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PUBLIC HEALTH ASSESSMENT
RAYMARK INDUSTRIES
STRATFORD, FAIRFIELD COUNTY, CONNECTICUT


APPENDIX A
SITE MAP


Appendix A: Site Map



APPENDIX B
ATSDR PUBLIC HEALTH ADVISORY, MAY 1993

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 C
INTERAGENCY COMMUNICATION PLAN

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 D
GIS MAPS


Contaminant Levels of Health Concern


Population Density


Minority Population


Population 5 Years of Age and Younger



APPENDIX E
HEALTH CONSULTATION
FISH AND SHELLFISH
SUBSISTENCE FISHING MEMO
PRESS RELEASE-FISH DATA
FACT SHEETS-PONDS

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 F
HEALTH CONSULTATION
PRIVATE WELL SURVEY

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 G
CITIZEN QUESTION AND ANSWERS

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 H
FACT SHEETS NEIGHBORHOOD FORUMS

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 I
STRATFORD ENVIRONMENTAL UPDATES

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 J
PUBLIC HEALTH CODE/PRIVATE WELLS

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 K
HEALTH CONSULTATION
BLOOD LEAD SCREENING

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 L
HEALTH CONSULTATION
CANCER INCIDENCE

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 M
MEMO-BIRTH DEFECTS

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 N
RESPONSE TO PUBLIC COMMENT

The following lists all of the public comments received on the Public Health Assessment duringthe public comment period that ran from August 21st through October 6th.

Comment #1: CTDPH and ATSDR found an excessive rate for mesothelioma which is generallyacknowledged to be indicative of asbestos exposure. However, this rate was based on Stratfordas a whole and not residents who lived near or worked at the Raymark facility. The 16 reportedcases should be investigated further to see how many of them may be Raymark-related. While itis true that this epidemiological study did not find statistically significantly higher cancer incidence(except to bladder cancer) this could be simply that the Raymark effects are "diluted" in the largerall-of-Stratford database. The justification for ignoring the statistically significant higherincidence of cancers among persons less than 25 years of age because "no one type of cancer wasmore common" will be less than reassuring to the residents of Stratford. There is clearly still aneed for more detailed epidemiological studies of cancer incidence.

In September of 1993, CTDPH and ATSDR recommended: "Cohorts of individuals who mayhave had higher exposure to the waste should be considered for more extensive follow-up." Aswas shown by the epidemiology discussed above, this is vitally important to the community, butno discussions were included that indicate this work has been started, yet alone completed.

Response: Page 10 of the Public Health Assessment specifically outlines the follow-uphealth studies that will be done using Geographic Information Systems. As indicated in thePublic Health Assessment, this additional analysis will allow us to further explore theassociation between proximity to waste and cancer risk as opposed to the first analysiswhich looked at Stratford as a whole. In addition, page 9 of the document discusses theevaluation of Stratford residents with waste present in their yards and Public Worksemployees, two cohorts that were evaluated because they represented cohorts that mayhave experienced more significant exposures.

Comment #2: It is unfortunate to have to point out to CTDPH and ATSDR that, despite the toneof their document, the potential serious exposures associated with off-site Raymark contaminatedsoil will not automatically disappear when these affected soils are redeposited on another in-townproperty. These soils are currently inadequately and illegally stored at the Raymark Facility. Notonly does this represent a health hazard to those who must work on site, but also the surroundingcommunity may be impacted by the dust or inadequate site security. The "space-age" foam usedto cover the wastes may even encourage inquisitive trespassing!

Response: The Public Health Assessment clearly states that excavated soil does pose apotential health threat to workers at the facility (p. 41), residents living near the facility (p.42) and trespassers (p. 42). The CT DPH have and continue to work very closely withEPA to assure that 1.) temporary piles are covered in such a manner as to prevent any soilfrom becoming airborne, and 2.) that on-site activities are occurring in such a manner asto prevent the spread of contamination off-site. These commitments are clearly outlined inConclusion #1 and Recommendation #2 of the Public Health Assessment. In addition,perimeter air monitoring is being done at the site on a daily basis to ensure thatcontamination is not migrating off-site at levels of health concern.

Comment #3a: The Public Health Assessment neglects to mention that EPA in their April 1995Proposed Cleanup Plan state that they will "begin additional studies to further evaluate thegroundwater contamination...to identify potential groundwater cleanup options in the future, ifnecessary." The Public Health Assessment also failed to address the potential impacts ofgroundwater or LNAPL vapors which may be discharging into the basements of homeowners orbusinesses.

Response: The Public Health Assessment does identify the groundwater contaminationand the potential for volatilization into confined spaces as a potential exposure pathway (pg42.) In addition, Conclusion #5 states that additional information regarding groundwatermigration, extent of contamination and potential for off-gassing needs to be gathered. Recommendation #4 outlines these same issues and as part of the Public Health ActionPlan, we commit to reviewing that additional data.

Comment #3b: The potential health problems associated with solvents were not mentioned norwas the ability of solvents to mobilize otherwise relatively immobile compounds in thesub-surface. Since the purpose of the well survey was to locate and test private wells in order toevaluate potential health impacts, it is inconsistent for agencies responsible for protecting publichealth not to collect and analyze groundwater from these wells to state that since public water is available, no one should ever access this contaminated groundwater for potable purposes.

Would the CT DPH further explain what actions it now plans to take in terms of these wellsspecifically, 1) if testing has been undertaken, and what results were obtained, 2) if well permitswere granted whether they will now be revoked, 3) if permits were not granted, what action willbe taken, 4) what warnings CT DPH has provided or will provide to the homeowners relating tothis well water and 5) the technical and regulatory basis for their statement on p. 44 that "These wells are not located near the Raymark facility or other waste locations." In particular, how does "less than one mile" equate to "not near?"

Response: Appendix F of the Public Health Assessment outlines the well surveymethodology, the findings and the follow-up activities. The purpose of the survey was to1.) identify wells within 0.5 miles of a known Raymark waste site, and 2.) sample any wellswithin 0.5 miles of a site. As stated, a total of 15 addresses were identified as having anactive private water supply well. Of these, none were located within 0.5 miles, six werelocated within one mile but greater than 0.5 miles two were located one to two miles from asite and seven were located 2.5 to 3.5 miles from any known waste site. Of the six privatewells located between 0.5 and one mile, four were near Wooster School, one was near theLordship area and 1 was near the Raymark facility but upgradient from the site.

The local health department followed up with the fifteen private wells and encouraged testing.

In initiating the private well survey, the agencies were most interested in determining ifprivate wells existed near the Raymark facility. Unlike the other off-site waste locationswhere soil contamination is not adversely impacting groundwater, the groundwater at thefacility is grossly contaminated and stated as such on page 19 of the Public HealthAssessment.

Comment #4: No discussion is given of the potential adverse health impacts (other than eatingshellfish) of the high levels of PCBs (greater than 10 ppm) found in Ferry Creek sediments. Sincethis was predominantly PCB-1268 (an unusual aroclor associated with Raymark wastes), it isrelated to the Raymark facility. No discussion was given of whether these sediments might beexposed at low tide or might otherwise impact local residents.

Response: Data available for Ferry Creek, at the time the document was written, wasinsufficient to evaluate the potential risks associated with direct contact with sediments. We are committed to evaluating this data.

Comment #5: I am concerned about the reports in the news media involving the study of cancerrates in Stratford. To only study the data of the Town of Stratford gives a misleading result. Theonly way to have an accurate picture of where Stratford truly stands is to study the health datafrom surrounding towns (Trumbull, Bridgeport, Shelton, Milford) as well. We do not live in avacuum. While Raymark was indeed a polluter, it also is not isolated. This entire region, forexample, is affected by air pollution from New York City. If it was found that surrounding townsalso had a slightly elevated number of bladder cancer incidents or the rare form of lung cancerthen perhaps the problem(if there is indeed a problem) is a regional one-not something that isunique to Stratford.

Response: The cancer incidence study in Stratford was initiated for two specific andfocused reasons: 1.) determine if Stratford had experienced a higher than expected rate ofcancers over the study time period and 2.) respond to citizens concerns regarding whethercertain cancers had occurred more in Stratford residents. Both of these questions wereraised in light of the Raymark environmental contamination in the town. The mostsignificant limitation of this type of cancer analysis is it does not show cause and effect ortell us what caused the differences in cancer rates.

Cancer is not one disease but many diseases with different causative factors. Whilehereditary, dietary and environmental agents may increase an individuals risk of cancer, certain characteristics of a population of people also change the risk of disease in thatgroup. Age, race, ethnicity and socioeconomic status all contribute to cancer risk in apopulation. Because of this, we compare Stratford to the State as opposed to comparing itto surrounding towns. We know than the population characteristics of Bridgeport,Trumbull or Shelton are very different than the population characteristics of Stratford. When we compare Stratford to the State the differences in population characteristics areless dramatic and provide for a better comparison.



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