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PUBLIC HEALTH ASSESSMENT

OLD SOUTHINGTON LANDFILL
SOUTHINGTON, HARTFORD COUNTY, CONNECTICUT


APPENDIX 1


Figure 1-1. Site Location Map


Figure 1-2. Site Diagram



APPENDIX 2

The following section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch
E-56
1600 Clifton Road NE, Atlanta, Georgia 30333


APPENDIX 3


Perinatal Mortality Rates


Infant Mortality Rates



APPENDIX 4

The following section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch
E-56
1600 Clifton Road NE, Atlanta, Georgia 30333


APPENIDIX 5
PUBLIC COMMENTS--RESPONSIVENESS SUMMARY

The Public Comment section for the OSL site contains the public comments received during the public comment period in July 1993 and their respective response.

PUBLIC COMMENTS RECEIVED FROM A LOCATION IN SOUTHINGTON, CT

COMMENT NO. 1.

    According to the Public Health Assessment the boundaries of the landfill are not clearly defined. If this is so, then why aren't more tests being done to determine the boundaries?

RESPONSE TO COMMENT NO.1.

    Since the writing of this document, information has been reviewed by the CT DPHAS and the CT DEP. The CT DPHAS and the CT DEP have determined that the northern, eastern and southern boundaries of site have been defined by the EPA RI/FS consultants ESE. At the present time there is still a question as to the western boundary of the landfill.

COMMENT NO.2.

    Why hasn't more testing of the wetlands around Black Pond been done? Even though the water in the pond has tested relatively clean, what about the silt that flows out with the water and stays after the pond water recedes? More testing of the silt from the pond and the wetlands on the northeast side of the pond needs to be done. We live at number 61 Rejean Road and many times have had Black Pond overflow into our back yard, sometimes as close as ten feet from our home. Testing has not been done in any of the back yards of the homes that get overflow from the pond? Why? We would like to know if there is anything there.

RESPONSE TO COMMENT NO. 2.

    Based on the data we have evaluated from Black Pond which includes, surface water, sediments and fish, we do not have any evidence that exposure to the overflow from the pond onto your backyards will cause an adverse health effect.

    In response to your concern, the CT DPHAS is planning to sample the surface water overflow and surface soil in the area of your property where water from Black Pond overflows.

COMMENT NO. 3.

    Why are so many of the towns wells contaminated? Our family drank the water from well number five for approximately two years. How are we and all the other people who drank from these wells going to be monitored for any illnesses in the future? What recourse do we have?

RESPONSE TO COMMENT NO. 3.

    Waste disposal activities account for the contamination of the four Southington town wells that have been contaminated through time. The source of contamination for wells number 4 and 6 is Solvents Recovery Services of New England. Allegedly, there are several sources that contributed to the contamination of town well number five. These include the OSL Landfill and other industrial facilities near the well. Well 2 was contaminated by the disposal of dry cleaner waste.

    In response to your question on monitoring people for illnesses, the CT DPHAS has educated physicians in Southington about the environmental history of the Town of Southington including the contamination of these four wells. This physicians education program is designed to alert physicians that exposures have occurred and that citizens are concerned for their health.

COMMENT NO. 4.

    Why did the Town of Southington allow homes and businesses to be built on a landfill where it was known that hazardous waste was dumped? How could the Town of Southington allow plans for a residential area to be made and have those plans on paper years before the landfill was closed?

RESPONSE TO COMMENT NO. 4.

    The CT DPHAS does not know the answer to this comment. This question should be directed to the Town Manager's office of Southington.

PUBLIC COMMENTS RECEIVED FROM A LOCATION IN PLANTSVILLE CT.

COMMENT NO. 1.

    Considering my location next to R.V. & Son, I feel more testing on my property should be done for gases and contaminants.

RESPONSE TO COMMENT NO. 1.

    The CT DPHAS and the ATSDR feel that adequate testing was done on-site to characterize the potential for you as a resident to be exposed to site contaminants. The CT DPHAS has reviewed the surface soil data, indoor air, drinking water and methane data that was available and did not find evidence that your family would be in danger of being exposed to contaminants from the site.

COMMENT NO. 2.

    I feel my property lacks adequate subsurface testing for gases and contaminants. Due to my location how does EPA justify that adequate testing was conducted in order to collect data for the Health Risk Assessment report.

RESPONSE TO COMMENT NO.2.

    The CT DPHAS cannot answer this question because it concerns the EPA Risk Assessment which is different from the ATSDR Public Health Assessment. This question should be addressed to the EPA Region I office for a response.

    The CT DPHAS feels that adequate testing was done on your property in order to assess the potential for exposures to occur at the present time. The CT DPHAS was concerned with surface soils, soil gas, indoor air, drinking water, and surface water from Black Pond. A review of the data from the above mentioned sources did not indicate that you or your family are being exposed to any contaminants. However, we are concerned about the methane levels that were detected in your backyard, and your home will be monitored regularly by the Southington Fire Department.

COMMENT NO. 3

    What information did the EPA use in order to establish quality guidelines for VOCs in our well water? B) How can the EPA be sure the guidelines are at a safe level for consuming? (pg. 19)

RESPONSE TO COMMENT NO. 3.

    These guidelines developed by the EPA are protective of public health. All these quality guidelines developed by the EPA are based on animal toxicity studies and they represent the highest concentration of a chemical that a person can be exposed to over a 70 year lifetime without causing a health problem.

COMMENT NO. 4.

    How does our site compare to other sites in the way of contamination and how it effects our health? What site was used in your study to compare with ours?

RESPONSE TO COMMENT NO. 4.

    As per our review of the available data from several sites in Connecticut the OSL site in comparison to other Superfund sites in the Connecticut is more contaminated than some and less contaminated than others. The CT DPHAS and the ATSDR did not use other sites for comparison in our analysis of the contamination on the OSL site. Each Superfund site that we investigate is assessed individually. The one element that all the Superfund sites have in common is contaminated ground water problems.

    This is the first time that the CT DPHAS has dealt with the problem of methane migrating into the indoor air. However, when the CT DPHAS, the ATSDR, and the EPA became aware of the presence of potentially dangerous levels of methane at the site, experts that had dealt with other landfills and methane hazards in the U.S. were consulted.

PUBLIC COMMENTS RECEIVED FROM A SECOND LOCATION IN PLANTSVILLE, CT.

As long standing residents of Southington CT, we have many concerns (past, present and future) regarding our health. My husband, ____ has been a Southington resident for over 40 years. I have a daughter, _______, who is seven years old.

COMMENT NO. 1.

    Our past concerns stem from contaminated drinking water, inhalation of smoke contaminated with toxic waste, and of toxic gases that we may have been exposed to from the Old Southington Landfill. We may have been exposed to contaminated water while bathing, gardening, swimming, or washing the car. We have been exposed to smoke, gases, and dust emitted from the landfill.

    Many chemicals at Old Southington Landfill are cancer causing others cause heart, lung, kidney or liver diseases. Still others attack the respiratory, central nervous, or blood systems. Residents of Southington have been exposed to all of them from Old Southington Landfill. Our family and many of our immediate neighbors suffer from dizziness, severe headaches, respiratory ailments, cancer, leukemia, numbness of extremities, high blood pressure, fatigue, abdominal pain, and others too numerous to mention. All of our health problems can be attributed to exposure to toxins at the Old Southington Landfill by inhalation, ingestion, or contact.

RESPONSE TO COMMENT NO. 1.

    It is true that some of the chemicals that were detected at the OSL site and in the public water wells have been found to cause heart, lung, kidney, and liver diseases in animal studies but at levels greater than those found at the site. In the Toxicologic Evaluation section each compound that was identified as a potential concern was assessed with respect to the potential for this contaminant to cause a health problems to humans. We did not find any evidence that the contaminants from the site could be causing the illness you describe above. However, we feel that your family and immediate friends should consult with a local physician or an occupational health clinic. Occupational health clinics specialize in exposures to chemicals that are found in the workplace as well as in the local environment. The CT DPHAS has consulted with physicians in Southington and with the Occupational Medicine Program at the University of Connecticut Health Center in Farmington concerning the history of the OSL site.

COMMENT NO. 2.

    Our present health concerns are more personal. Our home is on the northern border of the old Southington Landfill. We live approximately forty feet away from a toxic waste Superfund site that is on the National Priority List. Everyday we acknowledge that our family is exposed to life threatening chemicals, soil gases and landfill leachate. Some chemicals even in small amounts, are deadly.

RESPONSE TO COMMENT NO. 2.

    The CT DPHAS and the ATSDR have reviewed the available data and have found no evidence that you and your family are being exposed to substances that could cause you harm. If we felt that there could be a possibility that this was true, we would have contacted you immediately. If we felt that residents were exposed to a life threatening situation, the CT DPHAS, the EPA and the ATSDR would have taken the necessary actions and evacuated the residents.

COMMENT NO. 3.

    Methane gas is a major concern. Every time we hear a siren or see a fire truck in the street we panic. Have the levels of methane reached dangerous? Are we going to be evacuated? Methane migration has been detected in the southern areas of the landfill. Has any of the methane from the northern areas of the landfill migrated? Has it moved to our property? Did it carry any unknown gases or VOCs? Is methane building up in small enclosed areas -- causing an explosion danger? Are safe?

RESPONSE TO COMMENT NO. 3.

    Methane was detected indoors in the floor cracks of three non- residential buildings on the OSL site at levels that could pose a fire and explosion hazard. However, methane has not been detected indoors in any of the northern residential homes on the OSL site. The Southington Fire Department inspects and monitors the homes located on the landfill every day and has not identified methane inside any of the homes to date.

    Methane has been detected in methane wells installed in the backyards of homes that are on the OSL site. These wells are monitored regularly.

    At the present time we do not have any information to indicate that methane and other potentially toxic gases are migrating into your homes. However, the Southington Fire Department has offered to come and test the homes of residents who are concerned about the presence of combustible gases in their homes.

COMMENT NO. 4.

    High levels of VOCs and PAHs are in the soil. Elevated levels of Toluene, TCE, and other VOCs have been detected in indoor air samples at dangerous levels. The VOCs found in the samples cause dizziness and headaches. Is this the cause of our daughters unexplained chronic dizziness? Why hasn't the air been tested inside of the homes bordering the landfill?

RESPONSE TO COMMENT NO. 4.

    Elevated levels of toluene, TCE, and other VOCs have not been found in any of the homes. The levels of VOCs found in indoor air samples were below health comparison values and therefore, exposure to these are unlikely to cause health problems.

    Because there is no evidence that toxic gases or vapors are migrating substances into the homes located on the landfill, the CT DPHAS does not feel there is cause for concern in the homes bordering the landfill.

COMMENT NO. 5.

    Chemicals causing adverse dermal effect to patients with preexisting skin conditions are in the soil. Mixtures of pyrene with other PAHs including benzo(a)pyrene and fluoroanthene cause skin cancer. Is my husband at risk?

RESPONSE TO COMMENT NO. 5.

    The CT DPHAS does not believe that your husband is at risk of being exposed to subsurface soil contaminated with PAHs from the OSL site. There is no evidence that your home is on the landfill.

    As discussed in the Toxicologic Implications Section, those persons involved in excavations and/or diggings on the site could be at risk of exposure to PAHs, and high levels of VOCs. The PAHs were identified at 4 foot depths on the OSL site.

COMMENT NO. 6.

    Lead and mercury have been detected in ground water. Although contamination levels are relatively low - as parents we are concerned about long term exposure to mercury which can cause permanent brain damage.

RESPONSE TO COMMENT NO. 6

    The lead and mercury identified in Town well number five is believed to be the result of laboratory error. The lead and mercury were only detected in laboratory analysis in a sampling round. Because subsequent sampling did not detect the presence of lead or mercury, the CT DPHAS does not believe that Town well number five was contaminated with lead or mercury.

COMMENT NO. 7.

    Our future concerns center around recommended remediation of Old Southington Landfill.

    When the houses and factories that are situated on solid waste, methane, or VOC pockets are destroyed, how will the contamination be contained?

COMMENT NO. 8.

    When the vegetation is uprooted, how will the contaminated soil and dust be prevented from becoming air born?

COMMENT NO.9.

    How will methane gas and other contaminants be contained and prevented from migrating?

COMMENT NO. 10.

    Will an impermeable clay wall be installed to surround subsurface contamination?

COMMENT NO. 11.

    Will sewer and utility lines be removed (not capped) to insure that gases and other contamination will not follow them and pollute the entire neighborhood?

COMMENT NO. 12.

    Can mixed chemicals, PCBs and VOCs ignite or explode when exposed to oxygen?

COMMENT NO. 13.

    When a clay cap is placed over the landfill will pressure cause methane or other toxic waste to spread or redistribute? How will this be prevented?

COMMENT NO. 14.

    How and how often will the quality of air, soil, and water be monitored during clean up?

COMMENT NO. 15.

    Different chemicals and gases travel through different avenues, air - soil - water, will monitors be installed outside of the landfill current boundary to insure public safety?

COMMENT NO. 16.

    When our child sees the EPA employees in their space suits, what reassurance can we give her that she is absolutely not in danger?

COMMENT NO. 17.

    We live less than 40 feet away from the Old Southington Landfill. In 1984 this site was placed on the EPA National Priority List as one of the worst toxic waste sites in the U.S.. When clean up of this site begins, I want guarantees Guarantees ... that my family and friends will be safe during clean up.

COMMENT NO. 18.

    Guarantees ... that our lives will proceed as normal and not be disrupted because of landfill activities.

COMMENT NO. 19.

    Guarantees ... that we will be able to enjoy outdoor activities without worry.

COMMENT NO. 20.

    Guarantees ... that we will be able to leave our windows open and not be assaulted with contamination.

COMMENT NO. 21.

    Guarantees ... that future migration of gases, VOCs, PCBs, and landfill waste will not endanger us.

COMMENT NO. 22.

    Guarantees ... that the water we drink is safe that the air we breath is not contaminated that the soil beneath our feet is not killing us.

COMMENT NO. 23.

    I want to know beyond a shadow of doubt that our lives and health will not be diminished because we live on the border of a U.S. EPA Superfund Toxic Waste Site.

COMMENT NO. 24.

    Our concerns and anxieties are genuine. We are apprehensive about our future. Our physical and mental health is uncertain. Our daily lives have been and will continue to be disrupted by landfill activities. Questions remain unanswered.

RESPONSE TO COMMENT NO. 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, and 24.

    The CT DPHAS and the ATSDR cannot comment on the hazards of the prospective remediation plan or methods without reviewing the EPA specific plan. The CT DPHAS recommends that concerned residents like yourself review the Remediation plan when it is made available for public comment and that you submit written comments to the EPA and the CT DEP. The EPA Remediation plan will be made available for your review at the Southington Public Library. In addition, there will be several meetings concerning the remediation of the site that you should attend.

    The EPA RI/FS workers are required by law to wear health and safety equipment and clothing while they are on the site performing any sampling, investigative or remediation work. If the EPA identified a potential hazard, local residents and workers would be notified and evacuated if necessary.

COMMENT NO. 25.

    The CT DPHAS has provided Southington residents with a health assessment that is factual and understandable. Along with the CT DEP, your combined efforts have overcame obstacles and have provided residents with information that is vital for our understanding of this public disaster. Recognizing that the State of Connecticut Agencies willingly provide information when Federal and Local Governments are reluctant to do so, is a great comfort and deserving of Southington's residents gratitude. The knowledge that both the CT DPHAS and the CT DEP are safe-guarding people from harm is sincerely appreciated.

RESPONSE TO COMMENT NO. 25.

    The CT DPHAS thanks you for submitting comments on the Draft Public Health Assessment for Old Southington Landfill. If you require further information or clarification on the information presented here or other issues concerning the site, please do not hesitate to contact us. We are here to serve you.

PUBLIC COMMENTS RECEIVED JULY 28, 1993 FROM PEPE & HAZARD LAW OFFICES, GOODWIN SQUARE, HARTFORD, CT.

GENERAL COMMENTS

The CT DPHAS and the ATSDR have conducted an evaluation of the human health risks and hazards presented by contamination associated with the Site. As noted in the Draft Public Health Assessment (Draft PHA), the purpose of this evaluation "is to determine whether adverse health effects are possible and to recommend actions to reduce or prevent possible health effects."

Given the stated purpose of the Draft PHA, we believe that the Draft PHA as currently written has fallen short of the mark for a number of reasons as set forth below.

GENERAL COMMENT NO 1.

    * First, the Draft PHA has reviewed only selective data gathered over the years at the site. The Draft PHA has failed to include the most recent results of investigations at the Site, including the risk assessment and actions taken at the Site. These facts are critical in evaluation and presenting potential risks to nearby residences and businesses. Additionally, many of the facts reported are not correct. While there is available a large amount of information regarding the Site, much incorrect information has been reported and is repeated in the PHA. We would be willing to assist ATSDR in identifying and correcting such factual errors.

RESPONSE TO GENERAL COMMENT NO.1

    The Draft PHA was reviewed by the EPA and the CT DEP before it went out for public comment. The CT DPHAS and the ATSDR rely on the EPA and the CT DEP for their comments and review of the available data. At that time neither agency commented that the information that was included in the Draft PHA was incorrect. The CT DPHAS agrees that more recent data was not included in the Draft PHA 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 from town well number five and the present physical hazards associated with the methane contamination of indoor air in commercial facilities. The CT DPHAS and the ATSDR are conducting a study to try and reconstruct the dose of VOCs Southington residents may have received from contaminated drinking water with respect to the geographic location of their residence.

GENERAL COMMENT NO. 2.

    * Second, the Draft PHA is misleading in its presentation of current potential risks posed by the Site, by intermixing and emphasizing historic risks to groundwater town-wide, which have long since ceased with discussions as to current and future risks. The fact that there may have been potential risks due to drinking groundwater in the past is an insufficient reason to classify the site as a current public health risk.

RESPONSE TO COMMENTS NO. 2

What you are discussing above is the purpose of a risk assessment which is different than the purpose of an ATSDR Public Health Assessment. The following is a comparison of these two different assessment documents.

  1. The ATSDR Public Health Assessment is qualitative, and uses environmental and health outcome data and community health concerns as the primary sources of information. For the most part the health assessment is site-specific unless another source of exposure is identified near the site that may have or could impact the local community.

    The EPA risk assessment is quantitative, compound oriented, site specific and uses environmental contamination data.

  2. The ATSDR Public Health Assessment weighs medical and public health perspectives to assess health hazards. It is concerned with past, current, and future exposures.

    The EPA Risk Assessment uses statistical and/or biologic models to calculate numerical estimates of health risks. In addition, it deals with hypothetical populations and pathways. It is concerned with current and future exposures.

  3. The ATSDR Public Health Assessment is used to evaluate human health impacts and to identify public health interventions.

    The EPA Risk Assessment is used to facilitate remediations or other risk management actions.

  4. The ATSDR Public Health Assessment may identify populations for which further health actions or studies are indicated.

    The EPA Risk Assessment may lead to the selection of particular remediation measures at a site.

  5. The EPA Risk Assessment bears regulatory weight of authority. The PHA may lead to the issuance of a Public Health Advisory.

GENERAL COMMENT NO. 3.

    * A related problem is the inclusion in the Draft PHA for the Site of a discussion of the area wide cancer studies which sprang from the SRSNE Site. The discussion of those studies is confusing and likely to mislead the public as to the nature of potential risks posed by the Old Southington Superfund Site. This is compounded by the fragmented discussion which should clearly point out that the findings of those studies have not determined whether any elevated cancer incurrences are present which are attributable to conditions which may have historically existed. To the extent the ATSDR deems these matters to be of interest to the public, the discussion should be appended to the PHA for the Site and merely referenced within the PHA.

RESPONSE TO GENERAL COMMENT NO. 3.

    Although the cancer cluster investigation was initiated because of concern with the Solvents Recovery Services of New England (SRSNE) site, the cancer cases analyzed in this study were from the entire town of Southington. In addition, the CT DPHAS was evaluating the Old Southington Landfill site at the same time as the SRSNE site. Therefore, since the entire town was evaluated it was included in this public health assessment.

GENERAL COMMENT NO. 4.

    * Fourth, the draft PHA fails to clearly characterize the nature and results of combustible gas investigations at the Site and the efforts undertaken by the parties to assess and prevent potential impacts. The Draft PHA should clearly differentiate between the residence on the Site where numerous sampling events have shown no potential impacts. The Draft PHA should clearly differentiate between the residences on the Site, where numerous sampling events have shown not potential problems to exist, from the commercial buildings where actions have been taken to ensure the monitoring and prevention of problems which may occur. In addition, the Draft PHA does not describe the actions taken in cooperation with the CT DEP, the CT DPHAS, the EPA, and the Fire Department to monitor combustible gas, take immediate measures in response, and install monitors and venting systems for the long term.

RESPONSE TO GENERAL COMMENT NO. 4

    The CT DPHAS and the ATSDR feel that the information is clearly presented with respect to what has been identified on residential and commercial properties. The ATSDR Public Health Assessment is concerned with past, current, and future exposures. The Draft PHA does describe the actions taken by the EPA, the CT DEP, the Southington Fire Department, the ATSDR and the CT DPHAS in sections B. ON-SITE CONTAMINATION and in Public Health Action Plan.

COMMENT NO. 5.

    * Finally, the Draft PHA should be rewritten in a less inflammatory style. Merely reporting statements and rumors about potential risks has no place in this report. Nonscientific assertions as to stress, etc. and the need for counseling are simply not based upon factors of the Site, are misleading to the public and are unnecessarily inflammatory.

RESPONSE TO COMMENT NO. 5

    In reviewing your comments it is quite clear that you are unfamiliar with the health assessment process and most importantly its mission. The health concerns and statements of residents are not interpreted as "rumors".

    Addressing the health questions of the residents associated with the site is central to the overall mission of the ATSDR and to the purposes of the Draft PHA. The health concerns will vary from site to site. In addition, addressing the health concerns of the community including stress, is crucial if the health assessment is to satisfy its purpose of helping the public and health professionals understand all the risks posed by a site. The CT DPHAS has observed an unusually high amount of stress in several communities living near Superfund sites in Connecticut and recognizes that stress can effect the quality of family life.

COMMENT NO. 6

    Of the most critical importance, however, is the fact that the essential findings of the Draft PHA that the Site is a public health risk is based simply upon two conclusions: 1) historic risks due to contaminated groundwater; and 2) potential risks to businesses from combustible gas. Although the Draft PHA arrives at these conclusions, they are not clearly presented. As a result, the PHA is likely to cause unnecessary confusion and anxiety on the part of the public rather than to serve its primary function of guiding future response activities at the Site. Furthermore, the first conclusion cited in support of the findings of the Draft PHA provide no basis for that finding. While there may have been in the past potential risks due to contaminated supply wells, this risk no longer exists and is not relevant to the stated purpose for the PHA evaluation. Finally, with respect to the combustible gas issue, the facts as to the Site, measures taken and monitoring underway do not support these issues as a sufficient basis for the Draft PHA finding.

RESPONSE TO GENERAL COMMENT NO. 6

Please see response to GENERAL COMMENT numbers 1 and 2 above.

SPECIFIC COMMENTS

SPECIFIC COMMENT NO. 1, BACKGROUND, PAGE 2, PAR. A, PAR. 2

    The statement that "the extent of the landfill's boundaries are not established and have not been fully defined" is incorrect. Through the performance of the RI/FS, especially during the Post-Screening Field Investigations (PSFI), the boundaries of the landfill have been fully defined. The findings resulting from these extensive field investigations are consistent with information collected from the review of historical records, review of aerial photographs, and interviews. Attached as Exhibit I hereto is a letter to the EPA Remedial Project Manager setting forth in detail the bases for such findings. (See also Exhibit 2, EPA letter and attachments, dated June 18, 1992.)

SPECIFIC COMMENT NO. 2

    The PSFI were completed in two tasks: Task I was completed in December of 1991, and Task 2 was completed in late 1992, early 1993. The PSFI included several programs designed to provide additional information relative to the extent of refuse across the Site: delineation of the landfill boundary along the west side of Black Pond; further delineation of the southern boundary of the landfill; and further delineation of the northern boundary of the landfill.

    Based upon the installation of borings and chemical analysis of soils, across the Study during Task I investigations, findings were presented in the Task I Report (submitted March 26, 1992, as revised May 22, 1992) which differentiate the northern portion of the Study Site (wood debris characteristic of a "stump dump") from the southern portion (refuse characteristics of a municipal landfill). Further, the northernmost extent of the wood debris in the northern portion of the Site was confirmed to lie just south of Rejean Road.

    Based upon the installation of borings and chemical analysis of soils across the southern portion of the Site, during Task 2 investigations, findings were presented in the draft Remedial Investigation Report which clearly define the extent of refuse along the southern and southeasterly boundaries of the landfill. Likewise, hand auger investigations along the western side of Black Pond delineated the extent of refuse encroachment along the shore of the Pond.

RESPONSE TO SPECIFIC COMMENTS NO 1 AND 2.

    Your comments on the landfill boundaries were incorporated into the health assessment. However, in discussions with the CT DEP, there is still some controversy as to the southern limits of the landfill.

SPECIFIC COMMENT NO. 3, PAGE 2, PAR. 6

    With respect to the statement concerning open burning, we believe that the reference overstates the known occurrence of such activities. The Draft PHA should state instead that there are certain reports of open burning at the landfill prior to 1964, but such activities appear to have been sporadic over that period of time.

    In addition, this paragraph is misleading in its characterization of the volumes and nature of wastes received at the landfill. The Draft PHA states that approximately 2.5 million gallons of solvent were disposed of at the Site. While it is alleged that Solvents Recovery Services of New England (SRS) took approximately one million gallons of solvent contaminated wastewater to the landfill, analyses of these wastewater streams indicated that the natural percent of solvent ranged somewhere between 8 percent and 22 percent. As SRS was in the business of recycling and selling solvents, it is not likely it would have disposed of pure solvent. The Ecology and Environment report (Field Investigations of Uncontrolled Hazardous Waste Sites: FIT Project, December 29, 1980) suggests approximately 2.7 million gallons of solvent contaminated waste, not solvent waste. If ATSDR has additional information correctly indicating the amount of solvent disposed of, we would appreciate reviewing that information to determine how it may impact the RI/FS.

RESPONSE TO COMMENT 3

    As previously stated above in the general comments, the CT DEP and the EPA reviewed this document previously prior to it going out for public comment and neither agency questioned this information. It is unknown how much waste was disposed of at the landfill. In addition, the CT DPHAS personally interviewed an employee of the OSL landfill and the owner of Solomon Casket. Both reported that waste burning was commonly performed during the operation of the landfill. They also reported that spontaneous chemical fires also occurred.

    Your comment on the waste disposed of by SRS was addressed.

SPECIFIC COMMENT NO 4, PAGE 3, PAR. 2

    This statement should be changed to read:

    Since the time the landfill was covered and closed, and portions were subsequently subdivided, further remediation has not taken place. An RI/FS is being conducted at the Site, after which the EPA will determine the appropriate remedial measures to be taken based upon the extensive studies and the feasibility of remedial options.

RESPONSE TO SPECIFIC COMMENT 4

    The CT DPHAS does not see any reason to change this paragraph as it will not be adding any new information.

SPECIFIC COMMENT NO 5, PAGE 4 (B, PAR 4)

    We take issue with the statements made regarding the presence of seepage of landfill leachate. During the course of he various investigations conducted to date, no evidence of seeps has been observed. What has been observed, however, is the presence of surface water runoff from existing industrial activities.

RESPONSE TO COMMENT NO 5.

    On several occasions the CT DPHAS has observed and photographed what appears to be leachate seeps and not surface water runoff from the commercial facilities.

COMMENT NO. 6. PAGE 4 (B, PAR. 4)

    The Draft PHA states incorrectly that the areas north of the Rejean Road are believed to have been all wetlands prior to the construction of the existing subdivision. Based on aerial photographs, subdivision plans, and Town road construction drawings, the area directly north of the site was a wooded hill, but this was significantly northeast of the site.

RESPONSE TO COMMENT NO. 6.

    To respond to your comment, which concerns page 3, paragraph 2, the CT DPHAS is referring to the residential area immediately north of Rejean Road. This correction was included in the health assessment.

COMMENT NO. 7 page 4-5 (B, Par. 5)

    The statements made regarding combustible gases present an incomplete history of investigations undertaken by the agencies and the parties, as well as fail to detail the activities undertaken by the agencies and the parties, as well as fail to detail the activities undertaken to monitor and respond to concerns in the past and on a continuing basis.

    The Draft PHA should detail the fact that immediate steps were undertaken to seal floor cracks in the Parks and Recreation Building. Furthermore, an additional combustible gas indicator (CGI) has been placed in that building and an existing passive venting system was modified in June of 1992. In addition, a CGI has been placed in the three buildings at Southington Metal Fabricators and a passive venting system installed in two of the buildings which had detectable amounts of combustible gases. Finally, ESE, DPHAS, OSHA, and DEP have made available to workers, etc., the results of data collected with respect to those buildings, as well as information on appropriate precautions.

RESPONSE TO COMMENT NO. 7 pages 4-5(B, Par. 5)

    The Draft PHA does describe the actions taken and planned by the EPA, the CT DEP, the Southington Fire Department, the ATSDR, and the CT DPHAS in B. ON-SITE CONTAMINATION and in the PUBLIC HEALTH ACTION PLAN sections. However, in this, the final version of the PHA, we have included those actions taken during the health assessment process by the various agencies and the Southington Fire Department in the BACKGROUND section.

SPECIFIC COMMENT NO. 8, D. Health Outcome Data, Page 6

    We believe that the rationale for inclusion of the cancer study data arising out of the SRSNE Site is unsupported. The inclusion of this lengthy discussion is confusing and misleading to the public. This discussion should clearly note the results of the studies to date which do not show any correlation to this Site or any site for that matter.

    We would suggest that the final PHA include such discussion only as an appendix to the PHA for Site. While certainly of interest to the public, its inclusion within the body of a site-specific PHA is misleading and unnecessarily alarmist.

RESPONSE TO COMMENT NO. 8, D. Health Outcome Data, Page 6

    Although the cancer cluster investigation was initiated because of concern with the Solvents Recovery Services of New England (SRSNE) site, the cancer cases analyzed in this study were from the entire town of Southington. In addition, the CT DPHAS was evaluating the Old Southington Landfill site at the same time as the SRSNE site. Therefore, since the entire town was evaluated it was included in this public health assessment.

COMMENT NO. 9, COMMUNITY CONCERNS

    The Draft PHA should present a complete picture of the efforts undertaken to address community concerns. The Draft PHA should state that the EPA and the ATSDR held a public meeting in August of 1992 to provided information to the public on site conditions. In addition, the CT DEP, the EPA, and the parties' Project Technical Coordinator have met twice with residents and concerned citizens to discuss these concerns. Finally, data from monitoring in commercial and residential structures has been made available to owners of and workers within tested buildings, as well as information provided on appropriate precautions.

RESPONSE TO COMMENT NO. 9 COMMUNITY CONCERNS

    The Draft PHA presents community health concerns and those actions that were taken to address these concerns. For those actions taken to address community concerns please refer to the PUBLIC HEALTH IMPLICATIONS, section C. Community Health Concerns Evaluation . Those specific actions taken by the various agencies and the Southington Fire Department to address citizen's concerns are discussed in this section.

COMMENT NO. 10, ENVIRONMENTAL CONTAMINATION, Page 8, Par. 1

    See "General Comments" with respect to our concerns that the PHA was based upon selective review of data and incomplete consideration of activities conducted to date.

RESPONSE TO COMMENT NO. 10, ENVIRONMENTAL CONTAMINATION, Page 8, Par. 1

    The Draft PHA was reviewed by the EPA and the CT DEP before it went out for public comment. The CT DPHAS and the ATSDR rely on the EPA and the CT DEP for their comments and review of the available data. At that time neither agency commented that the information that was included in the Draft PHA was incorrect. The CT DPHAS agrees that more recent data was not included in the Draft PHA before it went out for Public comment. However, this data does not change our conclusions that the OSL site is a Public Health Hazard.

COMMENT NO. 11, PAGE 8, PAR. 2

    This statement as to the reason for indoor air sampling is incomplete and incorrect. This statement should be rewritten as follows:

    In addition, sampling for combustible gas in indoor air has and is being conducted as follow-up to citizen complaints, and as part of routine monitoring by Respondents, the CT DEP, the EPA and the OSHA. Continued sampling is being conducted in commercial buildings where elevated levels of combustible gas have previously been detected and measures taken. In addition, continued monitoring has been and continues to be performed in the residences. Both are being performed pursuant to a monitoring plan submitted to the CT DEP on June 26, 1992, and memorialized in an agreement with the CT DEP on August 15, 1992.

RESPONSE TO COMMENT NO. 11

    The CT DPHAS disagrees with your comment. Firstly, our review of the Southington Fire Department logs in November of 1993 indicate that continued sampling is not being conducted in all commercial buildings where elevated levels of combustible gas have been previously detected. According to the Southington Fire Department Record for the month of November 1993, the Southington Metal Fabricators buildings was no longer being monitored as per ESE's request. The CT DPHAS contacted the CT DEP with respect to this matter. In addition, the extent of the methane problem at the site was discovered as a result of information received by the CT DPHAS during site visits and a public availability session that occurred in November of 1991.

COMMENT NO. 12, TOXIC INVENTORY, PAGE 9

    This paragraph should make clear that the TRI would not serve to identify all facilities which may have contributed to contamination near the Site. It should be noted that considerable information regarding potential site and site vicinity contributors has been provided to the CT DEP and the EPA. In addition, information in DEP files demonstrates that other potential sources (i.e. Lori Corp.) may be responsible for historic ground water problems.

RESPONSE TO COMMENT NO. 12

    Your comment was incorporated in the PHA.

COMMENT NO. 13, B. ON-SITE, PAGES 9-16

    The Draft PHA concludes that there is no current health threat from contaminants which may be present as a result of the landfill, except for the potential physical hazard associated with combustible gas. This overall conclusion should be more clearly stated within the report. The RI/FS activities have, and through the remedial alternative selection process will, address contaminants present at the site and direct the steps necessary to continue to assure that the site does not pose a threat to human health.

RESPONSE TO COMMENT NO. 13

    Your comment was incorporated in the PHA.

COMMENT NO. 14, SUBSURFACE SOIL GAS, PAGE 13, PAR. 2

    This paragraph should further state the full facts regarding measures taken (e.g. passive venting) and monitoring underway. (See pages 2, 5 and of these comments). In addition, it should be noted that combustible gas readings within the commercial buildings have not indicated any significant problems.

RESPONSE TO COMMENT NO. 14, SUBSURFACE SOIL GAS, PAGE 13, PAR. 2

    The measures that have been taken to mitigate the methane problem in the commercial facilities on the landfill is discussed in the B. ON-SITE CONTAMINATION, Indoor Air section. Mitigation measures are addressed targeted towards the movement of soil gas into a building. Consequently, this is an indoor air issue.

    The CT DPHAS and the ATSDR disagree with your comment that the combustible gas readings within the commercial buildings have not indicated a significant problem. The identification of combustible gases in the interior of a building is cause for concern. In addition, the potential exists for toxic gases to migrate into the buildings and contaminate the indoor air.

COMMENT NO. 15, PAGE 14, PAR.2

    The reason for the presence of combustible gas outside of the two residential properties has not been fully determined. However, the statement that this presence is a result of migration from the southern portion of the Site is incorrect and contrary to the field data collected. A large number of combustible gas measurements have been taken in the soil gas across the northern portion of the Site. These measurements clearly show an absence of combustible gas across most of the northern portion, especially between the southern portion and the two residential properties. Additionally, measurements were taken from soil gas along the natural gas line utility trench, which runs parallel to Old Turnpike Road along the entire Site. These measurements clearly show an absence of combustible gas across most of the northern portion, especially between the southern portion and the two residential properties. Likewise, measurements taken from soil gas along the entire Site have demonstrated the lack of migration along this potential pathway. These data refute the notion that the combustible gas present at the two isolated locations is the result of migration from southern portion.

RESPONSE TO COMMENT NO. 15, PAGE 14, PAR. 2

    The paragraph offers two interpretations of the potential source of methane in the residential yards. The paragraph reads as follows: "This suggests that either methane is migrating from the southern areas of the landfill or is being generated naturally from buried organic materials."

    Since the CT DPHAS and the ATSDR are not 100 percent convinced that the methane is not migrating north from the southern portions of the landfill. In addition, in order for us to protect public health we have to be conservative in our interpretations of the pathways of contaminant migration.

COMMENT NO. 16, INDOOR AIR, PAGE 14-16

    This discussion should clearly differentiate between results at residences and those at businesses. The Draft PHA discussion is misleading as to the significance and location of any concerns. The Draft PHA should indicate that the EPA performed GC/MS at the residences twice and the results did not show any problem from those analyses, which included combustible gases.

RESPONSE TO COMMENT NO. 16, INDOOR AIR, PAGE 14-16.

    This information is already discussed in the health assessment.

COMMENT NO. 17, OFF-SITE CONTAMINATION - GROUNDWATER WELLS
PAGE 17

    The Draft PHA should clearly indicate that there are currently no private or public drinking water wells within this off-site area.

RESPONSE TO COMMENT NO. 17, OFF-SITE CONTAMINATION - GROUNDWATER WELLS PAGE 17

    On page 17, the discussion concerns off-site ground water monitoring wells. Your comment was incorporated in the Ground Water - Public Well and Ground Water - Private Wells sections.

COMMENT NO. 18, SURFACE WATER, PAGE 20, PAR. 3

    This paragraph improperly implies that compounds detected in the Quinnipiac River are site related. Numerous studies at the Quinnipiac River have shown the river to have been impacted by many sources upstream of the Site.

RESPONSE TO COMMENT NO. 18, SURFACE WATER, PAGE 20, PAR. 3

    The CT DPHAS knows that there are many sources in Southington that may have impacted the Quinnipiac River.

    This paragraph reports what contaminants were identified in the Quinnipiac River in the vicinity of the OSL site by the RI/FS consultants.

COMMENT NO. 19, PHYSICAL AND OTHER HAZARDS PAGE 22-23

    We believe that this section as presented relies upon selective review of data and an incomplete history of activities conducted to date. As such, it presents a biased and misleading characterization of such matters. This discussion should be balanced to reflect measures taken and monitoring underway. (See General Comments).

RESPONSE TO COMMENT NO. 19, PHYSICAL AND OTHER HAZARDS PAGE 22-23

    This section represents the concerns of state and federal health and regulatory agencies over the methane contamination problem on the OSL site. The CT DPHAS and the ATSDR believe the identification of combustible levels of methane are cause for concern. Indeed it is because state and federal regulatory and health agencies believe that the presence of methane at the OSL site poses a potential physical hazard that continuous monitoring is occurring and engineering controls have been installed.

COMMENT NO. 20, PATHWAYS ANALYSES PAGE 24, PAR. 2

    This section should be rewritten to reflect the fact that this potential exposure pathway was historic in nature. (See General Comments). In addition, the record does not clearly show that site-related contamination was responsible for this risk.

RESPONSE TO COMMENT NO. 20, PATHWAYS ANALYSES PAGE 24, PAR 3.

    The discussion of this completed exposure pathway clearly states that the exposure occurred in the past and as such will not be changed.

COMMENT NO. 21, PAGE 24, PAR 3.

    As noted in our General Comments, this discussion with respect to Town wells 2, 4, and 6 is inappropriate in this site specific PHA and is confusing and misleading to the public.

RESPONSE TO COMMENT NO. 21, PAGE 24, PAR 3.

    As part of the health assessment process all sources of exposure that are identified during our investigations of Superfund sites in a specific town are presented in this document. In addition, the CT DPHAS and the ATSDR are conducting a dose reconstruction study to assess the exposures that residents in Southington received from the Town's historically contaminated water supply.

    It is the purpose of the health assessment process to assess past, current, and potential future exposures.

COMMENT NO. 22, INDOOR AIR, PAGE 24

    This statement should be rewritten as follows: "Employees...may have received...

    as written, this statement is speculative and biased. The paragraph should reflect the fact that no adverse health effects are likely since methane is merely an asphyxiant, and should not speculate on "other unknown gases." Based upon numerous analyses by the EPA, combustible or other gases in the indoor air at the buildings at the site.

RESPONSE TO COMMENT NO. 22, INDOOR AIR, PAGE 24

    This statement is based on health effects that have been reported by several employees interviewed by the CT DPHAS. As such employees have become ill from the migration of gases into there working environment and the exposure occurred.

COMMENT NO. 23, SOIL PATHWAY, PAGE 25

    It should be noted that PAHs do not "readily evaporate."

RESPONSE TO COMMENT NO. 23, SOIL PATHWAY, PAGE 25

    Your comment is noted and a correction was made to the sentence in question.

COMMENT NO. 24, PAGE 26

    With respect to statements regarding landfill leachate see page 5 of these comments.

RESPONSE TO COMMENT NO. 24, PAGE 26

    Please refer to RESPONSE TO COMMENT NO. 5.

COMMENT NO. 25, AMBIENT-AIR PAGE 26

    This discussion is speculative and inflammatory. As stated above, the reports of open burning are not conclusive but rather indicate such activities occurred on a sporadic basis. The relevance of such historic allegations is unclear when the purpose of this PHA is to determine possible current and future risks associated with the Site and to recommend measures to address such risks.

RESPONSE TO COMMENT NO. 25, AMBIENT-AIR PAGE 26

    Again, your comment indicates that you don't understand the health assessment process. The purpose of the public health assessment is to determine all possible past, current, and future risks associated with the site.

    The CT DPHAS interviewed persons that worked in the landfill when it was in operation and residents who had businesses during this time. The CT DPHAS and the ATSDR have no reason to doubt eye- witness accounts of landfill activities from the community. Information received from the community is necessary for us to assess past exposures and at times can be more helpful to us in getting the historic exposure history than state and federal records.

COMMENT NO. 26, COMBUSTIBLE GAS PAGE 27, PAR. 2

    This statement should clarify that residences have been tested and no significant levels found. As written, homes and businesses are inappropriately grouped together. See General Comments above.

RESPONSE TO COMMENT NO. 26, COMBUSTIBLE GAS PAGE 27, PAR. 2

    The CT DPHAS and the ATSDR feel that the information is clearly presented with respect to what has been identified on residential and commercial properties. Additional information was added to this paragraph which discusses the high levels of combustible gases detected in the backyards of two residential properties.

COMMENT NO. 27, TCA AND TCE, PAGES 27 -28

    The Draft PHA should clarify the distinction between residences and businesses and the results of previous investigations. The PHA should not compare commercial business indoor air results with TEAM Study residential results. In addition, it should be noted that the TCE carcinogenicity assessment has been withdrawn from IRIS.

COMMENT NO. 28, TOLUENE AND BENZENE, PAGE 29 SEE COMMENT ABOVE
RESPONSE TO COMMENTS NO. 27, TCA AND TCE, PAGES 27-28 AND NO. 28, TOLUENE AND BENZENE, PAGE 29

    TCE, TCA, toluene, and benzene were identified in indoor air in residential homes at levels above what would be expected based on the results of the EPA TEAM study but below health comparison values. The Draft PHA does not compare the TEAM study results with the commercial facilities' indoor air results.

COMMENT NO. 29, LEAD/MERCURY, PAGE 31, PAR.2

    As stated in our General Comments, the inclusion of this discussion in a site specific PHA is inappropriate, confusing an misleading to the public, and inflammatory.

RESPONSE TO COMMENT NO. 29, LEAD/MERCURY

    Lead and mercury were detected in 1976 in three public water wells in Southington including well number five. The detection of lead and mercury in town production wells 4, 5, and 6 is information that the Southington Town residents are aware of, and as such, despite the fact that the CT DPHAS believes that the presence of these compounds was due to sampling or laboratory error, it must be discussed in the health assessment to clear up any misconceptions. As a rule the CT DPHAS is not in the business of holding back information from the public.

COMMENT NO. 30, CONCLUSIONS, INTRODUCTORY PARAGRAPH (SEE COMMENTS ON PAGE 3 OF THESE COMMENTS).

    This conclusion should state that Southington residents "may have been exposed...". This conclusion should indicate that other sources of site vicinity and area wide ground water problems are likely.

RESPONSE TO COMMENT NO 30, CONCLUSIONs, PAGE 38, # 1.

    The CT DPHAS obtained sufficient evidence from its review of the Southington Water Department files to conclude that people drank water that was contaminated. The Old Southington Landfill was placed on the National Priority List and is a Superfund Site because it contributed to the contamination of well number five.

    Other potential sources of contamination of this well are discussed in the Site Description and History Section.

COMMENT NO 31, PAGE 38, #2

    This conclusion should also state that based upon numerous analyses by the EPA, the CT DEP, the CT DPHAS, and ESE, combustible gases are not posing a threat to the residences.

RESPONSE TO COMMENT 31, PAGE 38, #2

    Although the ongoing monitoring, and wall monitors have not detected the presence of combustible gases to date, combustible gases have been identified in residential backyards. In addition, there is evidence of subsidence in the homes which could potentially create cracks in the foundation creating a potential methane migration pathway. It is because the EPA, the CT DEP, and the CT DPHAS feel that combustible gases could pose a threat to the residences that monitoring is required under a state order.

COMMENT NO. 32, PAGE 38, #3

    Conclusion should state that PCBs were only found in isolated subsurface samples.

RESPONSE TO NO. 32, PAGE 38, # 3

    The CT DPHAS sees no reason to change the wording in this conclusion. Since sampling was not performed underneath any of the building structures, stating that PCBs were only found in isolated subsurface samples is misleading.

COMMENT NO. 33, PAGE 38, #5

    As stated in our General Comments, these nonscientific assertions are inappropriate for a PHA and are misleading and inflammatory. While we appreciate the frustration which often accompanies the Superfund process, a frustration we also feel. These statements have no place in a document such as this.

RESPONSE TO COMMENT NO. 33, PAGE 38, #5

    See response to GENERAL COMMENT NO 5.

COMMENT NO. 34, PAGE 38, #6

    See previous discussion. Where the conclusions show no link to the Site, nor any demonstrated impact to the Town, they should not be part of this specific PHA.

RESPONSE TO COMMENT NO 34, PAGE 38, #6

    See response to GENERAL COMMENT NO. 3.

COMMENT NO. 35, PAGE 39, #1

    This recommendation should state that, pursuant to the monitoring plan submitted to the CT DEP and the EPA and memorialized in an agreement with DEP, combustible gases continue to be monitored and results submitted to the CT DEP. In addition, the EPA has performed monitoring in the residences. Finally, this recommendation should note that results of such investigations have shown no combustible gas impact on the four residences.

RESPONSE TO COMMENT NO. 35, PAGE 39, #1

    Continuous monitoring of all of the three affected facilities has not been ongoing. The CT DPHAS review of the Southington Fire Department files indicates that no monitoring was performed at the Southington Metal Fabricators Buildings in November of 1991 as per your request. The CT DPHAS contacted EPA and the CT DEP to address this matter. In addition, combustible gases have been identified in the backyards of residences. Although the level of combustible gases is below the lower explosive level (LEL), the CT DPHAS, the CT DEP, the EPA, and the ATSDR still feel that there is cause for concern. This concern is based on the fact that the homes are now showing signs of subsidence which could create cracks in the foundations potentially creating gas migration pathways.

COMMENT NO. 36, PAGE 39, #3

    Stress-See General Comments

RESPONSE TO COMMENT NO. 36, PAGE 39, # 4

    See response GENERAL COMMENT NO. 3.

COMMENT NO. 37

    As stated in our General Comments, landfill boundaries have been fully delineated. Moreover, the draft RI/FS submitted to the EPA characterizes the nature and extent of groundwater contamination.

RESPONSE TO COMMENT NO. 37

    Your comments on the landfill boundaries were incorporated into the health assessment. However, in discussions with the CT DEP, there is still some controversy as to the southern limits of the landfill. However, this recommendation will not be changed. The CT DPHAS and the ATSDR still feel that the Southington Community should be informed as to the extent and degree of overburden and bedrock contamination within and emanating from the landfill. Perhaps these questions will be answered in future public meetings that are planned to discuss the proposed remedial designs.

COMMENT NO. 38, PUBLIC HEALTH ACTION PLAN, PAGE 40, #1

    It should be stated in addition that both the Fire Department and ESE have been and continue to monitor conditions in the commercial buildings onsite and take any measures found necessary.

RESPONSE TO COMMENT NO. 38, PUBLIC HEALTH ACTION PLAN, PAGE 40, #1

    Part of your comment was incorporated in number 11 of the Public Health Action Plan. However, continuous monitoring of the three affected commercial facilities has not been occurring. The CT DPHAS review of the Southington Fire Department files indicates that monitoring was ordered stopped in November at the Southington Metal Fabricators Buildings as per your request. The CT DPHAS contacted the EPA and the CT DEP to look into this matter.

COMMENT NO. 39, PAGE 40, #2

    This statement should clarify that no adverse effects were indicated based upon the results of this assessment by the CT DEP.

RESPONSE TO COMMENT NO. 39, PAGE 40, #2

    Your comment was addressed in the PHA.

COMMENT NO. 40, PAGE 40, #3

    This statement should state that the results showed no contamination in the tap water.

RESPONSE TO COMMENT NO. 40, PAGE 40, #3

    Your comment was addressed in the PHA.

COMMENT NO. 41, PAGE 40, #6

    This paragraph should state that this action has been implemented pursuant to the monitoring plan submitted to the CT DEP and the EPA and memorialized in an agreement with the CT DEP.

RESPONSE TO NO. 41, PAGE 40, #6

    Your comment was incorporated in the Public Health Action Plan (PHAP). However, in November of 1993, the CT DPHAS was informed by the Southington Fire Department that the Southington Metal Fabricators facility was not to be monitored anymore. This facility continues to be a concern to the CT DPHAS with respect to the presence of combustible gases and should continue to be monitored.

COMMENT NO. 42, PAGE 40, #9

    The PHA should reflect the fact that the RI/FS has completed an investigation of surface soils and that the risk assessment has determined that surface soils do not present an unacceptable risk.

RESPONSE TO NO. 42, PAGE 40, #9

    Your comment was addressed in the health assessment. Although we agree with the risk assessments determination, our conclusions as to the health risk involved are based on the CT DPHAS and the ATSDR assessment of the soil and not the results of the EPA risk assessment. As previously stated the EPA Risk Assessment and the ATSDR PHA are two separate documents with different purposes.

COMMENT 43, PAGE 40, # 10

    For reasons set forth on pages 3 and 4 of these comments, the Site boundaries have been delineated.

RESPONSE TO COMMENT 43, PAGE 40, # 10

    See previous response.

COMMENT NO. 44, PAGE 40, #11

    This paragraph should state in addition that the residences are being monitored on a bimonthly basis.

RESPONSE TO COMMENT 44, PAGE 40, # 11

    This information was incorporated into the PHA.

COMMENT NO. 45

    Once again, we appreciate the opportunity to provide comments on the Draft PHA. As stated above we believe that the PHA should reflect the most current data available on site conditions and potential impacts. We believe that the PHA should be redrafted to focus on the presentation of potential current and future site-specific risks in a clear, understandable and unbiased fashion.

RESPONSE TO COMMENT NO. 45

    The most recent data does not change our conclusions concerning the site. The CT DPHAS and the ATSDR have categorized this site as a public health hazard based on past exposures to VOC contaminated drinking water from town well number five and the physical hazards associated with the methane contamination of indoor air. Please refer to our previous discussions concerning the differences between a Risk Assessment and a Public Health Assessment.

The CT DPHAS and the ATSDR thank you for submitting comments on the OSL PHA.



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