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PRELIMINARY PUBLIC HEALTH ASSESSMENT

TRI-CITIES BARREL COMPANY, INC.
FENTON, BROOME COUNTY, NEW YORK


APPENDIX A


Figure 1. Site Location Map


Figure 2. Suspected Lagoon Locations by Year


Figure 3. Phase II Sample Locations



APPENDIX B

TABLE 1

Analytical Results for Groundwater Samples
at the Tri-Cities Barrel Site
Fenton, Broome County, NY
(all units in micrograms per liter; mcg/L)
(see Table 5 for Comparison Values)


Analyte CW-1 CW-2B CW-3 CW-4

*Vinyl Chloride <10 6.5E 6.5E <10
*Trans-1,2-Dichloroethene <5 2.2E 17 <5
*Trichloroethene <5 5.5 10 <5
1,1-Dichloroethene <5 <5 1.7E <5
*1,1-Dichloroethane <5 <5 9.2 <5
*1,1,1-Trichloroethane <5 <5 6.8 <5
*Tetrachloroethene <5 <5 3.4E <5
*Toluene <5 <5 6.8 <5
Phenol <10 <10 5.3J <10
*Chlordane <0.5 <0.5 3.8 <0.5
*Aroclor 1242 <0.5 <0.5 2.9 <0.5
*Bis(2-ethylhexyl)phthalate <5 7.6 24 2.6J

*Contaminant selected for further evaluation
< - Less than detection limit
E - Indicates a value estimated or not reported due to the presence of interference.
J - Indicates the presence of a compound but the result is less than the detection limit but greater than zero.


TABLE 2

Analytical Results of Surface Water Samples
Tri Cities Barrel Site, Fenton, Broome County, NY
(all units in micrograms per liter; mcg/L)
(see Table 5 for Comparison Values)


Analyte S-1 S-2 S-3

Calcium 13,600 13,300 10,200
Iron 220 150 210
Lead 4 6 17
Manganese 132 118 23
Sodium 8,000 13,000 9,000
Zinc 20 <20 <20

< - Less than detection limit


TABLE 3

Analytical Results of Soil Samples
Tri-Cities Barrel Site, Fenton, Broome County, NY
(all units in milligrams per kilogram; mg/kg)
(see Table 6 for Comparison Values)


Analyte SS-1 SS-2 SS-3

Tetrachloroethene <0.006 0.020 0.076
1,1-Dichloroethane <0.006 <0.005 0.0063
Trans-1,2-Dichloroethene <0.006 0.0042E 0.02
1,1,1-Trichloroethane 0.006 0.005 0.017
Trichloroethene <0.006 <0.005 0.014
Fluoranthene 1.3 <22 <22
Pyrene 1.3 <22 <22
Chrysene 0.89 <22 <22

E - Estimated value below method detection limit
< - Less than detection limit


TABLE 4
Analytical Results for Sediment Samples
Tri-Cities Barrel Site, Fenton, Broome County, NY
(all units in milligrams per kilogram; mg/kg)
(see Table 6 for Comparison Values)


Analyte SD-1 SD-2 SD-3

Calcium 817 932 1602
Magnesium 3690 3910 3820
Manganese 921 674 1200
Zinc 92.5 95.2 130
Lead 8.5 16.1 34.8
Fluoranthane <0.924 <1.056 0.35E
Pyrene <0.924 <1.056 0.26E
Chrysene <0.924 <1.056 0.99E

E = Estimated value below method detection limit.
< = less than detection limit


TABLE 5
Tri-Cities Barrel Site, Fenton, Broome County, NY
Public Health Assessment Comparison Values for Contaminants Found in Sources of Drinking Water
(all values in micrograms per liter; mcg/L)


Chemical Water Quality Standards
Comparison Values
NEW YORK STATE
U.S. EPA
Drinking
Water
Ground-
water
Surface
Water
Drinking
Water
Cancer Source*** Noncancer Source***

Calcium -- -- -- -- -- -- -- --
Iron 300 300 300 300s -- -- -- --
Lead 50 25 50 50;15* -- -- -- --
Magnesium -- 35,000g 35,000 -- -- -- -- --
Manganese 300 300 300 50s -- -- 3,500 EPA RfD
Sodium ** 20,000 -- -- -- -- -- --
Zinc 5,000 300 300 5,000s -- -- 2,100 EPA LTHA
Vinyl chloride 2 2 0.3g 2 0.02 EPA CPF 0.7 ATSDR EMEG
Trans-1,2-Dichloroethene 5 5 5g 100 -- -- 100 EPA LTHA
Trichloroethene 5 5 3g 5 3 NYS CREG 52 EPA RfD
1,1-Dichloroethane 5 5 5g -- -- -- 700 EPA RfD
1,1-Dichloroethene 5 5 0.07g 7 0.058 ATSDR CREG 7 EPA LTHA
1,1,1-Trichloroethane 5 5 5g 200 -- -- 200 EPA LTHA
Tetrachloroethene 5 5 0.7g 5 0.7 NYS CREG 70 EPA RfD
Toluene 5 5 5g 1,000;40ps -- -- 1,000 EPA LTHA
Phenol 50 1 1 -- -- -- 4,000 EPA LTHA
Bis(2-ethylhexyl)phthalate 50 50 4g 6 2.5 EPA CPF 140 EPA RfD
Chlordane 2m 0.1m 0.02g,m 2m 0.016 NYS CREG 0.4 EPA RfD
Aroclor 1242 0.5c 0.1c 0.01c 0.5 0.0045 ATSDR CREG 0.18 ATSDR EMEG

c = total PCBs
g = guideline
m = applies to total chlordane
p = proposed
ps = proposed secondary standard
s = secondary standard

*The current maximum contaminant level (MCL) for lead is 50 mcg/L; after December 7, 1992 there will not be a MCL for lead. Efffective after that date,there will be a maximum contaminant level goal (MCLG) of zero for lead and an action level of 15 mcg/L at the tap.

**No designated limit; water containing more than 20,000 mcg/L should not be used for drinking by people on severely restricted sodium diets; water containing more than 270,000 mcg/L should not be used for drinking by people on moderately restricted sodium diets.

***ATSDR CREG = ATSDR Cancer Risk Evaluation Guide
ATSDR EMEG = ATSDR Environmental Media Evaluation Guide
EPA LTHA = EPA Drinking Water Lifetime Health Advisory
EPA CPF = EPA Cancer Potency Factor
EPA RfD = EPA Reference Dose
NYS CREG = NYS Cancer Risk Evaluation Guideline


Table 6.
Public Health Assessment Comparison Values for Soil
Contaminants at or Near the Tri-Cities Barrel Site, Fenton, Broome County, NY
[All values in milligrams per kilogram (mg/kg)]


Chemical Typical
Background*
Comparison Values

Source***
Cancer** Source*** Noncancer****

calcium 100-400,000 -- -- -- --
chrysene ***** -- -- -- --
1,1-dichloroethane ND -- -- 203,000 EPA RfD
trans-1,2-dichloroethene ND -- -- 40,600 EPA RfD
fluoranthene ***** -- -- 81,200 EPA RfD
lead 10-300 -- -- -- --
magnesium 50-6,000 -- -- -- --
manganese 500-3,000 -- -- 203,000 EPA RfD
pyrene ***** -- -- 60,900 EPA RfD
tetrachloroethene ND 111 EPA CPF 20,300 EPA RfD
1,1,1-trichloroethane ND -- -- 182,700 EPA RfD
trichloroethene ND 516 EPA CPF 14,500 EPA RfD
zinc 50-100 -- -- 406,000 EPA RfD

ND = not determined

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

**Comparison value determined for a 70 kg adult who ingests 50 milligrams of soil per day, 250 days per year for 25 years in an industrial/commercial setting.

***EPA RfD = EPA Reference Dose
EPA CPF = EPA Cancer Potency Factor

****Comparison value determined for a 70 kg adult who ingests 50 milligrams of soil per day, 250 days per year in an industrial/commercial setting.

*****Reported background levels for total polycyclic aromatic hydrocarbons of <1 to 13 milligrams per kilogram in soil (Edwards, 1983).


APPENDIX C
RESPONSES TO PUBLIC COMMENTS
TRI-CITIES BARREL

COMMENT #1

Is the on-site production well used for potable purposes?

RESPONSE #1

The production well is not used as a drinking water supply. Bottled water was brought to the site for potable uses.

COMMENT #2

The private well that exhibited aromatic chemical hits may be cross-gradient of the site.

RESPONSE #2

With the information presently available, the private water supply well is thought to be cross gradient from the site. There is another private well closer to the site; aromatic chemical have not been detected in this well. These contaminants were not in the on-site monitoring wells. For these reasons, these compounds in the private water supply well are not considered site related. However, the remedial investigation will provide a clearer picture of the extend of groundwater contamination and flow dynamics.

COMMENT #3

We would like to continue to have hour water sampled on a regular basis.

RESPONSE #3

A hydrogeologic investigation, which is included in the remedial investigation (RI) will provide information regarding potential migration of contaminants toward private wells. This method of evaluating groundwater as a drinking water source is preferred to continuously sampling private drinking water wells. We would prefer to initiate remedial action before a homeowner well is affected. Such an investigation is outline in the RI work plan.

COMMENT #4

It has been documented that at least some of the site lagoons were equipped with overflow ditches that discharged directly to Osborne Creek. In the 1976 flood, numerous barrels were washed from the site into Osborne Creek, and by implication, contaminated materials from these same lagoons. A 1958 aerial photograph, cited in the recent RI workplan, also shows what appears to be overland discharge channels leading from the site into the creek. Consideration should be given to including this wastewater disposal pathway along with volatilization and percolation.

RESPONSE #4

Osborne Creek, and the areas between the creek and the building, will be included in the RI as proposed by U.S. Environmental Protection Agency's (US EPA) consultant Roy F. Weston, Inc. The investigation will include soil sampling, sediment sampling, monitoring well installation, and surface water sampling.

COMMENT #5

Is there wastewater disposal through the facility septic system, floor drains and catch basins?

RESPONSE #5

The RI workplan, which is currently under review, includes an investigation of the sumps and septic tank system.

COMMENT #6

There is considerable community concern about the contamination of Osborne Creek.

RESPONSE #6

Water and sediment samples from Osborne Creek will be collected and analyzed during the remedial investigation. Results will be published in the final RI report.

COMMENT #7

The two stream sediment samples collected may not be representative of the most contaminated segment of Osborne Creek (i.e., the areas due north of the site where historical evidence of overland discharges exists). The possibility of human contact with these sediments may warrant their inclusion in the pathway analysis section.

RESPONSE #7

The two sediment samples were a part of a preliminary investigation designed only to determine the presence of hazardous waste. The remedial investigation will include a more detailed investigation of the area north of the site including soil, sediment and water sampling.

COMMENT #8

The "background sample" was collected from an on-site area that has been used for drum storage at various times during the past several years, and this may explain why polycyclic aromatic hydrocarbons (PAHs) were found there.

RESPONSE #8

The same comment regarding the suitability of SS-1 as a background sample was made by NYS DOH in our review of the workplan in July 1990. The revised workplan includes provisions for collection of additional background soil samples as part of the RI. Background soil samples will be collected from southwest of the facility (upwind of the incinerator) and on property not owned or previously owned by Tri-Cities Barrel, Inc.

COMMENT #9

The detection of Volatile Organic Compounds (VOCs) in a surface soil sample is a concern. Either contaminated fill was used to close the lagoon (which is unlikely) or a recent source of site-related chemicals has contaminated this soil.

COMMENT #10

Most of the barrel storage yard is unpaved. Vegetation is sparse over much of the lagoon fill area. Fugitive dust emissions may be another environmental pathway to consider, especially during dry periods.

RESPONSE #9 AND #10

Surface soil will be further investigated as part of the RI and appropriately addressed during site remediation.

COMMENT #11

The Public Health Assessment mentions an incinerator was used for burning flammable solids. Is this the same unit that is used to burn the interiors of barrels as part of the cleaning process? If so, the alternate use of this installation should also be listed in the assessment. If not, the barrel burner should be included as a separate source of air emissions.

RESPONSE #11

There is only one incinerator and it was used to clean the barrels. The flammable solids, to which the health assessment refers, is the residue in the barrels which are burned off as part of the cleaning process.

COMMENT #12

When Tri-Cities Barrel conducts burning during the summer, a film of ash gets on everything outside.

COMMENT #13

Barrel cleaning (burning) continues at the Tri-Cities Barrel site on a sporadic basis and complaints have been received concerning air emissions; the air pathways should be considered in this analysis.

RESPONSE #12 AND #13

If the incinerator is to remain in operation, the emissions should be addressed as a separate issue. The health assessment addresses residual contamination which classifies the site as a hazardous waste site. An operating incinerator is required to comply with a permit issued by the New York State Department of Environmental Conservation (NYS DEC). If this problem continues to occur, contact NYS DEC's Regional Air Engineer at (607) 773-7763 or the Broome County Health Department at (607) 778-2887. The NYS DOH routinely works with local health departments and NYS DEC in responding to such complaints and will alert NYS DEC of your complaints. It is our understanding that the incinerator is no longer being used.

COMMENT #14

Tri-Cities often leaves fires burning in the summer.

RESPONSE #14

Open fires should be reported to the New York State Department of Environmental Conservation (NYS DEC) local conservation officer or forest ranger. The closest NYS DEC office is the Region 7 office at Kirkwood. The telephone number there is (607) 773-7763.

COMMENT #15

Consideration should be given to including the following human exposure pathways in the analysis:

o consumption of contaminated groundwater from public (mobile home park) wells;

o inhalation of barrel cleaning emissions and fugitive dust from the site; and

o direct contact with and/or ingestion of contaminated stream sediments.

RESPONSE #15

All of the pathways of exposure identified in this comment will be evaluated in the RI. The public health assessment will be revised as needed to reflect any additional pathways of exposure revealed during the RI work.

COMMENT #16

The Tri-Cities Barrel facility is located on a public road, with a number of private residences in close proximity. it has been documented that area children ride their bicycles on the property. Access control measures (e.g., fence) are needed to prevent people from entering the site after work hours and weekends. Physical hazards may exist on the site.

RESPONSE #16

Due to changes in the operation of the facility in recent years, there is less worker presence on-site, and there is a need for better site security. The health assessment has been changed to recommend evaluating the need for site security based on this information.

COMMENT #17

Many federal Superfund sites are closed down, why is this site still operating? The business has also expanded from the original property to an area across the road which is not zoned for this type of business.

RESPONSE #17

Listing a site as a federal Superfund site does not cause an active business to close down. Many Superfund sites are still in business. The RI will evaluate all areas of contamination on and off-site, including the original property and any expansion areas. The operation of the facility is controlled by state environmental regulations and local ordinances. Concerns regarding property use should be referred to the appropriate jurisdiction, such as the town zoning board.

COMMENT #18

The Public Health Assessment states that "...the site was consequentially expanded to include the entire 13 acres owned by Tri-Cities Barrel." The property boundaries may encompass 13 acres, but the actual size of the site on the National Priorities List (NPL) is 3.5 acres. We are unaware of any "formal" expansion of this NPL site to 13 acres. We are aware that historical aerial photography indicates the presence of bodies of water north of I-88, but no data are available which confirm the presence of contaminants in this area.

RESPONSE #18

The statement that the site was expanded to include the entire 13 acres owned by Tri-Cities Barrel was taken directly from the remedial investigation work plan by Roy F. Weston, Inc. (see pg. 1-2). This US EPA decision to expand the area of the investigation was based on evidence provided since the site was originally listed. Additionally, the signed consent order describes the site as a 13 acre parcel which is bisected by I-88.

COMMENT #19

The Public Health Assessment states "The contaminated area north of Interstate I-88 was not evaluated in the preliminary investigation because contamination in this area was discovered only recently." We have no knowledge of the existence of analytical data which confirmed the presence of contamination in this area. Our understanding is that aerial photography indicated the presence of water bodies which may or may not have received wastewater from facility operations.

RESPONSE #19

The area of contamination north of I-88 has been indicated by a waste water discharge shown on a 1958 aerial photograph. There are no analytical data to confirm or deny the presence of contaminants in this area. The remedial investigation as proposed by US EPA will include this area to evaluate the full extent of contamination of the property.

COMMENT #20

The Public Health Assessment states "...contamination in areas north of Interstate 88 has not been defined." We would suggest that the language read "...contamination in areas north of Interstate 88 had not been confirmed or defined."

RESPONSE #20

We agree with this comment and the word "confirmed" has been added.

COMMENT #21

The Public Health Assessment states "the plume is not fully defined." The existence of a groundwater plume has not been confirmed. Analytical data from the single round of samples from the on-site groundwater monitoring wells indicate the presence of low concentrations of contamination in two wells. Additional sampling of the wells is warranted to confirm the presence of these contaminants in the groundwater.

RESPONSE #21

Additional sampling will be collected as part of the RI to determine the extent of the contamination in the groundwater. The RI is the next stage of the project and field work is anticipated to start in 1993.

COMMENT #22

The Public Health Assessment states "Future investigations of this site should include determination of the extent and depth of contamination migration in groundwater off-site." Future investigations should first determine the extent of groundwater contamination off-site before expanding the investigation to include potential off-site migration. The Public health Assessment goes on to state "An early warning system...is needed to alert the residence if the contaminants are moving towards the private drinking water wells...". An early warning system may not be needed if there is not a plume migrating off-site.

RESPONSE #22

Off-site contamination and contaminant migration in off-site groundwater has the same meaning in the context of this report.

Monitoring wells (the suggested early warning system) are needed outside the areas of contamination to define the limit of groundwater contamination. As long as contamination exists, these wells can be monitored to evaluate migration toward residential wells.

COMMENT #23

The MBM Mobile Home Park is situated approximately 1,000 feet from the site. The park has approximately 150 residents; wells located here are regulated by the Broome County Health Department as public water supplies. The possibility of site-related impacts on this public water supply should not be discounted without further hydrogeologic study; if a hydraulic connection exists, normal water demand here could cause the cone of influence of the park wells to capture part of the contaminant plume beneath the Tri-Cities site, especially during times of drought like those experienced last summer.

RESPONSE #23

The MBM Mobile Home park appears to be upgradient of the site, and is not considered to be presently at risk. This does not mean that it is being discounted. The RI will include a full hydrogeologic investigation of all areas and will further define groundwater flow dynamics at and near the site.

COMMENT #24

During the early stages of investigation, the State talked to me regarding drilling test wells on my property. I told them that they could drill on my property but they never got back to me. Why?

RESPONSE #24

Proposed locations for monitoring wells may be found in the RI workplan. If these wells or any additional wells are to be located on private property, the property owner will be notified and permission requested.

COMMENT #25

The residences in the area should continue to be monitored.

RESPONSE #25

Samples collected from the residential wells found no site related contamination. With the information available, the private water supply wells are thought to be upgradient, or possibly cross-gradient of the site, and drinking water wells are not expected to be affected by site contaminants. Since off-site monitoring wells are not yet in place, another round of private drinking water samples were collected in the Fall of 1992. Results of this sampling event showed no contamination in any of the homeowner wells. (See Response #3 for additional information)

COMMENT #26

The NYS DOH should check the employee's health.

RESPONSE #26

The New York State Department of Health (NYS DOH) does not routinely conduct physicals on employees in such industries. We do, however, have a staff of medical personnel who will discuss personal health concerns with the site workers or area residents. A contact person for such questions is Ms. Bonnie Farone, who can be reached at the NYS DOH's toll free number 1-800-458-1158.

COMMENT #27

If the NYS DOH is truly concerned with the site, why don't they keep more up to date on the goings on at the site?

RESPONSE #27

We realize that some changes have taken place at the site since the health assessment was first drafted. There have been site visits and correspondence which are not reflected in the document which was distributed for public comment. The NYS DOH works with US EPA and NYS DEC to keep the public informed about the investigation and remediation at inactive hazardous waste sites. The outreach from the agencies to the community usually occurs at project milestones, and this will be happening with the Tri-Cities Barrel site. No immediate health concern was identified after the NYS DOH conducted the initial site visit and sampled residential wells near the site. If you have questions in the interim, please contact Susan Van Patten of our Health Liaison Program at the toll free number 1-800-458-1158, extension 402.

COMMENT #28

Why did no one on the other side of the railroad tracks receive a copy of the draft Public Health Assessment?

RESPONSE #28

The NYS DOH tries to put together a comprehensive mailing list based on past correspondence with area residents, previous homeowner well sampling, identifying local interest groups, media, NYS DEC and US EPA mailing list, etc. We regret that we may have missed individuals interested in the public health assessment. Individuals who wish to receive a copy of the public health assessment for the Tri-Cities Barrel site may contact Susan Van Patten at the NYS DOH by calling the toll free number 1-800-458-1158; extension 402. Additionally, copies of site related information, including the public health assessment will be available for review in any of the following document repositories by contacting:

    Town Clerk
    P.O. Box 34
    Port Crane, New York 13833

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

    United States Environmental Protection Agency
    26 Federal Plaza, Room 29-102
    New York, New York 10278
    Attention: Caretaker - Document Repository


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