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PUBLIC HEALTH ASSESSMENT

BROAD BROOK MILL
(a/k/a MILLBROOK CONDOMINIUM SITE)
EAST WINDSOR, HARTFORD COUNTY, CONNECTICUT


ATTACHMENT A: FIGURE 1

Site Diagram
Figure 1. Site Diagram


ATTACHMENT B: HEALTH CONSULTATIONS

[MILLBROOK CONDOS]
--AND--
[ASSESSMENT OF SURFACE SOIL SAMPLING DATA AT THE MILLBROOK CONDOMINIUMS SITE]


HEALTH CONSULTATION

Assessment of Soil Gas Sampling Data
at the Millbrook Condominiums Site

MILLBROOK CONDOS
EAST WINDSOR, HARTFORD COUNTY, CONNECTICUT
EPA FACILITY ID: CT0002055887

September 22, 2000

Prepared by:

Connecticut Department of Public Health
Under Cooperative Agreement with the
Agency for Toxic Substances and Disease Registry


The conclusions and recommendations in this health consultation are based on the data and information made available to the Connecticut Department of Public Health and the Agency for Toxic Substances and Disease Registry. The Connecticut Department of Public Health and the Agency for Toxic Substances and Disease Registry will review additional information if and when received. The review of additional data could change the conclusions and recommendations listed in this document.


BACKGROUND AND STATEMENT OF ISSUES

The U.S. Environmental Protection Agency (EPA) requested a review of soil gas sampling data for the Millbrook Condominium Site in East Windsor, Connecticut. The EPA provided environmental sampling data from this site [1]. The purpose of this health consultation is to determine whether the soil gas levels pose a public health hazard.

A. Site Description and History

The site is located at 110-112 Main Street in East Windsor, Connecticut, and consists of two adjoining parcels of land identified as block 37, lots 8 and 8A, and a portion of land on block 37, lot 18 [2]. The property currently consists of the following: 21-unit condominium complex, commercial office building, commercial retail strip mall, and a vacant powerhouse building. The former mill building is one of the original structures to have survived a fire in May 1986, which also destroyed several other buildings in the complex. The former mill building was renovated into a 21-unit condominium that has been occupied since 1990. The area surrounding the former mill condominium building consists of paved areas, grassed sections, overgrown brush, and wooded areas. Broad Brook defines the northern and western boundary of the site.

On June 19, 1998, the Connecticut Department of Public Health (CT DPH) reviewed an investigation of site contaminants [2]. That review was conducted to determine what immediate public health risks may be present for residents currently living in the former mill condominium building. The review recommended that the contaminated soils be remediated, and residents be relocated prior to initiating any large scale remedial activities. The CT DPH also recommended that children not play on the grounds of the condominium complex based primarily on surface soil results showing elevated concentrations of carcinogenic polynuclear aromatic hydrocarbons (PAHs).

After the June 1998 review was released, there was an expectation that the people living in the condominiums would be relocated. However, since that failed to occur, the CT DPH and ATSDR were asked to review the health implication of the ongoing potential exposures. On April 19, 2000, the CT DPH and ATSDR developed a Health Consultation examining surface soil sampling data. The surface soil was determined to be contaminated with PAHs at concentrations representing a Public Health Hazard to residents who may be exposed.

As a result of past operations on this site, there are numerous areas of contamination surrounding the former mill condominium building. These historic sources include above ground fuel oil storage tanks, a manufactured gas plant, cleaning solvents, plating solutions containing heavy metals, and a former coal storage area. There is a potential that ash wastes generated from the manufactured gas plant were disposed throughout the site.

Since the past practices at this site included the use and potential of disposal of solvents, there is the possibility that subsurface contamination may pose a risk of migrating through the soil and entering into the condominiums. In an effort to determine the risks posed by such contamination, a preliminary soil gas survey was conducted during December of 1999 [3]. One of the findings of that investigation was the detection of elevated levels of 1,1-dichloroethylene. On March 30, 2000, the EPA conducted an indoor walk-through four of the condominium units. The purpose of the walk-through was to determine whether soil gas could potentially migrate into the living spaces of the condominiums. Observations made at that time indicated that there were no areas within the four units investigated from which soil gas would likely enter the occupied areas. The current structures do not include basements or sumps which if present, could increase the potential for soil gas infiltration.

B. Demographics

The population potentially exposed consists of current and former residents of the 21-unit condominium building. Approximately 80 people live in the complex. Twenty of these residents may be young children (under age 6). This corresponds to, on average, two adults, one older child and one young child per condominium unit. The population includes units that are rented, as well as owner occupied units.

C. Environmental Contamination and Exposure Pathways

On June 8, 2000, [1] the EPA conducted a soil gas survey to characterize the volatile organic compounds (VOCs) inside the soil pore areas as close to the foundation of the condominium units as possible. Sixteen locations were selected around the condominium complex for this soil gas sampling. Probes were placed at depths ranging from 1 foot 6 inches, to a maximum depth of 4 feet 3 inches. The target depth was four feet, and the depths deviated from that target when an obstruction or groundwater was encountered. Table 1 lists the probe depths, groundwater depth, and whether a confirmatory canister sampling was conducted as that location (see also Figure 1).

Table 1.

Millbrook Condominiums East Windsor Site, Soil Gas Sampling Depths, June 2000.
Probe Number Sample Depth Depth to Groundwater Confirmatory Canister Site
1 4 feet 2 inches — * No
2 4 feet 3 inches No
3 4 feet 2 inches No
4 4 feet 0 inches Yes
5 4 feet 3 inches Yes
6 3 feet 9 inches 4 to 5 feet No
7 2 feet 5 inches No
8 1 foot 6 inches No
9 4 feet 1 inches No
10 4 feet 3 inches Yes
11 3 feet 11 inches No
12 3 feet 5 inches No
13 4 feet 1 inches Yes
14 4 feet 1 inches No
15 3 feet 9 inches Yes
16 4 feet 3 inches No

Source: [1]
*Groundwater was not encountered during these probe installations.

All collection locations were selected to be as close as feasible to the foundation of the condominium. The data collected from all locations were analyzed using a portable gas chromatograph/mass spectrophotometer (GC/MS). The results of that analysis are presented in Table 2. The analysis targeted three chlorinated VOCs known to be site-related: trichloroethylene, 1,1,1-trichloroethane, tetrachloroethylene. The chemical previously detected in the preliminary analysis, 1,1-dichloroethylene, was also screened for, but not detected [personal communication between Gary Perlman (CT DPH) and Frank Gardener (US EPA), August 2000].1 Five of the locations where the highest recorded VOCs were measured, were subsequently sampled with a canister. The soil gas collected in the canister was subsequently sent to a laboratory for chemical analysis. The complete list of chemicals that were analyzed is listed in Appendix A. The result of the canister analysis is presented in Table 3.

Tables 2 and 3 contain the following column headings: frequency of detection, concentration range, background ambient air, health comparison value, and Connecticut residential volatilization criteria for soil vapor (CT RSR). The frequency of detection column lists a fraction of the total samples that detected the specified chemical. For example the value listed for tetrachloroethylene was 11/16. This indicates that eleven of the sixteen total samples detected this compound. The concentration range column provides information about the minimum and maximum levels detected. During the soil gas sampling, the ambient air background levels were simultaneously measured. The results are listed in the column labeled background ambient air.

The health comparison value column lists numbers that are used as guidelines for exposures to chemicals in the air. When concentrations of chemicals are below these values, no adverse health effects are likely. These levels were used to determine which chemicals should be examined further.

The last column contains the CT RSR soil gas volatilization criteria. This number is used to determine soil gas values that may result in indoor air levels posing a potential health hazard. The CT DEP and CT DPH jointly developed these health-based numbers. During the development of these numbers, both carcinogenic and non-carcinogenic health risks were considered. Consequently, when the soil gas levels are below the residential volatilization criteria, it is not anticipated that the soil gas concentrations would pose a risk to people living in residential dwellings. These criteria are based upon an ASTM2 model which simulates soil gas infiltration through a cracked foundation. The model incorporates many parameters including: soil characteristics, infiltration rates, and dilution factors. For example, the CT RSR for tetrachloroethylene is 11,000 ppb. This value represents the concentration, when detected in soil gas, that would not result in indoor concentrations at a level of health concern.

Table 2.

Millbrook Condominiums East Windsor Site, On-Site Portable Gas Chromatograph Soil Gas Sampling Results and Health Comparison Values, Volatile Organic Compounds: June 2000, (All values in parts per billion)
Compound Frequency of Detection Concentration Range Background Ambient Air Health Comparison Value* Source CT RSR
Tetrachloroethylene 6/16 ND§–7.9 ND 0.6 RBC 11,000
1,1,1-Trichloreoethylene 11/16 ND–258 0.57 700 Int MRL 1,310,000
Trichloroethylene 9/16 ND–136 ND 0.1 RBC 7,000

Source: [1]
* Health comparison value assumes a 70-kilogram adult inhales 20 cubic meters of air per day.
Connecticut residential volatilization criteria for soil vapor [4]
§ Not detected.
Risk-based Concentration for ambient air from EPA region III [5].
Intermediate Minimum Risk Level.

Background ambient air was sampled over an eight-hour period at a location 144 feet south of the garage. The ambient air sampling was conducted during the soil gas sampling activities. All data were of acceptable quality, and no data were rejected.

Table 3.

Millbrook Condominiums East Windsor Site, Gas Canister Soil Gas Sampling Results from Location numbers 4, 5, 10, 13, and 15, and Health Comparison Values: June 2000, (All values in parts per billion)
Compound Frequency of Detection Concentration Range Background Ambient Air Health Comparison Value Source CT RSR
Acetone 3/5 ND§-9.3 ND 10,000 C MRL 2,400,000
Carbon tetrachloride 1/5 ND-0.05 0.1 0.01 CREG# 1,000
Chloroform 4/5 ND-2.0 ND 0.008 CREG 4,500
Dichlorodifluoromethane 3/5 ND-0.7 0.59 37 RBC** ††
1,1-Dichloroethane 1/5 ND-2.4 ND 126 RBC 850,000
cis-1,2-Dichloroethylene 1/5 ND-3.5 ND 9 RBC
1,1-Dichloroethylene* 0/5 ND ND 0.005 CREG 1,000
Hexane 2/5 ND-1.0 1.3 600 C MRL
Methyl ethyl ketone 0/5 ND ND 300 RfC‡‡ 2,400,000
Styrene 1/5 ND-2.4 ND 60 C MRL 8,000
1,1,2-Trichloro-
1,2,2-trifluoroethane
5/5 0.15-111 0.15 4,096 RBC
Tetrachloroethylene 4/5 ND-6.3 ND 0.6 RBC 11,000
1,1,1-Trichloroethane 5/5 9.8-361 0.57 700 Int MRL 1,310,000
Trichloroethylene 4/5 ND-151 ND 0.1 RBC 7,000
Trichlorofluoromethane 4/5 ND-339 0.27 130 RBC
1,2,4-Trimethylbenzene 1/5 ND-8.2 0.09 1.3 RBC
1,3,5-Trimethylbenzene 1/5 ND-3.3 ND 1.3 RBC
Xylene 1/5 ND-3.3 0.13 100 C MRL 500,000

Source: [1]
* This contaminant was detected in the initial soil gas survey.
Health comparison value assumes a 70-kilogram adult inhales 20 cubic meters of air per day.
Connecticut residential volatilization criteria for soil vapor [4].
§ Not Detected.
Chronic Minimum Risk Level.
# Cancer Risk Evaluation Guide.
** Risk-based Concentration for ambient air from EPA region III [5].
†† None Assigned.
‡‡ Reference Concentration.

D. Community Health Concerns and Current Issues

On May 15, 2000, a public availability session was conducted. Approximately forty-five people attended this forum. During that meeting, many residents were asked about whether they were aware of the recommendations regarding the avoidance of activities that would disturb the soil. Many residents indicated that they were aware of these recommendations. However, several residents indicated that new tenants may not be aware of the restrictions. However, they indicated that the signs were clear and the message presented was easily understood. Residents did not express concern about soil gas measurements, but wanted to be kept informed of any soil gas results. Discussions then focused on legal issues related to the CT DEP's proposal to buy-out the condominiums.


DISCUSSION

In order to determine the health implications of exposures, the CT DPH and the ATSDR consider how people might come into contact with the contaminants. The CT DPH and ATSDR use a systematic process of reviewing available environmental data. If the concentration of a detected chemical in a specific media is below the health comparison value, then the exposure is not of health concern. Consequently, no further evaluation is required. However, if the concentration is above the health comparison value, then the exposure undergoes further evaluation to determine whether the exposure might result in the adverse health effects. If a chemical does not have any health comparison value, a review of the scientific literature is conducted to determine if the exposures are of health concern.

The indoor air potential exposure pathway was identified at the Millbrook Condominium Site after evaluation of the existing soil gas data. This potential pathway was assessed as to whether it represents a health concern for the public. The evaluation is presented below.

Potential Exposure Pathway—Soil Gas.

The potential for exposure to soil gas and, therefore, adverse health effects from exposures, at this site is low for three main reasons. First the EPA determined that there were no areas within the four units investigated from which soil gas could enter the occupied areas. Second, the current structures do not include basements or sumps which if present, could increase the potential for soil gas infiltration. Third, if the chemicals enter the occupied areas, the effect of dilution and other factors, would result in concentrations below a level of concern.

All soils contain gaps between the particles which are filled with either liquids (usually water) or gases. Soil gas is the term used to describe the gas that fills these voids. Volatile organic contaminants in on-site and off-site groundwater will tend to separate into a soil gas phase. Elevated levels of VOCs in the soils and shallow groundwater may contaminate ambient air on-site and/or off-site depending upon the migration potential of the soil gas. Site contaminants could migrate through porous media as soil gas and enter confined building spaces (basements) through crawl spaces, plumbing holes, other floor holes (e.g., sumps) and foundation cracks, and contaminate indoor air.

The chemical, 1,1-dichloroethylene, which was originally detected at elevated levels in the soil gas preliminary survey in December of 1999, was not subsequently detected in the current round of sampling. There has been no confirmation of that compound in any canister sampling rounds.

Seven chemicals were detected below their respective Health comparison values and CT residential volatilization criteria for soil vapor, and thus do not represent health concern. The following chemicals met the above criteria:

acetone
1,1-dichloroethane
1,1-dichloroethylene
methyl ethyl ketone
styrene
1,1,1-trichloroethane
xylene

Four chemicals were detected above their respective health comparison values, but were below their respective CT residential volatilization criteria for soil vapor. The health comparison values for these compounds were developed for ambient air exposures. Since levels detected in soil gas are diluted when infiltration occurs, the realistic indoor air exposure concentration will likely be well below health comparison values. Moreover, since the CT residential volatilization criteria for these chemicals were not exceeded, these four chemicals do not pose a public health conern.

carbon tetrachloride
chloroform
tetrachloroethylene
trichloroethylene

The seven remaining chemicals did not have any CT RSRs. Five of which were detected at concentrations below their respective health comparison values for direct inhalation. These five therefore do not represent a health concern. These chemicals include the following:

dichlorodifluoromethane
cis-1,2-dichloroethylene
hexane
1,1,2-trichloro-1,2,2-trifluoroethane
trichlorofluoromethane

These are two remaining chemicals which lack CT RSRs, and were detected above their respective health comparison values. These chemicals are 1,2,4-trimethylbenzene and 1,3,5-trimethylbenzene. Since levels detected in soil gas are diluted when infiltration occurs, the effect of dilution and other factors, would result in concentrations that are likely below a level of concern. Consequently, concentrations of these two chemicals do not pose a public health concern.


CONCLUSIONS

Based on ATSDR's public health hazard categories (See Appendix B), the soil gas concentrations, as measured during June of 2000, around the foundation of the Millbrook Condominium units represent no apparent public health hazard to occupants of the dwellings. The conclusion is based on two main factors. The first is the low potential for soil gas infiltration. The second is the effects of dilution and other factors on any infiltrating gases that would result in concentrations below a level of health concern. It should be noted that however, that this conclusion is based on a limited data set taken over a short period of time. This conclusion could be revised if new data become available.


RECOMMENDATIONS

None at this time.


PUBLIC HEALTH ACTION PLAN

The Public Health Action Plan for the Millbrook Condominiums site contains a description of the actions completed and to be taken by the Agency for Toxic Substances and Disease Registry, the Connecticut Department of Public Health, and the Connecticut Department of Environmental Protection. Included in this plan is a commitment on the part of the Agency for Toxic Substances and Disease Registry and the Connecticut Department of Public Health to follow up on this plan to ensure that there is implementation.

The public health actions implemented include:

  1. The Connecticut Department of Public Health and the CT DEP have advised residents of the 21-unit condominium complex that children should not play on the grounds of the former mill building property, as well as areas near the residential condominium building.

  2. The Connecticut Department of Public Health and the CT DEP have advised residents of the 21-unit condominium complex that children and adults should not engage in digging or gardening activities throughout the site and should keep their pets from disturbing the top layer of soil.

The public health actions to be implemented include:

  1. The Connecticut Department of Public Health and the CT DEP will review and summarize additional environmental sampling data.

  2. The Connecticut Department of Public Health will conduct environmental health education for local public health officials, and local citizens regarding the results of this health consultation and previous recommendations issued for this site.

  3. The CT DPH and ATSDR will review any additional data, if they become available.

PREPARERS OF HEALTH CONSULTATION

Gary D. Perlman, MPH
Epidemiologist
Environmental Epidemiology and Occupational Health
Connecticut Department of Public Health


ATSDR Regional Representative:

William Sweet
US EPA Region 1


ATSDR Technical Project Officer:

Greg Ulirsch
Superfund Site Assessment Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry


CERTIFICATION

The Health Consultation for the review of the Soil Gas Sampling Data for the Millbrook Condominium Site was prepared by the Connecticut Department of Public Health under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the health consultation was initiated.

Gregory V. Ulirsch
Technical Project Officer, SPS, SSAB, DHAC


The Division of Health Assessment and Consultation (DHAC), ATSDR, has reviewed this Health Consultation and concurs with its findings.

Richard Gillig,
Chief, SSAB, DHAC, ATSDR


REFERENCES

  1. U.S. Environmental Protection Agency New England Regional Laboratory Office of Environmental Measurements and Evaluation. June 2000. Soil Gas Survey final report Mill Brook Condominiums East Windsor, Connecticut.

  2. Agency for Toxic Substances and Disease Registry. Health Consultation Assessment of Surface Soil Sampling Data at the Millbrook Condominiums Site East Windsor, Hartford County, Connecticut. Atlanta: US Department of Health and Human Services; April 19, 2000.

  3. U.S. Environmental Protection Agency. Data sheets concerning volatile organic screening results for soil gas samples collected on December 10, 1999, at Millbrook Condominium Site. East Windsor, Connecticut. 1999.

  4. Connecticut General Statutes § 22a-133k (rev to January 1, 1999).

  5. EPA Region 3. April 2000 Update. Risk-Based Concentration Table. Available at: http://www.epa.gov/reg3hwmd/risk/riskmenu.htm . Accessed August 11, 2000.

APPENDIX A:

LIST OF CHEMICALS ANALYZED FOR IN SOIL GAS
Acetone Hexachlorobutadiene
Benzene Hexane
Bromodichloromethane 2-Hexanone
1,3-Butadiene Isopropyl Alcohol
Carbon Disulfide m,p-Xylene
Carbon Tetrachloride Methyl Bromide
Chlorobenzene Methyl Ethyl Ketone
Chloroethane Methyl isobutyl ketone
Chloroform Methylene Chloride
Chloromethane Methyl-t-butyl ether
Chloromethylbenzene o-Xylene
cis-1,2-Dichloroethylene Propylene
cis-1,3-Dichloropropene Styrene
Cyclohexane 1,1,2,2-Tetrachloroethane
Dibromochloromethane Tetrachloroethylene
1,2-Dibromoethane Tetrahydrofuran
1,2-Dichloro-1,1,2,2-Tetrafluoroethane Toluene
1,2-Dichlorobenzene trans-1,2-Dichloroethylene
1,3-Dichlorobenzene trans-1,3-Dichloropropene
1,4-Dichlorobenzene 1,1,1,2-Trichloro-1,2,2-Trifluoroethane
Dichlorodifluoromethane 1,2,4-Trichlorobenzene
1,1-Dichloroethane 1,1,1-Trichloroethane
1,2-Dichloroethane 1,1,2-Trichloroethane
1,1-Dichloroethylene Trichloroethylene
1,2-Dichloropropane Trichlorofluoromethane
Ethyl Acetate 1,2,4-Trimethylbenzene
Ethyl Benzene 1,3,5-Trimethylbenzene
4-Ethyl Toluene Vinyl Chloride
Heptane  


APPENDIX B:

APPENDIX B: ATSDR PUBLIC HEALTH HAZARD CATEGORIES
Category Definition Criteria
A. Urgent public health hazard This category is used for sites that pose an urgent public health hazard as the result of short-term exposures to hazardous substances.

evidence exists that exposures have occurred, are occurring, or are likely to occur in the future AND

estimated exposures are to a substance(s) at concentrations in the environment that, upon short-term exposures, can cause adverse health effects to any segment of the receptor population AND/OR

community-specific health outcome data indicate that the site has had an adverse impact on human health that requires rapid intervention AND/OR

physical hazards at the site pose an imminent risk of physical injury

B. Public health hazard This category is used for sites that pose a public health hazard as the result of long-term exposures to hazardous substances.

evidence exists that exposures have occurred, are occurring, or are likely to occur in the future AND

estimated exposures are to a substance(s) at concentrations in the environment that, upon long-term exposures, can cause adverse health effects to any segment of the receptor population AND/OR

community-specific health outcome data indicate that the site has had an adverse impact on human health that requires rapid intervention

C. Indeterminate public health hazard

This category is used for sites with incomplete information.

limited available data do not indicate that humans are being or have been exposed to levels of contamination that would be expected to cause adverse health effects; data or information are not available for all environmental media to which humans may be exposed AND

there are insufficient or no community-specific health outcome data to indicate that the site has had an adverse impact on human health.

D. No apparent public health hazard This category is used for sites where human exposure to contaminated media is occurring or has occurred in the past, but the exposure is below a level of health hazard.

exposures do not exceed an ATSDR chronic MRL or other comparable value AND

data are available for all environmental media to which humans are being exposed AND

there are no community-specific health outcome data to indicate that the site has had an adverse impact on human health.

E. No public health hazard This category is used for sites that do not pose a public health hazard.

no evidence of current or past human exposure to contaminated media AND

future exposures to contaminated media are not likely to occur AND

there are no community-specific health outcome data to indicate that the site has had an adverse impact on human health.



Soil Gas Probe Locations, Mill Brook Condominiums, East Windsor, CT
Figure 1. Soil Gas Probe Locations, Mill Brook Condominiums, East Windsor, CT


1 However, 1,1-dichloroethylene was not listed in the data tables supplied by the US EPA.
2 ASTM (the American Society for Testing and Materials) was organized in 1898, and is one of the largest voluntary standards development organizations in the world. ASTM is not-for-profit organization that provides a forum for the development and publication of voluntary consensus standards for materials, products, systems and services. ASTM develops standard test methods, specifications, practices, guides, classifications, and terminology in 130 areas covering subjects such as metals, paints, plastics, textiles, petroleum, construction, energy, the environment, consumer products, medical services and devices, computerized systems, electronics, and many others. [source: ASTM. Frequently Asked Questions, what is ASTM? Available at: http://www.astm.org. Accessed August 18, 2000.]

 


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HEALTH CONSULTATION

ASSESSMENT OF SURFACE SOIL SAMPLING DATA AT THE MILLBROOK CONDOMINIUMS SITE
EAST WINDSOR, HARTFORD COUNTY, CONNECTICUT

April 19, 2000

Prepared by:

Connecticut Department of Public Health
Under Cooperative Agreement with the
Agency for Toxic Substances and Disease Registry


The conclusions and recommendations in this health consultation are based on the data and information made available to the Connecticut Department of Public Health and the Agency for Toxic Substances and Disease Registry. The Connecticut Department of Public Health and the Agency for Toxic Substances and Disease Registry will incorporate additional information if and when received. The incorporation of additional data could change the conclusions and recommendations listed in this document.


BACKGROUND AND STATEMENT OF ISSUES

The Connecticut Department of Environmental Protection (CT DEP) requested during the fall of 1999 that the CT Department of Public Health (CT DPH) review the surface soil sampling data for the Millbrook Condominium Site in East Windsor, CT. The CT DEP provided environmental sampling data from this site. The purpose of this health consultation is to determine whether the surface soil is contaminated at levels that pose a public health hazard.

The site is located at 110-112 Main Street in East Windsor, CT, and consists of two contiguous parcels of land identified as Block 37, Lots 8 and 8A, and a section of land on Block 37, Lot 18[1]. The property currently consists of the following: a 21 unit condominium complex, commercial office building, commerical retail strip mall, and a vacant powerhouse building. The former mill building is one of the original structures to have survived a fire in May of 1986, which destroyed several other buildings in the complex at that time. The former mill building was renovated into a 21-unit condominium building that has been occupied since 1990; this building and the surrounding land areas constitute the focus of this health consultation. The area surrounding the former mill condominium building consists of pavement, grassed sections, overgrown brush, and wooded areas. Broad Brook defines the northern and western boundary of the site.

A grassed area in front of the condominium building is conducive to recreational activities and has the potential to be used by children and adults for much of the year. This grass cover extends from the building to the south and also occurs in sections to the east and west of the building and along the access road. The grass cover is not complete, as there are small patches of exposed soil and there is very little grass cover on the northern side of the former mill building.

The site history is summarized in the table below [1].

The population potentially exposed consists of current and former residents of the 21-unit condominium building. Approximately 80 people live in the complex. Twenty of these residents may

Date(s) Facility Name Facility Type Operations
From 1835 to 1849 Phelps Manufacturing Company. wool mill unspecified
From 1849 to February 23, 1954 Broad Brook Company wool mill and manufacturing facility carding, dressing, carbonizing, dyeing, napping, picking, scouring, shearing, and spinning.
February 23, 1954 to 1967 Hamilton Standard Division of United Technologies Corporation printed circuit board production assembly, chemical etching, electroplating, photographic development, potting, soldering, and testing.
February 23, 1954 to 1967 Hamilton Standard Division of United Technologies Corporation Ancillary Operations

- Coil winding for low-voltage transformers
-Machine shop
-Parts cleaners containing chlorinated solvents
-Spray painting
-Boiler house for steam
-Water treatment plant

1968 to 1974 Hamilton Standard Division of United Technologies Corporation boron filament manufacturing unspecified
1974 to 1977

Composite Material, Inc. (subsidiary of Alcoa) operations purchased from Hamilton Standard

boron filament manufacturing unspecified
January 31, 1977 to January 22, 1986 Broad Brook Center, Inc., James R. Testa, John Bartus, and Broad Brook Center Associates Site owners with new tenants -AVCO (formerly Composite Technologies) shipped hazardous waste containing: activated carbon, flammable liquids, freon, mercury, methyl ethyl ketone, paint liquids, sodium hydroxide, and waste oil.
-Light industry
January 22, 1986 to present Connecticut Building Corporation Fire May 22, 1986, destroyed most buildings -Residential condominiums
-Commerical strip mall

be young children (under age 6). This corresponds to, on average, two adults, one older child and one younger child per condominium unit. The population includes units that are rented, as well as owner occupied units.

As a result of past operations on this site, there are numerous areas of contamination surrounding the former mill condominium building. These historic sources include above ground fuel oil storage tanks, a manufactured gas plant, cleaning solvents, plating solutions containing heavy metals, and a former coal storage area. There is the potential that ash wastes generated from the manufactured gas plant were disposed throughout the site.

On June 19, 1998, the CT DPH reviewed an investigation of site contaminants [2]. That review was conducted to determine what immediate public health risks may be present for residents currently living in the former mill condominium building. The review recommended that the contaminated soils be remediated, and residents be relocated prior to initiating any large scale remedial activities. The CT DPH also recommended that children not play on the grounds of the condominium complex based primarily on surface soil results showing elevated concentrations of carcinogenic polynuclear aromatic hydrocarbons (PAHs). After that report was issued, the unit owners were given the option to have their properties purchased by the state of CT. However, an agreement acceptable by all parties has not been reached. Unit owners or their tenants are still living at the condominiums and surface soil contamination remains.

The CT DEP has asked the U.S. EPA to take the lead at this site. The EPA has developed a list of hazardous waste sites throughout the country that meet eligibility requirements to obtain federal funding to assist investigation and cleanup under the Superfund program. This list is known as the National Priorities List (NPL). The EPA is evaluating this site to determine whether the site conditions meet the criteria for an NPL nomination. This site is also currently being assessed by the EPA's Emergency Removal Program to determine which if any short-term actions need to be implemented to address threats of an immediate nature.

This health consultation was prepared because the potential for residents to be exposed to soil contaminants continues, and it represents the first effort to summarize all surface soil data collected at this site. It is intended to inform the CT DEP and others regarding health risks for on-site residents.


AVAILABLE DATA AND INFORMATION

Surface soil samples were collected by Loureiro Engineering Associates between 1994 and 1998 and separately by CT DEP between 1996 and April 1998, and analyzed for either semi-volatile organic compounds (SVOCs), metals, or both. The SVOCs which will be the focus of this report are the carcinogenic PAHs found on-site: benz(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, and indeno(1,2,3-c,d)pyrene. Arsenic is also a focus of this report because it was found at concentrations above the ATSDR health comparison value and due to its potential carcinogenic effects. For the most part, other semi-volatile compounds and metals detected in surface soil are considered to be non-carcinogenic by the oral route of exposure. A screen of the data indicated that non-cancer risks would not be substantial and are not a current focus. Given that the purpose of this assessment is to characterize the most significant potential risks to current residents, these additional analytes are not a focus of this report. The total list of compounds analyzed for in soil can be found in Appendix A.

All soil samples described in this assessment were obtained from depths that contained surface soil, with most samples from a depth of 0-3" and sample collection beginning just below the vegetative root zone. In a few cases, samples of 0-4" or 0-6" depth were taken. Data from these samples were combined with the 0-3" samples for a combined 0-6" dataset (N=52 site-wide). This dataset was used to derive dose estimates described in the public health implications section below.

An additional dataset comprises samples that include topsoil but also deeper levels down to 24" (N=42 site-wide). A summary of this 0-24" dataset in included in the Appendix. The depths of these samples make them less representative for assessing direct contact under current use conditions. However, these data were still analyzed because they point out locations of greater contamination, included in this assessment, or where more surficial sampling is needed. A comparison of the 0-6" dataset (Tables 1 and 2) with the 0-24" dataset (Appendix Tables B.3 and B.4 suggests that for carcinogenic PAHs, the 0-6" samples contain greater concentrations. This may be a chance observation given that the vertical gradient of contamination across the 0-24" soil horizon was not specifically evaluated at most locations. Other information such as site history and results of even deeper soil sampling suggest that there is extensive PAH contamination in such deeper layers. Thus, PAH contamination is not unique to the topmost soil layers but can be expected to occur at various depths. Regardless of whether a contaminant gradient exists with depth, the 0-6 inch data are most useful because it represents the soil horizon most accessible to site residents and is a sufficiently large database (N=52 site wide; N=22 near the condominium building) to be able to stand alone. This analysis suggests that the 0-6" PAH dataset provides a reasonable representation of the degree of surficial contamination. The broad, somewhat random distribution of PAHs in surface soils is consistent with site history in which manufactured gas plant wastes may have been incorporated into soils across the site. While a merger of the 0-24" data with the 0-6" data would decrease the variability in the PAH data due to having a larger number of samples (see Appendix B), it creates lower mean and 95 percent Upper Confidence Limit (UCL) concentrations which would underestimate the risks presented by the topmost soil layer.

The opposite trend is apparent for arsenic. On average, the 0-24" samples have approximately four times more arsenic than the 0-6" samples. This finding is consistent with sampling results at different depths at single locations conducted in the south end of the site. This portion of the site is more heavily contaminated with arsenic. Sampling at depth in this area showed that arsenic exceedences were restricted to subsurface soil. Use of the 0-6" sampling data for arsenic does not include these more contaminated samples, but this is appropriate for evaluating direct contact under current site conditions.

The following tables are divided according to whether samples are from the immediate proximity of the former mill condominium building (primarily grassed areas although samples north of the building did not have grass cover) or are from the primarily non-grassed areas that begin approximately 200 feet to the south and west of the building ("out areas"). The site map (Figure 1) shows the boundary between "near building" vs. "out area". This division is being used because children and other residents are more likely to utilize the well-maintained areas immediately surrounding the building on a regular basis as compared to the out areas, which in many places are overgrown with brush. The exposure and toxicological evaluations were conducted based upon two scenarios: exposure to contaminants in surface soil site-wide or to contaminants present in soils near the condominium building only.

The following soil contamination tables are presented: Table 1 - carcinogenic PAHs near condominium building; Table 2 - arsenic near condominium building; Table 3 - carcinogenic PAHs site-wide; Table 4 - arsenic site-wide. The tables also present the compound specific comparison values that represent risk-based soil screening values from ATSDR or EPA.

Table 1.

Carcinogenic PAHs at 0-6" Depth Near Condominium Building on Former Mill Property (N=22)
Contaminant Concentration Minimum Range (ppb) Maximum Comparison ppb Value Source

CT DEP
Residential RSRs (ppb)

benz(a)anthracene 100* 52,000 900 EPA SSL 1,000
benzo(a)pyrene 100* 45,000 100 CREG 1,000
benzo(b)fluoranthene 100* 41,000 900 EPA SSL 1,000
benzo(k)fluoranthene 100* 32,000 9,000 EPA SSL 8,400
Chrysene 100* 52,000 90,000 EPA SSL none
dibenz(a,h)anthracene 35 12,000 90 EPA SSL none
indeno(1,2,3,-c,d)pyrene 100* 24,000 900 EPA SSL none

* These values were listed as not detected, and were set to the detection limit of 100 ppb.
CREG Cancer Risk Evaluation Guide - ATSDR soil screening risk-based conc. to prevent cancer effects from direct soil exposure.
EPA SSL EPA Soil Screening Level - EPA Office of Solid Waste risk-based concentrations to protect against direct exposure.
ppb Parts per billion
RSR CT DEP Remediation Standard Regulation for direct soil exposure


Table 1b.

Statistical Evaluation of Carcinogenic PAHs at 0-6" Depth Near Condominium Building
Contaminant Mean (ppb) Standard Deviation Upper 95% Confidence Limit
of the arithmetric mean (ppb)
benz(a)anthracene 5,389 13,003 9,949
benzo(a)pyrene 5,391 12,638 9,824
benzo(b)fluoranthene 4,832 11,135 8,737
benzo(k)fluoranthene 3,618 8,795 6,703
Chrysene 5,617 13,625 10,395
Dibenz(a,h)anthracene 1,424 3,307 2,584
Indeno(1,2,3,-c,d)pyrene 2,673 6,492 4,950


Table 2.

Arsenic Concentrations at 0-6" Depth Near Condominium Building
Contaminant Concentration Minimum Range (ppb) Maximum Comparison ppb Value Source CT DEP
Residential RSR (ppb)
Arsenic 620 5,200 500 CREG 10,000


Table 2b.

Statistical Evaluation of Arsenic Concentrations at 0-6" Depth Near Condominium Building
Contaminant Mean (ppb) Standard Deviation Upper 95% Confidence Limit
of the arithmetric mean
Arsenic 1,787 1,279 2,000


Table 3.

Carcinogenic PAHs at 0-6" Depth Collected Site-Wide on Former Mill Property (N=52)
Contaminant Concentration Minimum Range (ppb) Maximum Comparison ppb Value Source CT DEP
Residential RSRs (ppb)
benz(a)anthracene 100* 440,000 900 EPA SSL 1,000
benzo(a)pyrene 49 400,000 100 CREG 1,000
benzo(b)fluoranthene 35 370,000 900 EPA SSL 1,000
benzo(k)fluoranthene 100* 300,000 9,000 EPA SSL 8,400
Chrysene 100* 440,000 90,000 EPA SSL none
Dibenz(a,h)anthracene 35 54,000 90 EPA SSL none
indeno(1,2,3,-c,d)pyrene 100* 180,000 900 EPA SSL none


Table 3b.

Statistical Evaluation of Carcinogenic PAHs at 0-6" Depth Collected Site-Wide
Contaminant Mean (ppb) Standard Deviation Upper 95% Confidence Limit
of the arithmetric mean (ppb)
benz(a)anthracene 11,697 61,206 25,659
benzo(a)pyrene 10,963 55,683 23,665
benzo(b)fluoranthene 10,082 51,456 21,820
benzo(k)fluoranthene 7,944 41,719 17,461
Chrysene 11,862 61,236 25,831
Dibenz(a,h)anthracene 1,906 7,696 3,662
indeno(1,2,3,-c,d)pyrene 5,159 25,118 10,889


Table 4.

Arsenic Concentrations at 0-6" Depth Collected Site-Wide on Former Mill Property (N=52)
Contaminant Concentration Minimum Range (ppb) Maximum Comparison ppb Value Source CT DEP
Residential RSR (ppb)
Arsenic 620 3,900 500 CREG 10,000

Table 4b.

Statistical Evaluation of Arsenic Concentrations at 0-6" Collected Site
Contaminant Mean (ppb) Standard Deviation Upper 95% Confidence Limit
of the arithmetric mean
Arsenic 3,670 6,250 5,000


DISCUSSION

Exposure Assessment - Child and Adult

Surface soil contamination at this site exists immediately adjacent to residential buildings as well as in other locations away from the dwellings. The exposure potential exists due to the presence of a grassed area in front of the condominium building, which is attractive and has the potential to be used by children and adults for much of the year. The grass cover is not complete in that there are small patches of exposed soil and there is very little grass cover on the northern side of the former mill building. Additionally, patches of bare soil exist sporadically throughout the entire site. A zone of potentially greater surficial contamination is the bank and sediments of the Broad Brook which runs just north and then also to the west of the condominium building.

In order to assess the public health risks posed by exposure to surface soil at this site, the CT DPH developed several exposure assumptions. These include such factors as frequency of site access, soil ingestion rates for both summer and winter, dermal exposure factors, and duration of exposure. These exposure factors are summarized in the table below and were used in all assessments of human health risk posed by skin contact and incidental ingestion of contaminants in the 0-6" soil layer.

Table 5.

Exposure Assessment Parameters, Millbrook Condominiums Site, East Windsor, CT
Factor Child Basis Adult Basis
Body weight 15 kg Standard default for 0-6 year old group 70 kg Standard default
Frequency of dermal exposure (summer) 30 days x 5 months Daily contact with soil over significant portion of body during normal play activities. 40 events per year Twice a week extensive contact with soil during the 5 warmest months.
Frequency of dermal exposure (winter) 30 days x 7 months Daily contact with soil over small portion of body during cold months. Some dermal contact indoors from soil incorporated into house dust. none  
Frequency for Soil Ingestion (warm weather) 30 days x 5 months Daily contact with soil which may be ingested during normal play activities. 40 events per year Twice a week extensive contact with soil during the 5 warmest months.
Frequency for Soil Ingestion (cold weather) 30 days x 7 months Daily contact with soil outdoors or in house dust which may be ingested. 325 days (365-40 warm days) Expect limited ingestion of soil or house dust on daily basis in cold weather and days where soil contact not extensive.
Incidental soil ingestion rates (warm weather) 200 mg per day Default, may be overestimate if good grass cover, but some soil exposure still possible near mill building - around plantings; soil more exposed in other parts of site. 100 mg per day Default, assuming adults using grounds for dog walking, light recreational activities but not digging or gardening.
Incidental soil ingestion rates (cold weather) 200 mg per day Daily contact with soil outdoors or in house dust which may be ingested. 20 mg per day Minimal ingestion of soil or house dust on daily basis.
Exposed Surface Area (warm weather) 2800 cm2 Head, hands, forearms, lower legs, feet for warm month exposures. Same as most recent EPA default for children (2800 cm2). 5230 cm2 Head, hands, forearms, lower legs; similar to most recent EPA default (5700 cm2).
Exposed Surface Area (cold weather) 919 cm2 Hands and feet for cold month exposures. Exposure 1/3 that in warm months. none  
Exposure duration 6 yr. For period covering 0-6 years of life. 24 yr. 90th percentile for residence at one location minus years of child residence.
PAH Dermal absorption factor 13%

Default for PAHs supported by BaP data.

13% Default for PAHs supported by BaP data.
Arsenic dermal absorption factor 3% Default for arsenic. 3% Default for arsenic.
Soil Adherence factor 0.2 mg per cm2 Most recent default for children's value from EPA dermal exposure document. 0.07 mg per cm2 Upper end of range for adults in EPA document, but still below child value.

Exposure calculations did not utilize the maximum detected contaminant, as this was in an isolated relatively inaccessible location, and did not represent the distribution of contaminants throughout the site. Therefore, toxicological evaluations utilized a statistical upper bound estimate of the central tendency concentration in surface soil. This exposure point concentration is known as the upper 95th percent confidence limit of the arithmetric mean [4], a value which takes into account the variability in the data set to ensure that the average exposure is not underestimated.

On the basis of these exposure assumptions, a determination of human health implications of surface soil contamination has been developed. Adults and children are separately evaluated for short-term exposures of 1 month and 1 year, and these two age groups are combined for calculation of lifetime public health implication (adult, 24 years of exposure added to child, 6 years of exposure). The inclusion of values less than one year was incorporated to determine whether an acute public health hazard exists. These estimates are presented in the tables below.

The following section utilized a risk assessment technique for evaluation of the risks posed by the surface soil contamination. This technique was used to determine the potential likelihood of adverse health effects. The risk determination also utilized three exposure durations, one month, one year, and lifetime. These were selected to determine whether there were immediate or chronic risks.

Evaluation of Risk Assessment Results

Toxicity assessment for PAHs utilizes the cancer potency factor for benzo(a)pyrene (B(a)P) listed on EPA's Integrated Risk Information System (IRIS) (7.3/mg/kg-day) and toxicity equivalency factors that relate cancer potency across PAHs based upon differences between chemicals found in skin tumor bioassays [3]. Tables 6a and 6b present near condominium and site-wide PAH concentrations in 0-6" surface soil weighted using the toxicological equivalent factor (TEF) approach and assuming additivity for PAH carcinogenicity. These tables also present the arsenic 0-6" near condominium building and site-wide soil results; the arsenic cancer slope factor used in risk calculations is the current value from EPA's IRIS file (1.5/mg/kg-day).

Table 6a.

Concentration of Carcinogens - Near Former Mill Buliding, 0-6" Depth (PAH Samples N=22 and Arsenic Samples N=19)
Chemical Avg. Conc. (ug/kg) 95% UCL on Avg TEF Relative to
B(a)P
Weighted Average Weighted 95% UCL
benz(a)anthracene 5,389 9,949 0.145 781 1,443
benzo(a)pyrene 5,391 9,824 1 5,391 9,824
benzo(b)fluoranthene 4,832 8,737 0.167 807 1,459
benzo(k)fluoranthene 3,618 6,703 0.02 72 134
chrysene 5,617 10,395 0.0044 25 46
dibenz(a,h)anthracene 1,424 2,584 1.11 1,581 2,868
indeno(1,2,3,-c,d)pyrene 2,673 4,950 0.055 147 272
Total benzo(a)pyrene Equivalents 8,804 16,046
Arsenic (mg/kg) 1.8 2.0 not applicable not applicable not applicable


Table 6b.

Concentration of Carcinogens - Site Wide, 0-6" Depth (PAH and Arsenic Samples N=52)
Chemical Avg. Conc. (ug/kg) 95% UCL on Avg TEF Relative to
B(a)P
Weighted Average Weighted 95% UCL
benz(a)anthracene 11,697 25,659 0.145 1696 3,721
benzo(a)pyrene 10,963 23,665 1 10,963 23,665
benzo(b)fluoranthene 10,082 21,820 0.167 1,684 3,644
benzo(k)fluoranthene 7,944 17,461 0.02 159 349
chrysene 11,862 25,831 0.0044 52 114
dibenz(a,h)anthracene 1,906 3,662 1.11 2,116 4,065
indeno(1,2,3,-c,d)pyrene 5,159 10,889 0.055 284 599
Total benzo(a)pyrene Equivalents 16,954 36,157
Arsenic (mg/kg) 3.7 5.0 not applicable not applicable not applicable

Cancer Assessment

Cancer assessments for the near condominium building and site-wide scenarios are shown in Tables 7 and 8 for PAHs and Tables 9 and 10 for arsenic. A cancer assessment is a computation based on contaminant levels actually detected, postulated daily ingestion amounts, dermal contact, and a cancer slope factor generated by the U.S. EPA. These cancer assessements are estimated based upon the exposure dose for contaminants present in the 0-6" surface soil layer using the 95% UCL on the arithmetic average concentration in that layer. This exposure dose is then multiplied by the cancer slope factor for that specific carcinogen and then pro-rated for less than lifetime exposure, recognizing that cancer slope factors are relevant to lifetime (70 years) exposure. Cancer risk estimations were calculated on a monthly or yearly basis for young children and separately for adults, with lifetime risks calculated by adding across the 6 years of childhood exposure and 24 years of adult exposure assumed in the residential scenario.


Table 7.

Cancer Risk Estimates from PAHs in 0-6" Soil Samples Collected Near the Condominium Building
Group 1 month 1 year Lifetime Risk
Child 2.2 excess cancers in 1,000,000 people exposed (2.2 x 10-6) 2.7 in 100,000 (2.7 x 10-5) ----a
Combined ----a ----a 1.8 in 10,000
(1.8 x 10-4)
Adult 6.8 in 100,000,000 (6.8 x 10-8) 8.1 in 10,000,000
(8.1 x 10-7)
----a

a Not relevant to calculate risks since other boxes better describe risk for these cases.


Table 8.

Cancer Risk Estimates from PAHs in 0-6" Samples Collected Site-Wide
Group 1 month 1 year Lifetime Risk
Child 5.1 in 1,000,000 (5.1 x 10-6) 6.1 in 100,000 (6.1 x 10-5) ----a
Combined ----a ----a 4.1 in 10,000 (4.1 x 10-4)
Adult 1.5 in 10,000,000 (1.5 x 10-7) 1.8 in 1,000,000 (1.8 x 10-6) ----a


Table 9.

Cancer Risk Estimates from Arsenic in 0-6" Soils Collected Near the Condominium Building
Group 1 month 1 year Lifetime Risk
Child 5.3 in 100,000,000 (5.3 x 10-8) 6.4 in 10,000,000 (6.4 x 10-7) ----a
Combined ----a ----a 4.3 in 1,000,000 (4.3 x 10-6)
Adult 1.7 in 1,000,000,000 (1.7 x 10-9) 2 in 100,000,000 (2.0 x 10-8) ----a


Table 10.

Cancer Risk Estimates from Arsenic in 0-6" Soil Samples Collected Site-Wide
Group 1 month 1 year Lifetime Risk
Child 3.5 in 10,000,000 (3.5 x 10-7) 4.1 in 1,000,000 (4.1 x 10-6) ----a
Combined ----a ----a 2.8 in 100,000 (2.8 x 10-5)
Adult 1 in 100,000,000 (1 x 10-8) 1.3 in 10,000,000 (1.3 x 10-7) ----a
 

This report indicates that PAH concentrations in the topmost soil layer represent a Public Health Hazard. The concentrations are elevated relative to ATSDR CREGs, CT DEP's Remediation Standard Regulations, and relative to EPA soil screening levels. Lifetime cancer estimates calculated for PAHs in the near condominium scenario are estimated to be 2 excess cancers per 10,000 people exposed (sometimes written as 2 x 10-4), which is outside of EPA's acceptable risk range for Superfund sites of 1 excess cancer in 10,000 people similarly exposed (1 x 10-4). These risks are driven by the estimates for children, which would accumulate 90% of the exposure dose for this 30 year exposure scenario (6 years as children, 24 years as adults). Cancer risks are also above a level of one excess cancer in one million people similarly exposed. This is sometimes referred to as a de minimus level. This level was exceeded on a 1 year and 1 month basis for children but not for adults (Tables 7 and 8). The 1 year risks for children are 3 contaminants (risk added across chemicals) at sites regulated by CT's RSRs. Further, the risks just described are approximately two-fold higher if exposure occurs to soil located both "near building" and in areas farther from the buildings but within 1/4 mile ("out areas"). The out areas are somewhat more concentrated with both PAHs and arsenic.

The grassed area in front of the condominium building is conducive to recreational activities and has the potential to be used by children and adults for much of the year. This grass cover extends from the building to the south and also occurs in strips to the east and west of the building and along the access road. It affords some protection from direct contact with soil contaminants lying just beneath the root zone and also from tracking contaminants into the home. However, the grass cover is not complete in that there are small patches of exposed soil and there is very little grass cover on the northern side of the former mill building. Given that a trail leads to a scenic spot along the Broad Brook just north of the building, a greater potential for surface soil exposure exists in this area.

The "out areas" are still close to the residential building (within 1/4 mile) with many areas covered by weeds and brush rather than grass. This vegetation helps to keep soil contaminants just beneath the surface but is no assurance that contact with contaminated soil will not occur. In fact, the patches of bare soil exist sporadically in these out areas. However, the dense brush that covers parts of the site will make access more difficult, especially for young children and during the summer months. Included in this zone of potentially greater surficial contamination is the bank and sediments of the Broad Brook which runs just north and then also to the west of the condominium building.

Risks were calculated for one month, one year, and lifetime (30 years) exposures, but it is recognized that some residents could have lived in the condominium building for the past 10 years. Such residents would be expected to have risk levels between the one year and 30 year estimates, although the past exposures of such residents are somewhat mitigated by the existence of surface barriers (grass or brush cover) over this time. While these surface barriers may have been protective in the past, they are not a guarantee against exposure in the near or distant future.

Arsenic was detected in surface soil across the site with concentrations elevated above the RSR level of 10 ppm in the out areas but only with depth (i.e., not in surface soil) and not in soils near the condominium building. Arsenic in surface soil still creates an elevated lifetime cancer risk estimate of 3 in 100,000 (3 x 10-5) in areas away from the condominium building. This risk is below that for the carcinogenic PAHs in surface soil and does not materially affect the total cancer risk. Arsenic is detected in the environment, and is sometimes referred to as background levels. The mean background level of arsenic in soils of the eastern region of the U.S. is about 5 ppm. Consequently, the concentrations detected maximally in the surface soil seem to be from a source other than natural background levels.

Public Health Implications

The lifetime cancer risks calculated for children and adults were based on worst case scenarios. The standardized cancer assessment approach for evaluating hazardous waste sites involves a number of assumptions that lead to an upper bound calculation of risk. For example, the default assumption that young children will ingest 200 mg of soil per day throughout the year was used even though this is unlikely to occur on a daily basis, especially in winter months. Further, the existing grass cover makes extensive contact with soil less likely.

In addition to the uncertainties regarding exposure assessment, this approach involves a number of uncertainties, especially when extrapolating from high dose animal studies to the much lower exposures people may receive due to PAHs in soil. For example, calculations for this site indicate worst case exposure levels that are approximately 40,000 times below the lowest dose shown to produce cancer in animals [3]. This large gap between animal effect level and the human exposure level makes the risk estimates for this site more uncertain than if they were based upon human epidemiologic studies. While epidemiologic evidence (inhalation and dermal studies) for carcinogenic PAHs support a link between exposure and cancer risk in humans, these studies do not provide quantitative data from which the public health implications of exposure could be refined.

Overall, the exposure and cancer risks are theoretical estimates that are likely to overestimate actual exposures and risks. Nevertheless, these calculations are useful in assessing the relative degree of hazard posed by the surface soil contaminants. These contaminants represent an avoidable source of carcinogenic PAHs. These PAHs are ubiquitous in the environment (air pollution, contaminated soils, cigarette smoke, char-broiled foods) and are associated with genetic changes (DNA adducts) and elevated cancer risks from such background sources. The potential for PAH exposure from this site is a theoretical addition to this background risk. For example, daily ingestion of 200 mg of near condominium surface soil at the carcinogenic PAH (as determined by total BaP equivalents) concentration of 16 ppm (Table 6a) yields 3.2 ug/day exposure to children. The estimated exposure to carcinogenic PAHs from smoking one pack of cigarettes a day is 2-5 ug [3]. While actual exposures from this site are unlikely to be as high as that calculated, this assessment shows that exposures of health concern are at least a theoretical possibility and that prudent measures should be taken to ensure that such exposures to do not occur in the future.

Community Health Concerns

The CT DPH assembles health concerns from people residing in the area of hazardous waste sites during the development of public health assessment documents. During November of 1997, the CT DPH met with the representatives of the Millbrook Condominium Association to discuss health concerns regarding the contamination at this site. This was an occasion for community representatives to express their concerns. The following sections are a compilation of questions and comments that CT DPH received during that meeting.

Public Concern

Condominium association representatives have expressed concerns with regard to the indoor air quality in the former mill building [5].

Response to public concern:
There are two potential pathways for indoor air contamination. The first is from VOC contamination below or surrounding the building. The second is from residual contamination remaining on indoor building materials. Initial soil gas results in the immediate vicinity of the condominium building did not identify a significant source of VOCs, which could impact the indoor air quality. The US EPA is following this up with additional soil gas surveys and is evaluating the need for additional monitoring.

Public Concern

Concerns were also raised by the condominium association representatives regarding various medical conditions reported by residents in the former mill building (one breast cancer, one thyroid cancer), and townhouses (one birth defect, several miscarriages). In addition, one case of childhood leukemia was reported to occur in a property adjacent to the townhouses [5].

Responses to public concern:
The illnesses described are characteristically considered as distinct and isolated medical conditions not linked by pathology or cause. Since cancer develops after a long latency period, it is unlikely that the reported tumors for adults could have resulted from exposures received while residing in these condominiums. The American Cancer society has estimated that nearly 8 million Americans alive today have a history of cancer [6]. The lifetime risk for men developing cancer is 1 in 2; the value for women is 1 in 3 [6]. Disorders such as cancer and miscarriages are common in the general population. They are associated with numerous factors (lifestyle, genetics, and environment). In summary, these issues combine to diminish the likelihood of a link between the disorders and contaminants present on-site. Moreover, the contaminants associated with some potential cancer risks have cancer sites that vary from those expressed by the residents [5].


CONCLUSIONS

The surface soil is contaminated with PAHs at concentrations representing a Public Health Hazard to residents who may be exposed. Although the levels of contaminants do not present an acute or immediate health threat, they present an ongoing threat of exposure to carcinogens. Therefore, steps should be taken in the near term to ensure that exposure to surface soil contaminants are insignificant. These determinations were based on theoretical estimates of developing cancer, and are likely to overestimate actual exposures and risks. Although the likelihood of a resident becoming ill as a result of exposure to the contaminated soil is low, these contaminants represent an avoidable source of carcinogenic PAHs.

It is important that children do not play in on-site soils (near the building and out areas) and that there is no disturbance or degradation of the intact grass layer where it exists. Further, the site should be remediated in the near future. These measures and others described below will help ensure that the projected risks do not actually occur.


RECOMMENDATIONS TO CEASE AND REDUCE EXPOSURES

Short-term Recommendations

  1. To ensure that contact with soil contaminants is minimized, parents should prevent children from playing outdoors on-site. Further, residents should make sure that pets do not dig in on-site soils, and that in general, grass cover or other vegetation is not disturbed.


  2. Warnings should be posted more visibly around the condominium building and in surrounding fields. Two small signs currently exist (one at the far end of the access road; one near the condominium building), but these do not appear to be sufficient to provide adequate warning. For example, there are no warning signs on the north side of the building, near the former boiler building, in any of the ungrassed fields, or along the Broad Brook. All of these locations should be clearly posted with the above precautions.

  3. Grass cover should be actively maintained using good lawn management practices (fertilizer usage, re-seeding bare areas).

  4. If the grass cover is disturbed or degraded, physical barriers (e.g., fencing) should be considered to make sure direct contact is avoided.

Long-term Recommendation

  1. Contaminated surface and subsurface soils should be remediated in a timely manner to reduce the long-term health risks posed by the site. The remediation should be conducted in a manner that protects public health of the residents.

PUBLIC HEALTH ACTION PLAN

The Public Health Action Plan for the Millbrook Condominiums site contains a description of the actions completed and to be taken by the Agency for Toxic Substances and Disease Registry, the Connecticut Department of Public Health, and the Connecticut Department of Environmental Protection. Included in this plan is a commitment on the part of the Agency for Toxic Substances and Disease Registry and the Connecticut Department of Public Health to follow up on this plan to ensure that there is implementation.

The public health actions implemented include:

  1. The Connecticut Department of Public Health and the CT DEP have advised residents of the 21-unit condominium complex that children should not play on the grounds of the former mill building property, as well as areas near the residential condominium building.

  2. The Connecticut Department of Public Health and the CT DEP have advised residents of the 21-unit condominium complex that children and adults should not engage in digging or gardening activities throughout the site and should keep their pets from disturbing the top layer of soil.

The public health actions to be implemented include:

  1. The Connecticut Department of Public Health and the CT DEP will review and summarize additional environmental sampling data.

  2. The Connecticut Department of Public Health will provide environmental health education for local public health officials, the local medical community and local citizens.

CERTIFICATION

The Health Consultation for the Assessment of Surface Soil Sampling Data at the Millbrook Condominiums site was prepared by the Connecticut Department of Public Health under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the health consultation was initiated.

Gregory V. Ulirsch
Technical Project Officer, SPS, SSAB, DHAC


The Division of Health Assessment and Consultation (DHAC), ATSDR, has reviewed this Health Consultation, and concurs with its findings.

Richard Gillig,
Chief, SSAB, DHAC, ATSDR


REFERENCES

  1. Loureiro Engineering Associates, Inc: Final Site Investigation Report: Property of Millbrook Owner's Association, Inc. Block 37 Lots 8 and 8A Tax Assessor's Map 22, East Windsor, Connecticut. May 1, 1998.

  2. Correspondence from: Mary Lou Fleissner (Director, Environmental Epidemiology and Occupational Health Division, CT DPH) to: Michael J. Harder (Director, Permitting, Enforcement & Remediation Division, PERD, CT DEP), June 19, 1998.

  3. Agency for Toxic Substances and Disease Registry, Toxicological Profile for Polycyclic Aromatic Hydrocarbons (PAHs), August 1995.

  4. U.S. Environmental Protection Agency, Risk Assessment Guidance for Superfund, Supplemental Guidance: Calculating the Concentration Term. May, 1992.

  5. Correspondence from: Gary Ginsberg (Toxicologist, Environmental Epidemiology and Occupational Health Division, CT DPH) and Brian Toal (Epidemiologist, Environmental Epidemiology and Occupational Health Division, CT DPH) to: Linda Alderman, Esq (of Alderman & Alderman), December 24, 1997.

  6. American Cancer Society (1999) Cancer Facts & Figures-1999. U.S. Department of Health and Human Services, Atlanta, Georgia. 1999.

PREPARERS OF HEALTH CONSULTATION

Gary D. Perlman, MPH
Epidemiologist
Evironmental Epidemiology and Occupational Health
Connecticut Department of Public Health

Gary Ginsberg, Ph.D.
Toxicologist
Evironmental Epidemiology and Occupational Health
Connecticut Department of Public Health

ATSDR Regional Representative:

William Sweet
EPA Region 1

ATSDR Technical Project Officer:

Greg Ulirsch
Superfund Site Assessment Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry


APPENDIX A:

LIST OF CHEMICALS ANALYZED
Chemical
AcenaphtheneDi-n-octyl PhthalateMethyl-2-pentanone,4-
AcenaphthyleneDibenzo[a,h]acridineMethyl-tert-butyl Ether
AcetoneDibenzo[a,h]anthraceneMethylcholanthrene,3-
AcroleinDibenzo[a,j]acridineMethylene Chloride
AcrylonitrileDibenzo[c,g]carbazole,7H-Naphthalene
AnthraceneDibromo-3-chloropropane,1,2-Nickel
ArsenicDibromomethaneNitrate (as N)
BariumDichlorobenzene,1,2-Nitrobenzene
BenzeneDichlorobenzene,1,3-Nitrophenol,2-
BenzidineDichlorobenzene,1,4-Nitrophenol,4-
Benzo[a]anthraceneDichlorobenzidine,3,3'-Nitroso-n-propylamine,n-
Benzo[a]pyreneDichlorobromomethaneNitrosodimethylamine,n-
Benzo[b]fluorantheneDichlorodifluoromethaneNitrosodiphenylamine,n-
Benzo[ghi]peryleneDichloroethane,1,1-PCB 1016
Benzo[j]fluorantheneDichloroethane,1,2-PCB 1221
Benzo[k]fluorantheneDichloroethylene,1,1-PCB 1232
Benzyl ChlorideDichloroethylene,1,2-cis-PCB 1242
Bis(2-chloroethoxy)methaneDichloroethylene,1,2-trans-PCB 1248
Bis(2-chloroethyl)etherDichlorophenol,2,4-PCB 1254
Bis(2-chloroisopropyl)etherDichloropropane,1,2-PCB 1260
Bis(2-ethylhexyl)phthalateDichloropropylene,1,3-cis-PCB, Total
BoronDichloropropylene,1,3-trans-Pentachlorophenol
BromobenzeneDiesel, TFHPhenanthrene
BromoformDiethyl PhthalatePhenol
Bromophenyl Phenyl Ether,4-Dimethyl PhthalatePotassium
Butyl Benzyl PhthalateDimethylphenol,2,4-Propane),2,2'-oxybis(2-chloro-
Butylbenzene,n-Dinitro-o-cresol,4,6-Propylbenzene,n-
CadmiumDinitrophenol,2,4-Pyrene
CalciumDinitrotoluene,2,4-Rhodium
Carbon DisulfideDinitrotoluene,2,6-Selenium
Carbon TetrachlorideDiphenylhydrazine,1,2-Silver
Chloro-m-cresol,p-EthylbenzeneSodium
ChloroacetaldehydeEthylene DibromideStyrene
ChlorobenzeneFluorantheneSulfate
ChlorodibromomethaneFluoreneTetrachloroethane,1,1,1,2-
ChloroethaneFluorideTetrachloroethane,1,1,2,2-
Chloroethyl Vinyl Ether,2-Gasoline, UnleadedTetrachloroethylene
ChloroformHexachlorobenzeneTetrahydrofuran
Chlorohexane,1-HexachlorobutadieneToluene
Chloromethyl Methyl EtherHexachlorocyclopentadieneTrichloro-1,2,2-trifluoroethane,1,1,2-
Chloronaphthalene,2-HexachloroethaneTrichlorobenzene,1,2,3-
Chlorophenol,2-Hexanone,2-Trichlorobenzene,1,2,4-
Chlorophenyl Phenyl Ether,4-Indeno(1,2,3-cd)pyreneTrichloroethane,1,1,1-
ChlorotolueneIronTrichloroethane,1,1,2-
Chlorotoluene,o-IsophoroneTrichloroethylene
Chlorotoluene,p-IsopropanolTrichloromonofluoromethane
ChromiumIsopropyltoluene,4-Trichlorophenol,2,4,6-
Chromium(VI)LeadTrichloropropane,1,2,3-
ChryseneMagnesiumTrimethylbenzene,1,2,4-
CopperManganeseTrimethylbenzene,1,3,5-
CumeneMercuryVinyl Acetate
CyanideMethyl BromideVinyl Chloride
Cyanide (Total)Methyl ChlorideXylenes (Total)
Di-n-butyl PhthalateMethyl Ethyl KetoneZinc


APPENDIX B: ADDITIONAL TABLES

Table B.1. All Depths Combined (0-6" + 0-24" samples), Site-Wide

B.1.a Range of Carcinogenic PAH Concentrations (N=94)

B.1.a

B.1.a Range of Carcinogenic PAH Concentrations (N=94)
Contaminant Concentration Range (ppb) Comparison Value CT DEP
Residential RSRs (ppb)
Minimum Maximum ppb Source
Benz(a)anthracene 100* 440,000 900 EPA SSL 1,000
Benzo(a)pyrene 49 400,000 100 CREG 1,000
Benzo(b)fluoranthene 35 370,000 900 EPA SSL 1,000
Benzo(k)fluoranthene 100* 300,000 9,000 EPA SSL 8,400
Chrysene 100* 440,000 90,000 EPA SSL none
Dibenz(a,h)anthracene 35 54,000 90 EPA SSL none
Indeno(1,2,3,-c,d)pyrene 100* 180,000 900 EPA SSL none

* These values were listed as not detected, and were set to the detection limit of 100 ppb.
CREG Cancer Risk Evaluation Guide - ATSDR soil screening risk-based conc. to prevent cancer effects from direct soil exposure.
EPA SSL EPA Soil Screening Level - EPA Office of Solid Waste risk-based concentrations to protect against direct exposure.
ppb parts per billion
RSR CT DEP Remediation Standard Regulation for direct soil exposure

B.1.b

Statistical Evaluation of Carcinogenic PAHs
Contaminant Mean (ppb) Standard deviation Upper 95% Confidence Limit of the arithmetric mean (ppb)
benz(a)anthracene 7,376 45,617 15,116
benzo(a)pyrene 6,838 41,511 13,881
benzo(b)fluoranthene 6,407 38,351 12,914
benzo(k)fluoranthene 4,916 31,088 10,190
chrysene 7,449 45,645 15,193
dibenz(a,h)anthracene 1,410 5,732 2,382
indeno(1,2,3,-c,d)pyrene 3,380 18,719 6,556

B.1.c

Range of Arsenic Concentrations (N=86)
Contaminant Concentration Range (ppb) Comparison Value CT DEP
Residential RSR (ppb)
Minimum Maximum ppb Source
arsenic 620 283,000 500 CREG 10,000

B.1.d

Statistical Evaluation of Arsenic Concentrations
Contaminant Mean (ppb) Standard deviation Upper 95% Confidence Limit of the arithmetric mean
arsenic 8,090 31,830 14,000


Table B.2. All Depths Combined (0-6" + 0-24"), Near the Condominium Building

B.2.a

Range of Carcinogenic PAH Concentrations (N=30)
Contaminant Concentration Range (ppb) Comparison Value CT DEP
Residential RSRs (ppb)
Minimum Maximum ppb Source
benz(a)anthracene 100* 52,000 900 EPA SSL 1,000
benzo(a)pyrene 100* 45,000 100 CREG 1,000
benzo(b)fluoranthene 100* 41,000 900 EPA SSL 1,000
benzo(k)fluoranthene 100* 32,000 9,000 EPA SSL 8,400
chrysene 100* 52,000 90,000 EPA SSL none
dibenz(a,h)anthracene 35 12,000 90 EPA SSL none
indeno(1,2,3,-c,d)pyrene 100* 24,000 900 EPA SSL none

B.2.b

Statistical Evaluation of Carcinogenic PAHs
Contaminant Mean (ppb) Standard deviation Upper 95% Confidence Limit of the arithmetric mean (ppb)
benz(a)anthracene 4,865 11,321 8,265
benzo(a)pyrene 4,677 10,945 7,964
benzo(b)fluoranthene 4,343 9,680 7,250
benzo(k)fluoranthene 3,145 7,588 5,424
chrysene 5,022 11,835 8,576
dibenz(a,h)anthracene 1,306 2,845 2,160
indeno(1,2,3,-c,d)pyrene 2,355 5,606 4,039

B.2.c

Range of Arsenic Concentrations (N=26)
Contaminant Concentration Range (ppb) Comparison Value CT DEP
Residential RSR (ppb)
Minimum Maximum ppb Source
arsenic 620 5,200 500 CREG 10,000

B.2.d

Statistical Evaluation of Arsenic Concentrations
Contaminant Mean (ppb) Standard deviation Upper 95% Confidence Limit of the arithmetric mean
Arsenic 1,796 1,120 2,160


Table B.3 0-24" Soil Samples, Site Wide

B.3.a

Range of Carcinogenic PAH Concentrations (N=42)
Contaminant Concentration Range (ppb) Comparison Value CT DEP
Residential RSRs (ppb)
Minimum Maximum ppb Source
benz(a)anthracene 100* 12,000 900 EPA SSL 1,000
benzo(a)pyrene 100* 10,000 100 CREG 1,000
benzo(b)fluoranthene 100* 9,700 900 EPA SSL 1,000
benzo(k)fluoranthene 100* 6,000 9,000 EPA SSL 8,400
chrysene 100* 12,000 90,000 EPA SSL none
dibenz(a,h)anthracene 100* 2,800 90 EPA SSL none
indeno(1,2,3,-c,d)pyrene 100* 5,200 900 EPA SSL none

B.3.b

Statistical Evaluation of Carcinogenic PAHs
Contaminant Mean (ppb) Standard deviation Upper 95% Confidence Limit of the arithmetric mean (ppb)
benz(a)anthracene 2,026 2,683 2,707
benzo(a)pyrene 1,730 1,902 2,213
benzo(b)fluoranthene 1,857 2,103 2,391
benzo(k)fluoranthene 1,166 1,042 1,431
chrysene 1,985 2,488 2,616
dibenz(a,h)anthracene 796 394 896
indeno(1,2,3,-c,d)pyrene 1,177 1,002 1,431

B.3.c

Range of Arsenic Concentrations (N=34)
Contaminant Concentration Range (ppb) Comparison Value CT DEP
Residential RSR (ppb)
Minimum Maximum ppb Source
arsenic 1,000 283,000 500 CREG 10,000

B.3.d

Statistical Evaluation of Arsenic Concentrations
Contaminant Mean (ppb) Standard deviation Upper 95% Confidence Limit of the arithmetric mean
arsenic 14,864 49,700 29,000


Table B.4 0-24" Soil Samples, Near Condominium Building

B.4.a

Range of Carcinogenic PAH Concentrations (N=8)
Contaminant Concentration Range (ppb) Comparison Value CT DEP
Residential RSRs (ppb)
Minimum Maximum ppb Source
benz(a)anthracene 610* 12,000 900 EPA SSL 1,000
benzo(a)pyrene 610* 10,000 100 CREG 1,000
benzo(b)fluoranthene 610* 9,700 900 EPA SSL 1,000
benzo(k)fluoranthene 610* 6,000 9,000 EPA SSL 8,400
chrysene 610* 12,000 90,000 EPA SSL none
dibenz(a,h)anthracene 610* 2,800 90 EPA SSL none
indeno(1,2,3,-c,d)pyrene 610* 5,200 900 EPA SSL none
* This detection limit was based on samples collected by LEA.

B.4.b

Statistical Evaluation of Carcinogenic PAHs
Contaminant Mean (ppb) Standard deviation Upper 95% Confidence Limit of the arithmetric mean (ppb)
benz(a)anthracene 3,424 4,530 6,059
benzo(a)pyrene 2,712 3,335 4,651
benzo(b)fluoranthene 2,999 3,660 5,127
benzo(k)fluoranthene 1,844 1,962 2,985
chrysene 3,387 4,380 5,934
dibenz(a,h)anthracene 981 739 1,411
indeno(1,2,3,-c,d)pyrene 1,480 1,602 2,412


B.4.c Range of Arsenic Concentrations (N=7)

B.4.c

Range of Arsenic Concentrations (N=7)
Contaminant Concentration Range (ppb) Comparison Value CT DEP
Residential RSR (ppb)
Minimum Maximum ppb Source
arsenic 1,000 2,590 500 CREG 10,000

B.4.d

Statistical Evaluation of Arsenic Concentrations
Contaminant Mean (ppb) Standard deviation Upper 95% Confidence Limit of the arithmetric mean
arsenic 1,820 587 2,000


Millbrook Condominium, Former Mill Property Map Includes Surface Soil Sampling Locations and Delineation of Near Building
Figure 1. Millbrook Condominium, Former Mill Property Map Includes Surface Soil Sampling Locations and Delineation of Near Building

 

 



ATTACHMENT C: SITE FACTS SHEETS

Site Fact Sheet page 1

Site Fact Sheet page 2

Site Fact Sheet page 3

Site Fact Sheet page 4


ATTACHMENT D:

LIST OF CHEMICALS ANALYZED IN SOIL
Chemical
AcenaphtheneDi-n-octyl PhthalateMethyl-2-pentanone,4-
AcenaphthyleneDibenzo[a,h]acridineMethyl-tert-butyl Ether
AcetoneDibenzo[a,h]anthraceneMethylcholanthrene,3-
AcroleinDibenzo[a,j]acridineMethylene Chloride
AcrylonitrileDibenzo[c,g]carbazole,7H-Naphthalene
AnthraceneDibromo-3-chloropropane,1,2-Nickel
ArsenicDibromomethaneNitrate (as N)
BariumDichlorobenzene,1,2-Nitrobenzene
BenzeneDichlorobenzene,1,3-Nitrophenol,2-
BenzidineDichlorobenzene,1,4-Nitrophenol,4-
Benzo[a]anthraceneDichlorobenzidine,3,3'-Nitroso-n-propylamine,n-
Benzo[a]pyreneDichlorobromomethaneNitrosodimethylamine,n-
Benzo[b]fluorantheneDichlorodifluoromethaneNitrosodiphenylamine,n-
Benzo[ghi]peryleneDichloroethane,1,1-PCB 1016
Benzo[j]fluorantheneDichloroethane,1,2-PCB 1221
Benzo[k]fluorantheneDichloroethylene,1,1-PCB 1232
Benzyl ChlorideDichloroethylene,1,2-cis-PCB 1242
Bis(2-chloroethoxy)methaneDichloroethylene,1,2-trans-PCB 1248
Bis(2-chloroethyl)etherDichlorophenol,2,4-PCB 1254
Bis(2-chloroisopropyl)etherDichloropropane,1,2-PCB 1260
Bis(2-ethylhexyl)phthalateDichloropropylene,1,3-cis-PCB, Total
BoronDichloropropylene,1,3-trans-Pentachlorophenol
BromobenzeneDiesel, TFHPhenanthrene
BromoformDiethyl PhthalatePhenol
Bromophenyl Phenyl Ether,4-Dimethyl PhthalatePotassium
Butyl Benzyl PhthalateDimethylphenol,2,4-Propane),2,2'-oxybis(2-chloro-
Butylbenzene,n-Dinitro-o-cresol,4,6-Propylbenzene,n-
CadmiumDinitrophenol,2,4-Pyrene
CalciumDinitrotoluene,2,4-Rhodium
Carbon DisulfideDinitrotoluene,2,6-Selenium
Carbon TetrachlorideDiphenylhydrazine,1,2-Silver
Chloro-m-cresol,p-EthylbenzeneSodium
ChloroacetaldehydeEthylene DibromideStyrene
ChlorobenzeneFluorantheneSulfate
ChlorodibromomethaneFluoreneTetrachloroethane,1,1,1,2-
ChloroethaneFluorideTetrachloroethane,1,1,2,2-
Chloroethyl Vinyl Ether,2-Gasoline, UnleadedTetrachloroethylene
ChloroformHexachlorobenzeneTetrahydrofuran
Chlorohexane,1-HexachlorobutadieneToluene
Chloromethyl Methyl EtherHexachlorocyclopentadieneTrichloro-1,2,2-trifluoroethane,1,1,2-
Chloronaphthalene,2-HexachloroethaneTrichlorobenzene,1,2,3-
Chlorophenol,2-Hexanone,2-Trichlorobenzene,1,2,4-
Chlorophenyl Phenyl Ether,4-Indeno(1,2,3-cd)pyreneTrichloroethane,1,1,1-
ChlorotolueneIronTrichloroethane,1,1,2-
Chlorotoluene,o-IsophoroneTrichloroethylene
Chlorotoluene,p-IsopropanolTrichloromonofluoromethane
ChromiumIsopropyltoluene,4-Trichlorophenol,2,4,6-
Chromium(VI)LeadTrichloropropane,1,2,3-
ChryseneMagnesiumTrimethylbenzene,1,2,4-
CopperManganeseTrimethylbenzene,1,3,5-
CumeneMercuryVinyl Acetate
CyanideMethyl BromideVinyl Chloride
Cyanide (Total)Methyl ChlorideXylenes (Total)
Di-n-butyl PhthalateMethyl Ethyl KetoneZinc


Table of Contents

 
 
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