HEALTH CONSULTATION

Evaluation of Soils at Properties Located Near Raymark Industries Waste Disposal Areas

RAYMARK INDUSTRIES, INCORPORATED
STRATFORD, FAIRFIELD COUNTY, CONNECTICUT

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

BACKGROUND AND STATEMENT OF ISSUE

In March 2002, the U.S. Environmental Protection Agency (EPA) requested that the ConnecticutDepartment of Public Health (CTDPH) review soil investigations and make public healthdeterminations for approximately 104 properties in Stratford that were initially investigated byEPA ten years ago as part of environmental studies of the Raymark Industries disposal sites. Inthe early and mid-1990s, EPA conducted site investigation activities at over 500 properties inStratford that were suspected to have received waste materials from Raymark Industries, Inc. EPA defined Raymark waste as material containing two of three compounds indicative ofRaymark materials (lead, polychlorinated biphenyls [PCBs], asbestos) at concentrationsexceeding levels of concerns for those compounds (400 mg/kg, 1 mg/kg, 1%, respectively)(Stratford CT Residential Property Investigation and Excavation Protocol, 1994).

At the time the EPA investigations were conducted, CTDPH reviewed data for most of the 500properties and issued Health Implication Statements for each property. Each Health ImplicationStatement outlined the public health implications for the specific property and maderecommendations for further actions, as needed. For a number of properties, the HealthImplication Statement concluded that current conditions posed no health threat but recommendedadditional sampling to determine the extent of contamination at depth. For most of theseproperties, additional samples were collected by EPA but a final Health Implication Statementevaluating the depth data and potential future exposures was not issued.

In order to reach closure on the properties identified by EPA as missing final Health ImplicationStatements, CTDPH was asked by EPA to review soil data for each property and issue a finalHealth Implication Statement. In providing information to CTDPH, EPA placed each of the properties into one of four categories, depending in part on what the initial Health ImplicationStatement indicated for the property. The list of properties was provided to CTDPH in tabularform, with each category of properties presented in a separate Table (Table 6a, 6b, 6c, 6d). A fileof relevant data was provided for each property. Although the categories are not relevant for thehealth evaluation per se, CTDPH has retained the categorization scheme developed by EPA for the sake of consistency.

DISCUSSION

CTDPH reviewed the files provided by EPA for each property. CTDPH's review focused on soildata collected at depth that had not been previously reviewed by CTDPH as part of the initialHealth Impact Statement. CTDPH evaluated data using the health-based residential propertycleanup levels for lead, PCBs and asbestos developed for Stratford by EPA 1993, in consultationwith ATSDR and CTDPH (Stratford CT Residential Property Investigation and ExcavationProtocol, 1994). The cleanup levels are 400 mg/kg for lead, 1 mg/kg for PCBs and 1% forasbestos. CTDPH also checked each file to confirm that there was follow up onrecommendations made to collect depth data. If depth data were never collected, CTDPHreevaluated the need for collecting such data.

A discussion of potential exposure pathways and potential health impacts from exposure toRaymark waste is presented in the Public Health Assessment for the Raymark Industries site(ATSDR 1996). The health basis for the residential property cleanup levels for lead, PCBs andasbestos is presented in three ATSDR Records of Activity (ATSDR 9/8/93; ATSDR 11/10/93;ATSDR 9/30/97).

CONCLUSIONS AND RECOMMENDATIONS

CTDPH has reviewed files provided for approximately 104 properties in Stratford which wereidentified by EPA as missing final Health Implication Statements. Based on the informationprovided by EPA, CTDPH has reached the following conclusions regarding public healthimplications from exposure to soils at these properties.

Health Implication Statements

1. No Public Health Threat, No Further Action Necessary

Based on the information provided by EPA, CTDPH has determined that the properties listed inAppendix A to this health consultation pose no public health threat at this time. No further actions are needed at this time for the properties listed in Appendix A.

2. No Public Health Threat, Recommend Depth Sampling if Digging Occurs in theFuture

For the following two properties, CTDPH has concluded that there is no public health threat atthis time. However, CTDPH recommends that if digging is anticipated, depth sampling will be necessary to determine if a health threat could be created.

Condo Association Property/4th Avenue Empty Lot (EPA Table 6a)
605 Broad Street/CT Business Institute (EPA Table 6a)

3. No Public Health Threat, Recommend Additional Depth Sampling if DiggingOccurs in the Future.

For the following two properties, CTDPH has concluded that there is no public health threat atthis time. Some depth sampling has been conducted at these properties but it is insufficient tosupport a conclusion about public health threat. Therefore, CTDPH recommends that if diggingis anticipated, more extensive depth sampling will be necessary to determine if a health threat could be created.

50 Clinton Avenue (EPA Table 6d)
1318 Elm Street (EPA Table 6c)

4. No Health Implication Statement Necessary

Properties listed in Appendix B are those properties which CTDPH referred to the Local HealthDepartment after EPA sampling found lead without either of the other two constituents indicativeof Raymark waste. Lead may be present because of lead-based paint and will be investigated assuch. CTDPH is working with the local health department to confirm that all necessary publichealth actions were taken at these properties. CTDPH will report to EPA on the status of these properties when the followup work has been completed.

REFERENCES

Agency for Toxic Substances and Disease Registry Record of Activity, September 8, 1993.

Agency for Toxic Substances and Disease Registry Record of Activity, November 10, 1993.

Agency for Toxic Substances and Disease Registry Record of Activity, September 30, 1997.

Public Health Assessment for Raymark Industries, Stratford, Connecticut, Agency for ToxicSubstances and Disease Registry, September 25, 1996.

Stratford Connecticut Residential Property Investigation and Excavation Protocol, August 30, 1994.

APPENDIX B: PROPERTIES THAT WERE REFERED TO THE LOCAL HEALTH DEPARTMENT FOR FOLLOW UP BECAUSE OF LEAD

PROPERTIES IN EPA TABLE 6b
48 Blakeman Place
106 Blakeman Place
146 Blakeman Place
80 Clinton Avenue
750 East Broadway
1618/1620 Elm Street
1 Harris Court
390 Patterson Avenue
640 Stratford Avenue

CERTIFICATION

The Health Consultation for SOILS AT PROPERTIES LOCATED NEAR RAYMARKINDUSTRIES WASTE DISPOSAL AREAS was prepared by the Connecticut Department ofPublic Health under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the health consultation was initiated.

Gregory V. Ulirsch
Technical Project Officer, S.P.S., SAAB, DAC

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

Roberta Erlwein
Chief, SAAB, DAC, ATSDR

PREPARER OF HEALTH CONSULTATION

Margaret L. Harvey, MPH
Epidemiologist
Environmental Epidemiology and Occupational Health
Connecticut Department of Public Health

ATSDR Regional Representative:

William Sweet
EPA/New England

ATSDR Technical Project Officer:

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

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