PUBLIC HEALTH ASSESSMENT
GENERAL MOTORS (CENTRAL FOUNDRY DIVISION)
MASSENA, ST. LAWRENCE COUNTY, NEW YORK
The General Motors-Central Foundry Division National Priorities List facility is in Massena, St. Lawrence County, New York, on the banks of the St. Lawrence River. Polychlorinated biphenyls (PCBs) were used at this facility in the hydraulic fluids of diecasting machines from 1968-1973. Sludges containing PCBs were placed on-site in disposal pits, in the industrial landfill, and in several lagoons . Although a cap has been placed on the landfill, limited contaminant migration continues from this and the other on-site sources. Soils, groundwater, air, river sediments, and biota are contaminated. A remedial investigation/feasibility study has been completed for the site.
This site is a public health hazard because of the risk to human health caused by human exposure to hazardous substances at levels that may result in adverse human health effects over time. The major public health concerns include (1) ingestion of PCB-contaminated biota, particularly fish; (2) area residents, particularly reservation residents, that may be at risk from exposure to air, sediment, soil and surface-water contaminants; and (3) area residents that may be at risk from exposure to inhalation of volatilized PCBs and PCB-contaminated particulates during remedial activities.
The St. Regis Indian Reservation that shares the eastern boundary of the General Motors (GM) facility has residences about 1,000 feet away. A medical examination and diet survey of the adult population of the St. Regis Mohawk Indian Reservation, Akwesasne, was conducted by the Mt. Sinai School of Medicine to investigate potential exposures and human health effects. A Health Risk Assessment (HRA) was issued by the New York State Department of Health (NYS DOH) in January 1995. Local fish, wildlife and breastmilk samples were analyzed for PCBs for the HRA, and the health risks from exposure to these media have been evaluated. As part of the HRA, a study has been conducted to investigate the occurrence of PCBs and associated chemicals in the breastmilk of Mohawk women of Akwesasne from 1986 to 1992. The findings indicate no statistically significant difference in levels of PCBs in breastmilk between the study and control groups beginning in 1990. This is believed to be a result of a significant decline in the consumption of local fish by Mohawk mothers. Further studies are on-going. A summary of the findings of these studies are found in Appendix C and are further discussed in the Health Outcome Data section.
Recommendations for this site include continuing educational efforts to inform the Mohawks about the risks of consuming contaminated fish and biota, air sampling and public water supply monitoring during remedial activities, and limiting access to contaminated off-site areas prior to remediation.
This Public Health Assessment for the General Motors-Central Foundry Division site contains information current to July 1995; therefore, some of the issues discussed and recommendations made have already been addressed. In cooperation with the Agency for Toxic Substances and Disease Registry (ATSDR), the NYS DOH will prepare a health consultation for the site to bring the information up to date.
This public health assessment has been reviewed by the ATSDR Health Activities Recommendation Panel (HARP). Because of past and current completed exposure pathways to PCBs, the panel determined that follow-up health actions are needed at the site. Specifically, the HARP determined that on-going community health education should continue. Site specific health education has been and continues to be conducted as a joint effort with the NYS DOH and the Mohawk Nation regarding possible adverse health effects related to past and current exposures to PCBs. In addition, the NYS DOH will periodically contact ATSDR regarding studies that are being conducted at Akwesasne to evaluate the need for additional health follow-up.
Public health actions taken include several steps to prevent exposures. An advisory regarding fish and wildlife consumption has been issued by NYS DOH. Reservation residents not connected to the public water supply prior to 1978 were provided with bottled water until it was determined their wells were not contaminated. The public water supply has been sampled on several occasions by NYS DOH. A cap was placed over the Industrial Landfill, which has also been surrounded by a fence, as is the entire GM plant facility. Plant security is on duty 24 hours per day. Public health actions planned include removal of off-site contamination and treatment or containment of these and other on-site wastes on-site. The results of the HRA have been used to determine the need for further health studies of the reservation population. In 1995 GM proposed an amendment to the Record of Decision which would allow the disposal of soil containing PCBs at up to 500 milligrams per kilogram (mg/kg) in a non-secure landfill on site.
In cooperation with the NYS DOH, the ATSDR will evaluate the public health significance of this site. More specifically, ATSDR and NYS DOH will determine whether health effects are possible and will recommend actions to reduce or prevent possible health effects. ATSDR, located in Atlanta, Georgia is a federal agency within the U.S. Department of Health and Human Services and is authorized by the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) to conduct public health assessments at hazardous waste sites.
The General Motors Central Foundry Division National Priorities List (NPL) site is in Massena, St. Lawrence County, New York, about 200 miles northwest of Albany. The 270-acre facility lies on the banks of the St. Lawrence River (Figures 1, 2 and 3). The eastern boundary of the GM facility is the Franklin County Line, where the St. Regis Indian Reservation begins. This site is bounded on the south and west by Routes 37 and 128, respectively. The site is relatively flat, but the surrounding land drops off sharply at the St. Lawrence River bank. An extensive surface water collection system collects and treats most surface water from the plant facility before entering the river system. An intermittent stream, known as the unnamed tributary or "Turtle Creek" by the Mohawks, drains into the St. Lawrence River between the GM facility and the Indian Reservation.
The General Motors Central Foundry Division (GM-CFD) is an aluminum casting facility that manufactures automobile parts such as cylinder heads. The facility was constructed in 1959 and has operated continuously. The plant currently manufactures aluminum and iron engine and transmission parts through the "lost foam" casting method. For a period from 1968 to 1973, polychlorinated biphenyls (PCBs) were used in the hydraulic fluids of the diecasting machines which molded the aluminum automobile parts. Sludges were generated from this PCB-contaminated hydraulic fluid during an oil reclamation operation at the facility. The PCBs detected at this facility and in nearby areas are a result of the use of PCBs in the past. The detection of PCBs in the St. Lawrence River during routine monitoring in the late 1970's led to the placement of the General Motors Landfill on the original New York State Hazardous Waste Site Registry as a suspect site.
On September 19, 1980, General Motors (GM) submitted a closure plan for the 1.5 million gallon lagoon that contained some of the PCB contaminated sludge. At a meeting between NYS Department of Environmental Conservation (NYS DEC) staff and GM on April 2, 1981, this plan was discussed and supplementary information was requested from GM. A revised closure plan was submitted in January 1982, which was deemed unacceptable by NYS DEC. Efforts were initiated to develop a consent order which would require GM to assess contamination at and near the site. The ensuing investigations revealed contamination at the site and led to the placement of the site on the National Priorities List (NPL) by the U.S. Environmental Protection Agency (US EPA) in 1983.
A remedial investigation (RI) was initiated for the site by GM pursuant to a 1985 Administrative Order on Consent. Remedial investigations follow preliminary site investigations conducted by town, county, state and/or federal agencies that verify hazardous wastes are present and that the wastes pose a significant threat to public health and the environment. The RI is carried out to determine the nature and extent of contamination. The RI, which was to be supplemented later by a Phase II RI, revealed contamination by PCBs both on-site and off-site. The off-site areas include the nearby St. Regis Mohawk Indian Reservation and sediments in the St. Lawrence River. To stop rain from infiltrating the landfill, a cap was placed over the landfill during the 1988 construction season. This cap consists of a 1 ½-foot clay layer, a geotextile membrane and a vegetated topsoil cover. The Phase II RI, completed in May 1988, was augmented by a sediment and water column investigation of the St. Lawrence and Raquette Rivers in May 1989. The Feasibility Study (FS), as completed by GM, was submitted in November 1989. The FS uses RI information to develop alternative remedial actions that will eliminate the threat to public health or the environment posed by the site. The US EPA issued a Draft Proposed Plan (DPP) for this site in March 1990. The comment period ended June 14, 1990. The first operable unit includes all on-site and off-site areas except the Industrial Landfill and the East Disposal area. A Record of Decision (ROD) was issued on December 7, 1990 for the first operable unit of this site. A ROD was issued for the second operable unit, which includes the Industrial Landfill and the East Disposal Area, in March 1992. The NYS DOH prepared a preliminary health assessment for ATSDR for this site in June 1989.
The information in this Public Health Assessment is current to July 1995. The NYS DOH will prepare a health consultation document after the US EPA responds to General Motors proposed amendment to the Record of Decision.
There have been many site visits on General Motors property and the adjoining Reservation lands by NYS DOH personnel. The last site visit on GM plant facility property was by Mr. John Sheehan was August, 1994. The Director of Environmental Services for the Mohawk Indian Reservation, accompanied Mr. Geoffrey Laccetti of the NYS DOH on a tour of off-site areas surrounding the GM plant on December 6, 1988. NYS DOH collected water samples from the public water supply on the reservation and toured off-site areas in March 1991.
The 270-acre site is accessed by a paved road off Route 37. Although the entire 270-acre property owned by GM is not fenced, a continuous fence encloses the plant facility. Within this fenced area are the industrial landfill, the North and East disposal areas, and four lagoons that contain hazardous waste. The only unfenced area containing hazardous waste is an area of fill soils near the Raquette River (levels up to 400 ppm PCBs). Although this area is accessible to the public, it is not frequently used. The large building that comprises the main plant area is completely fenced and a 24-hour security guard is maintained. These guards patrol the entire site within the boundary fence. The facility property has an extensive surface water collection system that gathers and treats site surface water before entering the river system.
A public meeting held to discuss site remediation was attended by NYS DOH in October 1991. This meeting was held to receive public comment on the second operable unit ROD. In May 1992 and June 1993, Dr. Edward Fitzgerald of NYS DOH, who is conducting ongoing studies of exposure to contaminants among the Mohawks at Akwesasne, held a public meeting on the reservation to discuss the status of the studies. In June 1995, the NYS DOH attended a public meeting held by the US EPA to solicit public input of an amendment to the ROD. This amendment proposed by GM would allow disposal of waste containing greater concentrations of PCBs than originally agreed upon in a non-secure landfill on-site. The concentrations of PCBs which would be allowed in the landfill have not yet been agreed upon.
The area in which the site is located can be characterized as low density, residential lands, including the St. Regis Mohawk Indian Reservation, which shares a boundary with the GM facility along its eastern perimeter. Both the Canadian and U.S. portions of the Mohawk Indian Reservation have about 8,000 residents. According to the 1990 census there are about 2,000 residents of the St. Regis Mohawk Indian Reservation on the United States side. Of these 2,000 residents, 97.2% are American Indian, 2.3% are white, and .5% are other races. Of these residents 11% are under 5 years old, 22% are aged 5 to 17 years, 58% are 18-64 years old, and 9% are older than 65 years.
There are about 225 Mohawk residents on Raquette Point with less than ten homes that currently use private wells, by their own choice, for drinking water. About one mile downstream on the St. Lawrence River is the surface water intake for the public water supply of the St. Regis Reservation. Eight miles to the west of the site is the Village of Massena with a population of about 13,000. The intake for the City of Massena public water supply is in the St. Lawrence River, about four miles upstream of the site.
The St. Lawrence, Grasse, and Raquette Rivers near the General Motors site are used for recreation (e.g., fishing and swimming) and fish propagation. The St. Lawrence, Grasse, and Raquette Rivers have also been the traditional subsistence fishing grounds for the St. Regis Mohawk Tribe. The unnamed tributary that separates the GM facility from the St. Regis Reservation has been used for fishing, recreation and trapping. This area has been posted by Mohawk Environmental Services as an area containing hazardous waste because of known high levels of PCBs in sediments and in adjoining shoreline soils.
The NYS DOH maintains several health outcome data bases which could be used to generate site specific data if warranted. These data bases include the cancer registry, the congenital malformation registry, the heavy metals registry, the occupational lung disease registry, vital records (birth and death certificates) and hospital discharge information. In 1986, Selikoff and Hammond of Mt. Sinai Hospital examined the relationship between St. Regis Mohawk Indian PCB blood levels and fish consumption. The Mt. Sinai study includes data on blood PCB levels determined for 47 adult residents of St. Regis Mohawk Indian Reservation. These data show that, although fish consumption was positively associated with blood PCB levels the average blood PCB levels in these subjects are comparable to the levels found in individuals without occupational or other identified PCB exposures. The NYS DOH is continuing to study PCB levels in the breastmilk of reservation mothers. As part of the NYS DOH's HRA, a study has been conducted to investigate the occurrence of PCBs and associated chemicals in the breastmilk of Mohawk women of Akwesasne. The initial part of this study was completed in October 1990 and the second phase was completed in 1992. The findings indicate no statistically significant difference in current level in breastmilk between the study and control groups since 1990. This is believed to be a result of a significant decline in the consumption of local fish by Mohawk mothers. The decline of the consumption of local fish is due largely to the recommendation made by the Mohawk Environmental Health Services and the NYS DOH through their fish and wildlife consumption advisories. NYS DOH's advisory has been included as Appendix F of this report. Another health study was completed in 1995: "Exposure to PCBs from Hazardous Waste Among Mohawk Women and Infants at Akwesasne". Further studies are on-going. The NYS DOH is currently conducting another study: "PCB & DDE Exposure Among Native American Men From Contaminated Great Lake Fish and Wildlife", to be completed in 1996. Studies completed and those in progress are listed in Appendix G.
The first concern regarding possible health effects from this site was expressed by a reservation mid-wife who was worried about a possible increase in birth defects on the reservation, because of mother's exposure to contaminated biota. The mid-wife contacted the NYS DEC staff who collected biota consumed by reservation residents; the biota were found to be contaminated with PCBs.
The primary community health concern about this site is the PCB contamination in the St. Lawrence, Grasse and Raquette Rivers and the subsequent contamination of local biota. The majority of the concern is from the Mohawk Indian Reservation, whose residents have traditionally used these rivers as a source of food and income. There is also a significant number of non-Mohawk U.S. and Canadian residents that use the river system and are concerned about the contamination that has affected it. Another concern that has been expressed, regarding past exposure, is that Mohawk children and young adults rode three-wheelers and mini-bikes on the industrial landfill before the fence was erected. There is a potential that this activity resulted in direct contact with exposed wastes.
Another significant community health concern is the air quality in the area, particularly on the reservation, which is downwind of the GM, Reynolds Metal Company, and Alcoa facilities. Presently, most of the odor emanating from the GM site is styrene, which is used in the "lost foam" casting process at the plant. There are long-standing concerns about the effect of air emissions from the nearby Reynolds Metals facility on the Reservation. This information has been gathered through discussions and meetings with residents of the Mohawk Indian Reservation. These concerns were also expressed at an April 25, 1990 public meeting on the DPP for the first operable unit for this site. The primary community concern at the public meeting held to discuss the second operable unit was the plan proposed by US EPA to contain contamination in the Industrial Landfill. The majority of residents who spoke at the meeting were in favor of a complete removal of materials in the landfill and East Disposal Area rather than treatment. During a public meeting in June 1995, residents of the Akwesasne Reservation expressed strong opposition to the proposed amendment to the signed ROD.
Several major investigations have been conducted at this site. There are hundreds of soil samples, over 75 groundwater monitoring wells and a health risk assessment that includes the collection of fish, wildlife and breastmilk samples.
A summary of the environmental contamination data collected for the General Motors/Central Foundry site is presented in Tables 1-7. The data included in these tables do not always include the range or median of all sampling results. The maximum values shown may not represent actual levels of contamination in all media. The listing of a contaminant does not necessarily mean that its presence is a public health concern. Contaminants selected for further evaluation are identified and evaluated in subsequent sections of the public health assessment to determine whether exposure to them has public health significance. When selected as a contaminant of concern in one medium, that contaminant will be reported in all media where it is detected. Contaminants selected for further evaluation are identified based upon consideration of the following factors:
- Concentrations of contaminant(s) in environmental media both on- and off-site;
- Field data quality, laboratory data quality, and sample design;
- Comparison of on-site and off-site contaminant concentrations in environmental media with typical background concentrations;.
- Comparison of contaminant concentrations in environmental media both on-site and off-site with health assessment comparison values. These comparison values include Environmental Media Evaluation Guides (EMEGs), Cancer Risk Evaluation Guides (CREGs), drinking water standards and other relevant guidelines.
- Community health concerns.
The selected contaminant(s) are evaluated in the Public Health Implications section (Toxicological Evaluation) of this PHA to determine whether exposure to these chemicals is of public health significance.
Environmental contamination data are available from the Phase I (May 1986) and Phase II (May 1988) Remedial Investigations, the Sediment and Water Column Investigation of the St. Lawrence and Raquette Rivers (May 1989) and the fish and wildlife data collected as part of the Health Risk Assessment. Media collected and analyzed during these investigations included surface soils, soil borings, groundwater, lagoon sludges, air (during interim remedial measures), fish and wildlife.
For this document, on-site is considered all plant property within the chain-link fence at the facility (see Figure 2).
Soil collected at 0-2 feet were considered surface samples during the RI. However, for the purpose of exposure assessment, NYS DOH considered surface soil to be 0-3". As shown in Table 1, samples of this soil contained PCBs up to 30,000 milligrams per kilogram (mg/kg). Phenol was detected as high as 11,200 mg/kg in the East Disposal area. Inorganic compounds (metals) were not significantly elevated, compared to organic compounds.
Soil borings were collected in several locations on-site and were drilled until naturally occurring till materials were encountered. Soil borings into the North Disposal area contained PCBs to 41,500 mg/kg (see Table 1). Inorganic compounds were not significantly elevated.
High levels of PCBs were detected in some on-site groundwater monitoring wells (see Table 2). Monitoring wells installed in the Industrial Landfill contained PCBs up to 1,200 micrograms per liter (mcg/L). PCBs up to 87 mcg/L were found in Lagoon monitoring wells, up to 4.1 mcg/L in wells in the North Disposal area and up to 1.7 mcg/L in the East Disposal area. Phenol was detected up to 2,770 mcg/L in on-site monitoring wells in the Lagoon area. The movement of groundwater from the site is predominantly toward the St. Lawrence River.
Air sampling data for on-site areas were collected in September, 1987 during construction of the interim cap covering the industrial landfill. PCBs up to 1,400 nanograms per cubic meter (ng/m3) were found at the perimeter of the landfill. No PCBs were found in the majority of the samples collected during construction of the cap. This monitoring detected styrene and related compounds. Styrene was a permitted air emission at the General Motors plant.
Contamination has migrated from the GM facility to the surrounding area, most notably the St. Lawrence River, its unnamed tributary and the St. Regis Mohawk Indian Reservation. From the early stages of the site investigation, the focus has been to evaluate the effects on the St. Regis Reservation and the St. Lawrence River.
Samples collected and analyzed during off-site investigations include surface soil, surface water and sediments, groundwater, fish, wildlife and a limited number of air samples. For the purposes of this document, off-site is considered to be all areas surrounding the plant facility that are outside the chain-link facility fence that have been subject to contamination from the GM facility. This includes areas on GM property outside the fence, the St. Lawrence, Raquette Rivers, the unnamed tributary, and parts of the Indian Reservation (see Figures 2 and 3). The off-site sampling results are summarized in Table 3.
Of 23 surface soil samples collected on St. Regis Indian Reservation, 9 contained PCBs with levels up to 3.3 mg/kg and a median of 0.36 mg/kg. No other significant organic or inorganic contamination was detected in those samples.
An area near the Raquette River received fill material from the GM plant site. Soil samples from this area had PCB levels as high as 400 mg/kg. PCBs were detected in 11 of 12 samples collected. The median of these samples was 1.2 mg/kg. One sample was 400 mg/kg, another was 23 mg/kg, the remaining 10 were less than 2.5 mg/kg. The material is not located at the river bank edge; it is on a flat area above the river bank.
Three groundwater monitoring well clusters are installed on the St. Regis Mohawk Reservation. These wells were sampled in 1986 and PCBs were not detected. Monitoring well MW-18A, which is located between the GM property and the unnamed tributary, contained a reported 4.8 mcg/L of PCBs in 1986; however, this was below the 10 mcg/L confidence limit established for these samples. Subsequent attempts by GM and NYS DOH to collect samples from these wells have failed because property owners have denied further access.
Several rounds of samples were collected from residential wells on the St. Regis Mohawk Reservation. The first samples were taken in December 1985. GM's consultant found PCB levels up to 6.0 mcg/L. US EPA's consultant did not detect PCBs in the same wells; a detection limit was not specified. All of these wells were resampled by GM's consultant in January 1986. Thirty-eight wells were sampled. PCBs were detected in only one well at a level of 0.5 mcg/L. The detection level for these analyses was 0.5 mcg/L. NYS DOH sampled 8 of these wells at this time and found 0.12 mcg/L of PCBs in one well while all others were less than the detection limit of 0.05 mcg/L (see Table 5).
All private residences on Raquette Point not connected to the public water supply were sampled by NYS DOH in December 1988 or March 1989. No PCBs were found at a detection limit of 0.05 mcg/L.
Surface Water and Sediments
PCB contamination has been found in surface water and sediments near this facility. PCBs have been found in surface water samples in the St. Lawrence River up to 2.2 mcg/L. Samples collected during the RI found levels of PCBs in sediments directly in front (north) of the plant in the St. Lawrence River at levels up to 5,700 mg/kg. Surface water and sediment samples may be affected by the multiple sources of PCBs in the Massena area. About 50,000 cubic yards of contaminated river sediments with PCB concentrations above 2 mg/kg (the proposed clean-up level) are in the St. Lawrence River, Raquette River, and the unnamed tributary. Levels of PCBs up to 48 mg/kg were detected in sediments in the unnamed tributary. Sediment samples collected on July 5, 1988 by NYS DEC and by representatives of the St. Regis Mohawk Tribe Environmental Program, found PCB concentrations in sediment in the unnamed tributary from 26.4 to 3,101 mg/kg in ten samples (Ken Jock, St. Regis Mohawk Tribe, 1990 personal communication). The public water supply for the reservation is a surface water supply, the St. Lawrence River, downstream of the GM plant. Results of raw and finished water samples from this facility are found in Table 4.
Several hundred biota samples have been collected near this site. The initial samples (e.g., snapping turtles) were collected by the NYS DEC in response to concerns by reservation residents. The majority of samples were collected for the HRA being conducted by NYS DEC and NYS DOH (see Tables 6 and 7).
No air samples were collected off-site during the RI. During the construction of the interim cap in 1987, samples were taken next to the home closest to the landfill and next to a small inlet of the St. Lawrence River. This inlet subsequently became known as Contaminant Cove. One sample was slightly above 1000 ng/m3. No PCBs were found in the majority of the samples, however, these instantaneous readings had relatively high detection limits because of the short-term health and safety purpose for which they were collected.
Air samples were collected off-site during 1988, 1989 and 1990 by a NYS DEC mobile air monitoring laboratory (Mo, 1988; 1989; and 1990). Samples were collected over a one to five hour period. The samples were collected in November 1988, August 1989 and September 1990. Seven samples were collected on roads near the General Motors and Reynolds Aluminum plants, nine were collected closer to residential areas, and two were collected near Contaminant Cover. Of the samples near the plants, one sample contained 269 ng/m3 total PCBs, one contained 181 ng/m3 and no PCBs were found in the remaining five samples. However, only concentrations of PCBs in air above 14-24 ng/m3 could be detected by the method used by this mobile laboratory. Of the samples collected in residential areas, one contained 22 and one 50 ng/m3 of total PCBs and no PCBs were detected in the remaining seven samples. The two samples collected near Contaminant Cove contained 53 and 72 ng/m3 total PCBs. No seasonal trends are apparent.
Air samples were also collected off-site during a study conducted from March 1993 to January 1994 (unpublished data, Brian Bush). The samples were collected near Contaminant Cove and on Cornwall Island to the north of the site. Each sample was collected for a one-month period and analyzed for congener-specific PCBs. The data reported here are for the total of all PCB congeners. The samples from Contaminant Cove averaged 7.1 ng/m3 total PCBs and ranged from 1.2 to 19.5 ng/m3. Samples on Cornwall Island averaged 1.4 ng/m3 total PCBs and ranged from 0.3 to 4.2 ng/m3. PCB levels were highest during the summer months. The field blanks during the study contained an average of 0.3 ng/m3 total PCBs and ranged from 0.08 to 0.89 ng/m3.
The data collected during the RI/FS at this site, including the HRA, have been subjected to data quality review. The data collected by other parties relating to this site have also been subject to adequate quality assurance and quality control (QA/QC).
The original round of residential well samples collected by GM's consultant found many positive results which were not confirmed in subsequent rounds. The positive results may be due to interferences from the high sulfur content which occurs in Raquette Point water supply wells. Samples were collected subsequently by the NYS DOH. Where a sulfur odor was noted on sample collection, the samples were treated to remove all sulfur compounds thereby eliminating the interference caused by sulfur compounds during analysis.
The air quality data for PCBs received the standard quality assurance and quality control (QA/QC) procedures used by the research scientists overseeing the work. The NYS DOH Environmental laboratories Approval Program (ELAM), which certifies environmental laboratories and their QA/QC procedures in New York State, does not certify laboratories for congener-specific PCB analysis. For this health assessment, the NYS DOH deferred QA/QC review to the research scientists who produced the data, recognizing that the data have not been produced and reviewed in the same way that data for superfund remedial investigations are.
There are no known physical hazards at this site outside the facility fence.
To identify contaminants emitted into air by the GM Foundry or other facilities (Alcoa and Reynolds Metal Company) near the GM Foundry, the NYS DOH searched the Toxic Chemical Release Inventory (TRI) for the years 1988 through 1992. A summary of the TRI-reported releases to air by these facilities for the year 1992 is presented in Table 8.
NYS DOH has developed a screening model to estimate if potential contaminant concentrations resulting from air emissions at a facility may be contributing to community exposures to contaminants at a site. This model uses information about the facility location (distance from the exposed population) and annual air emission data to calculate annual average air concentrations at a distance of 0.5 miles from the site.
Results of the screening evaluation indicate that air emissions from these facilities would not increase contaminant levels in ambient air above the screening criteria of 0.1 mcg/m3 for chromium, 0.02 mcg/m3 for nickel, 0.4 mcg/m3 for manganese or 1 mcg/m3 for other compounds. Based on the results of screening evaluation, the public health significance of contaminant air emissions from TRI facilities as an additional source of community exposure at the GM Foundry site will not be evaluated further in this public health assessment.
Because of past disposal practices and the subsequent release of PCBs, groundwater, surface and subsurface soils, river sediments, surface water, fish and wildlife and air are contaminated. To determine whether nearby residents and persons on-site are exposed to contaminants migrating from the site, the environmental and human components that lead to human exposure are evaluated. An exposure pathway is categorized as a completed or potential exposure pathway. A completed exposure pathway has five elements: a source of contamination, transport through an environmental medium, a point of exposure, a route of human exposure, and an exposed population.
A completed pathway indicates that exposure to a contaminant has occurred in the past, is currently occurring, or will occur in the future. Potential pathways, however, require that at least one of the five components is missing, but could exist. Potential pathways indicate that exposure to a contaminant could have occurred in the past, could be occurring now, or could occur in the future. A possible exposure pathway can be eliminated if at least one of the five elements is missing and will never be present. The discussion that follows incorporates only those pathways that are important and relevant to the site.
Surface Water and Sediment
Before PCB contamination was documented at this site, surface water near the GM plant received contamination through outfalls and surface water runoff. For many years, GM was permitted to discharge PCBs in process waters through plant outfalls into the St. Lawrence River. In 1989, the NYS DEC modified GM's State Pollution Discharge Elimination System (SPDES) permit so that no detectable PCBs were to be discharged. Before surface soil site contamination was documented, precipitation runoff carried contaminants into nearby surface waters including the St. Lawrence and Raquette Rivers and the unnamed tributary that separates the GM facility from the Mohawk Indian Reservation. Remedial actions have reduced this runoff. The interim cap placed over the industrial landfill has significantly decreased the infiltration of precipitation into the landfill and the subsequent releases to surface water. GM has instituted a surface water runoff control program which collects and treats runoff from contaminated areas. This collected surface runoff water and all process water go through a carbon filtration system that significantly minimizes PCB residuals before being discharged.
The PCB-contaminated sediments in the St. Lawrence River and the unnamed tributary have the potential to affect the surface water intake for the St. Regis Indian Reservation downstream of GM. Raw water samples from this intake have low levels of PCBs (see Table 4). The studies show an area of highly contaminated sediments near the former plant outfalls. Contaminant levels decrease as distance from the plant increases, but an area of approximately 20 acres of the St. Lawrence River is contaminated. Some of this contamination, particularly low level contamination that is not directly in front of the GM plant, may be due to sources other than GM. During the supplemental study to the RI, GM attempted to characterize sediment deposition.
A hydrogeologic investigation shows contaminated groundwater moving primarily in a northerly direction, towards the St. Lawrence River. There is some groundwater movement towards the Raquette River. Groundwater samples were analyzed for the hazardous substances list (HSL) chemicals.
Several residents on the Indian reservation use groundwater for domestic water. PCBs were found in some of these wells in 1985 (see Table 5). These positive results were not confirmed in subsequent analyses, including those done by NYS DOH. Groundwater users on Raquette Point were surveyed by Mohawk Environmental Services and NYS DOH and groundwater samples were collected from all current (1989) users. The analytical results were below detection limits for all these drinking water samples.
GM has recently proposed an amendment to the Record Of Decision. The proposal calls for disposing of soil and sediment containing up to 500 mg/kg of PCBs in the existing non-secure disposal area on the eastern edge of the GM property. The amount of waste to be disposed would double the areal extent of the landfill. Samples collected from groundwater in this area in the past have shown PCB contamination in the groundwater near the landfill indicating that there is migration of contaminants.
Fish and wildlife are contaminated with PCBs from the PCBs in surface water and sediment in the St. Lawrence and Raquette Rivers and the unnamed tributary. PCBs have a high affinity for body fat concentrate in fish flesh and are persistent in the environment. Because of these factors, PCB fish levels exceed the U.S. Food and Drug Administration (FDA) standards, and both aquatic and terrestrial wildlife species are contaminated (see Tables 6 and 7). The NYS DOH issues an annual health advisory for sportfish and game in New York State. The advisory is included as Appendix F of this report.
The fish and wildlife sampling has focused on those species frequently consumed by the local Indian population. As part of the HRA, local fish and wildlife were sampled and analyzed to evaluate the health risks associated with exposure to these media. The results of the HRA have been summarized and included in Appendix C of this report.
Some ambient air samples collected on- and off-site have contained PCBs, both during remedial activities and when no remediation was in progress. The predominant wind direction is from the west, which moves air-borne contamination from source areas (the plant sites, Contaminant Cove and contaminated river sediments) to residential areas. PCBs may be higher during the summer months. The contaminants become diluted in the ambient air as they move away from source areas. It is unlikely that residents would be exposed to the highest levels detected near the plant and average exposure levels are probably low (e.g., less than 20 ng/m3 ).
- Ingestion of PCB-contaminated fish or other consumable aquatic organisms has occurred in the past, is presently occurring, and may continue to occur. Both NYS DOH and Mohawk Environmental Health Services have issued warnings regarding the human consumption of fish and wildlife from the area of the GM facility. Despite these warnings, some members of the Mohawk tribe continue to consume fish and wildlife from areas with high levels of contaminants. The consumption of PCB-contaminated fish and/or wildlife in the past may have resulted in exposure to infants from breastmilk; however, the results of the breastmilk study since 1990 indicate that this exposure pathway is not as likely to be occurring due to mothers following the advisories that have been issued regarding ingestion of contaminated biota.
- Ingestion of contaminated wildlife has occurred in the past, is presently occurring, and may continue to occur. This completed human exposure pathway has been further evaluated in the Health Risk Assessment. Mohawk Environmental Health Services has provided information regarding the documented contamination of local wildlife in the area of the GM facility to residents of the reservation. The NYS DOH has issued an advisory regarding consumption of contaminated wildlife species (Appendix F). Because many Mohawks consider some of the local mammals, such as muskrat, a delicacy, this pathway continues to have potential public health effects. The NYS DOH exposure studies on Native American men and Native American women are ongoing to evaluate this route of exposure.
- There is a potential for direct contact or incidental ingestion to occur with soils not within the secured, fenced area. Direct contact with low-level contaminated soils on the reservation in residential areas can occur.
- Direct contact or incidental ingestion of PCBs while swimming or wading in the St. Lawrence or Raquette Rivers or the unnamed tributary has occurred in the past. Warning signs placed by the tribe have informed reservation residents that the area is contaminated and considered hazardous. Exposures are not known to be occurring at present; however, the potential for exposure remains as long as the contamination exists.
- Direct contact with contaminated soils by on-site workers within the facility fence has occurred in the past. Due to capping of this on-site soil in 1988 soil exposures are now less likely.
- Direct contact with and ingestion of PCB-contaminated soils off-site has occurred, and will continue to occur until these soils are removed. There is an area of fill soils near the Raquette River that is on GM property, but not within the secure fenced area. This area is accessible to the public, particularly along the banks of the river where there are visible footpaths. Hikers, fisherman, etc., could have been exposed to contaminated soils during recreational activities in the past, and the potential exists for further exposure until remediation is completed.
- There are some areas of low level PCB-contaminated surface soils on the St. Regis Reservation. Direct contact or incidental ingestion with these soils has occurred and continues to occur during normal domestic activities. This is of particular concern for infants and adolescents who play in areas of marginal contamination in residential areas. These exposures will continue into the future until remediation occurs.
- Inhalation of PCB-contaminated ambient air may have occurred in the past and may continue to occur. The available information indicates that, except during remedial activities, ambient air levels in residential areas are likely to be below 20 ng/m3 .
Ingestion of contaminated drinking water, both groundwater and surface water may have occurred in the past, is not known to be occurring now, and is not expected to occur in the future. Several rounds of homeowner well samples have been collected, with the only positive results in the first samples collected by GM's consultant. These results were never confirmed in subsequent rounds; however, GM provided bottled water to many of the residents of Raquette Point. Water from the residences not connected to the public water supply was sampled by NYS DOH in 1988 and 1989. When no PCBs were found, GM discontinued supplying bottled water. PCB concentrations in the surface water column could increase during remedial activities, particularly while the river sediments are dredged, if proper controls are not instituted. The public water supply intake for the St. Regis Indian Reservation is downstream of the dredging activities which may temporarily increase PCBs in the raw water. Samples collected to date indicate low nanograms per liter (ng/L) levels of PCBs in treated water. Although the treatment process at the St. Regis Water Treatment Plant appears efficient at removing contaminants, some additional exposure may occur through ingestion of these potable water supplies. Ingestion of contaminated drinking water has likely occurred in the past, but is not known to be occurring at present. The Health and Safety Plan provides for monitoring of the Mohawk's water supply during dredging. Actions will be taken to prevent exposure if elevated levels are found.
An analysis of the toxicological implications of the human exposure pathways of concern is presented below. To evaluate the potential health risk from contaminants of concern associated with the General Motors/Central Foundry Division site, the NYS DOH has assessed the risk for cancer and noncancer health effects. The health effects are related to contaminant concentration, exposure pathway, exposure frequency and duration. For additional information on how the NYS DOH determined and quantified health risks applicable to this health assessment, refer to Appendix C.
- Ingestion of PCB-contaminated fish is the most significant potential human exposure pathway at this site. PCBs are relatively insoluble in water but highly lipid soluble and are stored in the fatty tissues of fish and other animals. In PCB-polluted waters, PCBs can accumulate in the edible portions of fish. This is of particular importance because a large portion of the Indian diet is, or has been, local fish. The highest PCB levels in fish were well above the U.S. Food and Drug Administration (FDA) tolerance level of 2 parts per million (ppm) (Table 6). Individuals who consume these fish, particularly Mohawk Indians who may consume large amounts, are exposed to levels of PCBs that may adversely affect their health.
- Ingestion of PCB-contaminated wildlife (small mammals, ducks, etc.) is also an important human exposure pathway. The Mohawk Indians have traditionally consumed local wildlife and can be a large portion of their diets. The highest PCB levels in local wildlife were well above the only comparable FDA standard of 3 ppm in poultry (see Table 7). Because of limited sampling results, it is difficult to quantify exposure, but the data suggest that the risks of noncarcinogenic and carcinogenic effects could be high.
- The ingestion of contaminated drinking water was one of the first exposure routes addressed for this site. Initial samples collected from private water supply wells on the nearby Indian Reservation by GM's consultant showed PCB contamination. However, these results were never replicated in subsequent samples collected by NYS DOH. All recent samples at the Indian Reservation did not contain PCBs in any homeowner well or in the public water supply system. The public water supply system uses a diatomaceous earth filter that has been closely monitored and is effective at removing PCBs. Drinking water with PCBs above the NYS DOH or the US EPA standard of 0.5 mcg/L has not or is not being ingested (see Table 4).
- Direct contact or incidental ingestion of PCB contaminated surface water or sediments is of possible concern to those who may use contaminated areas for swimming or wading. Of particular concern would be youth from the infant to adolescent age group. PCBs can be absorbed through the skin; therefore, this exposure may contribute to total PCB body burden. Although it is difficult to quantify the levels of exposure from incidental ingestion of PCB-contaminated surface water or sediment, it does not appear that this exposure represents an immediate health concern, but could contribute to total PCB body burden.
- Direct contact or incidental ingestion of contaminated surface soils has occurred and continues to occur. Infants and adolescents playing in areas of low level contamination on the reservation would have skin contact or could have pica (soil-eating) behavior. PCBs can be absorbed through the skin which can contribute to total body burden of infants or adolescents. Ingestion of off-site soils will also contribute to total PCB burden. PCBs present in these soils at levels up to 3.3 mg/kg could pose a low risk of noncarcinogenic and carcinogenic effects.
- Inhalation of volatilized PCBs may have occurred in the past and may continue to occur for people in residential areas near the site. The available information indicates that, except during remedial activities, ambient air levels in residential areas are likely to be less than 20 ng/m3. This route of exposure may be more significant on hot summer days. If chronic exposure to 20 ng/m3 of PCBs occurred, it would pose a low increased cancer risk over a lifetime of exposure. In addition, PCBs are known to cause noncarcinogenic effects in animals at exposure levels about two to three orders of magnitude greater than exposure from off-site ambient air. Although the risks of noncarcinogenic health effects from these exposures aren't completely understood, the existing data suggest that they would be minimal.
- Soils and sediments (sludges) on-site and not accessible to the public are contaminated with organic chemicals and metals at concentrations, which with the exception of PCBs and benzo(a)pyrene, are not a health concern for short or long term-exposure by individuals working on-site. Past exposure (prior to capping of the on-site soil) of these workers to PCBs and benzo(a)pyrene in soil by ingestion and dermal contact would pose a high and low increased cancer risk, respectively.
- Persons engaged in on-site clean-up (remediation) activities have a potential for exposure to PCBs by multiple routes and could be at increased risk of adverse health effects. However, use of proper procedures, appropriate dust suppression methods and monitoring of ambient air for PCBs during clean-up would minimize any low level increased risk to workers and to nearby residents.
- On-site groundwater is contaminated with organic chemicals and metals at concentrations that exceed NYS DOH drinking water and/or groundwater standards or guidelines. There is a potential for ingestion, dermal and inhalation exposure to contaminants in private well water from contaminated groundwater.
Most information on the known and potential human health effects of PCB exposure comes from two sources: studies of occupational exposures and studies of women in the general population with elevated levels of PCBs in their blood. Although toxic effects occurred in people (and their children) in Japan and Taiwan who unknowingly ate rice oil containing PCBs (Yusho and Yu-Cheng incidents), the PCBs were heated to high temperatures and changed into more toxic compounds, including polychlorinated dibenzofurans (PCDFs). The scientific and medical consensus is that the latter chemicals, and not PCBs, were the major agents in the poisonings. Recent studies, however, suggest that it may be premature to conclude that PCBs had no role in the poisoning (Chen et al., 1992; Yu et al., 1991).
Effects reported after occupational exposures (mostly in air or through the skin) to PCBs include skin and eye irritation and sporadically headache, digestive disturbances and liver problems (ATSDR, 1995b; James et al., 1993). A study conducted by the NYS DOH of women exposed to PCBs in their workplace found evidence of a link between PCB exposure and lower birthweight children (Taylor et al., 1989). The conclusion that PCBs alone caused these effects is tentative because the workers were also exposed to other chemicals, including contaminants of PCBs.
Recent evidence suggests that behavioral anomalies and low birthweights occurred in infants whose mothers had a relatively high exposure to PCBs and other contaminants from the consumption of Great Lakes sportfish for many years prior to pregnancy (US EPA, 1993). Neurobehavioral effects were also noted in some of the same children when they were 5 years old. In a second study conducted in North Carolina, behavioral anomalies but not low birthweights were found in newborns of women who had elevated blood PCB levels (US EPA, 1993). Some of these same children showed neurological effects at 6, 12 and 24 months, but not at 3, 4 or 5 years of age. These studies, like many epidemiological studies, examined the correlations between PCB exposures and effects and cannot prove that PCBs were the sole factor responsible for the observed effects. This is a limitation of all epidemiological studies.
Animal experiments have clearly shown that PCBs cause noncarcinogenic effects in organs and organ systems, including the skin, liver, blood, nervous, reproductive and immune systems (ATSDR, 1995b). Some of these effects are similar to those seen in workers exposed occupationally to PCBs. Animal experiments also have clearly shown that PCBs are developmental and neurological toxicants in rodents and rhesus monkeys and that prenatal (before birth) PCB exposure produces lower birthweights and neurological effects in monkeys (ATSDR, 1995b; Golub et al., 1991). PCBs are known to produce these effects in animals at exposures generally less than one order of magnitude greater than exposure from consumption of PCB-contaminated fish from the St. Lawrence River and tributaries near the site. Although the risks of noncarcinogenic effects aren't completely understood, the existing data suggest that they are high for individuals regularly consuming one-half pound per week of these PCB-contaminated fish. This consumption rate is a reasonable estimate of fish consumption by recreational anglers and subsistence fisheaters including the Akwesasne Indians.
Some commercial mixtures of PCBs cause cancer in rats exposed to high concentrations over their lifetime, but studies are inadequate to evaluate the carcinogenic potential of any commercial mixture of PCBs in mice (ATSDR, 1995b). Whether or not PCBs cause cancer in humans is not known. Chemicals that cause cancer in laboratory animals may increase the risk of cancer in humans who are exposed to lower levels over long periods of time. Therefore, from extrapolation of animal studies, PCBs are considered to be potential human carcinogens (ATSDR, 1995b). Based on the results of animal studies and the limited sampling of fish collected from the St. Lawrence River and tributaries near the site, we estimate that if persons regularly consume one-half pound per week of PCB-contaminated fish, they have a high increased risk of developing cancer over their lifetimes.
The Raquette River fill area which is on-site but not fenced and therefore accessible to the public contains PCB-contaminated soils that are at levels which could pose a significant health risk to children playing in this area. Of particular concern, would be potential exposure through skin contact and ingestion. PCBs (up to 400 mg/kg) in these soils could pose a high and low risk of noncarcinogenic and carcinogenic effects, respectively. However, these risks are not expected to be as high because the highest level found (400 mg/kg) was only in one sample.
The health risks of exposure to PCBs have already been discussed (see #1 above). Chronic exposure to the levels of PCBs found in on-site groundwater would pose a very high increased cancer risk over a lifetime of exposure if consumed.
Other organic compounds were found in on-site groundwater (see Table 2). Benzo(b)fluoranthene (ATSDR, 1995a) has caused cancer in laboratory animals exposed to high levels over their lifetimes. Chemicals that cause cancer in laboratory animals may also increase the risk of cancer in humans who are exposed to lower levels over long periods of time. Whether or not benzo(b)fluoranthene causes cancer in humans is not known. In addition, quantitative data are not available from animal studies to assess the level of cancer risk to exposure to benzo(b)fluoranthene in drinking water. Toxicological data are inadequate to assess the carcinogenic potential of phenol (ATSDR, 1989c), 4-methylphenol (US EPA, 1990), 2,4-dimethylphenol (US EPA, 1990), and benzo(g,h,i)perylene (ATSDR, 1995a).
Phenol, 4-methylphenol and 2,4-dimethylphenol produce a variety of noncarcinogenic toxicities (primarily liver, kidney, heart, lung, stomach, blood and nervous system effects) at exposure about several orders of magnitude greater than potential exposures from on-site groundwater. Chemicals that cause effects in humans and/or animals after high levels of exposure may also pose a risk to humans who are exposed to lower levels over long periods of time. Although the risks of noncarcinogenic effects aren't completely understood, the existing data suggest that they would be high for 4-methylphenol and minimal for phenol and 2,4-dimethylphenol. Toxicological data are inadequate to assess the noncarcinogenic toxicities of benzo(b)fluoranthene and benzo(g,h,i)perylene (ATSDR, 1995a). In contrast, chronic exposure to PCBs at levels found in on-site groundwater would pose a high increased risk of noncarcinogenic effects.
Lead, arsenic, and chromium were found in on-site groundwater. Chronic exposure to elevated lead levels is predominantly associated with neurological and hematological effects (ATSDR, 1993c). At high exposure levels, lead can cause kidney damage, gastrointestinal distress, and reproductive effects including abortion and damage to the male reproductive system. The developing fetus and young children are particularly sensitive to lead-induced neurological effects, with symptoms ranging from delayed mental development and behavioral effects at low blood lead levels to frank ataxia, stupor, coma and convulsions at high blood levels. Arsenic can cause nerve, liver, blood vessel damage and behavioral problems including learning and hearing deficiencies (ATSDR, 1993a). Chronic (long-term) arsenic poisoning is characterized by a distinct pattern of skin abnormalities, including skin cancer in humans. Studies with laboratory animals indicate that exposure to elevated levels of arsenic during pregnancy may increase the risk of adverse developmental and reproductive effects. The primary toxicities associated with ingestion of large amounts of chromium have been kidney damage, birth defects and adverse effects on the reproductive system (ATSDR, 1993b). Chronic exposure to drinking water contaminated with arsenic could pose a high increase cancer risk, whereas exposure to chromium and lead at concentrations found in on-site groundwater would pose a low and moderate increased risk of adverse health effects, respectively.
The Mt. Sinai study, (Selikoff and Hammond, 1986) concluded that there was a direct relationship between blood levels of PCBs and mercury and the amount of fish eaten by the Akwesasne residents. The conclusion drawn from this report states, in summary, that consumption was significant and positively associated with blood and hair mercury levels. The mercury levels found in these biological media in St. Regis examinees were relatively low when compared with results reported in studies of other groups exposed to mercury-contaminated fish. Similarly, the report concludes that although PCB levels in fat and serum were associated with consumption of locally caught fish, the levels of PCBs in the fat and serum samples obtained from Akwesasne residents did not exceed the means and ranges reported in studies of other populations without known unusual exposures.
A collaborative study (NYS DOH, 1992) was conducted to investigate levels of 68 PCB congeners, total PCBs, p,p'-dichlorodiphenyl dichloroethene (p,p'-DDE), mirex and hexachlorobenzene in the breast milk of Mohawk women from Akwesasne (the St. Regis Mohawk Indian Reservation). The study was funded by NYS DOH, General Motors, ATSDR and the National Institute of Environmental Health Sciences. The study was initiated at the request of a Mohawk midwife who was concerned that breast-fed Akwesasne might be at higher risk of exposure to these chemicals, since these compounds are present in relatively high concentrations in environmental, fish, and wildlife samples collected in the area and because these chemicals concentrate in milk fat and other lipids. Ninety-three Mohawk women who gave birth between 1988 and 1992 were interviewed and provided a breast milk sample. The interview included sociodemographic characteristics, lifestyle variables, and occupational, residential, reproductive and dietary histories. The comparison population consisted of 154 nursing women from the Women and Infant Care (WIC) clinics of Warren and Schoharie counties who gave birth during the same period.
Mohawk mothers who gave birth in 1986-1989 had a higher geometric mean PCB concentration in breast milk than controls (0.602 vs. 0.375 ppm; p = 0.009). Beginning with mothers who participated in 1990, however, Mohawks did not have elevated average levels of total PCBs or individual congeners relative to the comparison group. Mohawk women showed a significant decline in their milk PCB concentration depending on when they participated, while levels in controls remained relatively stable over time. These differences paralleled similar differences in fish consumption. Mohawk women who participated later in the study reported that they consumed less local fish and were also more likely to remove the skin and trim the fat from the fish than women who participated earlier in the study.
PCB congener analysis suggested that Mohawk mothers, especially those with the greatest estimated lifetime exposure to PCBs from the consumption of local fish, had a congener pattern that was closer to that of perch caught near GM-CFD than did the controls.
The total PCB concentrations in breastmilk of both Mohawk and control mothers were on average similar to those reported to other American studies. This observation, together with the fact that the dietary intakes of most of the Mohawk mothers were well below Acceptable Daily Intakes and possible reference doses, suggests that it is unlikely that they are at increased risk for major health effects as a result of their exposure to PCBs, p,p'-DDE, mirex or hexachlorobenzene.
Although both the Mohawk and control infants were probably exposed to greater doses of these chemicals than bottle-fed infants, the known benefits of nursing are considered to outweigh the risks from chemical contamination at the low concentrations found in this and most other investigations.
The concerns regarding birth defects raised by the reservation midwife were addressed by the sampling of biota by NYS DEC and during the HRA.
The primary concern expressed by nearby residents regarding this site is the contamination in the river system. This contamination has changed the lifestyle of many members of the Mohawk tribe. The commercial fishery and guided fishing trip businesses have ceased because the fish can no longer be sold; and recreational anglers want to eat their catch. The concerns over the contamination in the river system can only begin to be addressed when removal of contamination is completed. The concerns over air emissions from both GM and Reynolds need to be evaluated.
- Based on the information reviewed, this site is a public health hazard because of past and continued human exposures to hazardous substances at levels of health concern. As outlined in the Human Exposure Pathways section, human exposure, primarily ingestion of PCB-contaminated fish and wildlife, has occurred and can continue to occur. This primary pathway has been evaluated in the Health Risk Assessment.
- Based on the health studies conducted to date, many Mohawk mothers have reduced their intake of local fish due to advisories provided by Mohawk, state and federal agencies. However, some Mohawks continue to consume fish as a significant portion of their diet.
- At this time, ingestion of contaminated groundwater is not occurring. All residences not connected to the public water supply have had their wells sampled and they do not contain contamination.
- Areas of highly contaminated sediments have been posted with warning signs, but exposure to low level soil contamination on the reservation continues.
- No access restriction has been implemented for the areas of contamination near the Raquette River.
- Ambient air sampling data taken near the GM plant show an increase in PCB levels above background during the hot summer months. Although an incremental increase in health risk exists for people exposed to these levels, the increase does not raise significant health concerns. Other air emissions may need further evaluation to address community health concerns.
- Site remedial activities may affect the quality of air and surface water, which may lead to exposures via inhalation or ingestion of drinking water.
ATSDR and the NYS DOH recommend the following:
- The results of the Health Risk Assessment conducted on this site and its surrounding areas determined that additional efforts are necessary to convince some segments of the Mohawk population that the consumption of fish and wildlife in the GM site area is to be avoided. Educational and outreach efforts should continue to advise and inform Mohawks and others about the risks associated with eating contaminated fish and wildlife until contaminant levels, particularly PCBs, decrease.
- During site remedial activities, there is a potential for further exposures to occur. The air exposure route may be especially significant, and all site remedial activities should be accompanied by continuous monitoring of air for vapor and particulates. During remediation, standard dust suppression procedures should be employed to minimize this route of exposure.
- There is a potential for sediment dredging activities in the St. Lawrence and Raquette Rivers to affect the intake of raw water for the St. Regis Reservation public water supply. Daily monitoring of the raw and potable water for this system should be a part of any remedial activity in the river system.
- Consideration should be given to determining whether or not remedial measures reduce ambient air levels of PCBs.
- Community health concerns about air emissions should be evaluated.
- Access to areas adjacent to the Raquette River with elevated levels of contamination in surface soils should be limited. The area should be posted with warning signs.
- A long term monitoring program for groundwater should be developed because not all site contamination will be removed.
- A health consultation document should be prepared after the US EPA has drafted a response to the General Motors proposed amendment to the Record of Decision.
The data and information developed in the public health assessment for the General Motors/Central Foundry Division site, Massena, New York, has been evaluated by ATSDR's Health Activities Recommendation Panel (HARP) to determine appropriate follow-up actions. Because of past and current completed exposure pathways to PCBs, the panel determined that follow-up health actions are needed at this site. Specifically, the HARP determined that community health and health profession education are needed. An on-going environmental education program is recommended to continue to inform the community and health professionals of the possible adverse health effects related to past and current exposures to PCBs, particularly from consuming contaminated fish and biota. The HARP also agreed with NYS DOH that these educational activities should be conducted in conjunction with the Mohawk Environmental Services. In addition, the HARP determined that further health actions will be considered after information from the final breast milk study and ATSDR Public Health Assessment are available for review.
The Public Health Action Plan (PHAP) for the General Motors/Central Foundry Division site contains a description of actions taken or planned by ATSDR, GM, US EPA, NYS DEC, and/or the NYS DOH at and near the site subsequent to the completion of this public health assessment. The purpose of the PHAP is to ensure that this health assessment not only identifies public health hazards, but provides a plan of action designed to mitigate and prevent adverse human health effects resulting from exposure to hazardous substances in the environment. Included is a commitment on the part of ATSDR/NYS DOH to follow up on this plan to ensure that it is implemented. The public health actions taken or planned are as follows:
Public Health Actions Taken
- An advisory concerning fish and wildlife consumption is issued by NYS DOH on an annual basis.
- Bottled water was provided by GM to reservation residents not connected to the public water supply. This was discontinued when further analyses did not find contamination in private wells still in use.
- The public water supply for the reservation was sampled by NYS DOH.
- GM placed a cap over the Industrial Landfill, reducing further percolation of rainfall through the highly contaminated soils.
- Mohawk Environmental Services placed warning signs in contaminated areas on the reservation that are not otherwise access restricted. This includes the surface water body between the reservation and GM where PCB-contaminated sediments are found.
- NYS DOH has coordinated the review of the HRA with ATSDR's Health Activities Recommendation Panel (HARP) to determine if further studies of the Reservation population are warranted.
- NYS DOH has used the results of the HRA to determine if additional advisories for fish or wildlife consumption need to be issued.
Public Health Actions Planned or Ongoing
- Under order from US EPA, GM will remove contaminated soil and sediment from areas not within the facility fence for on-site treatment and/or containment.
- NYS DOH will review the data generated from the sampling of the Mohawk's water supply intake during dredging as specified in the Health and Safety plan.
- NYS DOH and ATSDR's Division of Health Education will continue to coordinate with the Mohawk Environmental Health Services to conduct an environmental health education program to advise the public health professional and local medical community of the nature and possible consequences of exposure to contaminants from the General Motors site.
- NYS DOH, in consultation with the US EPA, will evaluate the need for additional air monitoring for PCBs to determine the effectiveness of remedial measures at the site.
- NYS DOH, in cooperation with ATSDR, will prepare a health consultation document to bring health information up to date. The health consultation will be prepared after the US EPA has drafted a response to General Motors amendment to the Record of Decision.
- NYS DOH will evaluate community concerns about air emissions from industry in the area.
ATSDR will reevaluate and expand the Public Health Action Plan when needed. New environmental, toxicological, or health outcome data, or the results of implementing the above proposed actions may determine the need to evaluate the feasibility of conducting follow-up health activities, including health studies.
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Public Health Specialist (Env) III
Bureau of Environmental Exposure Investigation
Public Health Specialist (Env) III
Bureau of Environmental Exposure Investigation
Kenneth G. Bogdan
Bureau of Toxic Substance Assessment
Joel H. Kaplan
Bureau of Toxic Substance Assessment
ATSDR Regional Representative
Office of Regional Operations
ATSDR Technical Project Officer
Technical Project Officer
Division of Health Assessment
and Consultation, Superfund Site Assessment Branch
The Public Health Assessment for the General Motors /Central Foundry Division
site was prepared by the New York State Department of Health under a cooperative
agreement with the Agency for Toxic Substances and Disease Registry (ATSDR).
It is in accordance with approved methodology and procedures existing at the
time the public health assessment was begun.
Gregory V. Ulirsch
Technical Project Officer
Superfund Site Assessment Branch (SSAB)
Division of Health Assessment and Consultation (DHAC)
The Division of Health Assessment and Consultation, ATSDR, has reviewed this Public Health Assessment, and concurs with its findings.
Acting Chief, SSAB, DHAC, ATSDR