprovided any documentation that children in fact play in these areas (Galloway Swamp) on afrequent basis.

Response #9

Since access to the Galloway Swamp is not restricted, its use for recreational purposes by adultsor children may occur at any time.

Comment #10

The State concludes that the public water supply should be extended to the residents withcontaminated private wells. This conclusion does not logically follow other informationpresented in the health assessment report. New York State has failed to provide support for theconclusion that the public water supply should be extended to all homes near the site.

Response #10

We disagree. The logic is: The landfill has contaminated groundwater. People have beenexposed to site contaminants in drinking water in the past continue to be expressed and peoplemay be exposed in the future. If public water is extended to these people, they will no longer beexposed to site contaminants.

Additional comments were received on June 11, 1992 (after the close of the comment period)from NL Industries, Inc. These comments are considered part of the public record and a copy ofthese comments will be maintained in the document repositories for the site, at the followinglocations:

Document Repository
New York State Department of Environmental Conservation
50 Wolf Road, Room 222
Albany, New York 12233-7010

Document Repository
Richmond Library
19 Ross Street
Batavia, New York 14020

Response to these comments will be prepared under separate cover and will also become part ofthe public record and maintained in the document repositories for the Batavia Landfill site.



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