PUBLIC HEALTH ASSESSMENT
LAUREL PARK, INC.
NAUGATUCK, NEW HAVEN COUNTY, CONNECTICUT
- Based on the information reviewed, ATSDR has concluded that this site is an indeterminant public health hazard. Past exposures may have occurred principally to contaminants in air from uncontrolled fires, the open burning of wastes, and other landfill activities. However, there is no analytical data to document any exposures to contaminants in air and thus adverse health effects cannot be assessed.
- Although all residents with private wells were provided with bottled water, those residents with contaminated wells received inhalation exposures while breathing indoor air during showering or bathing. It is unlikely that adverse health effects would have occurred at the levels found.
- There are four private wells in the area which could potentially be impacted by contaminants migrating through groundwater off-site. The lack of data on these wells from 1987 to present prevent firm conclusions about the quality of water in these wells at the present time.
- Residents potentially received inhalation and dermal exposures to VOCs from the migration of leachate contamination in surface water. Andrews School children potentially received inhalation exposures to VOCs from the stream that flowed adjacent to the school.
- Residents, landfill workers and truck drivers may have received inhalation and potentially ingestion exposures to contaminants in soil and road dust in the past when the landfill was operating.
- Residents involved in recreational activities on-site can potentially receive inhalation, skin and ingestion exposures to VOCs, PAHs and metals from leachate seeps and contaminated soils.
As noted in the Pathway Analyses section past exposures to VOCs and metals may have occurred due to contaminated private drinking water wells. Because quarterly sampling did not consistently detect contaminants and because residences were placed on bottled water in 1983, before water sampling detected contamination, we do not know if and for how long neighboring residents were exposed to these chemicals.
- The three private wells not connected to the public water supply should be sampled to ensure that they are not impacted by contaminants migrating off-site.
- Measures should be taken to ensure that the vacant lands immediately surrounding the landfill are not developed into commercial, residential or recreational properties without environmental data to indicate that the properties are not contaminated.
- The landfill should be capped as outlined in the Record of Decision, to prevent the migration of contaminants off-site through soil, surface water runoff and leachate.
The data and information evaluated in the public health assessment for the Laurel Park, Inc site has been reviewed by ATSDR's Health Activities Recommendations Panel for appropriate follow-up with respect to health actions. The panel agrees that the community health education planned by CT DPHAS is appropriate for the site.
The Public Health Action Plan (PHAP) for the Laurel Park site contains a description of actions to be taken by ATSDR, CTDPHAS, CT DEP, and/or EPA, at and in the vicinity of the site subsequent to the completion of this health assessment. For those actions already taken at the site, please see the Background section of this Public Health Assessment. The purpose of the PHAP is to ensure that this health assessment not only identifies public health hazards, but provides a plan of action designed to mitigate and prevent adverse human health effects resulting from exposure to hazardous substances in the environment. Included, is a commitment on the part of ATSDR/CTDPHAS to follow up on this plan to ensure that it is implemented. The public health actions to be implemented by ATSDR and CTDPHAS are as follows:
- The CT DPHAS will provide environmental health education for local public health officials, the local medical community and to local citizens to assist the community in assessing possible adverse health outcomes associated with exposure to hazardous substances.
- CT DPHAS will investigate the three remaining private wells in the area to ensure that the wells are not impacted by contaminants migrating off-site.
The Public Health Assessment for the Laural Park, Inc. site was prepared by the Connecticut Department of Public Health and Addition Services 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 public health assessment was initiated.
Gregory V. Ulirsch
Technical Project Officer, SPS, RPB, DHAC
The Division of Health Assessment and Consultation (DHAC), ATSDR, has reviewed this Public Health Assessment and concurs with its findings.
C. Harold Emmeto
for Division Director, DHAC, ATSDR
Edith Pestana, MS, MPH
Environmental Epidemiologist III
Connecticut Department of Health Services
Environmental Epidemiology and Occupational Health
Environmental Epidemiologist III
Connecticut Department of Health Services
Environmental Epidemiology and Occupational Health
ATSDR REGIONAL REPRESENTATIVE
Senior Regional Representative
Office of the Assistant Administrator
ATSDR TECHNICAL PROJECT OFFICER
Gregory V. Ulirsch
State Programs Section
Remedial Programs Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry. Toxicological Profile for Benzene. Atlanta, Georgia: ATSDR, October 1991 Draft.
Agency for Toxic Substances and Disease Registry. Toxicological Profile for Benzo(a)pyrene. Atlanta, Georgia: ATSDR, October 1987: Draft.
Agency for Toxic Substances and Disease Registry. Toxicological Profile for Chromium. Atlanta, Georgia: ATSDR, February 1992: Draft.
Agency for Toxic Substances and Disease Registry. Toxicological Profile for 1,2-dichloroethane. Atlanta, Georgia: ATSDR, December 1989: DHHS publication no (PHS)TP-89-10.
Agency for Toxic Substances and Disease Registry. Toxicological Profile for Ethyl Benzene. Atlanta, Georgia: ATSDR, December 1990: DHHS publication no (PHS)TP-90-15.
Agency for Toxic Substances and Disease Registry. Toxicological Profile for Lead. Atlanta, Georgia: ATSDR, June 1989: DHHS publication no (PHS)TP-89-17.
Agency for Toxic Substances and Disease Registry. Toxicological Profile for Methylene Chloride. Atlanta, Georgia: ATSDR, February 1992: DHHS publication no (PHS)TP-88-18.
Agency for Toxic Substances and Disease Registry. Toxicological Profile for Polycyclic Aromatic Hydrocarbons. Atlanta, Georgia: ATSDR, December 1990: DHHS publication no (PHS)TP-90-20.
Agency for Toxic Substances and Disease Registry. Toxicological Profile for 2,3,7,8-Tetrachlorodibenzo-p-dioxin. Atlanta, Georgia: ATSDR, June 1989: DHHS publication no (PHS)TP-88-23.
Agency for Toxic Substances and Disease Registry. Toxicological Profile for Tetrachloroethylene. Atlanta, Georgia: ATSDR, January 1990: DHHS publication no (PHS)TP-88-22.
Agency for Toxic Substances and Disease Registry. Toxicological Profile for Trichloroethylene. Atlanta, Georgia: ATSDR, October 1989: DHHS publication no (PHS)TP-88-24.
Agency for Toxic Substances and Disease Registry. Toxicological Profile for Vinyl Chloride. Atlanta, Georgia: ATSDR, October 1991: Draft.
Agency for Toxic Substances and Disease Registry. Health Assessment for the Laurel Park Landfill. Atlanta, Georgia: ATSDR, December 4, 1986. Addendum, May 11,1988.
Camp, Dresser & McKee, Inc., 1982; Draft, Remedial Action Master Plan for Laurel Park Landfill; Naugatuck, Connecticut.
Connecticut Department of Environmental Protection, Air Compliance Unit Files for Naugatuck. 79 Elm Street, Hartford, Connecticut.
Connecticut Department of Environmental Protection, Bureau of Water Management Files for Laurel Park, Naugatuck. 165 Capital Ave, Hartford, Connecticut.
Connecticut Department of Environmental Protection, Bureau of Site Remediation Superfund Files on Laurel Park, Naugatuck. 79 Elm Street, Hartford, Connecticut.
Connecticut Department of Environmental Protection, Waste Management Bureau Files on Laurel Park, Naugatuck. 79 Elm Street Hartford, Connecticut.
Fred C. Hart, "Laurel Park Landfill Annual Monitoring Report, October 1986. Meriden CT.
Langan Engineering and Environmental Services, Inc. "Remedial Design Work Plan for Closure of Laurel Park Superfund Site, Naugatuck, Connecticut. June 4, 1993. Elmwood Park, New Jersey.
Malcolm Pirnie, "Remedial Investigation Report," February 1987.
Malcolm Pirnie, "Endangerment Assessment," February 1987.
The following is a compilation of all public comments received on the Laurel Park Public Health Assessment, February 22, 1993. All public comments were addressed and are discussed in the following paragraphs.
All comments received from the EPA and CT DEP were incorporated into the health assessment, with the exception of the CT DEP comment concerning the following incidence: "In the fall of 1992, workers sampling monitoring wells on-site encountered what they believe was a rabid racoon".
COMMENTS RECEIVED FROM P.E.G., INC. P.O. BOX 1023, NAUGATUCK, CT
RE: PUBLIC HEALTH ASSESSMENT, Laurel Park, Inc.
Again, as I have stressed in the past, the people that have lived in the area of the Laurel Park Landfill, the firefighters that fought the fires at the site, the workers that dumped their products at Laurel Park should be a part of the health Assessment.
Your draft labeled "initial assessment, addresses a variety of toxic organic chemicals found at Laurel Park Landfill, or found in well water, but shows little to have on human health, nor what impact they are likely to have after they moved off site.
Many people have already been exposed to dangerous materials dumped at Laurel park, in the past, are presently still exposed and will be exposed in the future before any clean up operations are conducted. Upon investigation of other sites in Connecticut, it appears to be a fault of the State Dept, of Health in not assessing the health or testing residents around landfill sites. A study was requested numerous times by P.E.G. Inc., my guess is, the request have fallen on deaf ears. The local health doctor also refused to get involved because "he worked for Mayor Rado, and Rado told him to keep out of it. The lack of any monitoring records from the burning era, the lack of any testing of chemical spills on the route to the landfill and lack of testing of the people themselves, indicates no one has a base line from which to evaluate or research data. At one point in time, Yale School of Epidemiology did a survey of possible studies of health problems surrounding landfills. I don't know if anything was ever published.
Children and adults are still at risk from Laurel Park. There is easy access to the landfill by hunters, snowmobiles, ATV's and children both by direct entrance anywhere, and by indirect access from the stream that travels down Andrew Ave in close proximity to Andrew Ave School. The stream bed is still polluted and is easily accessible from the school yard.
Noted in your report that the homes not connected to the public water system should be monitored. PEG. Inc. agrees with this concept but monitoring should be at their expense as it was their option not to hook into the available system. Also noted that land adjacent to the landfill should not be developed, despite the fact that a home was built in 1991 with the approval of the health department and the Naugatuck land use board. It is my understanding that a family that recently moved into the area were not given any facts that there may be long term health risks, not what chemicals they may be exposed to daily.
Concerns about bottled water ... For approximately 2 years water was available to the residents only if they picked it up themselves at the Local Park Dept. Therefore, residents were still bathing in contaminated water for a long period of time. Again, if you review the hearing records you will get indications of great concerns. It is unfortunate that the landfill operations were unprofessional and had been allowed by D.E.P. and Dept. of Health despite the constant complaints of the citizens of the area.
Concerns about radiation and asbestos should also be addressed. Reasoning: records do not seem to be available that radiation was ever tested, fact: hospital and convalescent homes waste was disposed at the landfill, and the asbestos that was disposed at the landfill was never put in cells but allowed to be disposed of an possibly moved around just like other debris. The residents have no way of knowing if any of the aforementioned are leaving the site, via ground water runoff, leachate runoff or airborne.
It is P.E.G.'s opinion that this report tends to skim through all the health problems and seems to be protecting the unprofessional landfill operations over the many years.
In may opinion, I highly recommend that you add the stress of living in this toxic environment to your health assessment and you develop a base line from which to work from.
RESPONSE TO COMMENTS RECEIVED ON JULY 14, FROM PEG. NAUGATUCK NJ:
The purpose of the public health assessment is not to conduct an epidemiologic investigation but rather to look for any current or future impact on public health from the information reviewed.
In response to your concern with the exposures received by fire fighters, and truck drivers, etc., the public health assessment tries to identify the need for additional health information and health studies (i.e., large epidemiologic studies, door to door surveys, etc.) which include these you have suggested. However, even the public health assessment cannot identify a causal link to a particular disease of concern in the Laurel Park Landfill area. Unless a chemical/substance is well known to produce a specific disease in humans (such as asbestos and asbestosis of the lung) it is almost impossible to establish plausible cause. Even epidemiologic studies by themselves are insufficient to provide or establish definitive evidence that the disease we are investigating was caused by an exposure to a toxic chemical.
One of the major problems with this site is the lack of data to show that people were exposed to substances. The data is just not there. This has been very frustrating for CTDPHAS and ATSDR because we are in the field of public health to try and address health concerns like PEGs.
The Yale Medical School's Department of Epidemiology and Public Health did a study of the incidence of cancer in Naugatuck Valley for the years 1973 to 1982. They did not find an increase in total cancer incidence in Naugatuck despite the environmental history of this town. Their conclusions were that the rate of cancer incidence for males in the district had increased when compared to the state average. For females, the cancer incidence had been consistently lower as compared to the state average for females. Their overall conclusion was that there were no signs that the number of cases of cancer in the Naugatuck Valley District were increasing. This study is available for your review in the library of the Department of Epidemiology and Public Health at Yale Medical School. Even if the Yale study of cancer in Naugatuck found a correlation between the number of cancer cases and geographic location, this would not definitively establish a link between having cancer and the exposure that occurred. The results would only show a relationship. It is unfortunate that the epidemiologic techniques available to us to investigate your questions, lack the power needed to detect any increase in disease.
The study is entitled: "Yale University Community Project #24, Cancer Surveillance in the Naugatuck Valley Health District" by Sharon Brooks-Robinson, Stephen Gruber, Debra Brown, Chanelle Calhoun and Ann Phelps, Faculty Advisor Dr. James Jekel.
In response to your concern about access to the site, the site is now enclosed with a fence which should limit access. In addition the site is private property and people should not be trespassing.
In response to your concern about the stream bed being still polluted, unfortunately we do not have any data to support your concern at this time.
The three homes still using water from private wells will be contacted by CTDPHAS and their wells sampled, as needed.
We have discussed our assessment of the shower exposure, but the available data does not provide evidence that significant exposures occurred. Again, we do not have enough data dating back to when the landfill was operating.
CTDPHAS knew that the community would be frustrated with our conclusions. We understand that we have not been able to answer any of your questions and it is unfortunate that the health assessment process wasn't available when the landfill was operating. Then we would have been able to collect the necessary data to address at least some of your concerns. It is also unfortunate that the environmental laws were not stringent enough to protect your community. From our review of the newspapers, we realize how awful and how stressful it must have been for your community and we really do sympathize with how you feel.
In response to your thoughts that we are in support of the landfill operations, this is not true. But what conclusions can we arrive to, without appropriate environmental data. We cannot assess health risks without knowing what chemicals people were exposed to, how much of those chemicals they were exposed to, and for how long. CTDPHAS and ATSDR are truly sorry that you suffered as much as you did.
You are correct in identifying stress as a health factor. One of the goals of the Health Professionals Environmental Education Project is to make them aware of the Laurel Park site, the contaminants, and their potential health effects. The project encourages health professionals to recognize the need to be aware of the stress among community residents related to the site and to be able to address their patients concerns in ways that help alleviate stress.
COMMENTS RECEIVED ON MARCH 22, 1993 FROM THE LAUREL PARK COALITION, UNIROYAL CHEMICAL, MIDDLEBURY CT.
RE: Written Comments, Public Health Assessment, February 22, 1993
The Laurel Park Coalition (Coalition) has reviewed the Public Health Assessment; Laurel Park Inc.; Naugatuck, New Haven County, Connecticut; CERCLIS No. CTD 980521165; February 22, 1993 prepared by the Connecticut Department of Public Health and Addiction Services (CTDPHAS.) The coalition is providing written comments.
RESPONSE TO COMMENTS RECEIVED ON MARCH 22, 1993 FROM THE LAUREL PARK COALITION, UNIROYAL CHEMICAL, MIDDLEBURY CT.
The authors of the Laurel Park Health assessment thank you for your careful review of the document and for your invaluable comments. CTDPHAS incorporated most of the Laurel Park Coalition comments making changes where necessary. Where changes weren't made in the document, an explanation is provided.
Comment No. 1, page 1, paragraph 1
According to the Feasibility Study prepared for this site, the landfill occupies about 19 acres not 25 acres, and operated from 1949 to 1987 not early 1940's to 1988. this comment also applies to the release.
Response to comment 1, page 1, paragraph 1.
Your comments on the landfill acreage and the years the landfill operated were incorporated into the health assessment.
Comment No. 2, page 1, paragraph 2
According to the Office of the Borough Engineer, borough of Naugatuck, three homes not four have refused to be hooked up to public water.
Response to comment No. 2, page 1, paragraph 3.
The number of homes not hooked up to public water was changed from four to three.
Comment No. 3, page 1, paragraph 3
The information contained in the RI/FS has been supplemented by the Final Pre-Design Report. It is the Coalition's position that this information is sufficient and adequate to fully characterize the site, extent of contamination and the potential migration.
Response to comment No. 3, page 1, paragraph 3
CTDPHAS and ATSDR do not feel that there exists enough environmental data to characterize the on-site contamination, nor the potential migration of site-related contaminants off-site. In addition, CT DPHAS and ATSDR feel that the existing environmental data for the Laurel Park Landfill site and off-site is insufficient and inadequate to assess past, present and future exposure pathways. The data was insufficient to allow us to fully address past and present community concerns.
Comment No. 4, page 1, paragraphs 4 and 6
The landfill is no longer readily accessed. A six-foot high chain link fence has been constructed around much of the site and warning signs posted to minimize access and to try to eliminate trespassing.
Response to comment No. 4, page 1, paragraphs 4 and 6
Your comment on the accessibility of the landfill was incorporated into the health assessment.
Comment No. 5, page 1, paragraph 6
The three homes not connected to the public water supply were offered connection at no cost. They have repeatedly refused connection. The three homes are not located within the ground water contamination influence zone of the landfill. These homes as well as others on Hunter's Mountain use septic systems. It is likely that the contamination in the wells, if any, are from either their septic system of a neighbor's septic system.
Response to comment No. 5, page 1, paragraph 6
Your comment on the three private wells that have chosen not to connect to public water was incorporated into the health assessment. CT DPHAS and ATSDR still feel that these wells need to be tested and will contact these residents to test their wells. Hopefully these residents will choose to have their wells tested.
Comment No. 6, page 1, paragraph 6
The land adjacent to the site has been shown to be uncontaminated. Groundwater east of the landfill property may be contaminated by septic systems. The three homes should be required to hook up to the public water supply.
Response to comment No. 6, page 1, paragraph 6
Again we do not feel that the existing information is sufficient to assess whether or not the surrounding properties are contaminated.
Comment No. 7, page 2, paragraph 3
The site is currently owned by Laurel Park, Inc., a corporation.
Response to comment No. 7, page 2, paragraph 3
Your comment of ownership of the landfill was incorporated.
Comment No. 8, page 2, paragraph 4
The site was only in operation until 1987.
Response to comment No. 8, page 2, paragraph 4
Your comment on the operation date was incorporated.
Comment No. 9, page 3, paragraph 2
The leachate collection system was constructed in 1983, however, the CTDEP did not allow the collection system to flow into the municipal sewers until an additional separate leachate line was installed in December 1989.
Response to comment 9, page 3, paragraph 2
The information of the construction of the leachate collection system was incorporated.
Comment No. 10, pate 4, paragraph 5
The sewer line connecting the leachate collection system to the Naugatuck Municipal Sewage Treatment Plant treatment facility was constructed by the Borough funded by the CTDEP and certain PRP's in cooperation with USEPA.
Response to comment 10, page 4, paragraph 5
The information you provided on the sewer line connection system was not incorporated into the document because it is not relevant to the health assessment.
Comment No. 11, page 4, paragraph 7, bullet 4
These drums which were used as part of the pre-design studies in 1992 have since been properly removed from the site.
Response to comment 11, page 4, paragraph 7, bullet 4
Your comment on the removal of the drums observed on-site during our site visit was added to the health assessment.
Comment No. 12, page 5, line 1, first bullet
These drums which were used as part of the pre-design studies in 1992 have since been properly removed from the site.
Response to comment 12, page 5, line 1, first bullet
Your comment on the purpose of the sewage sludge ash was added to the health assessment.
Comment No. 13, page 5, bullet 6
These drums which were used as part of the pre-design studies in 1992 have since been properly removed from the site.
Response to comment No. 13, page 5, bullet 6
Your comment on the use of the drums and that the drums were properly removed was added to the health assessment.
Comment No. 14, page 5, bullet 9
Two inclinometers not clinometers.
Response to comment No. 14, page 5, bullet 9
The spelling correction was made in the health assessment.
Comment No. 15, page 6, paragraph 4
Long Meadow Pond Brook is correct not Long Meadow Brook Pond.
Response to comment No. 15, page 6, paragraph 4
The correction was made in the health assessment.
Comment No. 16, page 6, paragraph 4
Long Meadow Pond Brook flows along Cobber Avenue not Andrews Avenue and this is a mixed residential/commercial area not residential.
Response to comment No. 16, page 6, paragraphs 5
Your comment on the location of Long Meadow Pond Brook was incorporated and clarified in the health assessment. The unnamed stream flows along Andrews Avenue before it merges with Long Meadow Pond Brook.
Comment No. 17, page 7, items #'s 1 through 6
It is not clear whether these items are currently happening or whether they are due to past activities and are concerns. This should be clarified.
Response to comment No. 17, page 7, items #'s 1 through 6
We have clarified the community concerns. The community's present concerns relate to both the landfill's past operational activities, as well as the present environmental condition of the landfill.
Comment No. 18, page 7, first paragraph under Environmental Contamination...
Additional sampling of ground water from monitoring wells was performed during the Pre-Design in 1992, the report should indicate that this additional sampling was performed.
Response to comment No. 18, page 7, first paragraph
Your comment was incorporated into the health assessment.
Comment No. 19, page 9
Why is this page blank? Was part of the report deleted and for what reason?
Response to comment No. 19, page 9
The blank page was the result of clerical error during the formatting of the document. No information from the report was deleted.
Comment No. 20 page 10, line 2
LESI not ESI. The final Pre-Design should be referenced in the Table of References.
Response to comment No. 20, page 10 line 2
The final Pre-Design Report is now referenced in the Table of References. ESI was changed to LESI.
Comment No. 21, page 10, paragraph 1
The direction and orientation of the fractures are away from domestic wells. It is unlikely that contamination from the landfill has migrated to domestic wells. There is no evidence to confirm contamination of domestic wells from the
Response to comment 21, page 10, paragraph 1
CTDPHAS, CT DEP and ATSDR feel that there is no evidence to confirm that the direction and orientation of the fractures are away from domestic wells. Most of the residents in the area were connected to public water because there was enough evidence (see Table 3, and Potential Exposure Pathway, Private wells) that there was a potential for on-site contaminants to migrate into off-site domestic wells.
Comment No. 22, pages 10, 11, 12, 1, 14, 15, and 16
The discussion of ground water contamination is confusing, only Malcolm Pirnie's wells are discussed in detail. No data presented on the NW well series, the BH well series or the newly installed MW series. Does Table 1 only relate to the MP well series? Deep bedrock and shallow bedrock should be defined. How many monitoring wells are installed at the site or off-site? Which monitoring wells are relevant? For instance, MP10 and MP10A are not installed in the same bedrock formation found at the Laurel Park landfill.
We suggest that the RI/FS and Pre-Design Reports be referenced and that only a brief summary be included in the Health Assessment.
Why spend so much time discussing TCDD when it seems that it may never have been accurately identified in samples? This is misleading and may cause concern on the part of the reader.
The maximum values in Table 1 for Benzene and Toluene occurred in Monitoring Well DEP-5A. DEP-5A was installed through the landfill. Are these values leachate or groundwater?
Why does the first sentence on pg. 11 state that "Table 1 lists contaminants detected during these sampling events above comparison values.", when NA is listed for two compounds? Therefore, all reference to those two compounds should be deleted from the report. For instance benzene has a MCL of 5 PPB.
Are there other possible sources of contaminants, such as septic systems? Table 3 identifies the range detected for tetrachloroethylene as ND-168, however, Table 3-9 of the RI indicates a maximum value of 187. Tables 1, 2 and 4 of the Health Assessment do not indicate any tetrachloroethylene?
Tables 1,2,3, and 4 are not consistent and comprehensive with comparison values. All tables should list all compounds. If a compound was not tested for in one medium that should be indicated. It is not possible to make a meaningful comparison the way the data is presented.
It is inappropriate in a Health Assessment to not clearly identify what was tested, what levels were found and what does it mean. Lead on Table 1 was found as high as 1520 PPB, on Table 2 as high as 4280, not shown on Table 4 and only found at 17 PPB in private wells at Table 3. What is the significance of this ?
Response to comment 22, pages 10, 11, 12, 13, 14, 15, 16
Table 1 summarizes the range of contaminants that were detected in all on-site ground water monitoring wells. The Health Assessment separates the discussion of ground water data into two sections: On-Site Contamination and Off-Site Contamination. These sections discuss the number of ground water monitoring and private wells if they exist. For example if there aren't any off-site ground water monitoring wells than there is no discussion.
Why spend so much time discussing TCDD? TCDD is thoroughly discussed because the local community is concerned that they were exposed to it in ground water. In our discussion, we clearly outlined where TCDD was originally identified and that subsequent analysis by three laboratories never confirmed its presence. We also make it clear that TCDD was never found in any private wells, which is the pathway concern to the residents.
In response to your comment on whether Table 1 lists ground water or leachate, Table 1 lists ground water monitoring data. Leachate contamination is represented in Table 2 entitled "Leachate Contamination".
Those contaminants that were not found above health comparison values were deleted from Table 1.
In response to your comment on the different comparison values, it is ATSDR policy to use the most conservative comparison value that exists for a specific chemical in a specific media (e.g., soil, water, air). This policy is based in part on the changing toxicological data. In order for you to understand the comparison values please refer to the ENVIRONMENTAL CONTAMINATION AND OTHER HAZARDS section. This section describes how comparison values are selected, and why.
In response to your comment whether or not the presence of tetrachloroethylene was due to contaminants from septic systems, this is unknown.
In response to your comment as to why there are different concentrations of lead in Tables 1, 2, and 4, lead was found in on-site ground water monitoring wells (see Table 1), and in leachate (Table 2) at different concentrations above comparison values. Lead is not represented in Table 4, because it was not found in surface water. As a rule, chemicals are listed for ground water, soil and air if they are found above comparison values.
The comparison values change with the media (source) because the health threat of a chemical will vary depending on the source of exposure (i.e., soil versus water) and the route of exposure (e.g. inhalation, ingestion and dermal.) Certain chemicals are more toxic if inhaled, others if they are ingested. In addition, exposure doses will vary depending on the media.
Comment No. 23, page 15, first paragraph
Although there is leachate at the overburden bedrock contact at the landfill, the Pre-Design concludes that there is no pathway to residential wells and the statement included in this paragraph should be deleted.
Response to comment No. 23 page 15, first paragraph
Given the complexity of the geology in the site area, and the fact that several of the wells contained compounds (benzene and vinyl chloride) that were found in on-site ground water monitoring wells and leachate, CTDPHAS and ATSDR feel that the potential exists for site related contaminants to impact the residential wells that are still being used. As public health officials we need to be conservative when we are assessing potential sources of exposure.
Comment No. 24, page 15, second paragraph
b: phenyls not biphenols
Response to comment No. 24, page 15, second paragraph
The spelling corrections were made.
Comment No. 25, page 15, last paragraph
The leachate monitoring station is at the bottom of Andrews Avenue not the top as noted.
Response to comment No. 25, page 15 last paragraph
Your comment on the location of the leachate monitoring station was incorporated into the health assessment.
Comment No. 26, page 17, first paragraph
The QA/QC should have been obtained and reviewed. Drawing conclusions on invalidated date is inappropriate and should be avoided.
Comment No. 27, page 17, first paragraph
The QA/QC should have been obtained and reviewed. Drawing conclusions on invalidated is inappropriate and should be avoided.
Comment No. 28, page 17, paragraph 3
This paragraph should be restated to state that there is no evidence to support TCDD at the landfill since sample cross contamination may have occurred. All reference to TCDD in this report should be deleted.
Response to comments No. 26, 27, and 28 page 17,
We agree that the QA/QC should have been obtained and reviewed, but sometimes they are not available and as such we need to assess the environmental data conservatively in order to protect the public's health. We have discussed the analytical problems associated with the soil data and private well data, etc. and feel comfortable with our conclusions on the data that was available to us.
In response to your comment that we should delete all reference to TCDD in this report, this would only serve your purpose and not the local residents. Despite the evidence indicating that the presence of TCDD was not confirmed on subsequent sampling, this needs to be made clear to the community. TCDD is a very toxic chemical and therefore the detection of TCDD in ground water monitoring wells was quite alarming to the community. Some residents are concerned that they were exposed to TCDD. Therefore, it was necessary for CTDPHAS and ATSDR to discuss TCDD as thoroughly as possible.
Comment No. 29, page 18, paragraph 4
Chromium VI not Chromium IV
Response to comment No. 29, page 18, paragraph 3
The spelling error was corrected.
Comment No. 30, page 18, paragraph 4
Since there are no records to indicate the level of contamination in historical wastes it is inappropriate to make the statement in the first sentence.
Unsubstantiated observations provided in personal communications without reference to appropriate parameters without reference to time periods are not valid and should be removed or modified to refer to the data and time frame on which they are based.
Response to comment No. 30, page 18, paragraph 4
We feel that eye witness accounts by reputable and highly respected CT DEP personnel are excellent sources of information about the history of disposal and contamination of Laurel Park. Do you have a better explanation as to where approximately one million gallons of sludge and liquid hazardous waste went? If the Laurel Park Coalition has information as to where this waste is please provide this information to CTDPHAS and CT DEP.
Comment No. 31, page 19, Potential Exposure Pathways, paragraph 2
This is the first time that chloride is discussed in the assessment. It was not discussed at all in the Environmental Contamination and other hazards section of the report beginning on page 7 and including Tables 1, 2, 3 and 4. The steep slopes on Hunter's Mountain are salted in the winter months. Could the chloride found in residential wells be from road salt or from septic systems?
Response to comment No. 31, page 19, Potential Pathways, paragraph 2
In response to the discussion of chloride in the pathways section, the chloride was not discussed in the Environmental Contamination section because it was not found above comparison values. In response to your question, "Could the chloride found in the residential wells be from road salt or from septic systems?" Yes, this is possible and we have incorporated this in the health assessment.
Comment No. 32, page 20, first paragraph
This sentence states that residents still use groundwater for bathing or showering. Which residents are identified, all 54 or just the three remaining ?
Response to comment No. 32, page 20 second paragraph
This paragraph discusses how persons with contaminated wells can receive inhalation and dermal exposures to VOCs from bathing and showering. In this situation, past exposures were possible for all residents who had or have private wells in the area. Future exposures are possible to those residents not connected to public water.
Comment No. 33, page 20, second paragraph
Table 3 listed the maximum level of lead as 17 PPB in private wells. No correlation of lead in various sources has been presented in Health Assessment, why mention it in the Potential Exposure Pathway's section?
Response to comment No. 33, page 20, second paragraph
Lead was found above comparison values in private wells and given that lead in drinking water has been found to contribute to fetal and childhood lead poisoning, it is discussed in the pathway analysis section. If during the health assessment process a contaminant is found at levels above health comparison values, and these levels can cause an adverse health effect, it is discussed in the pathway section. Whether or not it correlates to the site is irrelevant.
Comment No. 34, page Ambient Air Pathway
This section seems to address only past ambient air pathway. What is the exposure today both to residents and trespassers? why wasn't methane, a common landfill gas, addressed in the Health Assessment?
Response to comment No. 34, page 20, Ambient Air Pathway
The present exposures to residents and trespassers is unknown given the lack of air monitoring data. The methane sampling was included in the health assessment. CTDPHAS will review the gas monitoring that is planned by the Laurel Park Coalition during the Remedial Design and assess the potential need for methane monitoring in nearby homes.
Comment No. 35, page 21, Surface Water/Leachate Pathways
This section seems to address only the past activity. Is leachate still entering the unnamed stream? Are residents still exposed? The RI on page 7-3 in the Public Health Risk Analysis states -- "Health risks associated with exposure to surface water are expected to be minimal because the contaminants are present at very low levels and the potential for contact is limited." Does the current assessment agree or disagree? Now that much of the leachate is transported to the Naugatuck Municipal Sewage Treatment Plant, what health risks may be associated with the unnamed stream?
Response to comment No. 35, page 21 Surface Water/Leachate
The ATSDR health assessment differs from the RI/FS Risk Analysis in that it assesses the risks from past exposures. This pathway analysis refers to past exposures. Although much of the leachate is transported to the Naugatuck Municipal Sewage Treatment Plant, during our site visit, CTDPHAS and CT DEP observed and photographed leachate seeps throughout the site. Therefore CTDPHAS and ATSDR are still concerned about persons coming in contact with leachate from the site.
Comment No. 36, page 21, Soil/Dust Pathways
What if any is the potential for exposure today to residents? the landfill is capped and the potential exposure is minimal if at all.
Response to comment No, 36, page 21, Soil/Dust Pathways
According to representatives from the EPA and CTDEP the landfill is not capped to date (10/1993). Therefore, the potential still exists for soil and dust exposures to occur to those persons who trespass on the property.
Comment No. 37, page 22, 23, 24, 25, and 26, Public Health Implications
The Toxicological Implications section of the report does not seem to be complete, for instance, toluene was found at very high levels in monitoring well DEP-5A, but was not discussed. Tetrachloroethylene was never found at the landfill, and only in private wells, which could indicate that it is from other sources. Are there other contaminants identified in private wells but not found at the landfill?
Response to comment No. 37, page 22, 23, 24, 25 and 26, Public Implications
The Toxicologic Implications section does not discuss toluene or arsenic because they were not detected in private drinking water wells. Only those contaminants identified in private drinking water wells are discussed. This is an ATSDR policy decision.
In response to your comment on tetrachloroethylene in private wells, if during the health assessment process a contaminant is found in drinking water wells at levels above health comparison values, it is discussed in the Toxic Implications section.
Comment No. 38, page 22, Fish Pathways paragraph
Methane was not discussed in any other sections of the report, not even the section on Ambient Air pathway. Why mention it in this section, particularly if it doesn't bioaccumulate in fish? Where is Meadow Brook Stream? Are there other sources of influence to Long Meadow Pond Brook? Refer to page 4-10 of the RI.
Lead and other metals were detected in Long Meadow Pond Brook? Should people be warned not to fish there?
Response to comment No. 38, page 22, Fish Pathways paragraph
The discussion on methane was added to the surface water and sediment paragraph in the Off-site Contamination section. The fact that it doesn't bioaccumulate in fish is expressed in the Fish Pathways paragraphs. In response to the biaccumulation of metals. The material you referenced was included in our discussion.
We do not feel that the lead from the contaminated sediments is cause for concern because it is most likely the inorganic form of lead. In order for lead to bioaccumulate in fish it has to be in the organic form, which is rarely found.
Comment No. 39, page 27, Health Outcome Data Evaluation
Why is inhalation exposure due to burning specifically addressed when records also indicate the groundwater contamination and exposure to dust may have occurred?
Response to comment No. 39. page 27, Health Outcome Data Evaluation
Your comment on the many exposures was incorporated into the health assessment. Thank you.
Comment No. 40, page 27, 28 and 29, Community Health Concerns Evaluation
It is not clear whether the concerns addressed are current or due to past problems. Is leachate still flowing into the unnamed stream?
The three residences still on private wells may be impacted from other sources, possibly their own septic systems or their neighbor's.
Are there still complaints about odors from the landfill? What comparison has been made, if any, concerning ambient air in an urban environment to odors or volatiles assumed to occur from the landfill.
Comment No. 41 page 30, Recommendation 2
The three residences still on private wells are going to be contacted by the CTDPHAS. CTDPHAS has plans to test these wells and assess the water quality. The presence of septic systems at these homes will also be evaluated. However, if these wells contain site-related contaminants we will contact CTDEP, the local health department and the EPA Regional Project Manager for Laurel Park, Almerinda Silva. If the wells are found to be contaminated they will have to be monitored and steps will be taken to remove this exposure from the residents.
The three remaining private wells may be impacted from contaminants from off-site sources as well as from the site. Since a public water supply is available, it would seem prudent to have them hook up rather than spend the State's money to investigate the wells. If they are not impacted today, would they be impacted tomorrow from the off-site or other sources, for how long will the State investigate these wells.
Response to comment 40, page 27, 28 and 29, Community Health Concerns Evaluation and Comment No. 41, page 30, Recommendation 2
The community health concern sections addresses both past present and future health concerns that residents have.
CTDPHAS has received reports that leachate is still seeping into the unnamed stream. In addition, during our site visit we observed numerous leachate seeps throughout the site.
The concerns of the surrounding community are discussed in the Community Concerns Section. CTDPHAS has not received complaints from residents concerning odors.
Comment No. 42, page 34
The Pre-Design Report was referenced on page 10 of the Health Assessment and should be included in the Reference List.
Response to comment No. 42, page 34
The Final Pre-Design Report was included in the Reference list.