Review of the Preliminary Draft Final Remedial Investigation Report for Operable Unit 6 - Commercial Properties
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.
The U.S. Environmental Protection Agency (EPA) and the Connecticut Department of Environmental Protection (CT DEP) requested that the Connecticut Department of Public Health (CT DPH) review and comment on the Preliminary Draft Final Remedial Investigation Report for Operable Unit 6 (OU6) - Commercial Properties, prepared for EPA by Tetra Tech NUS, Inc. (December 2003).
The Remedial Investigation Report (RI) for OU6 evaluates, for 27 properties, the nature and extent of contamination in soils or sediment that resulted from past disposal practices of the Raymark Industries facility in Stratford. The RI also documents the public health and environmental risks associated with Raymark waste at the 27 properties.
Raymark Industries was a manufacturer of automotive friction components in Stratford for 70 years, beginning in 1919. During its operation, it was common practice to dispose of manufacturing wastes at the Raymark facility and at various locations in the Town of Stratford. Beginning in 1993, EPA sampled soil at many commercial, recreational and residential properties throughout Stratford to identify the presence of Raymark wastes. In the mid 1990s, EPA conducted soil removal actions at a number of residential properties where the presence of Raymark waste presented the greatest health threats. Properties where sampling did not find immediate threats were designated to be addressed by EPA at a future date. These were primarily commercial properties. In 2002, EPA continued its investigation of soil at properties that had not previously been adequately investigated or addressed. The OU6 RI presents the results of these investigations as well as evaluations of health and environmental risks from Raymark wastes.
In reviewing the draft RI, CT DPH focused on the human health risk-related portions of the document. CT DPH provides the following comments to EPA for its consideration.
Section 1.4.3 Raymark Waste Area
1. It is not clear how samples from different depths at the same location were treated for purposes of deciding whether the location met the definition of Raymark Waste. For example, were all data (multiple sample depths) from the same location combined or was each sample treated separately? If each sample was treated separately, and a sample from one depth met the definition of Raymark Waste but other samples from different depths at the same location did not, which data from that location were used in the risk assessment?
2. The document should more clearly explain that in the phrase "fraction of the site with Raymark waste," the term "site" means the portion of the property not covered by buildings (that is, not the entire site/property).
3. The procedure described on page 1-15 (limitation #3) is not sufficiently health protective. Specifically, the procedure involves assuming that a sample is not Raymark waste if the first two criteria for defining Raymark waste are met but there are no data to determine whether the third criteria is met. When faced with a lack of data, health/risk assessors should choose the more conservative (health protective) approach. In this case, the more conservative approach was not followed. If there were not enough data to determine whether all criteria were met, the sample should have been assumed to be Raymark waste.
Section 126.96.36.199 Exposure Setting
4. This section (page 1-53) includes a statement that exposure is assumed to a depth of 15 feet, even where pavement currently exists. However, Table 1-1 includes a calculation of percentage of exposed soils covered by Raymark Waste. This fraction is used in the risk calculation. Please confirm that the risk assessment assumes that exposure occurs/may occur even where pavement currently exists.
Section 188.8.131.52 Potential Receptors
5. This section states that the commercial worker scenario is intended to be protective of customers and shoppers who may frequent the property. Is the scenario also protective of youth trespassers or nearby residents who may visit the property, especially portions of the property that are not paved and where access is not restricted? There are a number of properties (listed below) where the youth trespasser scenario seems appropriate. These are properties that are undeveloped, have none or limited access restrictions, no pavement, and are located near residential areas. At each of these properties, the future commercial worker was the only scenario evaluated. The document should state whether the risk assessment assumptions made in the commercial worker scenario would also be protective of a youth trespasser.
Properties where youth trespasser scenario seems reasonable:
Lot behind 326 Ferry Blvd.
CT Right Of Way
Wetland along Lockwood Avenue
300 Ferry Blvd.
576 East Broadway
600 East Broadway
304 E. Main Street
1 Beacon Point Road
Section 3.0 Property Evaluations
6. Figure 3-15 (DOT Ferry Blvd.) does not appear logical. It shows only a small portion (9.7%) of the site with Raymark Waste. However, of the two samples, one met the definition of Raymark Waste. How could the fraction of the site with Raymark Waste be so small?
Section 4.4 Conclusions
7. The final paragraph is confusing. It states that there are additional properties on Blackman Ave., Sidney St., East Main Street and South Avenue, to be investigated. If Raymark Waste is found on these properties, will they become part of OU6 or will they be evaluated with Short Beach Park and Stratford Landfill (OU6)? A related comment is that OU6 is mentioned in this section but is not included in the list in Section 1.3.2.
Based on its review of the draft RI, CT DPH believes that there are several changes that are needed to improve the clarity of the document. In addition, CT DPH has noted several instances where risk assessment assumptions could be modified to be more health protective. CT DPH recommends that EPA consider modifying the draft RI in accordance with CT DPH's comments provided in this health consultation.
The Health Consultation for Review of the Preliminary Draft Final Remedial Investigation Report for Operable Unit 6 - Commercial Properties, Raymark Industries Site was prepared by the Connecticut Department of Public Health under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ASTER). It is in accordance with approved methodology and procedures existing at the time the health consultation was initiated.
Gregory V. Ulirsch
Technical Project Officer, CAT, SSAB, DHAC
The Division of Health Assessment and Consultation (DHAC), ATSDR, has reviewed this Health Consultation and concurs with its findings.
for Team Leader, CAT, DHAC,ATSDR
Margaret L. Harvey, MPH
Environmental Epidemiology and Occupational Health
Connecticut Department of Public Health
ATSDR Regional Representative:
ATSDR Technical Project Officer:
Greg V. Ulirsch
Superfund Site Assessment Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry