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PUBLIC HEALTH ASSESSMENT

PETER COOPER
GOWANDA, CATTARAUGUS COUNTY, NEW YORK


ENVIRONMENTAL CONTAMINATION AND OTHER HAZARDS

Site conditions are characterized to evaluate if a site poses an existing or potential hazard to the exposed or potentially exposed population. This site characterization involves a review of sampling data for environmental media (e.g., soil, surface water, groundwater, air), both on-site and off-site, and an evaluation of the physical conditions of the contaminant sources or physical hazards near the site which may pose an additional health risk to the community.

Contaminants selected for further evaluation are identified based upon consideration of the following factors:

  1. Concentrations of contaminants in environmental media both on-site and off-site;
  2. Field data quality, laboratory data quality and sample design;
  3. Comparison of on-site and off-site contaminant concentrations in environmental media with typical background levels;
  4. Comparison of contaminant concentrations in environmental media both on-site and off-site with public health assessment comparison values for (1) noncarcinogenic endpoints and (2) carcinogenic endpoints and drinking water standards. Contaminant concentrations greater than a comparison value do not necessarily pose a health threat; and,
  5. Community health concerns.

The selected contaminants (see Table 7) are evaluated in the Public Health Implications section (Toxicological Evaluation) of this Public Health Assessment (PHA) to determine whether exposure to these chemicals is of public health significance. Please note in Table 7 that the public health comparison values were calculated for the specific pathway of exposure(s) associated with the Peter Cooper site. These comparison values should not be used for other site evaluations.

This section includes a discussion of sampling data for environmental media. Summary tables of sampling data are presented in Appendix B. Each of the data tables list the individual contaminants found in a particular media in the left most column The listing of a contaminant does not necessarily mean that it will cause adverse health effects from exposure. The columns to the right of the listed contaminants show the range of detection, the number of detects and the total number of samples: "Range of Detection" column shows the minimum concentration to maximum concentration at which a particular contaminant was found, excluding any non-detected samples; "Number of Detects" indicates the number of samples of a given media in which a particular contaminant was found; and "Total Samples" indicates the number of samples of a given media that were collected and analyzed for a particular contaminant.

The environmental data in this section were gathered during several investigations, primarily a Remedial Investigation that was completed in 1989, a Site Inspection Prioritization Report completed in 1996, and additional sampling that the US EPA conducted in 1996 (NYS Department of Health site files). Contaminants have been identified in wastes, leachate, soil, groundwater, surface water and sediment. The metals arsenic, chromium and zinc occur naturally, but these metals have been found at concentrations in excess of what would be considered naturally occurring. In addition to these metals, hexavalent chromium was found. Hexavalent chromium is not naturally occurring and its presence is associated with manufacturing waste. In addition to the metal (or inorganic) contamination, some organic chemical contamination has been found. The following sections summarize the results of the investigations of the Peter Cooper-Gowanda site.

A. On-site Contamination

Wastes

Six samples of waste material were collected in 1988, but three of these samples were composited for analysis. In 1996, seven samples were collected and analyzed for chromium, hexavalent chromium, and arsenic. The composite sample collected in 1988 and six of the waste samples collected in 1996 were analyzed for organic contaminants. The results are summarized on Table 1 (Appendix B).

Subsurface Soil

In 1988, 22 subsurface samples were collected and analyzed for chromium, hexavalent chromium, and arsenic. Nine of these were also analyzed for zinc. Five subsurface soil samples were collected in 1996 and analyzed for chromium, hexavalent chromium and arsenic. Four of the 27 subsurface soil samples were collected at depths greater than a foot and the remaining 23 samples were shallow subsurface samples that were collected up to a foot in depth. Two of the subsurface and one of the shallow subsurface samples collected in 1996 were also analyzed for organic contaminants. The results are summarized on Tables 2a and 2b (Appendix B).

Surface Soil

In 1988, 40 on-site surface soil and three "background" surface soil samples were collected from ground surface to a depth of three inches. The background samples were collected between the landfill and the facility buildings. In June 1995, three surface soil samples were collected from ground surface to six inches deep. In July 1995, 13 on-site surface soil samples and one "background" surface soil sample were collected. In 1996, seven surface soil samples were collected along the banks of the Cattaraugus Creek. Sixty-three on-site surface soil samples and four "background" surface soil samples have been collected. The results for these samples are summarized on Table 3 (Appendix B).

Groundwater

The 1985 environmental investigation showed that groundwater is in contact with the waste at about five feet beneath the land surface. Overburden and bedrock groundwater flow toward Cattaraugus Creek. Samples of groundwater were collected in September 1986, April 1987, July 1988, and December 1996. Suspended solids in the groundwater resulted in high turbidity; therefore, the analyses were done on filtered and unfiltered groundwater samples. Refer to Table 4 (Appendix B) for a summary of the results.

Air

During a 1996 site visit, NYS DOH staff sampled air at several landfill locations and along the edge of the creek. Real time measurements were taken for hydrogen sulfide, volatile organic compounds and methane.

The levels of air contaminants at locations near fissures (openings) in the landfill cover were generally higher than those at other locations. The highest hydrogen sulfide reading was 194 micrograms per cubic meter (mcg/m3) for a location near exposed waste, while the range for other locations was 4.2 mcg/m3 to 39 mcg/m3. Volatile organic compounds, including methane, were measured from 2 parts per million (ppm) to 2000 ppm. Methane concentrations, measured with the same FID using a carbon filter to filter out other volatile organic compounds, were 1 to 197 mcg/m3. Two air grab samples were taken from the areas where the highest methane readings were found. One of these areas was near exposed waste and the other was near a hole where leachate was seeping out. The grab air samples contained benzene at 1.1 mcg/m3 and 1.2 mcg/m3, and toluene at 10 mcg/m3 and 11 mcg/m3.

B. Off-Site Contamination

Surface Water

For the remedial investigation, surface water samples were collected from three locations in Cattaraugus Creek on four different occasions from September 1986 to August 1988. On each occasion, samples were collected from two upstream locations and one downstream location and analyzed for arsenic, zinc, chromium and hexavalent chromium. During the 1995 US EPA site inspection, surface water samples were collected from six locations in Cattaraugus Creek, two upstream, one next to the landfill, and three downstream. These samples were analyzed for volatile and semi-volatile organic chemicals, pesticides and metals. In December 1996, the US EPA collected six more samples from Cattaraugus Creek, two upstream, one next to the landfill, and three downstream. In total, 24 samples; 12 from upstream, 2 adjacent to the site and 10 from downstream; were collected from Cattaraugus Creek. The data from these samples are summarized on Table 5a.

In April 1987, samples were collected from an intermittent stream on the site and analyzed for arsenic, chromium, hexavalent chromium, and zinc. Arsenic and hexavalent chromium were not found in these samples. Chromium and zinc were found in both samples. Chromium was detected at 0.006 milligrams per liter (mg/L) and 0.008 mg/L and zinc was detected at 0.034 mg/L and 0.043 mg/L.

Sediment

One sediment sample was collected from Cattaraugus Creek downstream from the landfill during the remedial investigation in 1988. The US EPA collected six sediment samples in June 1995 and five sediment samples in December 1996 at locations which they collected surface water samples. A sediment sample was not collected at the furthest downstream location where a surface water sample was collected in 1996. Twelve sediment samples (four from upstream, two adjacent to the site and six from downstream) were collected from Cattaraugus Creek. The creek sediment data are summarized on Table 5b (Appendix B).

Elevated concentrations of arsenic and chromium were found in samples collected upstream of the Peter Cooper site. Arsenic and chromium are frequently associated with tannery wastes. Therefore, the elevated concentrations of arsenic that were found in upstream sediments may have originated from Moench Tanning or some other upstream source.

In addition to the creek samples, two sediment samples were collected from the adjacent wetland in 1996. Arsenic, chromium, hexavalent chromium, and total PAHs were found in both samples at concentrations of 5.1 milligrams per kilograms (mg/kg) and 6.7 mg/kg, 10 mg/kg and 27 mg/kg, 5.5 mg/kg and 5.7 mg/kg, and 0.141 mg/kg and 0.31 mg/kg, respectively.

Leachate

Leachate is liquid, primarily groundwater, that seeps out of waste material. During the remedial investigation, leachate samples were collected from two pipes that discharge into Cattaraugus Creek and from seepage between bedrock layers along Cattaraugus Creek. Liquid from the two discharge pipes was composited into one sample and liquid collected from the bedrock seepage into another sample. Samples were collected from the discharge pipes and of the bedrock seepage on two occasions. During the 1995 US EPA site inspection, seven leachate samples were collected. All eleven samples were analyzed for arsenic, chromium, and hexavalent chromium (one of the results for arsenic was rejected by the laboratory, so there are only ten results for arsenic). Four of the samples collected in 1995 were also analyzed for organic chemicals. Leachate results are summarized on Table 6 (Appendix B).

C. Quality Assurance and Quality Control

The analytical data used by the NYS DOH in preparing this Public Health Assessment are found in the Remedial Investigation (RI) and other investigations. Laboratory data are evaluated with respect to specific quality assurance (QA) and quality control (QC) measures. Data which do not meet certain QA/QC criteria for reasons such as excessive blank contamination or non-reproducible results, are not used in the PHA or are qualified as questionable results.

D. Physical and Other Hazards

During site visits, NYS DOH staff have noted that the former facility buildings have been partially demolished and several pieces of heavy equipment have been left on the property. The building demolition debris left on site may pose trip and fall hazards. People may fall into the foundations of the partially razed buildings. The building remnants do not appear to be stable, and they could collapse. Heavy equipment left on the site could pose a trip and fall hazard.

E. Toxic Chemical Release Inventory

The Toxic Chemical Release Inventory (TRI) has been developed by the US EPA from chemical release information provided by those industries that are required to report contaminant emissions and releases annually. The NYS DOH reviewed air emissions data reported to the TRI by industrial facilities identified to be within a 2.5 mile radius of the Peter Cooper-Gowanda site for the years 1988 through 1995. These data were reviewed to evaluate other sources of contamination that may pose an additional health risk to the exposed population at or near the site.

The NYS DOH has developed a screening model to estimate if potential contaminant concentration resulting from air emissions at a facility may be contributing to community (receptor population) 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 concentration at a distance of about 0.4 miles from the site.

Moench Tanning Company, Inc. is the only industrial facility which was identified that released air emissions within a 2.5 mile radius of the Peter Cooper site. During 1992, TRI-reported air releases indicate that this company released 21,895 pounds of glycol ethers, 17,577 pounds of xylene, 6790 pounds of sulfuric acid and 3444 pounds of ammonium sulfate. The facility closed in October of 1992.

The NYS DOH uses an air concentration of 1 microgram per cubic meter (mcg/m3) as a screening value to evaluate the contaminants further. Based on the most recent TRI air release data, the screening evaluation indicates that air emissions from this facility would not increase contaminant levels in ambient air near the Peter Cooper site to levels above this screening criterion. Based on the results of this screening evaluation, the public health significance of contaminant emissions from TRI facilities as an additional source of community exposures at the Peter Cooper-Gowanda site will not be evaluated further in this public health assessment.


PATHWAY ANALYSIS

This section of the public health assessment (PHA) identifies potential and completed exposure pathways associated with past, present and future use of the site. An exposure pathway is the process by which an individual may be exposed to contaminants originating from a site. An exposure pathway has five elements: (1) a contaminant source; (2) environmental media and tranport mechanisms; (3) a point of exposure; (4) a route of exposure; and (5) a receptor population.

The source of contamination is the source of contaminant release to the environment (any waste disposal area or point of discharge); if the original source is unknown, it is the environmental media (soil, air, biota, water) which are contaminated at the point of exposure. Environmental media and transport mechanisms carry contaminants from the source to points where people may be exposed. The exposure point is a location where actual or potential human contact with a contaminated medium may occur. The route of exposure is the manner in which a contaminant actually enters or contacts the body (i.e., ingestion, inhalation, dermal absorption). The receptor population is the persons who are exposed or may be exposed to contaminants at a point of exposure.

Two types of exposure pathways are evaluated in the PHA; a completed exposure pathway exists when the criteria for all five elements of an exposure pathway are documented; a potential exposure pathway exists when the criteria for any one of the five elements comprising and exposure pathway is not met. An exposure pathway is considered to be eliminated when any one of the five elements comprising an exposure pathway has not existed in the past, does not exist in the present, and will never exist in the future.

A. Completed Exposure Pathways

Leachate seeps along Cattaraugus Creek

People have been seen fishing in Cattaraugus Creek adjacent to the site. Since active leachate seeps have been observed along the Cattaraugus Creek boundary of the site, any people fishing in this area may be exposed to leachate by direct contact or incidental ingestion. For example, NYS DOH staff observed one fisherman placing a fish in leachate while he removed a hook from the fish. This fisherman did come in direct contact with leachate and may have incidentally ingested leachate. People who visit the site and go to the creek may be similarly exposed to leachate.

Surface soil, exposed waste, on-site surface water, and wetlands sediment

Unauthorized visitors have been observed at the Peter Cooper-Gowanda site on several occasions. Therefore, these people may come in direct contact with or incidentally ingest contaminated surface soil, exposed waste material, on-site surface water, and wetland sediments. The extent that unauthorized visitors may be exposed to surface material is unknown. Although data on the surface soil were collected, no samples of exposed waste material have been collected; therefore, exposure to wastes at the surface cannot be fully evaluated.

Unauthorized visitors may be exposed to shallow soil if the surface soil is disturbed by vehicle wheels or any other object digging into the surface material.

Cattaraugus Creek surface water and sediment near the site

People have been seen fishing in Cattaraugus Creek adjacent to the site. While fishing in this area or downstream of the site, people may be exposed to contaminated surface water and sediment through direct contact or incidental ingestion.

Air

Unauthorized visitors may breathe airborne volatile organic chemicals or contaminated airborne soil particulates (dust). Foul odors were present over large portions of the site during one site visit and measurements of air volatile organic chemicals were made during another site visit. During a removal action, area residents allegedly complained about odors; however, there are no records of complaints about odors from the landfill. Since it is likely that airborne releases are occurring, people on the site or nearby neighbors of the site could be exposed to airborne contaminants.

The air concentrations that were measured for benzene and toluene are similar to typical levels measured in urban air (ATSDR, 1997; 1998). The highest concentrations of these contaminants and for hydrogen sulfide do not exceed their corresponding public health comparison values for short-term exposure. Chronic (long-term) exposure to the highest levels of hydrogen sulfide, benzene and toluene is unlikely since the levels were mainly measured near exposed waste or leachate seepage. Furthermore, concentrations of contaminants are expected to be considerably lower at the site perimeter due to dilution. Therefore, this pathway will not be evaluated in the Toxicological Evaluation section.

Since the FID results indicate that the benzene and toluene may have come from the landfill, other volatile organic compounds may be present that were not characterized qualitatively or quantitatively. Also, it is unknown if the short-term air measurements are representative of long-term air concentrations at the landfill. However, the air data may not be representative of all conditions, especially when wastes are being disturbed. If additional information warrants, this pathway may need to be evaluated in the future.

B. Potential Exposure Pathways

Subsurface wastes and soil

There are no current exposures to subsurface waste or contaminated subsurface soil. However, any excavation into this material could leave it exposed to potential direct contact by unauthorized visitors to the site. Exposure of this material may facilitate release of volatile organic chemicals into air, where unauthorized visitors may breathe them. Erosion of the soil cap or material along the shoreline may encourage transport of contaminants to adjacent Cattaraugus Creek.

Soil Gases

Gases are being produced within the landfill; however, it is unknown whether soil gases from the Peter Cooper site have migrated through the ground into the basements or crawlspaces of nearby homes. Therefore, this pathway cannot be evaluated further. A soil gas survey of the area surrounding the Peter Cooper site is needed.

Fish

People who catch fish from the Cattaraugus Creek may eat it. However, it is unknown whether fish from the Cattaraugus Creek are contaminated, and if they are, to what extent. Since the contaminant levels are unknown, this exposure pathway cannot be evaluated further. However, the contaminants that were found in the creek water and sediments do not generally bioaccumulate to levels of public health concern in fin fish.

Cattaraugus Creek surface water, sediments, and fish at the Seneca Nation

Many people of the Seneca Nation use Cattaraugus Creek extensively for food gathering, recreation, and livelihood. There are several examples of activities that may expose people of the Seneca Nation to contaminants that may have migrated downstream in the Cattaraugus Creek. Wild onions that grow along the creek banks are harvested and eaten, particularly in a wild onion soup; deer, that may eat along the creek, are hunted and eaten; and some medicinal herbs, that are harvested for various uses, grow wild on the creek banks. People may be exposed, by dermal contact and incidental ingestion, to sediment and surface water while gathering gravel from gravel pits along the creek that are subject to seasonal flooding.

Some members of the Seneca Nation observe a traditional lifestyle, which means that they get most, if not all, of their food from natural local sources. People of the Seneca Nation that observe a traditional lifestyle would be exposed, directly or indirectly, to surface water and sediments from Cattaraugus Creek on a more frequent basis than people of the Seneca Nation that practice a more conventional lifestyle, where people get their food from several sources.

The possible levels of Peter Cooper contaminants in creek water, sediments, game animals, fish, or edible vegetation at the Seneca Nation Reservation are unknown. Contaminants that may have migrated from the Peter Cooper-Gowanda site to the Cattaraugus Reservation are not expected to be present at levels of public health concern in creek water and sediments. Likewise, contaminants are not expected to be present at levels of public health concern in vegetation, fish or game. However, if data from the remedial investigation or other investigations indicate that these pathways may be a concern, further investigation or evaluation of these pathways will be recommended.

C. Eliminated Exposure Pathways

Groundwater

There are no nearby residential wells; therefore, it is not expected that people would be exposed to groundwater contaminated with contaminants from Peter Cooper. Furthermore it is unlikely any wells would be placed in the area since public water is available.


PUBLIC HEALTH IMPLICATIONS

A. Toxicological Evaluation

An analysis of the toxicological implications of the human exposure pathways of concern is presented below. To evaluate the potential health risks from contaminants of concern associated with the human exposure pathways identified for the Peter Cooper-Gowanda site, the NYS DOH assessed the risks for cancer and non cancer 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 qualified health risks applicable to this health assessment, refer to Appendix D.

  1. Past and current completed incidental ingestion and dermal exposure to contaminants in leachate seeps along Cattaraugus Creek.

Waste sludge from operations at the Peter Cooper facility may have been disposed in the on-site landfill beginning in the early 1900s. The landfill is unlined and leachate seeps were observed during the site visit in May 1998 and previous site visits. Unauthorized visitors to the site and recreational users of the creek could have been exposed to contaminants in leachate seeps. Only one chemical contaminant detected in the leachate samples, arsenic, exceeded the public health assessment comparison value for incidental ingestion and dermal exposure. Arsenic is a known human carcinogen. Studies of people exposed to high levels of arsenic in drinking water in foreign countries provide evidence of an association between arsenic ingestion and skin cancer. Currently there exists a debate within the scientific community about the quantitative uncertainties in US EPA's cancer potency factor and epidemiology studies of Taiwanese populations exposed to arsenic in drinking water (ATSDR, 1993a). The existing data suggest that chronic exposure to the highest level of arsenic detected in leachate seeps (98.8 mcg/L) would pose a low increased cancer risk to unauthorized visitors to the site and recreational users of the creek.

  1. Incidental ingestion and dermal exposure to contaminants in on-site surface soil, surface water and wetlands sediment.

Arsenic and benzo(a)pyrene were detected in on-site surface soil at concentrations that exceed public health assessment comparison values. None of the contaminants detected in on-site surface water and wetlands sediment exceed public health assessment comparison values. Concentrations of antimony, chromium and zinc in surface soil exceed typical background levels, but are less than public health assessment comparison values.

The health effects of arsenic have already been discussed above. Benzo(a)pyrene causes cancer in laboratory animals exposed to high levels over their lifetimes (ATSDR, 1995). Whether or not benzo(a)pyrene causes cancer in humans is unknown. Chronic exposure of unauthorized visitors to arsenic and benzo(a)pyrene at the highest levels detected in on-site surface soil (417 mg/kg and 7.8 mg/kg, respectively), could pose a low increased cancer risk.

  1. Incidental ingestion and dermal exposure to contaminants in Cattaraugus Creek surface water and sediment.

Arsenic was detected in creek water adjacent to the site at concentrations that exceed public health assessment comparison values. None of the contaminants detected in creek water downstream from the site or in creek sediments adjacent to or downstream from the site exceed public health assessment comparison values. Concentrations of chromium in creek sediment adjacent to the site exceed typical soil background levels, but are less than public health assessment comparison values.

The health effects of arsenic have already been discussed above. Chronic exposure of recreational users of the creek to arsenic at the highest levels detected in creek water (123 mcg/L) could pose a low increased cancer risk.

  1. Potential incidental ingestion and dermal exposure to contaminants in on-site subsurface waste, subsurface soil and shallow soil.

The following contaminants were detected in on-site subsurface waste at concentrations that exceed public health assessment comparison values: arsenic, chromium and the polycyclic aromatic hydrocarbon (PAH), benzo(a)pyrene. Levels of chromium in shallow soil also exceeded the public health assessment comparison value. None of the contaminants detected in on-site subsurface soil exceed public health assessment comparison values. Concentrations of zinc in subsurface waste, chromium in subsurface soil and arsenic and zinc in shallow soil exceed typical soil background levels, but are less than public health assessment comparison values.

The health effects of arsenic and benzo(a)pyrene have already been discussed above. Although exposure to these contaminants is currently unlikely, unauthorized visitors could be exposed if the waste and soil were brought to the surface. If these contaminants were made available for human contact, chronic exposure to arsenic and benzo(a)pyrene at the highest levels detected in on-site subsurface waste (33 mg/kg and 12 mg/kg, respectively) could pose a low increased cancer risk.

Dermal exposure to high levels of chromium compounds (including hexavalent chromium) have resulted in allergic reactions, particularly to people who are very sensitive to chromium. These allergic reactions are characterized by redness and swelling of the skin (ATSDR, 1993b). The existing data suggest that dermal exposure to the highest levels of chromium detected in on-site subsurface waste and shallow soil (44,000 mg/kg and 33,000 mg/kg, respectively) could cause such allergic reactions in some unauthorized visitors if contaminants were made available for human contact.

B. ATSDR Child Health Initiative

The ATSDR Child Health Initiative emphasizes the ongoing examination of relevant child health issues in all of the agency's activities, including evaluating child-focused concerns through its mandated public health assessment activities. The ATSDR and New York State Department of Health consider children when we evaluate exposure pathways and potential health effects from environmental contaminants. We recognize that children are of special concern because of their greater potential for exposure from play and other behavior patterns. Children sometimes differ from adults in their susceptibility to hazardous chemicals, but whether there is a difference depends on the chemical. Children may be more or less susceptible than adults to health effects, and the relationship may change with developmental age.

The area around the Peter Cooper-Gowanda site includes homes that have children in their household who may trespass onto the site. For the contaminants that were identified in the completed pathways, arsenic and benzo(a)pyrene, we have no specific evidence that suggests that children will be more sensitive to the effects of exposure to these contaminants than adults.

C. Health Outcome Data Evaluation

No health outcome data have been generated or are planned to be generated specifically for the Peter Cooper-Gowanda site. However, at the request of the Chairman of the Cattaraugus County Solid Waste Committee, the New York State Department of Health is currently conducting a review of Cancer Incidence data for the Village of Gowanda, the Cattaraugus Reservation and the Towns of Perrysburg, Persia, Dayton, New Albion, and Otto. No other health outcome data evaluations are planned for this site.

D. Community Health Concerns Evaluation

  1. Nearby residents are concerned about possible health effects from their potential exposure to contaminants at the site, especially arsenic and hexavalent chromium.

  2. The NYS DOH estimates that long-term exposure to site-related contaminants (arsenic and benzo(a)pyrene) present a low increased risk of cancer. Short-term exposure to the highest level of chromium in on-site subsurface waste and shallow soil could cause an allergic reaction in some unauthorized site visitors if contaminants were made available to human contact.

    The NYS DOH will provide community education as appropriate.

  3. The community has expressed concern about nuisance odors.

  4. The NYS DOH or Cattaraugus County Health Department will address odor complaints as they occur. In addition, the public health assessment recommends that a proper cover be placed over the landfill.

  5. The community is concerned about the physical hazards associated with the salvaging operation that is being operated adjacent to the site.

  6. This public health assessment recommends that physical hazards either be removed or access to them be restricted.

  7. Nearby residents are concerned about the migration of landfill gas to the basements of nearby homes.

  8. This public health assessment recommends that soil gases near the site be investigated.

  9. The Seneca Nation is concerned about possible human exposures to contaminated sediments and biota downstream of the Peter Cooper site and adjacent to the Cattaraugus Reservation.

  10. Current information does not indicate that the Peter Cooper site is impacting the Cattaraugus Reservation. However, information from the US EPA's remedial investigation will be evaluated to determine if additional data from near the reservation needs to be collected.

    The public was invited to review the draft during the public comment period, which ran from February 29, 2000 -- April 14, 2000. We received one response, which was from a public agency. The response to these comments are presented in Appendix E.


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