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PUBLIC HEALTH ASSESSMENT

HOOKER CHEMICAL/RUCO POLYMER
HICKSVILLE, NASSAU COUNTY, NEW YORK


APPENDIX A


Figure 1. Location of the Hooker/Ruco Site


Figure 2. Map of Hooker/Ruco Site


Figure 3. Approximate Location of USGS Groundwater Monitoring Wells Near the Hooker/Ruco Site for which Data are presented in Table 3


Figure 4. Approximate Location of Public Water Supply Wells




APPENDIX B

Table 1.

On-Site Soil and Sediment Sample Results for the Hooker Chemical/Ruco Polymer Site
Collected During 1990 Remedial Investigation+
(All values in milligrams per kilogram, mg/kg)
[See Table 2 for Public Health Assessment Comparison Values]



  On-site shallow soils from
0.0 feet to 2.0 feet deep
On-site soils
greater than 1.0 feet deep***
Sediments****
  Range Frequency Range Frequency Range Frequency


Volatile Organic Chemicals            

*1,2-dichloroethene (total)

ND-0.011 5/30** ND-3.4 9/63 ND-0.076 2/13

 *carbon tetrachloride

ND-0.68 05/30 ND-<2.0 7/63 ND 0/13

 *trichloroethene

ND-0.720 12/30 ND-7.60 26/63 ND-0.002 4/13

 *tetrachloroethene

ND-0.710 16/30 ND-57.0 49/63 ND-0.001 2/13

 Semi-volatile Organics

           
*PCBs 1248 ND-5.3 11/30 ND-2,100.0 15/63 ND-73.0 7/13

*PCBs 1254

ND 0/30 ND-2.4 2/63 ND 0/13

 Inorganics

           

*antimony

ND-28.0 13/30 ND-28.0 28/63 ND-31.0 8/13

 *cadmium

ND-7.9 15/30 ND-11.0 30/63 ND-9.0 7/13


ND - not detected

< = less than

*Contaminant selected for further evaluation

**Frequency values represent the number of times the contaminant was found (5) out of the total number of samples collected (30) (5/30).

***This column does not include the data for soils reported as 0-2 feet in Appendix 10 and reported in the first column of this table.

****Total number of samples including a set of duplicates.

+Leggette, Brashears and Graham, Inc., 1990. Draft Remedial Investigation, Hooker Chemical/Ruco Polymer Site. Hicksville, New York. Draft Report I-IV.

Table 2.

Public Health Assessment Comparison Values for Contaminants
Found in On-Site Soil and Sediment at the Hooker Chemical/Ruco Polymer Site.
(All values in milligrams per kilogram, mg/kg) Comparison Values

 

  Typical
Background
Range
Comparison Values

  Minimal Health Risk
Nonresidential*
Minimal Health Risk
Residential Exposure**
  Cancer Source Noncancer Source Cancer Source Noncancer Source

Volatile Organic Chemicals                  

 

1,2-dichloroethene (total)

ND - - 14,000 EPA RfD - - 2 NYS RfG

carbon tetrachloride

ND 5.4 ATSDR CREG 490 EPA RfD 0.03 NYS CREG 0.7 NYS RfG

trichloroethene

ND 56 EPA CPF 5,200 EPA RfD 0.2 NYS CREG 5 NYS RfG

tetrachloroethene

ND 14 EPA CPF 7,000 EPA RfD 0.06 NYS CREG 10 NYS RfG

Semi-Volatile Organics

                 

PCBs 1248

<0.01-0.04a 0.09a ATSDR CREG 42 NYS RfG 0.03a NYS CREG 4 NYS RfG

PCBs 1254

<0.01-0.04a 0.09a ATSDR CREG 70 NYS RfG 0.03a NYS CREG 5 NYS RfG

Inorganics

                 
antimony 0.6-10 - - 20 EPA RfD - - NA -

cadmium

<0.5-1.0 - - 140 ATSDR EMEG - - 10 ATSDR EMEG

NA - not available
aTotal PCBs

*Soil ingestion by adults

**Ingestion of soil and homegrown vegetables by adults (cancer values) and children (noncancer)

ATSDR CREG = ATSDR Cancer Risk Evaluation Guide
ATSDR EMEG = ATSDR Environmental Media Evaluation Guide
EPA CPF = EPA Cancer Potency Factor
EPA RfD = EPA Reference Dose
NYS CREG = New York State Cancer Risk Evaluation Guide
NYS RfG = New York State Risk Reference Guide
NYS EMEG = New York State Environmental Media Evaluation Guide


Table 3.

Groundwater and Surface Water Data for Hooker-Ruco Site Collected
During 1990 Remedial Investigation
Hooker Chemical/Ruco Polymer Site
(All values in micrograms per liter, mcg/L)+

                  Comparison Values
                 

Standards

       
                  New York State US EPA        

Groundwater++
On-Site

Groundwater
Off-Site Downgradient
Groundwater
Upgradient
Surface Water Ground
Water
Drinking
Water
Drinking
Water
Minimal Health Risk For Drinking Water
  Range Frequency Range Frequency Range Frequency Range Frequency Cancer Source** Noncancer Source**

Volatile Organic Chemicals                              

*1,2-dichloroethene (total)

ND-54.0 14/29*** ND-2.0   ND 0/4 ND 0/3 5.0 5.0j 100t; 70k - - 70 EPA LTHA
*trichloroethene ND-18.0 10/29 ND-10.0 1/5 ND 0/4 ND 0/3 5.0 5.0 5.0 3 NYS CREG 52 EPA RfD

*tetrachloroethene

ND-98.0 12/29 ND-180.0 1/5 ND-3.0 0/4 ND 0/3 5.0 5.0 5.0 0.7 NYS CREG 70 EPA RfD
*vinyl chloride

ND-94.0

6/29 ND-560.0 1/5 ND 0/4 ND 0/3 2.0 2.0 2.0 0.02 EPA CPF 0.2 ATSDR EMEG

Semi-Volatile
Organics

                             
PCBs 1248 ND 0/29 ND 1/5 ND 0/4 ND-2.0 1/3              

 

PCBs 1254

ND 0/29 ND 1/5 ND 0/4 ND 0/3              

Inorganics

                             

*antimony

ND-66.0 3/29 ND 1/5 ND 0/4 ND 0/3 3g NA 6 - - 6  

*cadmium

ND-130.0 14/29 ND-3.0 2/6 ND 0/4 3.0-7.0 3/3 5 10 5.0 - - 2 ATSDR EMEG

NA - not available
ND - not detected

g = guidance value
p = proposed standard
t = total dichloroethene
c = total PCBs
j = applies separately to cis and trans isomers

*Contaminant selected for further evaluation

**ATSDR EMEG = ATSDR Environmental Media Evaluation Guide
EPA CPF = EPA Cancer Potency Factor
EPA RfD = EPA Reference Dose
EPA LTHA = EPA Lifetime Health Advisory
NYS CREG = New York State Cancer Risk Evaluation Guide

***Frequency values represent the number of times the contaminant was found (14) out of the total number of samples collected (29) (14/29).

+Leggette, Brashears and Graham, Inc., 1990. Draft Remedial Investigation, Hooker Chemical/Ruco Polymer Site. Hicksville, New York. Draft Report I-IV.

++This data is a summary of the information given in Table 4 and represents the results from sampling conducted in 1987 to 1990.


Table 4.

Summary of Historical Water-Quality Results
From USGS Monitor Wells Near Hooker/Ruco Polymer
(micrograms per liter, mcg/l)
[See Table 3 for comparison values]+


    N10812a N10593b* N10594b N10597b N10598b N9079c

tetrachloroethene            
 

1987(S)

3 2 ND 320 790 ND
  1987(F) 7 ND ND 30 240 1
 

1988(S)

8 78 ND 52 NS ND
 

1988(F)

7 9 ND 9 NS ND
 

19901/

ND ND ND NS 180 NS

trichloroethene

           
 

1987(S)

ND 36 170 5 5 7
 

1987(F)

ND 3 180 1 2 14
  1988(S) ND 40 230 3 NS 4
 

1988(F)

ND 51 440 ND NS 3
 

1990

ND ND ND NS 10 NS

dichloroethene

           
 

1987(S)

ND 340 ND 15 ND 15
 

1987(F)

ND 91 ND 1 ND 22
 

1988(S)

ND 330 ND ND NS 14
 

1988(f)

ND 260 ND ND NS ND
 

1990

ND ND ND NS ND NS

vinyl chloride

           
 

1987(S)

ND 67.4 ND ND 6 ND
 

1987(F)

ND 280 1 ND 35 ND
 

1988(S)

ND 72 1 ND NS ND
 

1988(F)

ND 776 ND ND NS ND
 

1990

ND 530 ND NS ND NS

1/ - 1990 RI groundwater sample results.
S - Denotes Spring
F - Denotes Fall
ND - Not Detected
NR - Results Not Reported
NS - Not Sampled
a - Upgradient Monitoring Well
b - Downgradient Monitoring Well
b* - Immediately Downgradient
c* - Side Gradient

+Leggette, Brashears and Graham, Inc., 1990. Draft Remedial Investigation, Hooker Chemical/Ruco Polymer Site. Hicksville, New York. Draft Report I-IV.


Table 5.

Toxic Release Inventory (TRI) Data for Facilities Near the
Hooker Chemical/Ruco Polymer Site - Air Releases of Chemicals
(Stack Plus Fugitive) in Pounds Per Year++



 
Facility
Chemical
Release

 

Grumman Aerospace Corporation

 
methanol 499

1,1,1-trichloroethane

97,158

methylene chloride

48,030

Freon 113

154,376+

methyl ethyl ketone

76,990

trichloroethene 217,875*+

toluene

10,000

tetrachloroethene 522,500*+

hydrogen fluoride

499

nitric acid 1,233

chromium

499

General Instrument Corporation

 
sulfuric acid 20

Alsy Manufacturing Inc.

 

1,1,1-trichloroethane

96,236

methyl ethyl ketone

4,418

Metco, Incorporated

 

aluminum

1,700

nickel

5,100

chromium

1,400

cobalt 1,180

Multiwire/EED

 

copper

5

Altana, Incorporated  

isopropanol

12,610


 

 

*Hooker/Ruco Polymer site contaminant of concern.

+Contaminant anticipated to exceed 1 microgram per cubic meter within 1/2 mile of the Hooker/Ruco Polymer site.

++1988 Toxic Release Inventory, US EPA

Table 6.

Completed and Potential Exposure Pathways
  Exposure Pathway Elements

Pathway
Name

Source Environmental
Media
Point of
Exposure
Route of
Exposure
Exposed
Population
Time

Completed Exposure
Pathway

PCB contaminated
on-site soils
near Plant 1

Surface soils
on-site; subsurface
soils during
excavations
workers
on-site
Ingestion
Dermal
contact
Approximately
100 employees
of Hooker/Ruco

Past
Current
Future

Potential
Exposure
Pathway

Contaminated
groundwater
Municipal water
supply - Bethpage
water district
Residences
& businesses
served by
Bethpage water
districts
Ingestion Inhalation
Skin contact
Users of
Bethpage
Water District
Future/will not
occur as long as
current monitoring
programs and
regulations are
kept in place

Potential Exposure
Pathway

Hooker/Ruco
Active Process
Air Emissions
Ambient
Air
People near
Hooker/Ruco
Inhalation
Dermal
contact
Community
Near
Hooker/Ruco
Past
Present
Future

 

APPENDIX C

Hooker Chemical/Ruco Polymer
Responses to Public Comments

This responsiveness summary was prepared to respond to the public'scomments and questions on the draft Public Health Assessment forthe Hooker Chemical/Ruco Polymer site. The public was invited toreview this draft public health assessment during the publiccomment period which ran from March 31, 1993 to May 3, 1993. Somecomments were grouped together to incorporate similar concernsraised by more than one person. Comments made by the OccidentalChemical Corporation and Ruco Polymer Corporation are listedseparately. If you have any questions about the responses topublic comments for the Hooker/Ruco site, contact the New YorkState Department of Health, Health Liaison Program at the toll-freenumber, 1-800-458-1158, extension 402.

Local Citizen Comments

Comment #1

Does the New York State Department of Health have any plans toevaluate health outcome data specific for the area surrounding theHooker/Ruco site? Will a community health survey be conducted?

Response #1

At this time the New York State Department of Health does not haveplans to evaluate health outcome data specific to the areasurrounding the Hooker/Ruco site. However, in the 1989 BreastCancer Incidence Study this area was examined and found to haverates consistent with that for all of Nassau County. The 1989study showed the rates for Suffolk and even more so for NassauCounty are elevated compared to national rates and is the basis foradditional work sponsored by the Centers for Disease Control andPrevention (CDC).

Comment #2

Synergistic exposures to a variety of these toxics could have acumulative effect leading to cancer and serious medical problems(non-cancerous).

Response #2

When there is exposure to multiple contaminants selected forfurther evaluation, the risks are evaluated for cancer andnoncancer health effects from such exposure to each contaminant. If the cancer and noncancer toxicological effects associated witheach of these contaminants are the same or very similar, then theindividual risks are added. This assumption of additivity ofeffects was used to determine the health risks described in thetoxicological evaluation section of the Public Health Assessmentfor the Hooker Chemical/Ruco Polymer site. On the other hand, ifthese contaminants acted in a synergistic fashion, then the degreeof risk would be greater than the sum of the risks associated fromexposure to each chemical. Although synergism or antagonism ofeffects from exposure to multiple contaminants is a possibility,data on toxicological mechanisms are inadequate to evaluate whatextent this synergism would occur.

Comment #3

An essential part of risk assessment is to determine whether or notthe contamination will reach the public water supply wells;therefore, testing should be performed to determine if thecontamination will reach the public water supply wells.

Response #3

The State of New York (the New York State Departments ofEnvironmental Conservation (DEC) and Health (DOH)) have activelypursued further study of the groundwater contamination as itrelates to public water supplies. Recently, Occidental ChemicalCorporation submitted a workplan for studying off-site groundwatercontamination. This work, in addition to work already in progressby Grumman Aerospace Corporation and the U.S. Navy, will provideinformation necessary to assess and protect the potential forimpacts on public wells.

Comment #4

Water treatment should be a combination of air stripper andGranular Activated Carbon (GAC).

A) Does an air stripper or GAC remove VOC's or PCB's at the Bethpage Water District?

B) Would air stripping cause PCB's to be airborne?

Response #4

A) PCBs have not been detected in samples of water from the Bethpage Water District or in groundwater anywhere off-site. The contaminants detected so far are volatile organic chemicals which are treatable by an air stripper or GAC. If PCBs were found, treatment would most likely be a GAC filter since air stripping would not remove all the PCBs.

B)

Air stripping of PCB contaminated water, if present, would volatilize some PCBs.

Comment #5

Will a 325 foot or 450 foot supply or production well pull incontamination? In other words, will a well change the naturalcourse of groundwater flow?

Response #5

Any well of any depth has an area from which it withdraws water. This area is known as the "cone of influence". The size of the"cone of influence" depends on the pumping rate and thecharacteristics of the aquifer. Computer modelling and fieldtesting have been used to characterize the cone of influences ofmany of the wells in the Bethpage area.

Comment #6

Is the contamination still occurring? If the soil is stillcontaminated with hazardous wastes, they will eventually end up inthe ground and the wells.

Response #6

The major areas of soil contamination have been identified andthese soils should be remediated shortly. The regulatory agenciesfor this site have worked to identify and eliminate on-goingsources of contamination. In addition, Grumman AerospaceCorporation, as part of its response to contamination at itsfacility, is installing groundwater monitoring wells betweenBethpage Water District supply wells and the Grumman Aerospace andHooker/Ruco sites. These wells will help to warn of contaminationwhich could reach the Bethpage Water Supply wells.

Further evaluation of the hydrogeology and contamination will beperformed as additional information becomes available. Additionally, the US EPA and NYS DEC have requested OccidentalChemical Corporation, the responsible party for this site, toconduct off-site groundwater monitoring. This work would becarried out under Federal and/or State Superfund Programs.

Comment #7

The presence of contamination that are known carcinogens, mutagens,toxins are always of concern to the public. Soil should be cleanedto zero contamination. Clean up to a level of 10 mg per kg soil ofPCBs is unacceptable.

Response #7

The cleanup level of 10 mg of PCBs per kg of soil was set with theunderstanding that the site will remain an industrial facility. The main objective of the PCB cleanup was to prevent furthermigration of the PCBs. No members of the public should be exposedto the soils left on-site if site conditions remain unchanged. Most of the PCB contaminated soils left on-site are covered bypavement. Additionally, institutional controls are part of theremediation of this site. The purpose of the institutionalcontrols is to prevent changes in site use which result in exposureto these soils.

Comment #8

Why have off site soil samples not been collected?

Response #8

The practices that resulted in the contamination of on-site soilsshould not have resulted in contamination of off-site soils. Thesepractices were the discharge of wastes to recharge basins on-site,and spills/leaks of liquids on-site. Sampling confirms that thecontamination is limited to on-site soils.

Comment #9

You need to determine whether leaking sewer lines have contaminatedthe soils and ground water underneath the sewers.

Response #9

This comment has been forwarded to the US EPA and NYS DEC, whichare responsible for investigating the sources and migration of thecontamination. We do not believe this is a significant concern forpublic health. The industrial waste water was discharged to sumpson-site which have been investigated. This includes the beds ofpipes used to transfer the waste water to these sumps. There is noinformation to indicate that the sanitary sewer systems are nowused to discharge these wastes.

Comment #10

Has the source of tetrachloroethene upgradient of Hooker beenidentified? (Are there two sources of contamination?)

Response #10

Given the low levels of tetrachloroethene found in the upgradientwells and that there are no supply wells affected by thiscontamination, this requested work is of low priority. However,further work into the source of this contamination is warranted.

Comment #11

When did the state start issuing SPDES permits? Where are reportsfiled? When SPDES permits are issued for use and storage ofhazardous wastes on site, does the county and the NYS DEC follow-upon investigations at frequent intervals to keep track ofcompliance?

Response #11

SPDES is an acronym for the program State Pollutant DischargeElimination System which was, along with the national program, setup under the Clean Water Act of 1970. The New York StateDepartment of Environmental Conservation oversees the SPDESprogram. For details on the SPDES program contact the NYS DECRegion 1 Office in Stony Brook. Their number is 516/751-7900.

Comment #12

Is the storage area for these wastes kept in proper condition toprevent further contamination?

Response #12

The handling and storage of waste on-site have significantlyimproved in recent years. Oversight of these practices is providedby the NYS DEC and the Nassau County Health Department. Theseagencies should be contacted if more information is desired.

Comment #13

Grumman should use recycling of water and a cap put on pumping toreduce plume movement. Air releases from Grumman are unacceptable. As long as Grumman continues to pump more than 14 million gallonsper day in the summer, VOCs will be pulled in to the wells at afaster rate.

Response #13

The NYS DOH agrees with the general opinion of the hydrogeologiststhat have studied this area that shutting down the Grummanproduction wells may be a greater concern than leaving them on-line. The current pumping by Grumman is retarding off-sitemigration of contaminated groundwater. Since the water Grummanpumps from the aquifer is contaminated, they are required to treattheir water before they discharge it to recharge basins on-site. This in essence is helping to remediate the contaminatedgroundwater.

Comment #14

What can be done to prevent ambient air releases of trichloro-ethene, Freon 113 and tetrachloroethene.

Response #14

Air emissions of these three chemicals, as well as all others inNassau County, are regulated by the New York State Department ofEnvironmental Conservation's Division of Air Resources and theNassau County Health Department. For more information pleasecontact Mr. Bryan Matthews of the Nassau County Health Departmentat 718-514-3719 or the New York State Department of EnvironmentalConservation (NYS DEC), Division of Air Resources at 516-444-0240.

Comment #15

A warning should be placed on the deed for this property.

Response #15

The New York State Department of Health and ATSDR agree with theneed for institutional controls for this property. Institutionalcontrols in the form of a deed notification have been requested. The US EPA is calling for institutional controls as part of theremedial design for operable unit 1.

MAJOR CONCERNS EXPRESSED BY RUCO POLYMER CORPORATION
AND/OR OCCIDENTAL CHEMICAL CORPORATION

The major concerns expressed by Ruco Polymer Corporation and/orOccidental Chemical are that the report did not accurately andconsistently reflect the nature and extent of remedial work alreadyperformed, and that the text speculates about or implies that theRuco site is or may be the source of various kinds of odor orgroundwater pollution without offering any substantiation.

The report was reviewed to address these concerns and many changeswere made. ATSDR and NYS DOH recognize that there has beensignificant remedial work completed at the Hooker/Ruco site. However, NYS DOH and ATSDR do not believe the 10.0 part per millionclean up level used for on-site PCB contaminated soils isappropriate for a residential setting. This appears to be thebasis for many of their comments. Additionally, Ruco Polymercorrectly indicates that the groundwater contamination off-site cannot be directly linked to the Hooker/Ruco site. The informationavailable is not sufficient to make this determination. However,practices at the Hooker/Ruco site led to groundwater contaminationand that the contamination may have migrated off-site.

Finally, Ruco Polymer expressed concern about the discussion ofambient air quality and its relation to the Toxic Release Inventory(TRI) data and odors. Ruco Polymer is correct in stating thatbased on the TRI data the amount of chemicals that they emit toambient air is small compared to that of the Grumman AerospaceCorporation. However, local residents have complained togovernment agencies of odors that they attributed to theHooker/Ruco site.

Specific Comments from Ruco Polymer Corporation

There were 47 comments received from Ruco Polymer Corporation. Thirty-five comments resulted in changes to the text to address theconcerns expressed. Most of these comments improved the accuracyof the report. For this reason, specific responses to thesecomments are not presented.

Page numbers referenced in the following comments relate to thePublic Comment Release Public Health Assessment (March 1993).

Comment #1

Page 1, paragraph 2: This paragraph creates the erroneousimpression that the soils underlying the Ruco plant site arepresently contaminated. A successful remediation of PCBcontaminated soils was performed with the approval of the UnitedStates EPA and completed with the removal of 3,028,786 pounds ofsoil. The soil was taken off site and disposed of according toapplicable regulations. The remediation was completed in August1992 in conformance with the remedial work plan.

Given the completion of the remediation efforts at the site,current site conditions and compliance efforts, the potential foreither worker or public exposure to contaminated soils is minimal. We accordingly request that this paragraph be revised to read asfollows:

    On-site soils in certain areas at the Hooker/Ruco Polymer sitewere formerly contaminated with polychlorinated biphenyls(PCBs), specifically the PCB known as Aroclor 1248. Thiscontamination was limited in area, was in a location removedfrom most workers and has undergone successful remediationpursuant to a Remedial Action Plan approved by the UnitedStates EPA. The Plan involved the removal of some 3,000,000pounds of affected soil. The remediation was completed inAugust 1992. In view of these actions and the fact that theentire site is fenced and patrolled by a 24-hour securityforce, there is little or no remaining potential for eitherworker or public exposure to PCB contaminated soils on site.

Response #1

Changes to the text were made to show that PCB contaminated soilson-site were cleaned to a level of 10.0 parts per million. changeswere made throughout the text to indicate that this work was done. Included in the changes was an effort to portray that the potentialfor on-site workers or the public to be exposed to PCB contaminatedsoils is minimal. However, the text was amended to also make itclear that a clean-up level of 10.0 ppm is not consideredacceptable for a residential setting by NYS DOH and ATSDR. It isfor this reason that NYS DOH requested that institutional controlsbe included as part of the Record of Decision (ROD) to limit thepotential for the site to be developed for residential propertywithout further clean-up.

Comment #2

Page 4, paragraph 3: Has a syllabus for the community healtheducation been approved? Will Ruco be given the opportunity toparticipate in the process?

Response #2

Specifics of the community health education program have not beendeveloped. Ruco Polymer will have an opportunity to participate inthe process, however, the NYS DOH and ATSDR will determine thecontent and presentation of the program.

Comment #3

Page 15, paragraph 2, sentence 2: Please revise "workers thatshould be trained" to read "workers who are routinely trained...".

Response #3

This change was not made since the statement "The workers should betrained" is appropriate whether they are trained or not. Obviously, we encourage Ruco Polymer to continue to train theiremployees as implied in this comment.

Comment #4

Page 19, paragraph 2: We would like to offer the following commentsbearing on the relevance of this paragraph: According to the EPA ata recent seminar on TRI compounds, in all of Nassau County during1992, 2,293,000 pounds of TRI compounds were emitted. Of thisnumber, 1,028,000 pounds were emitted by a large industrialneighbor to our east. This is 44.83% of the total for NassauCounty. Ruco emitted 1,600 pounds of TRI compounds. This is0.069% of the Nassau County total. None of the compounds emittedby Ruco were involved in any of the investigations. Accordingly,we cannot perceive what relevance, if any, the emission of suchcompounds from the Ruco site can reasonably have to any assessmentof public health implications.

Response #4

The local citizens feel that this is very relevant and for thisreason it has been discussed in this document. Many residents havecomplained of offensive odors they attributed to the Ruco PolymerCorporation. In addition, these emissions are evaluated todetermine whether they represent an additional human exposure tothose already presented by the hazardous waste site.

Comment #5

Page 19, paragraph 4: We fail to see how an admitted lack oftoxicity data can serve as a basis for a finding that the site"currently presents an indeterminate health hazard". Since thereis no reasonable basis for such a conclusion, we request that thisparagraph be revised accordingly.

Response #5

The indeterminate public health hazard category is based on thelack of environmental data for the groundwater pathway, not thelack of toxicity data.

The Hooker/Ruco site was given this classification since at thistime it is not possible to determine the exact contribution theHooker/Ruco site has had to off-site groundwater contamination. Additionally, we know that groundwater is the sole source forpotable water and if government did not monitor or regulate thisuse, people may be drinking water contaminated by the Hooker/Rucosite.

Comment #6

Page 19, paragraph 5: The text here speculates about possiblefuture exposure to contaminated groundwater when in fact, neitherthe constituents, quantities or sources of the "contamination" haveyet been established. What use is served by speculation aboutpossible human exposure in the future to what has not beenestablished as existing in the present?

Response #6

The purpose of considering potential future exposures is to preventexposures from occurring. For example, it will allow for the timenecessary to install a treatment system on a water supply wellbefore it becomes contaminated and, therefore, prevent watershortages or human exposure.

Comment #7

Page 20, paragraph 1, sentence 1: The text should read"...residents in the area of the Hooker/Ruco plant site...". Page20, paragraph 2: Air quality in the area of the Ruco site may beimpacted by a large industrial neighbor. There is adisproportionate amount of chemicals released by this neighbor ascompared to Ruco Polymer Corporation. Ruco releases less than0.16% of the amount released by our neighbor.

Response #7

Some changes to the text were made; however, the text alreadyshowed that for TRI emissions, the Grumman Aerospace Facility is agreater source of emissions than the Ruco Polymer Corporation.

Specific Comments from Occidental Chemical Corporation

Comment #1

The remedial program for PCB's in soil has been completed and hasreceived United States Environmental Protection Agency (US EPA)approval. Therefore, all references to current or future exposureto levels in excess of 10 mg/kg (milligrams per kilogram) are nowinappropriate and should be deleted.

Response #1

These changes have been made.

Comment #2

The document should discuss the fact the vinyl chloride in theground water in the area is likely a result of the degradation oftetrachloroethene or trichloroethene.

Response #2

Changes were made to indicate that the vinyl chloride found ispotentially from the degradation of tetrachloroethene ortrichloroethene. However, the document also indicates that thevinyl chloride could also be directly from disposal practices.

Comment #3

The Public Health Assessment contains references totrichloroethylene in the Bethpage Water District well. By far thelargest users of trichloroethylene in the area are Grumman and theNavy. It is extremely unlikely that the Hooker/Ruco site has hadan adverse effect on the public supply well.

Response #3

Agreed, but the off-site data detailing the migration ofcontamination from the Hooker/Ruco site does not allow for thispossibility to be ruled out.

Comment #4

A distinction must be made between the Hooker/Ruco site and RucoPolymer Corporation. The former refers to the CERCLA site, whichis on the National Priorities List because of past waste disposalpractices. The latter is an operating chemical manufacturingfacility. This distinction is especially important when discussingcurrent air quality.

Response #4

Agreed. Changes were made to help make this distinction.

Comment #5

Page 11, Ground Water. This section concludes that "...the site isthe source of contamination in groundwater off site..." Thesentence should be changed to state that the site is a"contributing source", not "the source". This section shouldinclude a discussion about other known downgradient sources oftrichloroethene, tetrachloroethene and vinyl chloride. Thediscussion should include a statement that discusses thedegradation of trichloroethene and tetrachloroethene to vinylchloride.

Response #5

Changes made in text.

Comment #6

Page 11, Ground Water. This section also has a qualifyingstatement about the data being generated from wells completed todepths of less than 200 feet. Occidental Chemical Corporationbelieves that the RI has completely characterized the extent ofsite-related chemistry in ground water both horizontally andvertically, and deeper data are not needed. Concentrations ofchloroethylene compounds in the deeper wells at the downgradientproperty line were at levels less than 100 ug/l (micrograms perliter).

Response #6

The NYS DOH believes deeper wells are needed because all of thepublic water supply wells are at a depth of about 500 feet. Nochanges made.

Comment #7

Page 11, Soils. This section states that no off site soil samplingwas conducted to determine if off site soils have been impacted byactivities at the Hooker/Ruco site. The Risk Assessment concludedthat there was not risk to human health related to on site soils,so there is not need to assess off site soil, especially given themultiple sources of chemicals in the area.

Response #7

The risk assessment concluded that the risk was acceptableaccording to US EPA guidelines, but that there is a risk. Thebetter point, as made in the report, is that the activities on-siteshould not have contaminated off-site soils.

Comment #8

Page 15, On site Soils. This entire section fails to take intoaccount the fact that PCB's in soil have been removed from the siteto a level of 10 mg/kg. The Risk Assessment did not demonstrateany current risks to site workers from exposure to shallow soils. The future use scenario of this site as residential is improbablefor the immediate future. Regardless of the frame it is notimpossible that it becomes residential. However, were this tooccur, site remediation would be required and exposure potentialwould be removed. This would apply to inorganic and organicchemicals.

Response #8

Amendments were made. The risk assessment demonstrated that thecurrent risks to on-site workers are acceptable according to US EPAguidance, but that there are risks.

Comment #9

Page 16 and 17, On site and Off site Groundwater. This sectionthen goes on to describe the toxicological implications ofingesting groundwater at the highest observed concentrations ofcertain chemicals. This situation will not occur, and thedescriptions are, therefore, meaningless in this document. Thisreport may be read by the local populace who may not be aware thatthere is no chance for them to be exposed to the chemistry in thegroundwater at or near the Hooker/Ruco site. This document alsofocuses on trichloroethene, which is predominantly associated withthe Grumman/Navy sites, not the Hooker/Ruco site.

Response #9

The discussion of the toxicological implications of ingestinggroundwater at the highest concentration shows the need forremediation and further investigation of groundwater contamination. Groundwater is the sole source of potable water in this area and,therefore, it is important to determine the implications of usinggroundwater as it is. The ultimate fate of the contaminated on-site groundwater is unknown and is why more study is needed.

Comment #10

Several comments on the accuracy of the tables in public healthassessments were made. Occidental Chemical Corporation providedtables with changes to improve the accuracy of the ones in thepublic health assessment.

Response #10

Changes to the tables have been made according to neededcorrections indicated by Occidental Chemical Corporation. However,some of the requested changes were not made. The amended tables asprovided by Occidental Chemical Corporation are included in thecomment section of the final Public Health Assessment.

Comment #11

Table 1 amendments provided by Occidental Chemical Corporation areshown in the following table.

On-Site Soil and Sediment Sample Results for the Hooker
Chemical/Ruco Polymer Site Collected During 1990 Remedial
Investigation


  On-Site
Shallow Soils
Sediments
Compound Range Frequency Range Frequency

1,2-dichloroethene
(total)

  6/30 ND-0.076 2/13

carbon tetrachloride

  3/30   0/13

trichloroethene

  13/30   4/13

tetrachloroethene

  18/30 ND-0.0006 2/13

PCB 1248

ND-51 10/30   7/13

PCB 1254

ND-1.2 2/30   0/13
antimony

ND-33

10/30   10/13

cadmium

  12/30   9/13

 

Response #11

Table 1 in this report was amended, however, not all changes weremade. Table 1 in this report was generated from review of Appendix10 of the 1990 RI.

Comment #12

Occidental Chemical Corporation does not concur with inclusion ofthe USGS Monitor Well N10597 for the Groundwater Off siteDowngradient data. As noted in table 4, Summary of HistoricalWater - Quality Results from USGS Monitor Wells near Hooker/RucoPolymer, Well N10597 was last sampled in the fall of 1988. Becausethe latest sampling round was done over one year prior to the RIsampling, this data is not representative of ground-water qualityevaluated during the RI. In addition, the title of table 3 refersspecifically to data collected during the 1990 RI.

Response #12

Table 3 was amended to include a notation that the off site dataare from Table 4.

Comment #13

Table 3 amendments provided by Occidental Chemical Company areshown in the following Table.

Groundwater and Surface Water Data for Hooker/Ruco Site
Collected During 1990 Remedial Investigation


 

Groundwater

Groundwater Groundwater Surface Water
Compound Range Frequency Range Frequency Range Frequency Range Frequency

1,2-dichloroethene
(total)

      1/5   0/4    

trichloroethene

    ND-10 1/5   0/4    

tetrachloroethene

      1/5 ND-3 2/4 ND 0/3

vinyl chloride

      1/5   0/4    

PCB 1248

      0/5   0/4    

PCB 1254

      0/5   0/4    

antimony

      0/5   0/4    

cadmium

  10/29 ND-3 2/5 ND-4 1/4    

Response #13

Amendments were made and others were not since errors were found in the original table and the amended table provided by Occidental Chemical Corp. The Table 3 in this report was generated from review of Appendix 10 of the 1990 RI.

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