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PUBLIC HEALTH ASSESSMENT
LINEMASTER SWITCH CORPORATION
WOODSTOCK, WINDHAM COUNTY, CONNECTICUT


CONCLUSIONS

Based on the information reviewed, the ATSDR has concluded that this site is a public health hazard based upon past exposure to VOCs. Residents in the vicinity of Linemaster Switch Corporation, who consumed water from contaminated wells, received exposures to site related compounds in private drinking water wells for an undetermined amount of time between 1969 to 1988. Currently, the site poses a no apparent public health hazard because site-related exposures are below levels of health concern.

  1. Approximately eight private residences, employees of the Woodstock Town Hall and volunteers of the Woodstock Fire Department were exposed to a variety of site related compounds through the contamination of private drinking water wells. On-site and off-site wells were found to have levels of TCE that could increase the risk of developing cancer in persons who drank from contaminated wells.

    The maximum concentration of TCE detected in drinking water wells located on-site was 10,327 ppb. The maximum concentration of TCE detected in off-site drinking water wells was 220 ppb. The cancer risk estimates were calculated separately for on-site and off-site well contamination. Residents exposed to the maximally detected off-site concentration of TCE (220 ppb) have a low increased risk for developing cancer. Those exposed to the TCE detected in the on-site wells (10,327 ppb) have a moderate increased risk for developing cancer. The actual concentration children or adults may have been exposed to may have been lower.

  2. Analysis of samples taken after one year of operation of the Interim Removal System indicate that TCE concentrations have been reduced to less than 5 ppb in six water supply wells, including the wells which supply the Woodstock Town Hall and the restaurant. TCE concentrations in the well supplying the Tarr apartments remain unchanged.

  3. Approximately eight private residences south of the Woodstock Public School received past exposures to benzene and MTBE for an undetermined amount of time between 1988 and 1991. No adverse health effects are expected based upon the detected levels of contaminants.

  4. Residents in the area may be exposed to arsenic through contaminated private drinking water wells. Arsenic occurs naturally in the Woodstock area and is not related to the Linemaster Switch site. The arsenic occurs in both the overburden and bedrock aquifers. The presence of arsenic could explain why some residents complained about itchy skin. The CT DPHAS is concerned about the possibility of arsenic contamination in other wells in Woodstock. This is because as discussed in the Toxicologic Implication Section, several wells had arsenic levels that could increase the risk of developing cancer.

  5. Lead was identified in several wells. The source of lead is probably from plumbing fixtures in the individual homes. Therefore the potential exists for persons to be exposed to lead through ingestion. This is cause for concern because it can contribute to the overall body burden of lead. In addition, even at low exposure levels health effects have been documented.

RECOMMENDATIONS

  1. The current well water quality monitoring program should continue. We understand that the current monitoring program has utilized various criteria for selecting wells for periodic sampling. Further, we understand that if wells previously not contaminated become contaminated confirmatory re-sampling will be conducted. If subsequent sampling confirms the contamination is above established drinking water criteria, treatment systems will be installed. Additionally, we understand that once previously uncontaminated wells become contaminated, the monitoring program will be expanded to include wells located downgradient from the Linemaster Switch site.

  2. Those private wells where high levels of naturally occurring arsenic have been found (GW-21, GW-34db, and GW-69db) should continue to treat their drinking water to reduce the arsenic levels. Other residents in Woodstock should consider testing their wells for arsenic. If arsenic is found above comparison values, the well water should be treated.

  3. Long-term exposures to low levels of lead in drinking water are cause for concern because it can contribute to the overall body burden. When the faucets have not been used for over an 8 hour period lead can accumulate in the pipes. Running the tap water up to three minutes can reduce the lead levels in water. Treating the water may be another alternative to eliminate the lead.

  4. Residents living around the site should be educated as to the findings of the health assessment.

Health Activities Recommendation Panel (HARP) Recommendations

The data and information developed in the public health assessment for Linemaster Switch, Woodstock, CT have been evaluated by the ATSDR Health Activities Recommendations Panel for appropriate follow-up with respect to health actions. The panel determined that community health education is indicated for this site. The panel also determined that the ATSDR should evaluate the CT DPHAS health statistics review for consideration of additional health actions.

PUBLIC HEALTH ACTION PLAN

The Public Health Action Plan (PHAP) for the Linemaster Switch site contains a description of the actions to be taken by the ATSDR, the CT DPHAS, the CT DEP, and/or the EPA in the vicinity of the site. 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 the ATSDR and the CT DPHAS to follow up on this plan to ensure that there is implementation. The public health actions to be implemented by the ATSDR, the CT DPHAS, and the CT DEP are as follows:

  1. The CT DEP and the CT DPHAS will continue to review monitoring reports from those private wells identified as contaminated from the Linemaster Switch and the Woodstock Public School sites.

  2. The CT DPHAS will provide environmental health education for local public health officials, the local medical community and local citizens to assist the community in assessing possible adverse health outcomes associated with exposures to toxic substances.

  3. The CT DPHAS will attempt to coordinate a well survey of the Town of Woodstock to investigate the extent of naturally occurring arsenic contamination in the private wells. In addition, the CT DPHAS will investigate and make recommendations regarding the appropriate filters for treating wells with arsenic contamination.

CERTIFICATION

The public health assessment for the Linemaster Switch 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, SSAB, DHAC

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


Richard Gillig
for Division Director, DHAC, ATSDR


PREPARERS OF REPORT

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

Edith M. Pestana, MS, MPH
Epidemiologist
Division of Environmental Epidemiology and
Occupational Health Connecticut
Department of Public Health and Addiction Services

Kenny Foscue, MPH
Epidemiologist
Environmental Epidemiology and
Occupational Health Connecticut
Department of Public Health and Addiction Services

ATSDR Regional Representative:

Louise House
EPA Region I

ATSDR Technical Project Officer:

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


REFERENCES

  1. NUS Corp. Final Inspection Report Linemaster Switch Corporation, Woodstock, CT. TDDNo. F1-8612-01, March 27, 1987.


  2. ATSDR Preliminary Health Assessment for Linemaster Switch Corporation Superfund Site, CERCLIS NO. CTD001153923, June 1, 1993.


  3. Bramley, David, L. Senior Environmental Engineer, Fuss & O'Neill Inc. 146 Hartford Road, Manchester, CT. Personal communications.


  4. Fuss & O'Neill Inc. Initial Site characterization Linemaster Switch Corporation, Woodstock, CT, November 1991.


  5. Weston & Sampson, Engineers, Inc. Town of Woodstock, CT Hydrologeologic Investigation of the Woodstock Public School Site, September 1992.

  6. Census Sample Count, Part A, Connecticut Population and Housing Characteristics, August 1991.


  7. Fuss & O'Neill Inc. Draft Remedial Investigation/Feasibility Study Remedial Investigation Report, Linemaster Switch Corporation, Woodstock, CT, Volumes I and IV of V, August 1992.


  8. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Tetrachloroethylene," February 1992.


  9. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Trichloroethylene," April 1993.


  10. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Benzene," February 1992.


  11. Kondakis, XG, Makris, N, Leotsinidis, M, Prinou, M, Papapetropoulos, T. Possible Health Effects of High Manganese Concentration in Drinking Water. Archives of Environmental Health. Vol. 44:175-178, 1989.


  12. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Chloroform," February 1992.


  13. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Arsenic," February 1992.


  14. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Lead," February 1992.


  15. Feliciano DV, 1992. Everything you wanted to know about Grave's disease. Am J Surgery. Vol. 164(5):404-11, November 1992.


  16. Bizzaro N. Familial association of autoimmune thrombocytopenia and hyperthyroidism. Am J Hematol. Vol. 39 (4):294-8, April 1992.


  17. Harsch I, Paschke R, & Usadel KH. The possible etiologic role of psychological disturbances in Grave's disease. Acta Med Austriaca. Vol. 19 Suppl 1:62-5, 1992.


  18. Byers VS, Levin AS, Ozonoff DM, et al.. Association between clinical symptoms and lymphocyte abnormalities in a population with chronic domestic exposure to industrial solvent-contaminated domestic water supply and a high incidence of leukemia. Cancer Immunol. Vol. 27:77-81, 1988.


  19. Lagakos SW, Wessen BJ, Zelen M, et al.. An analysis of contaminated well water and health effects in Woburn, MA. J. Am Stat Assoc. Vol. 81:583-614, 1986.


  20. Germolec DR, Yang RSH, Ackerman MF, et al.. Toxicology studies of a chemical mixture of 25 ground water contaminants: II. Immunosuppression in B6CF1 mice. Fundam Appl Toxicol Vol. 13:377-387, 1989.


  21. United States Geological Service Topographic Map for Putnam, Conn.,. 41071-H8-TF024. Scale 1:24,000. Putnam Quadrangle Connecticut-Windham Co. 7.5 Minute Series(Topographic).


  22. Fagliano J, Berry M, Bove F, et al.. Drinking water contamination and the incidence of leukemia: An ecologic study. Am J Public Health. Vol. 80:1209-1212, 1990.


  23. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for 1,2-Dichloroethane," Update May 1994.


  24. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for 1,2-Dichloroethylene," Update August 1994.


  25. Arthur D. Little. Draft Report for "Human Health and Ecological Baseline Risk Assessments at the Linemaster Switch Site, Woodstock, CT." March 4, 1992 (sic) 1993.


  26. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Bromodichloromethane," December 1989.


  27. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Bromoform," December 1990.


  28. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Cadmium," April 1993.


  29. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Chloroform," April 1993.


  30. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Chromium," April 1993.


  31. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Manganese," July 1992.


  32. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Nickel," April 1993.


  33. Agency for Toxic Substances and Disease Registry, "Toxicological Profile for Vinyl chloride," April 1993.


  34. Witkowski, KM, Johnson NE Organic-solvent water pollution and low birth weight in Michigan. Soc Biol. Vol. 39(1-2):45-54, Spring-Summer 1992.


  35. Fuss & O'Neill, Inc.. Second Annual Monitoring Report, Interim Removal Action, Linemaster Switch Corporation. January 1995.


  36. Correspondence from: Elise I. Jakabhazy, Remedial Project Manager (Superfund Section United States Environmental Protection Agency), to: Gary D. Perlman, Epidemiologist (Connecticut Department of Public Health and Addiction Services - Division of Environmental Epidemiology and Occupational Health). February 24, 1995.


  37. Correspondence from: Superfund Technical Support Center, Environmental Criteria and Assessment Office, U.S. Environmental Protection Agency, to: Gary D. Perlman, Epidemiologist (Connecticut Department of Public Health and Addiction Services - Division of Environmental Epidemiology and Occupational Health). March 31, 1995.

PUBLIC COMMENTS

The Public Comment section for the Linemaster Switch site contains the public comments received during the public comment period in February 1995 and their respective response.

PUBLIC COMMENTS RECEIVED FROM THE CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION.

COMMENT NO. 1.

    p. iv List of Tables. The titles for Tables 8 and 9 are switched.

RESPONSE TO COMMENT NO. 1.

    This suggestion was incorporated as stated.

COMMENT NO. 2.

    p. 1. paragraph 2. Sixth sentence. Add a comma after "shed", delete "is", add comma after "facility", delete "that".

RESPONSE TO COMMENT NO. 2.

    This suggestion was incorporated as stated.

COMMENT NO. 3.

    p. 1. paragraph 2. Last sentence. Figure number is 2-1 in Appendix C-1.

RESPONSE TO COMMENT NO. 3.

    This suggestion was incorporated as stated.

COMMENT NO. 4.

    p. 2. paragraph 1. Last sentence. Change "residence" to residential.

RESPONSE TO COMMENT NO. 4.

    This suggestion was incorporated as stated.

COMMENT NO. 5.

    p. 2. paragraph 2. Third, fourth and fifth sentence. In order to clearly describe actions taken to remove VOCs from the groundwater, the following is suggested: In 1989, an air stripping tower and carbon polishing filter were installed to remove VOCs from the on-site well water supply. This tower and filter are located in the southern portion of the factory building. In 1992, a groundwater collection and treatment system, (the Interim Removal Treatment System (IRTS)) was installed to prevent the migration of VOCs off-site. Contaminated groundwater is pumped from six bedrock extraction wells to the treatment system which consists of an air stripper and carbon polishing filters. The treatment system is located in a small building to the east of the manufacturing building. Since initiation of the IRTS, approximately 448 pounds of VOCs (407 pounds of TCE) have been removed from the groundwater (Source-Second Annual Monitoring Report, Interim Removal Action, Linemaster Switch Corporation, dated January 1995, prepared by Fuss & O'Neill, Inc.)

RESPONSE TO COMMENT NO. 5.

    This suggestion was incorporated as stated.

COMMENT NO. 6.

    p. 2. paragraph 6. First sentence. Change "not site related" to not related to the Linemaster site.

RESPONSE TO COMMENT NO. 6.

    This suggestion was incorporated as stated.

COMMENT NO. 7.

    p. 3. Section B2. This section identifies public health actions implemented by the CT DPHAS. As written, (1) and (2) identify the same actions; the only difference is that (2) identifies the recipient of the site specific information. Either (1) should be deleted or a different recipient should be identified.

RESPONSE TO COMMENT NO. 7.

    The first action was deleted, and the second action was left unchanged.

COMMENT NO. 8.

    p. 4. Second bullet. Last sentence. Change "solvent" to solvent-based.

RESPONSE TO COMMENT NO. 8.

    This suggestion was incorporated as stated.

COMMENT NO. 9.

    p. 4. Fourth bullet. Last line. Change "south" to east.

RESPONSE TO COMMENT NO. 9.

    This suggestion was incorporated as stated.

COMMENT NO. 10.

    p. 5. Second paragraph. Next to last line. The only map in the Appendices that covers distances up to three miles from the Linemaster site is the Site Location Map in Appendix A. Appendix C2 identifies the location of off-site residential wells.

RESPONSE TO COMMENT NO. 10.

    This suggestion was incorporated as stated.

COMMENT NO. 11.

    p. 5. Fifth sentence. Beginning with "There is...", text should read There are monitoring programs for the Interim Removal Treatment System wells, on-site monitoring wells, and on-site and off-site domestic water supply wells. Forty six domestic supply wells are monitored; five wells are monitored bi-monthly, twenty wells are monitored quarterly, nineteen wells are monitored semi-annually, and two wells are monitored annually.

RESPONSE TO COMMENT NO. 11.

    This suggestion was incorporated as stated.

COMMENT NO. 12.

    p. 6. paragraph 1. Second sentence. The Town of Woodstock plans to install sewer service along Routes 169 and 171, just outside the eastern and southern boundaries of the linemaster property. Construction is expected to begin by the summer of 1995.

RESPONSE TO COMMENT NO. 12.

    This suggestion was incorporated as stated.

COMMENT NO. 13.

    p. 9. paragraph 5. Opening sentence should begin In June of 1992.

RESPONSE TO COMMENT NO. 13.

    This suggestion was incorporated as stated.

COMMENT NO. 14.

    p. 9. paragraph 5. Second sentence. While data that was available after six months of operation of the IRTS may indicate that levels of VOCs in till and shallow bedrock wells remained unchanged, the system has now been in operation for almost three years. The latest IRTS report indicates that levels in some of the overburden and shallow bedrock wells have decreased. This report is already out of date since it does not include 1994 analyses for samples taken from these wells.

    The Public Health Assessment should either contain an evaluation of the most recent data or clearly indicate that the study only evaluated data available through December 1992 and that more recent data not included in the study may show other trends in contaminant levels.

RESPONSE TO COMMENT NO. 14.

    We have altered the wording to the following: However, when the data (through December of 1992) was evaluated, the levels of VOCs in till and shallow bedrock wells had remained relatively unchanged after six months of operation of the IRTS.

COMMENT NO. 15.

    p. 12. Paragraph 1. There are currently two water supply wells on the Linemaster site that provide drinking water. GW-08, which is treated by an air stripper and carbon polishing unit, provides water for the manufacturing facility and the ____ Residence. GW-12 formerly served the ____ residence; this well was taken out of service after the IRTS went on line. GW-09 provided water for the Bald Hill Restaurant (no longer in operation) and the ____ Residence (currently vacant).

    It should be noted that he maximum reported concentration of TCE (10,327 ppb) as identified in Table 3 was found in GW12, a supply well that is no longer in use. This concentration of TCE was never confirmed as the next highest reported concentration in this well for this period of January, 1987 through November, 1994 was 6897 ppb.

RESPONSE TO COMMENT NO. 15.

    We incorporated your suggestion, and have added the following: The concentration of TCE was detected in a supply well that is not currently being used.

COMMENT NO. 16.

    p. 17. First paragraph. Last line should read Figures 2-1 and 2-2 in Appendix C.

RESPONSE TO COMMENT NO. 16.

    This suggestion was incorporated as stated.

COMMENT NO. 17.

    p. 17. Second paragraph. Last sentence should be moved to become the second sentence and should read "These wells are located northeast on Route 169 and southeast on Route 171".

RESPONSE TO COMMENT NO. 17.

    This suggestion was incorporated as stated.

COMMENT NO. 18.

    p. 17. Fourth paragraph. Last sentence. Delete "with site related compounds".

RESPONSE TO COMMENT NO. 18.

    This suggestion was incorporated as stated.

COMMENT NO. 19.

    p. 18. First line below table 7. IRTS instead of IRST.

RESPONSE TO COMMENT NO. 19.

    This suggestion was incorporated as stated.

COMMENT NO. 20.

    p. 20 Ground Water - Private Well Pathway.. This section should clearly indicate that while past exposures to VOCs may have occurred for the period of 1969 through approximately 1986 (when TCE was first used at the facility until the pollution was identified and bottled water/treatment units provided), present and/or future exposures are not expected for the following reasons: 1) monitoring of on-site and off-site supply wells continues, 2) all on-site wells used as supply wells are treated by air stripping and/or GAC to remove the VOCs, 3) the IRTS was installed to prevent the migration of contaminated groundwater off-site, 4)GAC has been provided to treat off-site supply wells as needed.

RESPONSE TO COMMENT NO. 20.

    The paragraph you are referring to has been moved to the Potential Exposure Pathways Section.

COMMENT NO. 21.

    p. 20. Table 8. Linemaster Switch property should be identified as On-site.

RESPONSE TO COMMENT NO. 21.

    This suggestion was incorporated as stated.

COMMENT NO. 22.

    p. 20. Second paragraph. First, second and third sentences. Add may have before "received".

RESPONSE TO COMMENT NO. 22.

    We do not share you uncertainty with regard to the exposed populations.

COMMENT NO. 23.

    p. 21. Second paragraph. Last sentence. Add However before "Because".

RESPONSE TO COMMENT NO. 23.

    This suggestion was incorporated as stated.

COMMENT NO. 24.

    p. 21. First and third paragraph. The third paragraph addresses exposure to water contaminated with benzene and MTBE. It states that present and future exposures are unlikely since GAC treatment devices are installed and monitoring is being conducted. This same statement should be made regarding present and future exposures to other VOCs.

RESPONSE TO COMMENT NO. 24.

    This suggestion was incorporated as stated.
COMMENT NO. 25.
    p. 21. Third paragraph. Third sentence. Change sentence to read However, if individual filters fail to ...

RESPONSE TO COMMENT NO. 25.

    This suggestion was incorporated as stated.

COMMENT NO. 26.

    p. 21. Fourth paragraph. Last sentence. Substitute prior to 1992 for "between 1988 and 1992". The contamination was first identified in 1988, however it is possible that exposures occurred prior to that date.

RESPONSE TO COMMENT NO. 26.

    This suggestion was incorporated as stated.

COMMENT NO. 27.

    p. 23. Trichloroethylene (TCE). As noted in comment #15, the maximum reported concentration of TCE (10,327 ppb) was measured in April, 1987 at GW-12, an on-site supply well that is no longer in use. Use of this concentration to evaluate health effects is extremely conservative. It is unreasonable to assume that any children or adults were exposed to this concentration of TCE for any period of time, given that this concentration was not confirmed or duplicated in all of the monitoring that occurred from January 1987 through November 1994; the next highest reported concentration of TCE in this supply well was 6897 ppb. For the monitoring period of January 1987 through June 1989 (prior to operation of IRTS), the average concentration of TCE in GW-12DB was 5222 ppb. The concentration of TCE in all other on-site and off-site supply wells was and continues to be significantly lower.

    If the maximum reported TCE concentration of 10,327 ppb is to be used in the final health assessment, if should also be clearly noted that there is no date to indicate that any child or adult was actually exposed to this concentration for 19 years.

RESPONSE TO COMMENT NO. 27.

    The discussion of TCE has been altered; incorporating your concerns. Specifically, the discussion has been stratified into on-site maximum TCE concentration, and off-site maximum TCE concentration.

COMMENT NO. 28.

    p. 40. First paragraph. The first sentence states "... ATSDR has concluded that this site is a public health hazard". This paragraph should be expanded to clarify that while past exposures over an unknown period of time may have resulted in increased health risks to some residents in the vicinity of Linemaster Switch Corporation, the residential well monitoring program, installation of GAC filter systems, and implementation of the IRTS have eliminated further exposures. Therefore, there are no ongoing or other activities that are or could create a public health hazard.

RESPONSE TO COMMENT NO. 28.

    The conclusion now incorporates the following wording: Based on the information reviewed, the ATSDR has concluded that this site is a public health hazard based upon past exposure to VOCs.

COMMENT NO. 29.

    First paragraph. Second sentence. Sentence should be edited to clarify which residents may have received exposures; "Residents in the vicinity of Linemaster Switch Corporation may have received....";

RESPONSE TO COMMENT NO. 29.

    We have included the following clarification: Residents in the vicinity of Linemaster Switch Corporation.

COMMENT NO. 30.

    p. 40. Second paragraph. Last sentence. The statement that "one well was found to have levels of TCE that could increase the risk of developing cancer in persons who drank from this well" is misleading. As noted on page 24 of the Public Health Assessment, "..children and adults who drank and bathed in water containing TCE at the maximal concentration of 10,327 ppb for 19 years, have a moderate increase risk of developing cancer". There is no evidence that any population was exposed to this concentration for a 19 year period. Additional information indicating that the maximum concentration of TCE in the on-site supply wells was used to calculate cancer risk and that this concentration is not representative of monitoring data for other on-site or off-site wells should be provided.

RESPONSE TO COMMENT NO. 30.

    We included the following clarification, based on your suggestion: The maximum concentration of TCE detected in drinking water wells located on-site was 10,327 ppb. The maximum concentration of TCE detected in off-site drinking water wells was 220 ppb. The cancer risk estimates were calculated separately for on-site and off-site well contamination. Residents exposed to the maximally detected off-site concentration of TCE (220 ppb) have a low increased risk for developing cancer. Those exposed to the TCE detected in the on-site wells (10,327 ppb) have a moderate increased risk for developing cancer. The actual concentration children or adults may have been exposed to may have been lower.

COMMENT NO. 31.

    p. 41. Recommendations. First paragraph. The monitoring program for private well water supplies in the vicinity of Linemaster Switch Corporation was implemented at the request of DEP. Monitoring locations were selected based on technical considerations, including available sampling data and hydrogeologic characteristics of the site. The program has been modified as needed and all data generated is reviewed by the DEP. This program is sufficient to evaluate the extent of groundwater pollution in the vicinity of Linemaster Switch Corporation and assure residents in the area that they have a safe water supply. There is no technical justification for expanding the monitoring to include all wells within 1/2 mile of the site.

    This recommendation should state "The private water quality monitoring program currently in place should be continued".

RESPONSE TO COMMENT NO. 31.

    The recommendation has been changed, and includes the following wording: The current well water quality monitoring program should continue. We understand that the current monitoring program has utilized various criteria for selecting wells for periodic sampling. Further, we understand that if wells previously not contaminated become contaminated confirmatory re-sampling will be conducted, and if the contamination is above established drinking water criteria, treatment systems will be installed. Additionally, we understand that once previously uncontaminated wells become contaminated, the monitoring program will be expanded to include wells located downgradient from the Linemaster Switch site.

PUBLIC COMMENTS RECEIVED FROM THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY.

GENERAL COMMENTS:

    The document is well written and provides valuable historical past-exposure pathway information. However, EPA does not completely agree with the conclusions of this Public Health Assessment. EPA is extremely concerned that no current data (that obtained from mid 1993-1995) was used for risk calculations and/or conclusions.

    The 1992 Remedial Investigation/Feasibility Study, prepared by Fuss & O'Neill Inc. for the Linemaster Switch Corporation (Linemaster) was the primary document used by EPA in writing the Proposed Plan and the Record of Decision for the Linemaster Switch Corporation Superfund site. The ROD was signed by the EPA Regional Administrator July 21, 1993.

    Since February 1992, Linemaster has been operating an Interim Removal Treatment System (IRTS). The purpose of this IRTS is to contain the contamination from Linemaster Switch on-site and away from all residential homes. Meanwhile, a design is being prepared to construct the Remedial Action that shall remediate the site to remove most of the contamination to levels that are not in risk of endangering human health or the environment. Though the IRTS has been in operation for nearly three years, this Public Health Assessment does not use any the current data generated from the IRTS evaluations.

    EPA would like CT DPHAS to evaluate two documents prepared by Fuss & O'Neill for Linemaster prior to issuing the final Public Health Assessment. These are: 1) "Annual Monitoring Report, Interim Removal Action, Linemaster Switch Corporation, Woodstock, CT," dated November 1993 (this document contains data from the start-up through August 1993); and 2) "Second Annual Monitoring Report, Interim Removal Action, Linemaster Switch Corporation, Woodstock, CT," dated January 1995 (this document contains data from April 1992 - November 1994).

    Historically, prior to the initiation of the IRTS, Trichloroethylene (TCE) was detected in several off-site residential water-supply wells including: an apartment complex, four residences, the Woodstock Town Hall, and a bookstore. All of the TCE detections were less than 5 ug/l (the Maximum Contaminant Level for TCE) except at the Town Hall. Granulated Activated Carbon (GAC) treatment systems were installed at all these locations. Since June 1992, TCE has been detected in one additional residence during two sampling events. Both of these concentrations, 0.8 ug/l (2/19/93) and 0.5 ug/l (8/10/93) were also well below the MCL of 5 ug/l, and TCE has not been detected at this location since August 1993. At the apartment complex, TCE was detected during September and December 1993 (0.60 ug/l), also below the MCL. At the Town Hall, TCE was detected at 0.60 ug/l during September 1993, but since that event quarterly sampling has occurred without further detections.

    Historical data does have value in demonstrating the magnitude of the past contamination at Linemaster. However, EPA does not feel that historical numbers derived from studies completed over four years ago are representative of current conditions. In addition, using the highest detected levels for all risk calculations in an effort to be ultra-conservative may not always be for the best. Specifically, the highest detected level of TCE in residential water-supply wells was selected from a water-supply well that is no longer in use (e.g., GW-12).

    Residents were possibly exposed for nineteen years to contamination attributable to the Linemaster Switch Corporation. The historical analysis of past exposure pathways is quite valid. However, future risk scenarios should be made by using the most currently available data.

    EPA does not support the conclusion that the well water quality monitoring program should be expanded to include all residential water-supply wells within 1/2 mile of the site. Both CT DEP and EPA have developed, with Linemaster, an extensive on-site and off-site sampling plan to ensure that both residents and Linemaster employees are protected from this risk of using contaminated well water. Forty-six domestic water-supply wells are monitored: five wells are monitored bi-monthly; twenty wells are monitored quarterly; nineteen wells are monitored semi-annually, and two wells are monitored annually. This sampling program was derived by several engineers and scientists based on past and current information.

RESPONSE TO GENERAL COMMENT:

    The public health assessment examined data through December of 1992. The data used for the risk calculations and conclusions was based on past exposures. We will examine subsequent data in a future addendum.

    We have altered our discussion of the exposure scenarios for TCE from contaminated wells. Please see the CT DPHAS RESPONSE TO COMMENT NO. 27 (from the CT DEP), and the CT DPHAS RESPONSE TO COMMENT NO. 30 (from the CT DEP).

    See also the CT DPHAS RESPONSE TO COMMENT NO. 31 (from the CT DEP) regarding the recommendation for the well water monitoring program.

SPECIFIC COMMENTS:

COMMENT NO. 1

    p.iv List of Tables: Table 8 & Table 9 have their titles reversed.

RESPONSE TO COMMENT NO. 1.

    This suggestion was incorporated as stated.

COMMENT NO. 2

    p.1, paragraph 2: the paint shed no longer exists.

RESPONSE TO COMMENT NO. 2.

    This suggestion was incorporated as stated.

COMMENT NO. 3

    p.1, paragraph 2: Appendix B is the CT DPHAS drop in session memorandum. Please refer to figure 2 as being located Appendix C1.

RESPONSE TO COMMENT NO. 3.

    This suggestion was incorporated as stated.

COMMENT NO. 4

    p.2, paragraph 1, last sentence: Please change to read: "...Town Hall well, and three residential water supply wells have....."

RESPONSE TO COMMENT NO. 4.

    This suggestion was incorporated as stated.

COMMENT NO. 5

    p.2, paragraph 2: Please explain the IRTS as explained in the January 1995 "Second Annual Monitoring Report," as referenced above in the General Comments. Please use the current data to demonstrate the removal rates achieved to date.

RESPONSE TO COMMENT NO. 5.

    This suggestion was incorporated as stated.

COMMENT NO. 6

    p.2, paragraph 6: Please change to read: "CT DEP has identified another source of groundwater contamination that is not related to the Linemaster site..."

RESPONSE TO COMMENT NO. 6.

    Wording that was similar to your suggestion was used.

COMMENT NO. 7

    p.4, Third bullet: FYI: In June 1989, pursuant to a CT DEP Abatement Order, Linemaster removed the dry well. At that time, approximately, 1,000 gallons of hazardous liquid were removed from the well and disposed at a licensed hazardous waste storage facility. After the Removal Action, Linemaster filled the area with clean soils, placed a plastic barrier over the soils in the Zone 1 area, and have spread bark mulch over the area.

RESPONSE TO COMMENT NO. 7.

    The site description was based on observations made during the site visit on March 30, 1993. Thank you for the additional information.

COMMENT NO. 8

    p.4, Fourth bullet: The air stripper is located due east of the manufacturing facility.

RESPONSE TO COMMENT NO. 8.

    This suggestion was incorporated as stated.

COMMENT NO. 9

    p.5, paragraph 2: Please check all references to the Appendices.

RESPONSE TO COMMENT NO. 9.

    This suggestion was incorporated as stated.

COMMENT NO. 10

    p.5, paragraph 2, reference to private residential wells: Please see EPA's General Comments above. An extensive monitoring program currently exists for these residents.

RESPONSE TO COMMENT NO. 10.

    The monitoring program described above is now discussed in detail in the same page.

COMMENT NO. 11

    p.6, paragraph 1: Please change to read: "...plans to begin installing sewer service in the vicinity of the site during the summer and fall of 1995.

RESPONSE TO COMMENT NO. 11.

    Wording similar to your suggestion was incorporated into the document.

COMMENT NO. 12

    p.9, paragraph 5: The IRTS was initiated on June 2, 1992. In addition, the current data from the 1995 IRTS report shows that some of the water levels in some till and shallow bedrock wells have decreased. Please review this report.

RESPONSE TO COMMENT NO. 12.

    The public health assessment examined data through December of 1992. The June date was added to the document. We will examine subsequent data in a future addendum.

COMMENT NO. 13

    p.12, paragraph 1: The ____ residence received their water from GW-12 only until 1992 when the IRTS was initiated. Currently, the ____ residence shares a treated water-supply well with the manufacturing facility (GW-08).

RESPONSE TO COMMENT NO. 13.

    We have incorporated the suggested wording.

COMMENT NO. 14

    p.17, paragraph 4: This paragraph is confusing. "site-related" in the last sentence refers to the Woodstock Public School site? Please clarify.

RESPONSE TO COMMENT NO. 14.

    Your suggestion was incorporated into the following: All the wells that have been identified as contaminated were initially provided with bottled water and subsequently with granulated activated carbon filters.

COMMENT NO. 15

    p.18, below Table 7: Please correct IRST to "IRTS."

RESPONSE TO COMMENT NO. 15.

    This suggestion was incorporated as stated.

COMMENT NO. 16

    p.20-22 Private Well Pathway: As mentioned above in the General Comments, please update the present and future exposure pathways by using the most current data available. Also, please use the word "may" when discussing past exposure pathways, for example: people may have been exposed, exposures may have occurred, homes may have received etc...

RESPONSE TO COMMENT NO. 16.

    We have removed the present and future exposure scenarios from the completed exposure pathways section and included these exposures in the potential exposure pathways section.

    The past exposure description remains unchanged. The wells were known to have been contaminated in the past. If people used any water from a contaminated well, then they were exposed to the contaminants. There is no uncertainty with regard to exposure status post utilization of water from a contaminated well.

COMMENT NO. 17

    p.20, Table 8: Linemaster Switch is "On-site."

RESPONSE TO COMMENT NO. 17.

    This suggestion was incorporated as stated.

COMMENT NO. 18

    p.23, TCE - paragraph 1 (long): EPA does not agree with CT DPHAS and ATSDR using the value of 10,327 ug/l as the maximum concentration detected in residential water-supply wells. This number is not a reasonable number to use for a future exposure scenario. Not only has GW-12 not been in operation since 1992, but while it was in operation no off-site residents were ever exposed to this pathway. Please choose a different value that more accurately represents off-site conditions.

RESPONSE TO COMMENT NO. 18.

    Please se the CT DPHAS RESPONSE TO COMMENT NO. 27 (from the CT DEP).

COMMENT NO. 19

    p.24, last paragraph: same as comment 18) above.

RESPONSE TO COMMENT NO. 19.

    See RESPONSE TO COMMENT NO. 18.

COMMENT NO. 20

    p.40, Conclusions, first paragraph: EPA agrees with the paragraph regarding past exposures, yet the sentence should reflect that only the residents who had contaminants in their well water were "the residents" who may have received exposures. It should also be explained that current pathways have been eliminated through the continued use of: 1) the IRTS; 2) the on-going residential water-supply well sampling program; 3) GAC filter systems, and; 4) on-going remediation efforts at the site. The Remedial Action to construct and begin operating the remedy shall begin July 1995.

RESPONSE TO COMMENT NO. 20.

    We have incorporated much of your suggestion in the conclusion. However, the elimination of current and future pathways entails a conclusion with certainty that there will be no filter system failure. Since we are unable to provide this assurance, present and future exposures are not discussed.

COMMENT NO. 21

    p.41, Recommendation #1: As mentioned earlier, EPA does not agree with this recommendation. There is no technical basis for this conclusion. However, there is a great deal of technical analysis and deliberation that went into developing the existing monitoring program. Please re-consider this recommendation to reflect that the current and future monitoring programs are adequate.

RESPONSE TO COMMENT NO. 21.

    Wording incorporating your suggestion was used instead of the original first recommendation.

PUBLIC COMMENTS RECEIVED FROM LINEMASTER SWITCH CORPORATION.

GENERAL COMMENTS

    COMMENTS TO JANUARY 12, 1995 PUBLIC HEALTH ASSESSMENT

    Linemaster Switch Corporation ("Linemaster") has reviewed the January 12, 1995 Public Health Assessment (the "Assessment"). While Linemaster is pleased to learn that cancer rate for the area are below the state average, it is troubled by flaws in a number of assumptions in the Assessment and with some of the recommendations and/or conclusions made in the Assessment. Significantly, the Assessment is based upon old data that does not reflect the effectiveness of the remedial action undertaken by Linemaster. As a result, the recommendation that the existing off-site groundwater monitoring plan be extended indefinitely and to all wells within one half mile of the Linemaster site is without justification. Linemaster questions the reliability of data used and the methodology of processing this data, as well as the scope of the Assessment.

RESPONSE TO INTRODUCTORY COMMENT

    The CT DPHAS and the ATSDR have reviewed the assumptions used throughout this Public Health Assessment, and have classified the assumptions as based on valid scientific reasoning. Past exposures have been used throughout this document. This is not an assumption, but rather an incorporation of a known fact.

    The conclusions drawn for this health assessment are determined by the availability and reliability of the referenced information and it is assumed that adequate quality assurance and quality control measures were followed with regard to chain of custody, laboratory procedures, and data reporting.

    The scope of the work required for the Public Health Assessment is specified in CERCLA as amended in 1986:

    "The 1986 Superfund Amendments and Reauthorization Act (SARA) to the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) directs the Agency for Toxic Substances and Disease Registry (ATSDR) to perform specific public health activities associated with actual or potential exposure to hazardous substances released into the environment. Among these activities, ATSDR was mandated to perform a health assessment by December 10, 1988, for each facility listed or proposed to be listed on the National Priorities List (NPL). ATSDR must conduct health assessments on all sites added to the NPL since October 17, 1986, within one year of being listed (or proposed for listing)."

    (Source: U.S. Department of Health and Human Services Public Health Service Agency for Toxic Substances and Disease Registry. Public Health Assessment Guidance Manual. Boca Raton: Lewis Publishers. 1992.)

GENERAL COMMENT NO 1.

    The Use of Old Data Misrepresents Current Conditions and Current Health Risks.

    In general, the data that have been used to perform the assessment and upon which conclusions have been drawn are approximately three years out of date. Figures 7 and 8 from the attached Second Annual Monitoring Report for the Interim Removal Action ("IRA", the groundwater extraction and treatment system) demonstrate that the treatment system, during the more than two years that it has been operating, has successfully contained contaminant migration.

    Figure 7 shows the inferred extent of TCE impact prior to the initiation of the IRA. Figure 8 shows the inferred extent based upon sampling conducted through August, 1994. Although the spatial distribution of TCE in the bedrock aquifer has retained its original shape, the concentration of TCE in most of the wells has been reduced as result of IRA operation.

    The 100 ug/1 TCE contour initially extended south of the facility well, GW-08db, but by August, 1994 the contour had receded approximately 7600 feet toward the facility. To the northeast, the 100 ug/1 TCE concentration previously crossed Route 169, but at present even the 10 ug/1 contour is within the property boundary. Based upon a comparison with the extent of TCE present prior to IRA operation and current conditions, the data demonstrates that the remediation system is mitigating contaminant migration from the Linemaster site.

RESPONSE TO GENERAL COMMENT NO. 1

    The CT DPHAS agrees that more recent data was not included in the Public Health Assessment before it went out for Public comment. However, this data does not change our assessment and conclusions of the site that it is a public health hazard. This conclusion is based on past exposures to VOC contaminated drinking water.

    We will review more recent data in an addendum.

GENERAL COMMENT NO 2.

    Current Monitoring Programs and Institutional Controls are Sufficient to Evaluate Contaminant Migration.

    Since 1991, Linemaster has conducted an extensive program of off-site, domestic water-supply well monitoring. This program has been approved by both the Connecticut Department of Environmental Protection ("DEP") and the United States Environmental Protection Agency ("EPA").

    Linemaster currently monitors 47 off-site wells at frequencies ranging from bi-monthly to annually depending on location and analytical history. Periodically, at the request of individual homeowners, Linemaster has voluntarily sampled and analyzed wells not part of the regular program. Linemaster also has been responsive to providing information and, in some instances, special sampling events to facilitate property transfers. The success of the IRA supports a reduction in the frequency of sampling rather than an expansion of the extent of the monitoring area. Review of the data from the attached figures supports this conclusion.

    Beyond remediation, Linemaster has taken affirmative steps to reduce the likelihood of any future exposures to the site. The Assessment should note that access to the Linemaster site is restricted by a fence surrounding the property and that the site is subject to various Institutional Controls and Deed Restrictions. Under a consent decree entered with the EPA, Linemaster is obligated to communicate with local agencies to evaluate any off-site activities which might affect the remedial action. Deed restrictions prohibit the use of untreated groundwater on-site for drinking water. Considering both the current remediation and Linemaster's affirmative steps, no further monitoring is necessary.

RESPONSE TO GENERAL COMMENT NO. 2

    Please see RESPONSE TO COMMENT NO. 31 from the CT DEP.

GENERAL COMMENT NO 3.

    The Assessment Reports on Risks Unrelated to the Linemaster Site.

    Titling the Assessment "Linemaster Switch" is misleading because the report is not limited to the Linemaster site. Rather, the report goes well beyond the scope of any contamination that may be present at the site. Three of the four conclusions contained in the Assessment at page 40 do not concern Linemaster.

    The Assessment addresses naturally occurring soil and groundwater contaminants which are not a result of any activities of Linemaster Switch.

    For example, arsenic is discussed throughout the Assessment. The Assessment addresses historic soil or groundwater contamination which, although not naturally occurring, is traceable to other sources. For example, the MTBE and benzene contamination at the Woodstock public school is addressed. The Assessment also considers lead contamination caused by lead pipes in local homes. Again, this contamination is totally unrelated to the Linemaster Site in any way. Because the Assessment goes well beyond the Linemaster site in terms of the types, sources, and location of contamination, the Assessment would more appropriately be entitled, "Public Health Assessment, Town of Woodstock."

RESPONSE TO GENERAL COMMENT NO. 3

    As part of the health assessment process all sources of exposure that are identified during our investigation of Superfund sites in a specific town are presented in this document. As a rule the CT DPHAS does not withhold information from the public.

GENERAL COMMENT NO 4.

    Conclusions in the Assessment are Internally Inconsistent.

    Linemaster is puzzled by the Assessment's conclusion that certain historic pathways may be regarded as "complete" when a 1990 preliminary health assessment performed by the ATSDR concluded that "there was no evidence of current exposure and no ability to ascertain past exposures to TCE." Assessment at p.2. The fifth criteria of the pathway analysis (an exposed population) is not met because there is no evidence of actual exposure. Thus, the groundwater pathway, like the soil and indoor air pathways, should be regarded only as a potential pathway because there is no evidence of a population that was actually exposed. In light of this statement, the conclusion in the Assessment's summary on page V that "the site is a public health hazard" should be qualified in the summary noting the extensive assumptions used to reach that result, and the inherent limitations of such conclusion.

    Further, throughout the pathways analysis, (pages 20-34), all references that persons "received" exposures should be changed to "may have received" to reflect the fact that past exposures can not be confirmed.

RESPONSE TO GENERAL COMMENT NO. 4

    This document has incorporated additional information since the 1990 Preliminary Health Assessment. Please see RESPONSE TO GENERAL COMMENT NO. 1 and RESPONSE TO COMMENT NO. 16 (from the CT DEP).

SPECIFIC COMMENTS

SPECIFIC COMMENT NO. 1

    Page v, 3rd paragraph: Fuss & O'Neill does not maintain the activated carbon filters.

RESPONSE TO SPECIFIC COMMENT NO. 1

    This suggestion was incorporated.

SPECIFIC COMMENT NO. 2

    Page 2, 2nd paragraph: As of August, 1994, 448 pounds of VOCs ("contaminants") have been removed.

RESPONSE TO SPECIFIC COMMENT NO. 2.

    This suggestion was incorporated.

SPECIFIC COMMENT NO. 3

    Page 5, 1st paragraph: The nearest off-site private residences are at least 50 feet from the Linemaster property line, not 25 feet.

RESPONSE TO SPECIFIC COMMENT NO. 3.

    The closest residence, as depicted in figure 1-2 from Fuss & O'Neil (1992), is approximately 25 feet.

SPECIFIC COMMENT NO. 4

    Page 12, 1st paragraph: There are only two on-site residential wells. GW 12 formerly served the ____ residence but was removed from service in 1991. In addition, water from GW-12 was not available to the general public. No public health risk existed due to the presence of TCE in that well. GW-09 served both the Linemaster owned residence at the corner of Route 169 and 171, and the former Restaurant at Bald Hill. The restaurant has been closed since October, 1994. The only detection of TCE in GW-09 above the Drinking Water Standard (5.0 ug/1) occurred in December, 1987 (7.2 ug/1). This detection was not confirmed by subsequent analyses.

RESPONSE TO SPECIFIC COMMENT NO. 4.

    There are three on-site residential wells, GW-09, GW-10, and GW-36 (7). The public health assessment only examined data through December of 1992. We will examine subsequent data in a future addendum.

SPECIFIC COMMENT NO. 5

    Page 21, 1st paragraph: The detection of GW-44 was the result of an elevated detection limit. This detection was not confirmed by subsequent analyses.

RESPONSE TO SPECIFIC COMMENT NO. 5.

    We will examine subsequent data in a future addendum.

SPECIFIC COMMENT NO. 6

    Page 22, Indoor Air Pathways: There is no inhalation exposure to VOC exposure to VOC vapors (sic) possible because the Linemaster facility does not have a basement. Also, since the initiation of the groundwater extraction and treatment system, there have been no new detections of TCE in off-site wells. In addition, as discussed above, the extent and magnitude of the concentration of TCE in off-site wells has decreased to Not Detected in all but two wells.

RESPONSE TO SPECIFIC COMMENT NO. 6.

    The Indoor Air Pathway section no longer discusses present or future exposures to VOC vapors in the facility's non-existent basement.

SPECIFIC COMMENT NO. 7

    Page 23, TCE: The assumption used in the Assessment for the potential for adverse health effects result in misleading conclusions. The concentration of TCE selected (10,327 ug/L) was detected in GW-12 in December, 1987. Analyses conducted over the entire seven year period of monitoring yield an average concentration of 5,600 ug/L. The next highest concentration detected was 6,897 ug/L in October, 1988.

    The Assessment used a child's body eight (sic) of 10 kg (22 pounds). The EPA's default value is 15 kg (33 pounds). Recalculation of the exposure using the average TCE concentration yields 0.56 mg/kg/day which is below the MRL of 0.7 mg/kg/day. Use of the 15 kg child's weight with a TCE concentration of 10,327 ug/L, yields an exposure value of 0.69 mg/kg/day which also is below the MRL. Consequently, the health risks to children are overstated with the assumptions used.

RESPONSE TO SPECIFIC COMMENT NO. 7.

    The ATSDR default child weight is 10 kg. Therefore, the 10 kg body weight was used.

SPECIFIC COMMENT NO. 8

    Page 24, last paragraph: The Connecticut DPHAS recognizes that the carcinogenic classification of TCE was withdrawn by the EPA on July 1, 1994 and is under review by an EPA work group. It is likely that TCE will be downgraded from Class B2 (probable human carcinogen, inadequately supported by human health data) to Class C (possible human carcinogen). Both the oral RfD (August 1, 1992) and the inhalation RfC values are also under review by EPA. Risk, if any, calculated for exposure to TCE is based upon outdated, and possibly incorrect, toxicological data.

    Linemaster appreciated the opportunity to comment on the ATSDR report for the Woodstock area.

RESPONSE TO SPECIFIC COMMENT NO. 8.

    Although the values you are referring to were removed from the EPA's Integrated Risk Information System (IRIS), the calculations for non-cancerous health effects were based on data supplied from the ATSDR. Additionally, the Superfund Technical Support Center, Environmental Criteria and Assessment Office (ECAO) of the EPA provided quantitative risk estimation parameters for TCE (37).

The CT DPHAS and the ATSDR thank you for submitting comments on the Linemaster Public Health Assessment.



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