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HEALTH CONSULTATION

Follow up 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 recommendations listed in this document.


BACKGROUND AND STATEMENT OF ISSUE

In February 2003, the U.S. Environmental Protection Agency (EPA) requested that the ConnecticutDepartment of Public Health (CTDPH) review soil investigations and make public healthdeterminations for four properties in Stratford that were initially investigated by EPA 10 years agoas part of environmental studies of the Raymark Industries disposal sites. CTDPH has alreadyresponded to a similar request from EPA to review soil data for 104 properties. CTDPH prepareda health consultation in July 2002 on the review of 104 properties (ATSDR 2002). That healthconsultation is included in Attachment A and should be referred to for full details on the background and methods for this evaluation.


DISCUSSION

CTDPH reviewed the files provided by EPA for each of the four properties. The review focused onsoil data collected at depth that had not been previously reviewed by CTDPH as part of its originalHealth Impact Statement.(1) CTDPH evaluated data using the health-based residential propertycleanup levels for lead, PCBs, and asbestos developed for Stratford by EPA (ATSDR 2002). Thecleanup levels are 400 mg/kg for lead, 1 mg/kg for PCBs, and 1% for asbestos. CTDPH alsochecked each file to confirm that there was follow up on prior recommendations to collect depthdata. 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 the 2002 health consultation included in Attachment A (ATSDR 2002).


CONCLUSIONS AND RECOMMENDATIONS

CTDPH has reviewed files provided for four properties in Stratford which were identified by EPAas missing final Health Implication Statements. Based on the information provided by EPA,CTDPH has determined that there is no public health threat for each of the following four properties. Recommendations regarding follow up actions are provided below.

50 Clinton Avenue and 1318 Elm Street
Elevated concentrations of lead are present in soils at depth at these two properties. However, the concentrations do not meet the definition of Raymark waste (refer to ATSDR 2002 for a definition of Raymark Waste). Therefore, no further EPA actions are needed. These properties have been referred to the local health department which will follow up with a letter, reminding residents about the presence of lead in soils at depth and advising them about ways to minimize exposure.

800 Housatonic Ave. Extension
Elevated concentrations of lead in surface soils at this property appear to be related to possible lead paint, rather than Raymark waste. No further EPA actions are needed. However, this property has been referred to the local health department for follow up regarding the lead in surface soils.

Fourth Avenue Pond
This property does not have elevated levels of contaminants in soils. No further actions are necessary.


REFERENCES

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

Health Consultation - Evaluation of Soils at Properties Located Near Raymark Industries Waste Disposal Areas, Agency for Toxic Substances and Disease Registry, July 31, 2002.


CERTIFICATION

The Health Consultation for FOLLOW UP EVALUATION OF SOILS AT PROPERTIES INSTRATFORD LOCATED NEAR RAYMARK WASTE DISPOSAL AREAS was prepared bythe Connecticut Department of Public Health under a cooperative agreement with the Agency forToxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the health consultation was initiated.

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


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

Chief, SSAB, DHAC, 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


ATTACHMENT A: HEALTH CONSULTATION: EVALUATION OF SOILS AT PROPERTIES LOCATED NEAR RAYMARK INDUSTRIES WASTE DISPOSAL AREAS - JULY 2002


HEALTH CONSULTATION

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

RAYMARK INDUSTRIES, INCORPORATED
STRATFORD, FAIRFIELD COUNTY, CONNECTICUT
EPA FACILITY ID: CTD001186618

July 31, 2002

Prepared by:

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


TABLE OF CONTENTS

BACKGROUND AND STATEMENT OF ISSUE

DISCUSSION

CONCLUSIONS AND RECOMMENDATIONS

REFERENCES

APPENDIX A: PROPERTIES THAT CTDPH HAS DETERMINED POSE NO PUBLIC HEALTH THREAT AT THIS TIME AND NO FURTHER ACTIONS ARE NECESSARY

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

CERTIFICATION

PREPARER OF HEALTH CONSULTATION



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.

  1. 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)

  1. 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)

  1. 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 A:

PROPERTIES THAT CTDPH HAS DETERMINED POSE NO PUBLIC HEALTH THREAT AT THIS TIME AND NO FURTHER ACTIONS ARE NECESSARY

PROPERTIES IN EPA TABLE 6a
10 Clinton Avenue
40 Clinton Avenue
130 Clinton Avenue
52 Cottage Place
66 Cottage Place
1336 Elm Street
1 Fifth Avenue
50 Fifth Avenue
126 Fifth Avenue
80 Shoreline Drive
15 Housatonic Avenue
25 Housatonic Avenue
35 Housatonic Avenue
65 Housatonic Avenue
75 Housatonic Avenue
181 Housatonic Avenue
42 Shoreline Drive
44 Shoreline Drive
46 Shoreline Drive
48 Shoreline Drive
50 Shoreline Drive
52 Shoreline Drive
54 Shoreline Drive
56 Shoreline Drive
58 Shoreline Drive
62 Shoreline Drive
64 Shoreline Drive
66 Shoreline Drive
68 Shoreline Drive
72 Shoreline Drive
76 Shoreline Drive
78 Shoreline Drive
116 Third Avenue

PROPERTIES IN EPA TABLE 6c
68 Blakeman Place
78 Blakeman Place
116 Blakeman Place
47 Clinton Avenue
57 Clinton Avenue
60 Clinton Avenue
70 Clinton Avenue
54 Cottage Place
650 E. Broadway
668/670 E. Broadway
1010 Elm Street
1262 Elm Street
1346 Elm Street
1290/1292 Elm Street
90 Fifth Avenue
2 Harris Court
59 Housatonic Avenue
103 Housatonic Avenue
74 Meadow Street
370 Patterson Avenue
414 Patterson Avenue
70 Shoreline Drive
74 Shoreline Drive
674 Stratford Avenue
699 Stratford Avenue
40 Third Avenue
1070 Elm Street
1100 Elm Street
1178 Elm Street
35 Fifth Avenue
111 Fifth Avenue
191 Housatonic Avenue
309 Housatonic Avenue
60 Third Avenue

PROPERTIES IN EPA TABLE 6d
58 Blakeman Place
86 Blakeman Place
134/136 Blakeman Place
156/158 Blakeman Place
14 Clinton Avenue
100 Clinton Avenue
110 Clinton Avenue
36 Cottage Place
720 East Broadway
1139 Elm Street
1279 Elm Street
1280 Elm Street
1356 Elm Street
191 Ferry Boulevard
121 Housatonic Avenue
231 Housatonic Avenue
338 Housatonic Avenue
64 Meadow Street
382 Patterson Avenue
402 Patterson Avenue
35 Third Avenue
73 Willow Avenue
125 Willow Avenue



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

Table of Contents





1 Health Implication Statements were prepared by CTDPH at the time the original EPA investigations were conducted ten years ago. Each Health Implication Statement outlined the public health implications for a specific property and made recommendations for further actions, as needed.


Table of Contents

  
 
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