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PUBLIC HEALTH ASSESSMENT

ROWE INDUSTRIES GROUNDWATER CONTAMINATION
SAG HARBOR, SUFFOLK COUNTY, NEW YORK


APPENDIX A


Figure 1. Site Location Map


Figure 2. Site Location Map


Figure 3. Surface Soil Sampling Locations


Figure 4. Rowe Industries Site


Figure 5. Stream and Bay Surface Sediment Results


Figure 6. Stream and Bay Surface Water Results



APPENDIX B

Table 1.

Rowe Industries
Remedial Investigation
Summary of On-Site Soil Gas Survey
(All values in parts per billion)


Compound Range of
Detection
Comparison
Values**
Source***

*tetrachloroethene

ND-24,039 0.3 ATSDR CREG

*1,1,1-trichloroethane

ND-10,367 180 EPA RfC

*trichloroethene

ND-2,922 0.11 EPA CPF

1,1-dichloroethane

NA    

1,1-dichloroethene

NA    
freon 113 NA    

benzene

NA    

xylene

NA    
toluene NA    

ethylbenzene

NA    
acetone NA    
methylene chloride NA    

ND - not detected
NA - not available

*Contaminant selected for further evaluation

**Comparison value determined for a 70 kilogram adult who inhales 20 cubic meters of air per day.

***EPA RfC = EPA Reference Concentration
EPA CPF = EPA Cancer Potency Factor
ATSDR CREG = ATSDR Cancer Risk Evaluation Guide


Table 2.

Rowe Industries
Remedial Investigation
On-Site Subsurface Soil Samples
(All values in milligrams per kilogram, mg/kg)


Compound Subsurface
Soil
Frequency of
Detection
Typical
Background
Range**
Comparison
Value***
Source****

*tetrachloroethene ND-67.0 11-34 ND 14 NYS CREG

1,1,1-trichloroethane

ND-0.008 1-34 ND 4,500 NYS RfG

trichloroethene

ND-0.620 3-34 ND 56 NYS CREG

1,1-dichloroethane

ND 0-34 ND 70 NYS RfG

1,1-dichloroethene

ND 0-34 ND 1.2 ATSDR CREG

1,2-dichloroethene (total)

ND 0-34 ND 150 EPA RfD

freon 113

ND-6.2JR 16-34 ND 15,300 NYS RfG

benzene

ND 0-34 ND 24 ATSDR CREG

xylene

ND-66.0 5-34 ND 100,000 EPA RfD

toluene

ND-2.10 3-34 ND 10,000 EPA RfD

ethylbenzene

ND-0.016 3-34 ND 5,000 EPA RfD

acetone

ND-1300 BJ 15-34 ND 5,000 EPA RfD

methylene chloride

ND-0.033 R 16-34 ND 93 ATSDR CREG

lead

3.6-16.8 7-7 10-300 NA  

chromium

2.5-21.3 7-7 10-40 250 EPA RfD

cadmium

ND-4.1 5-7 <0.5-1 10 ATSDR EMEG

ND - not detected
B = Compound found in associated blank
J = estimated value
R = rejected by validator
NA = Not Available

*Contaminant selected for further evaluation.

**References: Clarke et al. (1985); Connor et al. (1957); Dragun (1988); Frank et al. (1976); McGovern (1988); Shacklette and Boerngen (1984)

***Comparison value for cancer risk determined for a 70 kg adult who ingests 100 mg soil per day; comparison value for noncancer risk determined for a 10 kg child who ingests 200 mg soil per day.

****EPA RfD = US EPA Reference Dose
NYS CREG = New York State Cancer Risk Evaluation Guideline
NYS RfG = New York State Risk Reference Guideline for noncarcinogenic effects
ATSDR CREG = ATSDR Cancer Risk Evaluation Guide
ATSDR EMEG = ATSDR Environmental Media Evaluation Guide


Table 3.

Rowe Industries
Remedial Investigation
On-Site Surface Soil Samples
(All values in milligrams per kilogram, mg/kg)


Compound 0-6" Soil Frequency of
Detection
Typical
Background
Range**
Comparison
Value***
Source****

tetrachloroethene ND 0-13 ND 14 NYS CREG

1,1,1-trichloroethane

ND 0-13 ND 4,500 NYS RfG

trichloroethene

ND 0-13 ND 56 NYS CREG

1,1-dichloroethane

ND 0-13 ND 70 NYS RfG

1,1-dichloroethene

ND 0-13 ND 1.2 ATSDR CREG

1,2-dichloroethene (total)

ND-0.005 2-13 ND 150 EPA RfD

freon 113

ND 0-13 ND 15,300 NYS RfG

benzene

ND 0-13 ND 24 ATSDR CREG

xylene

ND 0-13 ND 100,000 EPA RfD

toluene

ND-0.005 8-13 ND 10,000 EPA RfD

ethylbenzene

ND 0-13 ND 5,000 EPA RfD

acetone

ND 0-13 ND 5,000 EPA RfD

methylene chloride

ND 0-13 ND 93 ATSDR CREG

lead

5.9-522 13-13 10-300 NA  

*chromium

2.3-438 13-13 10-40 250 EPA RfD

cadmium

ND-4.4 9-13 <0.5-1 10 ATSDR EMEG

ND - not detected
NA = Not Available
*Contaminant selected for further evaluation.

**References: Clarke et al. (1985); Connor et al. (1957); Dragun (1988); Frank et al. (1976); McGovern (1988); Shacklette and Boerngen (1984)

***Comparison value for cancer risk determined for a 70 kg adult who ingests 100 mg soil per day; comparison value for noncancer risk determined for a 10 kg child who ingests 200 mg soil per day.

****EPA RfD = US EPA Reference Dose
NYS CREG = New York State Cancer Risk Evaluation Guideline
NYS RfG = New York State Risk Reference Guideline for noncarcinogenic effects
ATSDR EMEG = ATSDR Environmental Media Evaluation Guide
ATSDR CREG = ATSDR Cancer Risk Evaluation Guide


Table 4.

Rowe Industries
Remedial Investigation
Groundwater Sample Results
(All values in micrograms per liter)


Compound On-Site Off-Site Water Quality Standards Source***
New York State

U.S. EPA

Comparison
Value**
Upgradient Downgradient

Ground-
water

Drinking
Water
Drinking
Water

*tetrachloroethene ND-12,000 ND ND-1900.0 5 5 5 0.7 NYS CREG

*1,1,1-trichloroethane

  ND-3,700 ND ND-1800.0 5 200 200 EPA LTHA

*trichloroethene

ND-1,400 ND ND-1400.0 5 5 5 3 NYS CREG

*1,1-dichloroethane

ND-31.0 ND ND-98.0 5 5 - 700 EPA RfD

*1,1-dichloroethene

ND-24.0 ND ND-130.0 5 5 7 0.07 NYS CREG

*1,2-dichloroethene
(total)

ND-560.0 ND ND-56.0 5 5 100 70 EPA LTHA
*freon 113 ND-5,000BJ ND ND-3.0 5 5 - 250,000 EPA RfD

benzene

ND ND ND 0.7 5 5 0.7 NYS CREG

*xylenes

ND-1,800 ND ND-8.0 5n 5n 10,000i;20ps 10,000 EPA LTHA

*toluene

ND-13.0 ND ND-4.0 5 5 1,000;40ps 1,000 EPA LTHA

*ethylbenzene

ND-120.0 ND ND-0.5 5 5 700;30ps 700 EPA LTHA

*acetone

ND-2,700 ND ND-86.0 50 50 - 700 EPA RfD

*methylene chloride

ND-540BJ ND ND-27.0 5 5 5p 4.7 ATSDR CREG

*lead

ND-70.9 12.5-18.3 10.4-93.3 25 50 15A -  

*chromium

ND-66.4 36.0-103.0 ND-7,210 50 50 100 100 EPA LTHA

*cadmium

ND-17.0 ND-4.6 ND-33.4 5 10 5 5 EPA LTHA

ND - not detected

*Contaminant selected for further evaluation.

A = The maximum contaminant level goal (MCLG) for lead is zero and the action level is 15 mcg/L at the tap.
i = total xylenes
n = applies to each isomer separately unless isomers are analytically indistinguishable
p = proposed maximum contaminant level (MCL)
ps = proposed secondary MCL

**Comparison value determined for a 70 kilogram adult who ingests 2 liters of water per day.

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



Table 5.

Rowe Industries
Remedial Investigation
On-Site Pond Sediment Samples
(All values in milligrams per kilogram, mg/kg)


Compound Sediment
0-6"
Frequency of
Detection
Typical
Background
Range*
Comparison
Value**
Source***

tetrachloroethene ND 0-3 ND 14 NYS CREG

1,1,1-trichloroethane

ND 0-3 ND 4,500 NYS RfG

trichloroethene

ND 0-3 ND 56 NYS CREG

1,1-dichloroethane

ND 0-3 ND 70 NYS RfG

1,1-dichloroethene

ND 0-3 ND 1.2 ATSDR CREG

freon 113

ND 0-3 ND 15,300 NYS RfG

benzene

ND 0-3 ND 24 ATSDR CREG

xylene

ND 0-3 ND 100,000 EPA RfD

toluene

ND 0-3 ND 10,000 EPA RfD

ethylbenzene

ND-0.002 1-3 ND 5,000 EPA RfD

acetone

ND 0-3 ND 5,000 EPA RfD

methylene chloride

ND 0-3 ND 93 ATSDR CREG

lead

15.8a   10-300 NA  

chromium

12.9a   10-40 250 EPA RfD

cadmium

3.1a   <0.5-1 10 ATSDR EMEG

ND - not detected
NA = Not Available
aOnly one sample result available for pond sediment inorganics

*References: Clarke et al. (1985); Connor et al. (1957); Dragun (1988); Frank et al. (1976); McGovern (1988); Shacklette and Boerngen (1984)

**Comparison value for cancer risk determined for a 70 kg adult who ingests 100 mg soil per day; comparison value for noncancer risk determined for a 10 kg child who ingests 200 mg soil per day.

***EPA RfD = US EPA Reference Dose
NYS CREG = New York State Cancer Risk Evaluation Guideline
ATSDR EMEG = ATSDR Environmental Media Evaluation Guide
NYS RfG = New York State Risk Reference Guide for Noncarcinogenic Health Risks
ATSDR CREG = ATSDR Cancer Risk Evaluation Guide


Table 6.

Rowe Industries
Remedial Investigation
On-Site Drywell Sediment Samples
(All values in milligrams per kilogram, mg/kg)


Compound Concentration
Range
Frequency of
Detection
Typical
Background
Range
Comparison
Value**
Source***

tetrachloroethene

0.007-9.1 6/22 ND 14 NYS CREG

1,1,1-trichloroethane

0.003-5.3 4/22 ND 4,500 NYS RfG

trichloroethene

0.01-27 4/22 ND 56 NYS CREG

1,1-dichloroethane

0.006-2.4 2/21 ND 70 NYS RfG

1,2-dichloroethene
(total)

0.017-28 2/22 ND 150 EPA RfD

freon 113

2.1-230 2/22 ND 15,300 NYS RfG

xylene

0.07-20 6/22 ND 100,000 EPA RfD

toluene

0.013-27 8/22 ND 10,000 EPA RfD

ethylbenzene

0.02-2.3 3/22 ND 5,000 EPA RfD

acetone

19 1/21 ND 5,000 EPA RfD

methylene chloride

0.440 1/21 ND 93 ATSDR CREG

lead

65.8-75.2 2/2 10-300 NA  

chromium

320.0-382.0* 2/2 10-40 250 EPA RfD

cadmium

4.1-4.6 2/2 <0.5-1 10 ATSDR EMEG

ND - not detected
NA = Not Available
*Duplicate analysis not within control limits

**Comparison value for cancer risk determined for a 70 kg adult who ingests 100 mg soil per day; comparison value for noncancer risk determined for a 10 kg child who ingests 200 mg soil per day.

***EPA RfD = US EPA Reference Dose
NYS CREG = New York State Cancer Risk Evaluation Guideline
NYS RfG = New York State Risk Reference Guideline for noncarcinogenic effects
ATSDR EMEG = ATSDR Environmental Media Evaluation Guide
ATSDR CREG = ATSDR Cancer Risk Evaluation Guide


Table 7.

Rowe Industries
Remedial Investigation
Homeowner Well Samples
(All values in micrograms per liter, mcg/L)


Compound Downgradient Upgradient Water Quality Standards Comparison
Value**
Source***

New York State

U.S. EPA

Ground-
water

Drinking
Water
Drinking
Water

*tetrachloroethene ND-1800.0 ND 5 5 5 0.7 NYS CREG

*1,1,1-trichloroethane

ND-2600.0 ND 5 5 200 200 EPA LTHA

*trichloroethene

ND-910.0 ND 5 5 5 3 NYS CREG

*1,1-dichloroethane

ND-300.0 ND 5 5 - 700 EPA RfD

*1,1-dichloroethene

ND-330.0 ND 5 5 7 0.07 NYS CREG

*1,2-dichloroethene (total)

ND-100.0 ND 5 5 100 70 EPA LTHA

benzene

NA NA          

xylene

NA NA          

toluene

NA NA          

ethylbenzene

NA NA          

acetone

ND ND 50 50 - 700 EPA RfD
methylene chloride

ND

ND-5B 5 5 5p 4.7 ATSDR CREG

lead

14.0 12.7-22J 25 50 15A -  

chromium

9.0B ND 50 50 100 100 EPA LTHA

cadmium

ND ND-4.1B 5 10 5 2 ATSDR EMEG

NA - not analyzed
ND - not detected

*Contaminant selected for further evaluation.

A = The maximum contaminant level goal (MCLG) for lead is zero and the action level is 15 mcg/L at the tap.
p = proposed maximum contaminant level (MCL)

**Comparison value determined for a 70 kilogram adult who ingests 2 liters of water per day.

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


Table 8.

Rowe Industries
Remedial Investigation
Off-Site Surface Water Samples - Ligonee Brook, Sag Harbor Cove
(All results in micrograms per liter)


Compound Result Range Frequency New York State
Surface Water
Quality Standards
Comparison
Value**
Source***

*tetrachloroethene ND-13.0 11-16 0.7g 0.7 NYS CREG

*1,1,1-trichloroethane

ND-30.0 9-16 5g 200 EPA LTHA

*trichloroethene

ND-18.0 9-16 3g 3 NYS CREG

*1,1-dichloroethane

ND-6.0 8-16 5g 700 EPA RfD

*1,1-dichloroethene

ND-6.0 10-16 0.07g 0.07 NYS CREG

freon 113

ND-10.0 8-16 5g 250,000 EPA RfD

*benzene

ND-4.0 6-16 0.7 0.7 NYS CREG

xylene

ND-0.7 1-16 5g,h 10,000 EPA LTHA

toluene

ND-0.3 3-16 5g 1,000 EPA LTHA

ethylbenzene

ND-0.2 1-16 5g 700 EPA LTHA

acetone

ND-8.0 2-16 - 700 EPA RfD

methylene chloride

ND-0.4 5-16 5g 4.7 ATSDR CREG

lead

ND-2.7 2-3 50 -  

chromium

ND-7.0 1-3 50 100 EPA LTHA

cadmium

ND 0-3 10 2 ATSDR EMEG

ND - not detected

*Contaminant selected for further evaluation.

g = guidance value
n = applies to each isomer separately unless isomers are analytically indistinguishable

**Comparison value determined for a 70 kilogram adult who ingests 2 liters of water per day.

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


Table 9.

Rowe Industries
Remedial Investigation
Sediment Samples - Ligonee Brook, Sag Harbor Cove
(All values in milligrams per kilogram)


Compound Range of
Results
Frequency of
Detection
Typical
Background
Range
Comparison
Value**
Source***

tetrachloroethene ND-0.34 3-19 ND 14 NYS CREG

1,1,1-trichloroethane

ND-0.032 2-19 ND 4,500 NYS RfG

trichloroethene

ND-0.030 4-19 ND 56 NYS CREG

1,1-dichloroethane

ND-0.004 2-19 ND 70 NYS RfG

1,1-dichloroethene

ND-0.009 5-19 ND 1.2 ATSDR CREG

freon 113

ND-0.008 5-19 ND 15,300 NYS RfG

benzene

ND 0-19 ND 24 ATSDR CREG

xylene

ND 0-19 ND 100,000 EPA RfD

toluene

ND-0.006 9-19 ND 10,000 EPA RfD

ethylbenzene

ND-0.003 1-19 ND 5,000 EPA RfD

acetone

ND-0.069 6-19 ND 5,000 EPA RfD

methylene chloride

ND-0.012 13-19 ND 93 ATSDR CREG

lead

8.6-32.5 3-3 10-300 - -

chromium

4.5-8.3* 3-3 10-40 250 EPA RfD

cadmium

2.0-3.1 3-3 <0.5-1 10 ATSDR EMEG

 

ND - not detected

*Duplicate analysis not within control limits

**Comparison value for cancer risk determined for a 70 kg adult who ingests 100 mg soil per day; comparison value for noncancer risk determined for a 10 kg child who ingests 200 mg soil per day.

***EPA RfD = US EPA Reference Dose
NYS CREG = New York State Cancer Risk Evaluation Guideline
NYS RfG = New York State Risk Reference Guideline for noncarcinogenic effects
ATSDR CREG = ATSDR Cancer Risk Evaluation Guide
ATSDR EMEG = ATSDR Environmental Media Evaluation Guide


APPENDIX C

Response to Public Comments
Rowe Industries

HEALTH

Comment #1

One resident expressed some specific health concerns. How can the residents contact a NYS DOH physician for specific concerns and problems?

Response #1

NYS DOH medical staff are available to speak with the resident's physician regarding potential health problems by calling 1-800-458-1158 and asking for Ms. Bonnie Farone at extension 202.

Comment #2

How many local physicians were able to discuss potential health effects or problems of their patients with a NYS DOH physician?

Response #2

There have been no contacts made to NYS DOH medical staff regarding the Rowe Industries site.

Comment #3

The fourth paragraph states that there are no known citizen concerns at present. Such concerns were expressed by citizens at the September 9, 1992 meeting as noted under Community Health Concerns and in subparagraph C.1, page 21 Public Health Implications. The health assessment says that there has been no more concern about the contamination in the wells in this area. You are wrong. There are three families here without public water. Everyone is concerned and will continue to be very concerned until the cleanup of the groundwater contamination is completed.

Response #3

The summary has been amended to reflect these concerns.

Comment #4

Do you consider that the health-related concerns raised by local residents have been adequately addressed?

Response #4

Yes. We have responded to all concerns we have received verbally or in writing.

Comment #5

Is the NYS DOH or anyone else planning to evaluate health outcome data specifically for the Rowe Industries site?

Response #5

The NYS DOH evaluates health outcome data for a specific site when requested or when there is information that significant exposures have occurred. As of now, no specific studies are being planned. However, a breast cancer study for small geographical areas did not show any association between breast cancer incidence patterns and contaminated drinking water wells or hazardous waste sites. The NYS DOH will also consider including the people exposed to VOCs in drinking water on NYS DOH's registry for VOC exposures from contaminated drinking water.

Comment #6

The Community Health Concerns section did not begin to address the main issue: nearby residents and longtime Rowe employees, in a significant amount of cases, have developed serious health problems.

Response #6

This comment was made to the NYS DOH by someone who is not employed by Rowe. Anyone who has specific information about serious health problems at Rowe Industries should contact the NYS DOH.

Comment #7

How has community health education been performed for persons who were exposed to contaminants in their drinking water? How effective was the program?

Response #7

Community health education refers to actions such as interpreting data and advising individual residents about their drinking water quality. These actions took place during the initial private water supply sampling by the Suffolk County Health Department. In addition, the public meeting conducted by the US EPA and NYS DOH is considered a part of the community health education program.

Comment #8

Rowe has made a lot of people sick. Where is the data?

Response #8

The NYS DOH discussed health concerns with several individuals after the September 1992 public meeting. There has been no specific information received from the community regarding a large number of illnesses that are thought to be site-related. Also, the NYS DOH has received no specific information regarding increased illness experienced by workers at Rowe.

Comment #9

Why weren't comparisons made with other local people regarding instances of cancer? Have any of the data bases referenced in subparagraph E of the Health Outcome Data been used in the investigation of this site?

Response #9

The NYS DOH evaluates health outcome data for a specific site when requested or when there is information that significant exposures have occurred. As of now, no specific studies are being planned. However, a breast cancer study for small geographical areas did not show any association between breast cancer incidence patterns and contaminated drinking water wells or hazardous waste sites. The NYS DOH will also consider including the people exposed to VOCs in drinking water on NYS DOH's registry for VOC exposures from contaminated drinking water. As noted in the Background, Section E, the cancer registry was used in the breast cancer incidence study.

Comment #10

Have persons exposed in the past been added to the NYS DOH registry?

Response #10

The persons whose wells were contaminated above drinking water standards will be considered for addition to the NYS DOH registry.

SAMPLING

Comment #11

There was not sufficient sampling done at the pond site.

Response #11

The surface water and sediment samples collected at the pond did not indicate any significant contamination. Agency personnel consider the sampling conducted at the on-site pond to be sufficient. If we receive a specific reason for needing additional sampling, we will review this request.

Comment #12

Have the NYS DOH recommendations noted in the fifth paragraph been implemented? If so, what is the frequency of monitoring water supplies and surveying off-site soil gas? Any results to date?

Response #12

Recommendation #1 regarding monitoring public and private supplies is on-going. All public water supply wells in Suffolk County are monitored on a quarterly basis. Private water supplies are monitored by the Suffolk County Department of Health Services when requested. No off-site soil gas survey is currently planned.

Comment #13

Why was no off-site surface or sub-surface soil sampled? Are there any plans to do so?

Response #13

There was no indication of disposal of hazardous materials off the site property and the area of subsurface contamination has been defined. There are no plans to collect off-site surface or sub-surface soil samples at this time.

SOIL/SOIL GAS

Comment #14

Why was off-site soil gas not sampled? Since there is a potential for vapors to infiltrate in basement areas of residential homes, are there plans to do off site soil gas testing or surveys? How can we find out whether our basement is infiltrated and what are the real health risks?

Response #14

Off-site soil gas was not sampled in the original investigation. We have recommended conducting a limited off-site soil gas survey to determine the potential for soil gas to accumulate in the basements of residences adjacent to the site.

Comment #15

Is there also a "potential" soil vapor hazard in the gardens and lawns of nearby residents?

Response #15

No. The only potential hazard from soil vapor is when it infiltrates and accumulates in enclosed indoor spaces such as basements. At the Rowe Industries site, there would be a concern only for those residences directly adjacent to the site, not those in the plume area because the contamination in the plume area is very deep, approximately 65 feet.

Comment #16

Why do you reference the levels of gas on the site and then correlate that with unknown and possible non-existent levels in nearby basements within the spread of the plume? Why do you assess a "potential" if you cannot cite any factual basis or support data?

Response #16

One of the tasks in the public health assessment is to identify potential exposure routes. If there are no data, a recommendation to obtain the data is made.

Comment #17

Was there any unsatisfactory field data quality, laboratory data quality or sample design which eliminated the evaluation of a given contaminant, or was better data or a better sample design pursued?

Response #17

None of the data failed the quality assurance/quality control review.

Comment #18

Are there any efforts being made to obtain additional data in order to assess the potential carcinogenic or toxicological effects of a number of the contaminants detected?

Response #18

A registry of persons exposed to volatile organic compounds (VOCs) in drinking water is being developed by the NYS DOH. The persons who ingested contaminated water from this site will be considered for inclusion in the registry. Data from this registry will, in the future, be used in the assessment of the carcinogenic or toxicological effects of the VOCs.

Comment #19

Why aren't air stripping towers removing the TCE? These VOCs should not be allowed to flow into the aquifer.

Response #19

The Record of Decision (ROD) call for groundwater extraction and treatment. The method of groundwater treatment prior to discharge will be air stripping.

Comment #20

Which of the on-site drywells continue to be a source of groundwater contamination as indicated by Drywell Sediment testing?

Response #20

Six drywells are located on the site. The investigation found drywells C and D are likely contributing to the primary and secondary plume constituents.

Comment #21

The contamination will kill the ducks, geese, swans and fish in Otter Pond.

Response #21

No contamination has been found in Otter Pond. The contaminant levels in the on-site pond are low. To our knowledge the New York State Department of Environmental Conservation and the United States Environmental Protection Agency have not raised any concerns about adverse effects on local wildlife.

REMEDIATION

Comment #22

Remediation by removal of contaminated soil is absolutely necessary as soon as possible - it should have been done years ago.

Response #22

The process of the clean-up of a site from discovery to final remediation can be lengthy. The important thing to remember is that the exposure to contaminated groundwater was stopped very soon after the contamination was found in the private water supply wells by the installation of a public water main to the affected residences.

Comment #23

Remediation should return the site to a pre-development state; free of all contamination.

Response #23

The goal of the remediation is to return the site to as close to a pre-development state as is practible and feasible.

WATER

Comment #24

The community is also concerned with the potential impact on the groundwater supply and the water level in nearby ponds of removing such vast quantities of water from the ground and discharging it into the local marine waters.

Response #24

The figures regarding gallons per day to be pumped and treated are the maximum the system can handle. The system will not operate at the maximum rate all the time. There is no indication that operating the system, even at the maximum, will deleteriously effect the water level in nearby ponds or negatively impact local marine waters.

Comment #25

What safeguards will be established to insure that the treated water (whenever it may be discharged) meets the specified standards?

Response #25

A monitoring program will be required as part of the remedial design. This monitoring program will include frequent sampling of the discharge water to ensure applicable standards are met. These sampling results will be reviewed by the government agencies and will be made available for public review.

Comment #26

What studies or investigations were made to support the conclusion that disposal of the treated water into local marine waters should cause no adverse effects on local marine life?

Response #26

We have forwarded this concern to the United States Environmental Protection Agency; it is the appropriate agency to respond.

GENERAL

Comment #27

It is not clear what the numbers listed under "Comparison Value" really means.

Response #27

Comparison values are one of the factors used to evaluate if the contaminants at a site are likely to pose a health threat. Each environmental medium (air, soil, water) has its own comparison value for a contaminant. If a contaminant concentration is above its comparison value, the contaminant is evaluated further to determine if exposure is of public health significance. A general discussion of comparison values and the selection of contaminants for further evaluation is provided in the Environmental Contamination and Other Hazards Section of the Public Health Assessment for Rowe Industries. The potential for exposure is evaluated in the Pathways Analysis Section and the potential for health effects is discussed in the Toxicological Evaluation.

Comment #28

The transfer of ownership of a hazardous waste site shows the necessity of enacting legislation mandating a special seal to be placed on hazardous waste site deeds warning potential buyers of the problem - the buyer beware.

Response #28

The transfer of ownership of a hazardous waste site on the NYS registry requires notification of NYS DEC and the potential buyer. Transfer of ownership of properties adjoining these sites also requires this notification.

Comment #29

The public meeting held at Sag Harbor on September 9, 1992 should be clearly identified.

Response #29

The public health assessment has been amended to reflect this comment.

Comment #30

How serious of an attempt was made to gain access to the on-site pond during the July 1988 and September 1992 inspections if the inspectors were turned back by a heavy overgrowth of vegetation (subparagraph c)?

Response #30

The vegetation was heavy enough so that access without clearing equipment was not feasible. The only concern regarding the pond is access by trespassers, which is not considered to be a problem due to the heavy vegetation.

Comment #31

Have both actions determined to be necessary by the ATSDR's Health Activities Recommendation Panel been implemented?

Response #31

The persons exposed in the past will be considered for addition to NYS DOH's registry being developed for persons exposed to VOCs. The community health education recommendation has been implemented.

Comment #32

What measures have been established and implemented to check on the extent of the plume migration?

Response #32

Samples are collected from the monitoring wells installed during the original Suffolk County Health Department investigation, and monitoring wells installed under the direction of the US EPA.

Comment #33

A better way of expressing the thought in subparagraph C-1 on page 21 would seem to be "Local residents have been concerned ever since contamination was discovered."

Response #33

The public health assessment has been amended to reflect this comment.

Comment #34

It should be noted in this health assessment that the Village of Sag Harbor has a Local Waterfront Revitalization Program to protect and improve the marine habitats of the Cove.

Response #34

This information was not added to the public health assessment because it does not pertain to the assessment of potential public health impacts.

Comment #35

Figure 4 is totally unreadable.

Response #35

The original of this figure is not very clear. Photocopying has further degraded the clarity. This figure has been replaced in the final document.

Comment #36

Page 5, last paragraph - It is incorrect to say that Rowe Industries operated at the site from 1961 to 1974 as this statement implies that only one corporate entity operated at the site during this time period. Rowe Industries, a corporation owned by Robert Rowe, Ethel Beck and Ralph Schwenk, operated at the site from January 10, 1961 until March 4, 1966. At the time, Rowe Industries changed its name to R.I. Liquidation Corp. On March 7, 1966 the assets of R.I. Liquidation Corp. were sold to a new corporation, also named Rowe Industries. The parent of this new Rowe Industries was Aurora Plastics Corp. (later named Aurora Products Corp.).

Response #36

The public health assessment has been changed to incorporate this information.

Comment #37

Page 5, last paragraph - Nabisco purchased Aurora on May 28, 1971 and sold Rowe assets, except the Sag Harbor property, on July 14, 1978.

Response #37

The public health assessment has been changed to incorporate this information.

Comment #38

Page 6, top paragraph - There is no evidence that the solvents were discharged directly to the on-site pond. Indeed there is evidence that all sludge containing solvents or other chemicals was to be disposed of by Hogan Chemical Co. The only evidence related to the pond is the few empty discarded drums that were in the pond.

Response #38

The statement regarding disposal in the pond is based on information provided in a deposition by a former employee of Rowe Industries.

Comment #39

Page 8, top paragraph - The majority of the 50 to 60 drums observed on-site were the empty drums that previously contained drill cuttings from the RI. These were removed from the site in October 1992.

Response #39

The public health assessment has been changed to incorporate this information.

Comment #40

Page 9, top paragraph - Based on one year of monitoring, Ligonee Brook normally is dry until it reaches Sag Harbor Turnpike, at which point discharging groundwater causes it to flow.

Response #40

The public health assessment has been changed to incorporate this information.

Comment #41

Page 10, section A - The name Leggette, Brashears & Graham, Inc., is spelled incorrectly.

Response #41

This misspelling has been corrected in the final version of the health assessment.

Comment #42

Page 10, last paragraph and page 16 and 23; and page 13, last sentence - The former drum storage area is not owned by Sag Harbor Industries ("SHI"). Thus, the soil vapor survey did extend beyond the property line. In addition, the survey extended toward Home No. 44 to trace the extent of the vapor travel.

Response #42

The soil gas survey should have continued into adjacent residential property to determine the potential for soil gas contamination in these areas.

Comment #43

Page 12, last paragraph, third sentence should state, "All of the private wells in the plume have been replaced by a public water supply."

Response #43

The public health assessment has been changed to include this statement.

Comment #44

Page 13, first complete paragraph, third sentence should start, "Off site, the highest concentrations..."

Response #44

The public health assessment has been changed to include this statement.

Comment #45

Page 15, Section B, "Groundwater". Too much emphasis is given to the possibility of the plume shifting or enlarging. The RI showed no change in the location, width or length of the plume from 1984 to 1991. This conclusion is set forth in the approved RI report.

Response #45

It is accurate to state that there have been no significant changes in the plume over this time period; however, the potential for changes remains.

Comment #46

Page 17, last paragraph. The statement, "persons exposed...at the highest levels found in homeowner wells could have a high increase risk of developing cancer" is unnecessarily strong, particularly in light of the preceding statement that is uncertain if the chemicals cause cancer in humans. Is this statement supported by an analysis of the contact time and realistic consumption rates? Are the "high levels" that laboratory animals were exposed to comparable to the levels dissolved in the groundwater in Sag Harbor? A strong statement such as this which can cause panic among the general public, should not be made when scientific data is lacking and it is supported only by mere speculation.

Response #46

Tetrachloroethene, trichloroethene and 1,1-dichloroethene have caused cancer in laboratory animals exposed to much higher doses than the levels found in groundwater in Sag Harbor. However, chemicals that cause cancer in laboratory animals exposed to high levels over their lifetimes may also increase the risk of cancer in humans who are exposed to lower levels over long periods of time. Although it is not known whether tetrachloroethene, trichloroethene and 1,1-dichloroethene cause cancer in humans, the results from animal studies are sufficient to conclude that these chemicals are potential carcinogens.

For an undetermined period of time, a number of residential wells near the Rowe Industries site were contaminated with volatile organic chemicals. These wells were sampled in 1984 and all affected residences were connected to public water supplies by 1985. Since Rowe Industries began operation in 1961, people could have been exposed to contaminated drinking water for no more than 24 years.

Chronic exposure to volatile organic chemicals in drinking water was possible by ingestion, skin contact, and inhalation when contaminated water was used for showering, bathing and cooking. Although exposures would have varied depending on individual lifestyles, each of these exposures routes contributed to overall daily uptake of contaminants. For this analysis, we assumed that daily uptake of volatile organic contaminants from inhalation and skin contact is equal to that from drinking two liters of contaminated water a day. Based on the results of animal studies, the increased cancer risk was estimated to exceed one in one thousand for persons exposed for more than four years to drinking water contaminated with 1,1-dichloroethene, tetrachloroethene and trichloroethene at the highest levels found in homeowner well samples. An estimated increased cancer risk of one in one thousand or greater is considered high and led to the conclusion that increased risk from past exposure to contaminated drinking water could be high.

Comment #47

Page 18, second full paragraph - The data show the plume is stable. There are no municipal water supply wells close enough to the site to possibly be affected by the plume. The closest wells are in the Suffolk County Water Authority Division Street Well Field, which is located about 4,700 feet east (cross gradient) of the plume. There is not even a conservative scenario that puts those wells as risk.

Response #47

"Municipal" has been removed from the final public health assessment.

Comment #48

Page 18, "Organic Compounds" section. The analysis in the approved RI report shows that the only methylene chloride that cannot be attributed to laboratory contamination is in the dry wells and immediately adjacent monitor wells. Methylene chloride is not a constituent of the off-site plume. Some off-site wells were reported to contain sub-1 part per billion concentrations, including in the upgradient well cluster and in blanks. Therefore, the detections are a laboratory anomaly. See Comment No. 13 for Nabisco's concerns regarding statements of a "high increased cancer risk."

Response #48

Methylene chloride has been removed from the section titled "Organic Compounds."

Comment #49

Page 19, the metals discussion implies chromium, lead and cadmium in the groundwater are widespread site-related compounds. The discussion on pages 4-30 to 4-41 in the approved RI report includes that the occurrences are highly random, are detected in upgradient wells at similar levels to downgradient wells, and, thus, cannot be attributed to site activities.

Response #49

The public health assessment discusses all potential health affects on the affected population from exposure to groundwater. This does not necessarily infer that the metal contamination is related to the Rowe site.

Comment #50

Page 20, top of page - Air monitoring on the ground floor of the SHI building revealed no solvent vapors. This is above the area of highest groundwater contamination. Concentrations in vapor trail off to non-detectable, up to a maximum of about 150 parts per billion, at or near the SHI property line. Solvent vapors beneath residents would not approach the maximum levels detected on site, if they would be detected at all. Therefore, the conclusion that "soil vapor would pose a high risks of adverse health effects if found in indoor air," which seems to be based on the highest concentrations detected on site, is not supported by fact.

Response #50

The concentration of tetrachloroethene vapor at the edge of the adjacent private residence property nearest to the Rowe Industries fence was found to be 657 ppb (2-8). Approximately 50 ft. west of this point, station Q-8 was 9,742 ppb. These levels are within 50-100 feet of the nearest residence. The entire section in this issue had several qualifiers, including the following:

  • the data are inadequate to assess the toxicological implications of this potential pathway since no data exist on levels of volatile organic contaminants in nearby residences; and
  • although it is not known what levels could potentially impact air quality in nearby buildings, the levels of these three volatile organic contaminants found in soil vapor would pose a high risk of adverse health effects if found in indoor air (see Table 1).

Comment #51

Page 21. The discussion about recommended remedial action under concern No. 1 should not be a recommendation. The remedies are already in the Record of Decision, and have been so since October 1, 1992.

Response #51

The public health assessment makes recommendations for necessary remedial actions--we recognize that they may already be incorporated in the ROD.

Comment #52

This assessment is "recommending" remediation already required by the October 1, 1992 Record of Decision.

Response #52

The public health assessment makes recommendations for necessary remedial actions--we recognize that they may already be incorporated in the ROD.

Comment #53

Summary, third paragraph. The last two sentences imply that there is concrete evidence that contaminated vapor is entering basements. In fact, this is only speculation and seems unlikely given the soil vapor data collected during the RI.

Response #53

There is a potential for this to occur. The recommended survey would determine the extent and magnitude of soil gas off-site.


APPENDIX D

PROCEDURE FOR EVALUATING POTENTIAL HEALTH RISKS
FOR CONTAMINANTS OF CONCERN

To evaluate the potential health risks from contaminants of concern associated with the Rowe Industries site, the New York State Department of Health assessed the risks for cancer and noncancer health effects.

Increased cancer risks were estimated by using site-specific information on exposure levels for the contaminant of concern and interpreting them using cancer potency estimates derived for that contaminant by the US EPA or, in some cases, by the NYS DOH. The following qualitative ranking of cancer risk estimates, developed by the NYS DOH, was then used to rank the risk from very low to very high. For example, if the qualitative descriptor was "low", then the excess lifetime cancer risk from that exposure is in the range of greater than one per million to less than one per ten thousand. Other qualitative descriptors are listed below:

Excess Lifetime Cancer Risk

Risk Ratio Qualitative Descriptor
equal to or less than one per million very low
greater than one per million to less
than one per ten thousand
low
one per ten thousand to less than one
per thousand
moderate
one per thousand to less than one per ten high
equal to or greater than one per ten very high

An increased excess lifetime cancer risk is not a specific estimate of expected cancers. Rather, it is an estimate of the probability that a person may develop cancer sometime in his or her lifetime following exposure to that contaminant.

There is insufficient knowledge of cancer mechanisms to decide if there exists a level of exposure to a cancer-causing agent below which there is no risk of getting cancer, namely, a threshold level. Therefore, every exposure, no matter how low, to a cancer-causing compound is assumed to be associated with some increased risk. As the dose of a carcinogen decreases, the chance of developing cancer decreases, but each exposure is accompanied by some increased risk.

There is no general consensus within the scientific or regulatory communities on what level of estimated excess cancer risk is acceptable. Some have recommended the use of the relatively conservative excess lifetime cancer risk level of one in one million because of the uncertainties in our scientific knowledge about the mechanism of cancer. Others feel that risks that are lower or higher may be acceptable, depending on scientific, economic and social factors. An increased lifetime cancer risk of one in one million or less is generally considered an insignificant increase in cancer risk.

For noncarcinogenic health risks, the contaminant intake was estimated using exposure assumptions for the site conditions. This dose was then compared to a risk reference dose (estimated daily intake of a chemical that is likely to be without an appreciable risk of health effects) developed by the US EPA, ATSDR and/or NYS DOH. The resulting ratio was then compared to the following qualitative scale of health risk:

Qualitative Descriptions for
Noncarcinogenic Health Risks
Ratio of Estimated Contaminant
Intake to Risk Reference Dose
Qualitative
Descriptor
equal to or less than the risk
reference dose
minimal
greater than one to five times
the risk reference dose
low
greater than five to ten times
the risk reference dose
moderate
greater than ten times the
risk reference dose
high

Noncarcinogenic effects unlike carcinogenic effects are believed to have a threshold, that is, a dose below which adverse effects will not occur. As a result, the current practice is to identify, usually from animal toxicology experiments, a no-observed-effect-level (NOEL). This is the experimental exposure level in animals at which no adverse toxic effect is observed. The NOEL is then divided by an uncertainty factor to yield the risk reference dose. The uncertainty factor is a number which reflects the degree of uncertainty that exists when experimental animal data are extrapolated to the general human population. The magnitude of the uncertainty factor takes into consideration various factors such as sensitive subpopulations (for example, children or the elderly), extrapolation from animals to humans, and the incompleteness of available data. Thus, the risk reference dose is not expected to cause health effects because it is selected to be much lower than dosages that do not cause adverse health effects in laboratory animals.

The measure used to describe the potential for noncancer health effects to occur in an individual is expressed as a ratio of estimated contaminant intake to the risk reference dose. If exposure to the contaminant exceeds the risk reference dose, there is concern for potential noncancer health effects. As a rule, the greater the ratio of the estimated contaminant intake to the risk reference dose, the greater the level of concern. A ratio equal to or less than one is generally considered an insignificant (minimal) increase in risk.


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