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PUBLIC HEALTH ASSESSMENT

PFOHL BROTHERS LANDFILL
CHEEKTOWAGA, ERIE COUNTY, NEW YORK


APPENDIX 4

ENVIRONMENTAL EXPOSURE PATHWAYS

TABLES 1 AND 2

Appendix 4, Table 1 - Completed Environmental Exposure Pathways at the Proposed Pfohl Brother Landfill National Priorities List Site, Cheektowaga, New York
Pathway Name Point of Exposure Route of Exposure Exposed Population Time of Exposure Contaminants of Concern Estimated Population
Waste and On-Site Surface Soil At the Landfill and Landfill Border Ingestion
Inhalation
Skin Contact
People Who Walked, Played, and Worked on the Landfill Past Dibenzofuran, Carcinogenic PAHs, Aluminum, Barium, Cadmium, Copper, Lead, Mercury, and Zinc Unknown
Physical Hazards At the Landfill Physical Contact People Who Walked and Played on the Landfill Past Physical Injury Concern Unknown
Aero Lake In the Lake Ingestion
Inhalation
Skin Contact
People Who Swam and Played at Aero Lake Past Bis (2-Ethylhexyl) Phthalate, Carcinogenic PAHs, Barium, Cadmium, and Lead Unknown
Appendix 4, Table 2 - Possible Environmental Exposure Pathways at the Proposed Pfohl Brother Landfill National Priorities List Site, Cheektowaga, New York
Pathway Name Point of Exposure Route of Exposure Exposed Population Time of Exposure Contaminant of Concern Estimated Exposed Population
Groundwater Private Drinking Water Wells near the Landfill Ingestion
Inhalation
Skin Contact
People Living Near the Landfill Prior to 1986 Past Polychlorinated Biphenyls (??), Barium, Cadmium, and Manganese Unknown
On-Site Leachate, Surface Water, and Sediment At the Landfill Ingestion
Inhalation
Skin Contact
People Who Walked and Played on the Landfill Past Dibenzofuran, Carcinogenic PAHs, aluminum, Arsenic, Barium, Cadmium, Chromium, Lead, Manganese, Nickel, and Zinc Unknown
Radiation Near the Sources of Radiation Removed from the Landfill Irradiation People Who Removed any Sources of Radiation Past
Current
Future
Gamma Radiation Unknown


APPENDIX 5

COMPARISON OF ESTIMATED EXPOSURE DOSE TO HEALTH GUIDELINES

TABLES 1 AND 2

Appendix 5, Table 1 - Comparison of Estimated Exposure Dose to Health Guidelines for Persons Exposed to On-site Contaminants at the Proposed Pfohl Brothers Landfill National Priorities List Site, Cheektowaga, New York
Contaminant Exposure
Pathway
Health Guideline Cancer
Class
Value
(mg/kg/day)
Source Exceeded by
Estimated
Exposure Dose
Acetone Waste 0.1 RfD NO
Aluminum Waste
Surface Soil
1 Provisional
RfD
NO
Arsenic Waste
Surface Soil
0.0003 MRL NO
NO
A
Barium Surface Soil 0.07 RfD NO
Cadmium Waste
Surface Soil
0.0007 MRL NO
NO
B1
Chromium (III) Waste
Surface Soil
1 RfD NO
NO

Chromium (VI) Waste
Surface Soil
0.005 RfD NO
NO
A
Cobalt Surface Soil none


Copper Waste
Surface Soil
none


Cyanide Waste 0.02 RfD NO
Dibenzofuran Waste
Surface Soil
none


Lead Waste
Surface Soil
none

B2
Manganese Waste
Surface Soil
0.14 RfD NO
NO

Mercury Waste
Surface Soil
0.002 iMRL* NO
NO

Nickel Surface Soil 0.02 RfD NO RAC
Phenol Waste 0.6 RfD NO
Polychlorinated Biphenyls Surface Soil 0.00002 MRL NO B2
Carcinogenic PAHs* Waste
Surface Soil
0.1 aMRL** NO
NO
B2
Non-Carcinogenic PAHs*** Waste
Surface Soil
0.03 RfD NO
Selenium Surface Soil 0.003 MRL NO
Vanadium Surface Soil 0.003 iMRL**** NO
Zinc Surface Soil 0.3 RfD NO
*Health guidelines for Benzo(a)pyrene
**aMRL = acute MRL
***Health guidelines for pyrene
****iMRL = intermediate MRL
Appendix 5, Table 2 - Comparison of Estimated Exposure Dose to Health Guidelines for Persons Exposed to Aero Lake Contaminants Near the Proposed Pfohl Brothers Landfill National Priorities List Site, Cheektowaga, New York
Contaminant Exposure
Pathway
Health Guideline Cancer
Class
Value
(mg/kg/day)
Source Exceeded by
Estimated
Exposure Dose
Aluminum Sediment 1 Provisional
RfD
NO
Arsenic Sediment 0.0003 MRL NO A
Barium Surface Water
Sediment
0.07 RfD NO
NO

Bis (2-Ethylhexyl) Phthalate Surface Water 0.02 RfD NO B2
Cadmium Surface Water
Sediment
0.0007 MRL NO
NO
B1
Chromium (III) Sediment 1 RfD NO
Chromium (VI) Sediment 0.005 RfD NO A
Lead Sediment none

B2
Manganese Sediment 0.14 RfD NO
Carcinogenic PAHs* Sediment 0.1 aMRL** NO B2
Vanadium Sediment 0.003 iMRL*** NO
*Health guideline for Benzo(a)pyrene
**aMRL = acute MRL
***iMRL = intermediate MRL

ATSDR RESPONSE TO PUBLIC COMMENTS

The public comment period for the Pfohl Brothers Landfill National Priorities List site Public Health Assessment was from August 31, 1994 to September 30, 1994; however, public comments were accepted through February 22, 1995.

ATSDR received comments from several individuals during the public comment period and during a subsequent public meeting held February 22, 1995. The comments received and the responses to these comments are contained in this section of the Pfohl Brothers Landfill National Priorities List site Public Health Assessment.

Comment:Studies should be conducted by independent study. It is apparent that data given is insufficient and tainted. NYS has apparently done a dog and pony show. All studies MUST BE INDEPENDENT. There is sufficient justification to perform independent studies. Tonight's meeting is a run around of these people.
Response: The ATSDR public health assessment is based upon relevant health data, environmental data, and community health concerns from the EPA, state and local health and environmental agencies, the community, and potentially responsible parties. ATSDR held public availability sessions to gather the community's concerns and information. ATSDR independently reviewed the data and information it received. The document represents the Agency's best efforts, based upon the data and information available at the time the Agency wrote the document.
Comment: Why won't you accept or consider to sample fatty tissue of the residents?
Response: Operations at the site ceased in 1971. Access to the landfill has been restricted since 1990. ATSDR has determined that any chemical that may have entered the human body due to exposure would not be present in the body (above normal background levels) today due to the breakdown and elimination of the chemical.

Most of the chemicals found at the Pfohl Brothers Landfill National Priorities List site are commonly found in the environment, the workplace, and even in homes. Therefore, it is not uncommon to find minute amounts of these chemicals in individuals not living near or working at hazardous waste sites or industrial facilities. The National Health and Nutritional Examination Survey (N-HANES) demonstrated very clearly that most individuals have trace amounts of various chemicals in their body (e.g., arsenic, lead, PCBs, and zinc). During the N-HANES, approximately 1,200 people gave biological samples and the analytical results indicated that various amounts of chemicals were in the survey participants' blood and urine.

Comment:Are you familiar with the dumping procedures that Pfohl Brothers conducted?
Response: ATSDR's current knowledge regarding dumping procedures at the landfill is based upon information contained in state and local environmental files supplied to ATSDR by said agencies.
Comment: Did you know that chemicals were dumped on the ground without any concern about whether or not they were sealed in any type of container?
Response: According to documents prepared by the New York State Department of Environmental Conservation (NYSDEC), the landfill was operated, in general, as a cut and fill operation where drums, which were filled with substances that could be spilled out, were emptied and then salvaged.
Comment:Why don't you recommend a dust sample?
Response: In response to community concerns expressed during a public meeting held in September 1994, ATSDR developed an Attic Dust Sampling Protocol. ATSDR staff met with concerned citizens during public availability sessions and during a public meeting to discuss the draft protocol and to elicit their concerns on February 22, 1995. Staff from ATSDR revised the protocol to address community concerns expressed during those meetings. The revised protocol was sent to the Pfohl Area Homeowners and Residents Association for their consideration early April 1995. Although ATSDR contacted the concerned citizens several times via letters and telephone calls, ATSDR has not received any response to ATSDR contacts. Therefore, ATSDR as assumed that the Pfohl Area Homeowners and Residents Association does not want to participate in the proposed attic dust sampling investigation.
Comment: The opening ATSDR paragraphs states that "ATSDR's mission is to prevent exposure and adverse human health effects . . . : The report focuses upon current and future potential exposures and largely ignores past exposure. The current approach of the ATSDR is in violation of the mission for which it stands. Previous exposure to the barrage of confirmed human carcinogens which were present in the soils, fugitive dust, air and well water should be of great concern to the ATSDR because of the lag in time from exposure to clinical onset of disease (latency period). This crucial oversight may significantly impact the health of those residents previously exposed as crucial medical monitoring (health exams) and human health studies examining the overall rate of disease among those previously exposed would be denied. Increased preventive health monitoring would increase the probability of early detection and reduce overall morbidity and mortality. Unfortunately, the ATSDR has chosen to focus on current and future exposure, ignoring the unfortunate residents who were directly and heavily impacted by the toxic waste site. Even the ATSDR states that "removal actions and remedial activities have greatly reduced the likelihood of exposure to site-related contaminants." The following studies must be conducted:
  1. All projected risks as provided in the DRAFT report must also be performed using historic exposure data prior to site remediation, public water and fence installation and must consider the impact of fugitive dust and the fly ash cover material to which previous residents were exposed.
  2. An impartial community health study must be funded to fully evaluate any associations between previous exposure and current disease and cancer incidence. A 1991 health risk assessment conducted by the New York State Department of Health found a statistically significant increase in the incidence of prostate and breast cancer among residents living in the vicinity of the landfill. However, because study bias and confounding factors were not adequately addressed, the investigation provided little useful information about cancer and health risk to individuals who have lived and worked in the immediate vicinity of the landfill. The study did, however, peak concern of the residents as several potential pathways of exposure to carcinogens migrating from the waste site onto residential and business properties were identified, including the consumption of well water contaminated by carcinogenic polluted ground water, dust emissions and direct soil transfer from the waste site. A fully refined epidemiological environmental health study is strongly indicated based on the presumptive findings reported by the New York State Health Department. This study would need to grade exposure as high/low based upon distance from the landfill and consider previous consumption of contaminated well water. If the study were to confirm increased risk for the development of the specific cancers, appropriate medical monitoring and preventive measures could be employed to reduce overall morbidity and mortality from previously encountered exposure. Past exposure to carcinogens can not be overlooked, as this could potentially jeopardize the health and well being of previously exposed community members.
Response: ATSDR has consulted with local and state health officials as well as concerned community members in order to gain information regarding past exposures and the practices which may have led to such exposures. ATSDR has reviewed health surveys and health outcome data provided by these parties and its analyses are presented in this report. However, the information reviewed is insufficient for ATSDR to make a judgement regarding past exposures which may have occurred and the resultant health effects, if any. It should be noted that exposure to a source of contamination does not necessarily result in adverse health effects. Other factors must be considered, including the duration of exposure, the level of the contaminant in the environment, and the route of exposure. Because the information on past exposures is insufficient and information/data that could address past exposures can not be obtained (the samples should have been taken in the past prior to 1979), ATSDR has determined that the site is an indeterminate public health threat for past exposures.
Comment: Attempts to quantitatively evaluate adverse non-carcinogenic health effects and cancer risk relied upon monitoring results which were not truly characteristic of the site or potential exposures reported. Important human carcinogens such as vinyl chloride, TCDD (dioxins), benzene and other volatile organics reported in previous ground water and soil were stricken from the ATSDR assessment. Significant concentrations of 2,3,7,8-Dioxin and its equivalents have been detected throughout the site and even in residential soil near 1020 Rein Road. Polychlorinated biphenyls (PCBs) were previously detected throughout the site, off site and in the well water supplies of local businesses which were tested. Dangerously high concentrations of 2,3,7,8-Dioxin and phenol tars have been detected at the surface of the landfill in the form of small tarry balls which were encountered by recreational users. In addition, there is considerable documentation of off site leachate migration. The 2,3,7,8-dioxin concentration measured in these balls exceeded 1 ppm (part per million) pure 2,3,7,8-dioxin congener. Off site drainage ditches in the residential area have been reported to contain high levels of PCBs. High level exposure data has been selectively omitted from the report and risk assessment computations utilized within the report. These types of omissions could seriously alter the outcome of the report, ultimately effecting the health of the community members as specific medical monitoring could be employed if specific risks are identified.
Response: Based upon the data that ATSDR reviewed, PCBs were found in on-site waste material, sub-surface soils and groundwater. ATSDR discussed the PCB results in the Environmental Contamination section (page 12) of the Pfohl Brothers Landfill public health assessment. Dioxin was found in on-site waste materials, surface soils. 2,3,7,8-tetrachlorodibenzodioxin in on-site surface soils were not detected above health comparison values. Dioxins contained in phenol tars (waste materials) are not likely to move out of the tar matrix because the dioxins are bound very tightly to the tar.
Comment: The "ATSDR characterizes this site as an indeterminate public health hazard for past exposures . . . ," and within the same report states that "increased risk of developing cancer is not expected based on the evaluated data." These statement are in conflict. Actual cancer risk from previous exposure must be addressed using all previous monitoring data.
Response: Removal actions and remedial activities have greatly reduced the likelihood of exposure to site-related contamination. ATSDR concluded that the site represented no apparent public health hazard currently because available data do not suggest exposure to contaminants in the environmental media to be high enough to cause adverse health effects. In addition, ATSDR characterized the site as an indeterminate public health hazard for past exposures because ATSDR was not able to conduct any groundwater contaminant trend analysis. ATSDR has requested that the groundwater monitoring wells for the site be sampled and analyzed for all of the compounds on the EPA Target Compound List over a one year period.
Comment: A second resume of the site has been established in the ATSDR report. The ATSDR refers to analyses conducted by the New York State Department of Health (NYSDOH) which found only non-carcinogenic polynuclear aromatic hydrocarbons on site (page 5). In addition, other low level or negative findings are referenced which greatly play down the serious health threat posed by this toxic site. A profile of site contamination exists entitled "SITE DATA, PROVIDED FOR CONTRACTOR'S INFORMATION ONLY"; however it is not referenced or displayed by ATSDR in their summary. This data profile includes dangerously high levels of cancer causing polynuclear aromatic hydrocarbons such as benzo(a)pyrene measured from 510 - 21,000 ug/Kg. In addition numerous carcinogens were identified at exceedingly high levels in landfill soils including PCBs, heavy metals and dioxins. The ATSDR has selectively relied upon less toxic data which compromises the impartiality and reliability of the report.
Response: High levels of a contaminant in an environmental medium does not necessarily result in adverse health effects. ATSDR considers numerous factors regarding exposure when performing public health assessments. Some of the factors considered are the source of contamination, the environmental medium in which the contaminant is present and the transport of the contaminant through that medium, the point at which people may come in contact with the contaminated medium, the means by which contaminants enter the human body, and the population that is exposed or potentially exposed through the identified exposure routes to contaminants at an exposure point.

ATSDR reviewed available data regarding contaminants in the landfill soils. High levels of contaminants were found in the soil samples, however, the highest levels were found in the subsurface soils. Unless someone excavates the soil it is unlikely that significant exposure to these contaminants would occur.

In addition, ATSDR generally does not use unvalidated data in its determinations. The data referred by this commentor is unvalidated. Given the vast extent of validated data for this site, there is no reason for ATSDR to use the unvalidated data.

Comment: Arsenic is not normally detected in the natural soils of the northeastern United States at concentrations up to 73 ppm as stated in Table 14. This is contrary to published scientific data on uncontaminated surface soils. Neither is cadmium, chromium, lead, mercury, nickel, vanadium and cobalt found in uncontaminated soils at the preposterous concentrations listed in Table 14. These ranges are excessive, misleading and indicative of highly contaminated soils from anthropogenic input (man) or industrial sources and should not be used in a health study as a control. The use and inclusion of such erroneous "Background range" data in a report is unethical and unscientific.
Response:Three sources which could be used to compare the levels of contaminants found in soil are an Estimated Mean-Eastern U.S. concentration, metal concentrations in suburban soils, and local background concentrations. ATSDR made its comparison using the element concentrations in soils and other surficial materials of the coterminous United States. Based upon this information from the U.S. Geological Survey, the cited background ranges are correct for the Eastern United States.
Comment: The ATSDR report (page 12) fails to include health risks from dioxins. As stated, "Because the chemical extraction procedure used by the NYSDOH laboratory are not a natural process, the dioxins are not likely to move out of the tar matrix because the dioxins are bound tightly to the tar. Therefore, the dioxin levels detected in the tar material will not be discussed in this public health assessment." Dioxins were in fact detected off site in the residential area. There is evidence that the dioxins are released and dispersed from the tar matrix as they have been measured in the drainage ditch soils of 1020 Rein Road and 85 Pfohl Road (residential area). In addition, the NYSDOH has documented direct contact of children (NYSDEC/DOH Dioxin Sampling Results, June 21, 1990) to high level dioxin-containing tar. To presume that these dioxins are completely immobile is unfounded. In fact, organic extraction solvents have been measured on site in concentrations as high as 83,000,000 ug/L (eighty-three million ug/L). Such enormous concentrations of organic extraction solvent would have the strong propensity to dissolve and mobilize these highly toxic organics from the tar matrix. The combination of these tars with the organic solvents also detected on site present a high potential for both mobility and human bioavailability. Another potential health hazard is being played down and ignored by the ATSDR.
Response: Based upon the data ATSDR reviewed, dioxins present in off-site surface soils were not above health comparison values.
Comment: The report states that elevated gamma radiation readings were scattered randomly throughout areas B & C of the Pfohl Landfill. However, it is the opinion of the ATSDR that no health concerns exist provided that people did not remove the discrete objects that are the radiation sources. This approach negates the potential risks for those who were actively engaged in recreational activities in the soils and all of the residents who were impacted by direct fugitive dust emissions from the landfill and roadways. Historically, tremendous quantities of fugitive dust emissions were reported. No wetting of roads or washing of truck tires occurred, thus under EPA evaluation guidelines, large quantities of fugitive dust emissions would be anticipated and should have been included in the assessment. The fugitive dust emissions would be characteristic of the highly contaminated landfill surface soils which have been fully documented.
Response: To address community concerns and to address the fugitive dust issue ATSDR has developed an Attic Dust Sampling Protocol. The sampling effort is designed to compare the attic dust levels of various heavy metals in homes next to the landfill to the levels found in control homes. The heavy metals were selected for analysis because they were found in on-site waste material and on-site surface soil samples at levels of health concern and are frequently found in the ash disposed of at the landfill. Most of the other contaminants found on-site at levels of health concern, tend to volatilize out of dust within a few years.
Comment: Loading of impacted homes with contaminated fugitive dust has not been considered as an ongoing source of contamination. Contaminated household dust presents as a long term source of contamination as certain contaminates such as PCBs, dioxins, heavy metals and certain polynuclear aromatic hydrocarbons remain highly persistent in indoor dust. Analyses from homes in the immediate vicinity of the landfill and its primary access roads would determine whether such risks exist.
Response: In response to your comment and others ATSDR has proposed a sampling effort to compare the attic (non-living space) dust concentrations of arsenic, cadmium, chromium, copper, lead, nickel, and zinc in homes next to the Pfohl Brothers Landfill National Priorities List (NPL) site to the levels found in control homes. Although ATSDR contacted (via letters and telephone calls) the concerned citizens several times, ATSDR has not been informed whether the citizens wish to proceed with the dust sampling. Therefore, ATSDR has assumed that the Pfohl Area Homeowners and Residents Association does not want to participate in the proposed attic dust sampling investigation.
Comment: Monitoring wells installed by the NYSDEC under the RI process have frequently detected benzene and other carcinogens; however, out of service residential wells have not been developed and examined to determine previous exposure. The needed testing must be conducted on a quarterly basis due to shifts in the consolidated and unconsolidated aquifers. Dangerously high levels of benzene (2 - 290 ug/L), PCBs (0.5 - 110 ug/L), chromium (1 - 278 ug/L) and lead (2 - 369 ug/L) have been repeatedly detected from ground water samples taken beneath the landfill; however, no complete effort has been made to determine the migration path of these volatile organic contaminants (VOCs) from the waste site. For many years, 100% of the residential population around the landfill depended upon ground water as the primary source of drinking water. Consumption of previously contaminated well water must be addressed to insure that those chronically exposed now receive adequate medical monitoring. To ignore this issue, is again, in violation of the mission for which ATSDR stands. As stated (page 15), the NYSDEC has failed to conduct complete trend analyses (quarterly testing). In addition, the present scope of monitoring wells is vastly inadequate to determine where the VOCs have migrated. Although ATSDR acknowledges plans for routine monitoring of wells as part of the long-term remediation of the landfill, additional wells must be installed to determine the migration pathway of the highly contaminated ground water under the landfill. Additional off site monitoring wells are indicated and must be tested using EPA 500 series methods to insure appropriate detection limits. Previous analytical techniques employed by the NYSDEC contractors and the landfill owners have used high detection limits of 20 ug/L as opposed to 0.2 ug/L (EPA 524.2, vinyl chloride). Use of inadequate detection limits to analyze off site ground water is unacceptable and must be scrutinized by the ATSDR.
Response: NYSDEC will be conducting quarterly sampling of monitoring wells. ATSDR cannot make a determination regarding possible exposure in the past to contaminants in residential drinking water without sampling data from these wells taken during the time in which the exposure allegedly occurred. All dwellings in the vicinity of the landfill were connected to the municipal water supply system by the end of 1985. If people were exposed to contaminated groundwater from their private drinking water wells, the exposure would have stopped by this time because the municipal water supply is not contaminated with site-related compounds. Because of this data gap (lack of monitoring data prior to 1979), ATSDR is unable to determine the public health significance of past human exposures to hazardous chemicals from residential drinking water wells.
Comment: ATSDR is incorrect (page 14) with respect to the testing of surface waters and on-site drainage ditches. Erie County has identified high levels of PCB contamination and red oily substances in a drainage ditch along both sides of the entrance to the landfill Erie County Environmental Control (4/24/80). Upon examination by the Erie County Laboratory, the water and oil film layer was found to contain 5000 ppm Aroclor 1249 and 1254 (PCBs). This level of PCB is approximately 56,000-times above the ATSDR comparison value source, thus, the statement "Analytical results of samples taken from the on-site drainage ditches and wetlands did not detect any organic compounds above health comparison values" is flawed.
Response: While the highest detected concentration of PCBs did exceed ATSDR's environmental comparison value, the estimated dose did not exceed ATSDR's health comparison value. ATSDR uses two types of comparison values when performing public health assessments. The first type of comparison value used in the public health assessment is the environmental media evaluation guide (EMEG) or other applicable comparison value if an EMEG is not available. The EMEGs are media-specific comparison values that are used to select contaminants of concern at hazardous waste sites. EMEGs have been calculated for chemicals for which ATSDR has developed toxicological profiles. These chemicals were selected because of their toxicity, frequency-of-occurrence at sites or facilities on the NPL, and potential for human exposures to the substance. The EMEG is derived from the minimal risk levels (MRLs) presented in ATSDR's toxicological profiles. EMEGs are used to determine if a contaminant in an environmental medium needs to be evaluated in subsequent sections of the public health assessment.

If the contaminant is selected for further analysis then ATSDR uses its second type of comparison value, the health guideline. Health guidelines provide a basis for comparing estimated exposures with concentrations of contaminants in various environmental media to which people might be exposed. The health guidelines most often used are ATSDR's MRL and EPA's RfD. These guidelines are explained in the Public Health Implications section of this document.

As discussed in the public health assessment, there is some question as to whether or not the Erie County PCB analysis is accurate. Therefore, ATSDR used the data which it could validate.

Comment: It is grossly inappropriate to extrapolate long-term residential exposure to landfill gases using gas probe meters designed to measure potential explosive limits in the 5,000,000 ug/m3 range when public health risks to vinyl chloride and other toxic landfill gases exists at levels as low as 0.1 - 1 ug/m3. Likewise, OVAs and photoionization detectors are specifically designated for industrial exposure limits. It is preposterous that the ATSDR would rely on instrumentation designed to evaluate explosive limits and industrial hygiene (short term worker protection) in place of regulated methods specifically designed by the USEPA (USEPA Method TO-2 or TO-14). There are no data contained within the report indicating that appropriate EPA methodologies were employed to measure potential residential exposures. Appropriate air monitoring was not conducted before and during remedial site activities. The referenced analyses (Page 15) were not intended to evaluate long term public health and should not be misstated as such. The ethics and motives behind such an attempt to twist the use of industrial hygiene data must be evaluated by other Federal officials as this is indicative of incompetence within the agency or corruption.
Response: The Pfohl Brothers Landfill does not have any material on top of it that would force VOC and landfill gases to move laterally. Therefore, it is unlikely that lateral movement would occur. The landfill gas survey results indicates that the landfill does not generate any significant amount of methane and is not forcing any VOCs or landfill gases into the houses. Therefore, it is unlikely that any measurements taken in the homes would detect any landfill related contaminants at levels of health concern.

To measure possible residential exposure to radioactive sources, NYSDOH provided radon detection canisters to people living on Pfohl Road (near the landfill). These canisters were then analyzed in an EPA laboratory. The results of these analyses did not indicate radon to be present in these homes near the landfill above the guidelines established by EPA.

Comment: It is highly speculative that the numerous findings of PCBs in private wells during 1980 was due to invalid testing. The lack of their presence during the fall of 1980 is most likely attributed to seasonal variation in the hydrogeological conditions, not multiple laboratory errors. It is also important to note that the monitoring conducted by Erie County and the NYSDEC during 1980 was in response to documented high level PCB contamination which had migrated off site via drainage ditches. Specific testing for many additional semi-volatile contaminants including polynuclear aromatic hydrocarbons and VOCs was not conducted at this time. It is the responsibility of the ATSDR to examine previous exposure and recommend the appropriate long-term medical monitoring to those exposed. Additional off site monitoring wells are needed and must be sampled on a quarterly basis for trend analyses.
Response:Most of the chemical found at the Pfohl Brothers Landfill site are commonly found in the environment, in the workplace, and even in homes. PCBs, VOCs, and semi-volatile contaminants including polynuclear aromatic hydrocarbons which have a biological half-life of two years or less would not be expected to be at detectable levels in individuals associated with the site. Homes next to the landfill stopped using private drinking water wells in 1985 (nearly 10 years ago), access to the site has been restricted since the fence was installed in 1990 (over five years ago), and the environmental monitoring data indicate that there are no contaminants at levels of public health concern off of the landfill. ATSDR believes that if any site-related contaminants were inhaled or ingested by individuals, the contaminants have long since been excreted by the body via normal body functions. Therefore, ATSDR does not have a basis for recommending long-term medical monitoring.

NYSDEC has sampled wells off site. Analysis of the results do not indicate that site-related compounds are present at levels above health comparison values.

As discussed in the public health assessment, the chemical properties of PCBs makes it very unlikely that PCBs will migrate very rapidly in groundwater. Therefore, there is some question as to the validity of the 1980 analytical results.

Comment: It is unfortunate that a group of people can come and spend all that time and money defending themselves, and not addressing the real issues. Instead of telling us what you "didn't" do, or what you "can't" do, why can't someone tell us what the can do, or what they will do. We apparently are under the misconception that you were coming here to help us. We were very wrong - you don't even care.
Response: ATSDR has reviewed previous health studies conducted by NYSDOH. ATSDR will assist NYSDOH in their ongoing environmental health education program in the community living near the Pfohl Brothers Landfill National Priorities List site. The purpose of the program will be to advise the local public health professionals, health care providers and local residents of the nature and possible consequences of potential exposures to contaminants associated with the site. ATSDR will continue to review any new environmental and health outcome data associated with the Pfohl Brothers Landfill site and, if necessary, revise the conclusion and recommendations contained in its public health assessment for the site. ATSDR will collaborate with the appropriate federal, state, and local agencies to pursue the implementation of the recommendations outlined in its public health assessment.
Comment: Sleep well! Just think. Your government is my government; it will SCREW (&KILL) YOU JUST AS IT HAS ME & MY FAMILY, AND ANYONE WHO HAD ANY CONTACT WITH PFOHL DUMP.
Response: ATSDR has performed a public health assessment of the Pfohl Brothers Landfill National Priorities List site and determined that the site does not pose a public health hazard at this time. Because the information on past exposures is insufficient and information/data that could address past exposures can not be obtained (the samples should have been taken in the past prior to 1979), ATSDR has determined that the site is an indeterminate public health threat for past exposures.
Comment: I have serious concerns about the methodological aspects of the NYSDOH report dated November 1991. The most recent "Summary" report from NYSDOH dated August 1994 also presents several causes for wonder. The major problems I would like to call to your attention are:

[Nov. 1991 report] This report blames risk factors in case-patients for an excess of disease in the population of the census tract. Specifically, such risk factors as family history of breast cancer were evaluated only in case-patients and then used to explain the increased incidence of breast cancer in the study area.

This reasoning assumes some correspondence between the prevalence of a risk factor in cases and the prevalence of the risk factor in the source population from which those cases arose. Were a population to have an elevated rate of a risk factor, it might well explain some or all of the increased incidence of a disease. The Nov. 1991 report, however, does not provide the required data on the source population but is limited almost exclusively to descriptions of the case-patients' characteristics.

The fallacy of the reasoning may be seen by applying it to a well-known study of lung cancer (Blot, Harrington, Toledo, Hoover, Heath, & Fraumeni, 1978). The study population of shipbuilders had been exposed to asbestos, and some were also smokers. If one were unaware of the role of asbestos in the etiology of lung cancer (especially in interaction with tobacco exposure) and had examined only the smoking rates, the case patients in this "cluster" would have had a smoking exposure prevalence of 88% (vs. 57% in controls). Using the reasoning followed in the NYSDOH report regarding Pfohl Landfill, one might then assume that the excess incidence of lung cancer must be due to a source population with a high smoking prevalence, thus "explaining" the cluster. In fact, the source population of shipbuilders without lung cancer had a smoking prevalence typical of the general male population of that ear. It was asbestos exposure that explained the high incidence, although in interaction with smoking; a supposed increase in smoking prevalence was not present and should not have been inferred on the basis of smoking prevalence in the case-patients.

Most of the epidemiologist with whom I have discussed this blaming-risk- factors-in-cases method found it scientifically unacceptable. From the point of view of social scientists involved with environmental hazards, it also has the distinct flavor of "blaming the victims" -- as if the fact a woman has had a family history is sufficient to explain the development of breast cancer (actual probability is considerably less than 50%). Genetic epidemiologist to whom I described the methodology used in the Pfohl report found it especially strange, in that family history is quite likely to interact with other exposures -- precisely the condition that makes an exact parallel between cases' risk factors and the source population's unlikely.

I understand that NYSDOH has been under considerable pressure to explain clusters and other excess localized disease, but I sincerely doubt that they would want this methodological error committed in explaining away a residential or occupational disease cluster than might directly affect them. There are methods for evaluating whether risk factors in a source population are indeed excessive, but that isn't what was done in this report. A simple and brief telephone survey could easily estimate whether family history of breast cancer is excessive in this census tract relative to other areas, and provide a reasonable estimate of whether such an elevation if it exists would be sufficient to explain any sizable portion of the increased incidence of disease. Having done such attributable risk calculations, I know that it often requires a sizable increase in the prevalence of a risk factor to account for much of an increase in disease. It is, for example, generally not true that a doubling of a risk factor will account for a doubling of a disease rate.

I have attempted to discuss this problem with NYSDOH officials (Ms. Carole Ju; Dr. G Anders Carlson), but they seemed unable to relinquish this inappropriate method of investigation. Thus, I was hopeful that the additional expertise available at the ATSDR would be used to resolve this situation without additional political and media attention

Response: Elevation of disease in a population potentially exposed to hazardous substances at a waste site requires: a source of contamination, a contaminated environmental medium, a point at which a person may come in contact with the substance in the contaminated medium, a route for the medium to enter the body (ingest, inhale, or dermal absorption), and a group of individuals within the population who could become exposed. In the cancer incidence study dated November 1991, of the 25 subjects interview for census tract 100.01 only four were reported to have engaged in activities that could have potentially lead to exposure to contaminants from the Pfohl Brothers Landfill site. In addition, none of the 25 subjects resided in the area of the site (they resided west of the Buffalo airport). All of them resided more than one-mile from the site. ATSDR would require a good exposure situation in order to make a determination of exactly who would be included in the "exposed" population.

Since the New York studies did not look specifically at people who developed disease after living and/or working in the immediate vicinity of the site for an extended period of time and compare those individuals to persons who lived or worked in the vicinity of the site for extended periods of time without developing disease, ATSDR could not make any determination regarding risk factors among the populations potentially affected by the Pfohl Brothers Landfill site.

Comment: It is my understanding that part of the request to ATSDR to review the NYSDOH investigation required an assessment of the methodology used. The comments in the draft report you issued in August 1994 were quite limited regarding the methodological aspects of the epidemiological studies conducted by NYSDOH. On the one hand, you concluded that the "NYSDOH's studies of cancer incidence in the Pfohl Brothers Landfill area . . . was conducted appropriately." On the other hand, the report suggests that the data can only be descriptive and can't be used to determine associations with possible agents. (ATSDR, p. 43) I believe this summary is not adequate -- not what is needed by the people affected and the government officials who requested your help. NYSDOH has clearly made claims that the method they are using is able to explain an excess incidence of diagnosis, when it does not.

I request that you clarify this methodological problem for NYSDOH, and recommend the small amount of additional data collection and analysis (estimating risk factors in the source population, rather than just in the cases) and appropriate calculation of expected rates if they continue to assert that some (unverified) elevation in risk factors can explain away a high incidence of disease in the previous report (or in additional reports they may issue about the Pfohl Landfill in the future).

Response: NYSDOH reviewed the data it was provided by looking for a cancer cluster. Their interpretation was made from the viewpoint of a cluster investigation not an incidence investigation. Standard indicators of cancer clusters include several cases of the same cancers diagnosed in the study area within a short span of time, two or more cases of a rather rare type of cancer, and many cases of the same type or site of cancer. More information is needed about the kidney cancer cases as well as all of the other alleged cancer cases in order to determine if there was an increase in the incidence rate of cancer in the population potentially impacted by the site.

Since the New York studies did not look specifically at people who developed disease after living and/or working in the immediate vicinity of the site for an extended period of time and compare those individuals to persons who lived or worked in the vicinity of the site for extended periods of time without developing disease, ATSDR could not make any determination regarding risk factors among the populations potentially affected by the Pfohl Brothers Landfill site.

Before an incidence epidemiologic study can be undertaken, an exposed population needs to be accurately defined. Because there is not sufficient information to define who was exposed in the past, ATSDR is unable to conduct an scientifically valid epidemiologic study.

Comment: [Nov. 1991 report] The focus of an entire census tract appears to have been a matter of convenience; the majority of the population of that census tract actually live further away from Pfohl (on the opposite side of the Buffalo International Airport) than many members of other census tracts. This creates a problem of dilution; the observed elevation in breast cancer, on which the November 1991 report focuses, actually deals with a group of case-patients who live at some distance. This problem is described by Landrigan (1983), who cautions against a mixing of high and low (or no) exposure groups.

When I discussed this with Dr. Carlson, he noted that environmentalists sometimes request the Health Department to study a larger group or that they sometimes choose to do so in order to have a greater sample size and statistical power is available. Such requests for enlarging the study base often come from concerns that even some low exposure subpopulations may have suffered adverse effects. The solution is not to initially mix together low and high exposure groups, but to study both separately and combine them only if disease rates are similar. One can thus look for dose-response relationships, or revert to directing most attention to the high exposure group.

Response: The population surrounding the Pfohl Brothers Landfill National Priorities List site is small. ATSDR agrees that if the cancer cases present within this population were to be lumped together with all cancer cases present in its census tract (100.01) there would be a dilution of effect.

Before an incidence epidemiologic study can be undertaken, an exposed population needs to be accurately defined. Because there is not sufficient information to define who was exposed in the past, ATSDR is unable to conduct an scientifically valid epidemiologic study.

Comment: [Nov. 1991 report] The use of the NY State Cancer Registry to identify cases in this investigation likely presents a problem with underascertainment. The Registry is limited to certain years and to individuals living in the area under study continuously. It omits cases occurring in individuals who have immigrated to other states and even to other census tracts. The method used also underestimates incidence by counting in the population sized those individuals whose residence in the area is less than the likely latencies of the cancers under study.

The Pfohl area is small, and the resident population is capable of being enumerated and followed up. This isn't some densely populated, highly transient city population. Several of the residents have already attempted a great deal of this follow-up; it would appear appropriate to complete this, and to determine a more appropriate description of the source population which would facilitate age-adjustment of rates as well as completeness of evaluation of rates for specific cancers.

Response: NYSDOH concluded that because of the small number of people potentially exposed to contaminants from the Pfohl Brothers Landfill National Priorities List site, a full-scale epidemiologic study of the area residents would not be possible. In addition, the lack of exposure information also makes it not possible to conduct a full-scale epidemiologic study.
Comment: [August 1994 report] This report, labeled a "Summary" but for which there is apparently no longer explanation available, came in for considerable disparagement for the audience at the ATSDR public meeting because of some misinformation about latencies for cancers. There is enough epidemiological knowledge in the community these days that "bad science" is often noticed. For example, NYSDOH's use of the fact that three kidney cancer case-patients were diagnosed in different calendar years as evidence that they were likely to be unrelated suggests an unwarranted willingness to strain the public's patience and credibility. Most elementary epidemiological textbooks describe the substantial degree of variability in latency periods for cancers; the most recent edition of Lilienfeld's text has to such histograms which make this clear. For cancers with known etiological exposures, it is far more likely that three cases would have been diagnosed in different years than in the exact same calendar year. The NYSDOH report also makes no reference to date of entry in the source population; if this varied among the case-patients, it would have meant an even more varied distribution of expected calendar years of diagnosis.
Response: NYSDOH reviewed the data it was provided by looking for a cancer cluster. Their interpretation was made from the viewpoint of a cluster investigation not an incidence investigation. Standard indicators of cancer clusters include several cases of the same cancers diagnosed in the study area within a short span of time, two or more cases of a rather rare type of cancer, and many cases of the same type or site of cancer. More information is needed about the kidney cancer cases as well as all of the other alleged cancer cases in order to determine if there was an increase in the incidence rate of cancer in the population potentially impacted by the Pfohl Brothers Landfill National Priorities List site.

Before an incidence epidemiologic study can be undertaken, an exposed population needs to be accurately defined. Because there is not sufficient information to define who was exposed in the past, ATSDR is unable to conduct an scientifically valid epidemiologic study.

Comment: I believe ATSDR has an important responsibility here, in assisting NYSDOH to do a better evaluation and in providing appropriate health education. Reports which are uncritical of obvious errors will decrease ATSDR's credibility in providing other information, and leave everyone dissatisfied.
Response: The ATSDR Division of Health Studies (DHS) reviewed the survey entitled "Summary of Survey Results: Pfohl Brothers Landfill, March, 1991". The report stated that the survey revealed no unusual patterns of reported illnesses among residents or workers. It was acknowledged in the survey that due to the small number of persons available to evaluate, no firm conclusions could be established. DHS agrees with the New York Department of Health's interpretation of the survey.

DHS reviewed the study entitled "Follow-up Study of Female Breast Cancer Patients in Census Tract 100.01 (Cheektowaga), Erie County 1978-1987". The study followed and interviewed cases of breast cancer from the 1978-1987 breast cancer case reports in the Cancer Surveillance Program.

DHS reviewed the cancer information provided by concerned citizens for homes and business on Rein Road. DHS determined that the small number of cases are not going to supply sufficient power to evaluate any causal associations between exposures to chemicals from the site and cancer, either for all cancers or a specific tissue or anatomical site. The case reports provided by concerned citizens are case reports of persons with many different cancer (anatomical) sites. DHS did not have any information to assess whether the few cases of breast cancer included were among those persons in the Cancer Surveillance Program cases and subsequently interviewed.

Although the reports do not completely discount a hypothetical association, due to lack of landfill contaminant contact among cases interviewed by the New York Department of Health and the ATSDR Division of Health Assessment and Consultation's conclusion that the levels of contaminants were not likely to have adverse health effects, DHS does not recommend that additional follow up studies be conducted.

ATSDR will assist NYSDOH in their ongoing environmental health education program in the community living near the Pfohl Brothers Landfill National Priorities List site. The purpose of the program will be to advise the local public health professionals, health care providers and local residents of the nature and possible consequences of potential exposures to contaminants associated with the site.


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