PUBLIC HEALTH ASSESSMENT
SOLVENTS RECOVERY SERVICES OF NEW ENGLAND
SOUTHINGTON, HARTFORD COUNTY, CONNECTICUT
Based on information reviewed, ATSDR has concluded that this siteis a public health hazard because of the risk to human healthresulting from past, present, and potentially future exposures tohazardous substances at concentrations that may result in adversehealth effects. As discussed in the Human Exposure Pathwayssection, human exposure to volatile organic compounds and heavymetals via inhalation, ingestion and dermal contact has occurred inthe past and may occur in the future through migration ofcontaminants off-site. Exposure has occurred, and couldpotentially occur through surface water, ground water, air, soil,and fish contamination. The three major sources of thiscontamination were from the contaminated public water supply,airborne exposure to sludge incineration products, and exposure toambient air containing VOC's resulting from ground water stripping.
Given the extent of contamination identified to date on the SRSNEsite, the former Cianci property, and the other potentiallycontaminated off-site properties identified, the followingconclusions and recommendations are warranted.
- A large portion of the population of Southington was exposed toa variety of site related contaminants for an unknown period oftime, through the contamination of public wells (#4 and #6). This exposure was stopped over l0 years ago by removing thosewells from production. In addition public wells 2 and 5 werecontaminated at times. Although not directly site related,these sources interacted with site related contamination through mixing and distribution in the public drinking water system. Continued monitoring has assured that the public water supply iscurrently safe.
- The potential exists for contaminated ground water from theCurtiss wellfield area to migrate south and southeast now thatWells 4 and 6 are no longer pumping. The CT DEP has assessedevery property to the west, south, southeast and southwest ofthe SRSNE site for private water wells. The CT DEP hasmonitored and has plans to continue monitoring private wells inthese areas.
- One (1) site related private well was found to be contaminatedwith solvents during the 1990 sampling conducted by the CT DHS. Though the individual living at the residence with contaminatedwater has been drinking bottled water for approximately 10years, other exposures from the contaminated well may beoccurring (e.g. VOC exposure from shower sprays). Thisindividual was notified and the property is being connected tothe public water supply system.
- Based on community concerns, sampling of sixty-four privatewells was conducted by the EPA in 1990 and subsequentlyresampled by the CT DEP. These results revealed one (1) homewith lead levels above the proposed MCL of 20 ug/l. Two privatewells were found to have elevated levels of total VOC's andseven homes had elevated sodium levels.
- The potential exists for public and private wells located on thefringe of the zone of ground water contamination emanating fromSRSNE to become contaminated. These wells should beperiodically monitored.
- PCBs (soil and ground water) and dioxin (soil only) have beenidentified on site.
- Excavation and removal of contaminated soils and wastematerials, may expose workers to VOCs, PCBs, dioxins, and heavymetals through inhalation of volatiles and fugitive dusts.
- The ground water recovery system and air stripper are reducingground water levels of VOCs but increasing their levels inambient air. Ambient air samples taken in July 1990 documentedlevels of VOC contamination, some of which exceeded background(USEPA TEAM Study 1987). Air pollution equipment is recommendedto at least ensure compliance with CT air toxics standards andprevent exposures that may pose a public health risk.
- Deteriorated asbestos-like material was observed in theinsulation on the condenser located outside in the old processarea. This material should be analyzed as asbestos inhalationexposures to onsite workers may occur.
- Due to documented exposures to site related compounds and due to specific concerns expressed by local citizens, a number ofhealth outcome data bases were evaluated. Given the inherentlimitations of epidemiology, any elevation in disease rates forSouthington during the time period when solvent exposure likelyoccurred cannot be considered causal in nature. A review oftumor incidence data indicates that there are slight elevationsin some age specific bladder cancers for the town of Southingtonbetween 1979-1988. However, based on the available data, thereis no difference in rates for birth defects or learningdisabilities between Southington and the State of Connecticut. While there were increases in infant and perinatal mortalityrates for Southington, as compared with towns surroundingSouthington, or the State, between 1949-1965, these rates are nolonger elevated and in fact, remain lower than the twocomparison populations in the State of Connecticut and nearbytowns.
- A preliminary investigation into the potential causes forthe elevation of bladder cancer is currently beingconducted. A recommendation regarding the need for futurehealth studies on these health effects will be made basedupon completion of this investigation.
- No further evaluation into birth defects or learningdisabilities is now being conducted, based upon thefindings, as stated above.
- The early patterns of elevated perinatal and infantmortality for the town of Southington are not consistentwith adjacent towns or the state. Although these patternscould be associated with environmental contamination, suchan association would be virtually impossible to prove due toa lack of environmental data from that period. For thisreason no further research into this health outcome isrecommended at this time.
- Psychological stress associated with the past and presentoperations at SRSNE including both health (e.g., headaches,nausea) and attitudinal effects (demoralization, upset,perceived threat, lack of trust and general helplessness)have been observed in this community and are cause forconcern.
- According to a citizen's concern, six residents that livedadjacent to SRSNE died from phosgene exposure related tosite activities. No direct information or evidence tosupport this exposure was found.
- There are a number of areas where key pieces ofenvironmental data are not available, incomplete, oruninterpretable. Lack of these data during cleanupactivities could lead to further contamination if, forexample, contaminated sediments that had not been previouslyidentified are disturbed during the remediation process. Problems with quality assurance also raises doubt about someof the data.
- Area residents may be, or have been, at risk from exposureto air, surface water, and soil contamination while engagedin recreational activities in the Quinnipiac River andoff-site marshlands (former Cianci property, wetlandslocated just south east of the subject site), and thoseproperties suspected of having been previously used by SRSNEfor disposal of their hazardous waste sludges The CT DEPand the EPA are currently investigating those propertiessuspected of having been contaminated with wastes from theSRSNE facility.
The home with lead levels was retested by the CT DEP to confirmthe laboratory results and determined not to be site related. The CT DEP believes the source of lead could be internal leadplumbing fixtures in the house. Information regarding thepotential health effects of lead, both in children and adults,should be made available to the residents with the contaminatedwell.
The two (2) homes identified with elevated VOC's were placed onbottled water by the State of Connecticut. The CT DEP hasdetermined that the source of contamination is not SRSNE. Inaddition, the CT DEP assessed and sampled all private wellswithin close proximity to SRSNE. The residents with elevatedsodium levels in their wells have been notified and they haveconsulted with their physicians. One (1) resident was providedwith bottled water. The residents with elevated sodium have beeninformed of the possible health hazards and one (l) resident hasbeen provided with bottled water.
The identification of PCB, dioxin and furan contaminationwarrants future and ongoing monitoring efforts to identify themagnitude, extent and source of contamination. Dioxin and furanisomers (tetra, penta, hexa, hepta, and octa) should beidentified. In addition to subsurface soil sampling, surfacesoil samples should be collected from a depth of 0-3 inches.
As part of the Remedial Investigation/Feasibility Study (RI/FS)for SRSNE, sampling for PCB, dioxin and furan will be conductedto identify the magnitude, extent and source of thiscontamination.
The RI/FS will evaluate treatments that will minimize releasesand residuals at the work site periphery to protect workers andnearby residents during remedial activities.
Since a complex mixture of organic solvents is being strippedfrom the water, it is necessary to assess the risks based on themixture, instead of individual volatiles if strict air pollutioncontrols are not put in place. A cumulative risk analysis isrecommended.
Psychological stress should be addressed within thecommunity. Local counseling centers, and physicians, shouldbe notified of the present situation, so that they may takeit into account when seeing patients.
Specifically, more information on off-site air emissions,sediment data for the Quinnipiac river, the extent of flyash and heavy metal contamination (identified in neighboringproperties in 1974), and the total extent of contaminationsurrounding the site needs to be identified andcharacterized.
Access to the former Cianci property should be limited tothose engaged in remediation activities. Warning signsregarding the potential hazards of ingesting contaminatedbiota (i.e., rabbits) should be placed around theproperties.
HEALTH ACTIVITIES RECOMMENDATION PANEL (HARP) RECOMMENDATION
The Solvents Recovery Services of Southington, Connecticut hasbeen evaluated for appropriate follow-up with respect to healthactivities. It is recommended that follow-up health activitieswould be appropriate. Specifically, after further evaluation adecision will be made as to the need for a disease andprevalence study or some continued evaluation of cancerincidence. Furthermore, an environmental health educationprogram is recommended to advise the public health professionaland the local medical community of the nature and possibleconsequences of exposure to contaminants at the SolventsRecovery Services of New England Inc., site. The value ofobtaining a complete and accurate exposure history will bestressed as part of this program. In addition, information thatis provided on contaminants may include, but not be limited to,the physical nature of the contaminant, potential exposurepathways (i.e., soil, water, air, food) exposure routes(inhalation, ingestion, dermal), potential health effects,symptoms of exposure and testing and treatment, if known.
To respond to community concerns, and based on the HARP (HealthActivities Recommendation Panel) recommendations, ATSDR hasdeveloped the following Public Health Action Plan.
ATSDR in cooperation with the State of Connecticut Department ofHealth Services will conduct the following Public Health Actions:
- The CT DHS will provide environmental health education for localpublic health officials, the local medical community and tolocal citizens to assist the community in assessing possibleadverse health outcomes associated with exposure to hazardoussubstances. This program will start December 1, 1991.
- The CT DHS in conjunction with ATSDR will evaluate the need forfollow-up health study activities with respect to a disease andprevalence study or some continued evaluation of cancerincidence.
- The CT DHS will ensure monitoring of municipal water supplywells near the site to determine and document whether or not thewater quality in these wells is affected by site-relatedcontaminants.
- Information regarding the potential health effects associatedwith lead in drinking water will be provided to all interestedresidents by the CT DHS Lead Poisoning Prevention Program.
In addition, other State and Federal agencies have agreed to takethe following actions:
- The CT DEP will ensure that those private water supply wellslocated on the fringe of the zone of ground water contaminationemanating from SRSNE are monitored to determine whether thesepotable water supplies are affected by contaminants emanatingfrom the site.
- The CT DEP will ensure that Best Available Control Technology(BACT) is installed to eliminate emissions of volatile organiccompounds (VOCs) generated from the on-site ground waterrecovery/treatment system.
- As part of the Phase III Remedial Investigation and FeasibilityStudy, the United States Environmental Protection Agency (USEPA)will conduct investigations to characterize the ambient airconcentrations of the VOCs generated from the ground waterrecovery system.
- The USEPA will characterize the ground water flow pattern(s)south of Curtiss street to assess the migration pathways ofsolvents from the site.
This public health assessment was prepared by the ConnecticutDepartment of Health Services under a cooperative agreement withthe Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and proceduresexisting at the time the public health assessment was initiated.
Gregory V. Ulirsch
Technical Project Officer, SPS, RPB, DHAC
The Division of Health Assessment and Consultation (DHAC),ATSDR, has reviewed this public health assessment and concurswith its findings.
Division Director, DHAC, ATSDR
Environmental and Health
Edith Pestana, M.S.
Environmental Epidemiology and Occupational
Health Division, CT Department of Health
Sandy Geschwind, Dr.P.H., M.P.H.
Environmental Epidemiology and Occupational
Health Division, CT Department of Health
Brian Toal, M.S.P.H.
Environmental Epidemiology and Occupational
Health Division, CT Department of Health
ATSDR REGIONAL REPRESENTATIVE
Public Health Advisor
Region I, Regional Service
TECHNICAL PROJECT OFFICER
Technical Project Officer
Environmental Health Engineer
Division of Health Assessment and Consultation
The following documents were reviewed. These documents form thebasis of this public health assessment.
Agency of Toxic Substances and Disease Registry, "ToxicologicalProfile for l,l-Dichloroethane," Doct., #ATSDR/TP-88/ll.
Agency of Toxic Substances and Disease Registry, "ToxicologicalProfile for Methylene Chloride," Doct., #ATSDR/TP-88/l8.
Agency of Toxic Substances and Disease Registry, "ToxicologicalProfile for Carbon Tetrachloride" Doct., #ATSDR/TP-89/05. Decemberl989.
Agency of Toxic Substances and Disease Registry, "ToxicologicalProfile for Lead," Doct., #ATSDR/TP-89/l7. June l989.
Agency of Toxic Substances and Disease Registry, "ToxicologicalProfile for Mercury," Doct., #ATSDR/TP-89/l6. December l989.
Agency of Toxic Substances and Disease Registry, "ToxicologicalProfile for 2,3,7,8, Tetrachlorodibenzo-p-dioxin," Doct.,#ATSDR/TP-88/23. June l989.
Agency of Toxic Substances and Disease Registry, "ToxicologicalProfile for Tetrachloroethylene," Doct., #ATSDR/TP-88/22. Januaryl990.
Agency of Toxic Substances and Disease Registry, "ToxicologicalProfile for Toluene," Doct., #ATSDR/TP-89/23. December l989.
Agency of Toxic Substances and Disease Registry, "ToxicologicalProfile for Trichloroethylene," Doct., #ATSDR/TP-88/24. October,1989.
Casarett and Doull's, Toxicology, The Basic Science of Poisons,Second Edition. Editors: Doull, J., Klaassen, C.D., and Amdur,M.O. Macmillan Pub. Co. N.Y.
Connecticut Department of Environmental Protection, Air ComplianceUnit files for SRSNE. l65 Capitol Avenue, Hartford, Connecticut.
Connecticut Department of Environmental Protection, Bureau of WaterManagement's files for SRSNE. l22 Washington Street, Hartford,Connecticut.
Connecticut Department of Environmental Protection, Bureau of SiteRemediation Superfund files. l65 Capitol Avenue, Hartford,Connecticut.
Connecticut Department of Environmental Protection, WasteManagement Bureau's files for SRSNE late l960's to present. l65Capitol Avenue, Hartford, Connecticut.
Connecticut Department of Environmental Protection, WaterCompliance: An Assessment of the Extent and Probable Source ofSurface and Groundwater Contaminations in and around SolventsRecovery Services of New England Interdepartment Message: FromPaul Marin, To: Robert B. Taylor; l0/25/78.
Connecticut Fund for the Environment (1979). Petition to theUnited States Environmental Protection Agency to Bring Suit Againstthe Southington Water Company. CFE,152 Temple Street, New Haven,CT.
Dreisbach, R.H. Handbook of Poisoning. 9the Ed. Lange MedicalPublications Los Altos, California, l977.
Ecology and Environment, Inc., December, l980. "PreliminaryInvestigation of the Abandoned Landfill, Old Turnpike Road,Southington, Connecticut," FIT Project TDD #Fl-80ll-03.
Hazardous Air Pollutant Control Program, Air Compliance Unit, CTDepartment of Environmental Protection, December, 1986.
Housman, Jr. J.J., Hazardous Lead Emissions from Solvents Recovery,Inc., Lazy Lane, Southington, Connecticut, Connecticut Departmentof Environmental Protection, Air Compliance Engineering. August,l974
Mazzaferro, D.L., Hardman, E.H., and Thomas, M.P. "Water ResourcesInventory of Connecticut, Part 8, Quinnipiac River Basin."Connecticut Water Resource Bulletin No. 27, l979.
New England Bioassay Inc., Comparative Toxicity Testing SolventsRecovery of New England and Quinnipiac River, January 25, l990,March 2l, l990.
NUS Corporation, Phase 1 Field Investigation Activities, RemedialInvestigation/Feasibility Study, Solvents Recovery Sources of NewEngland, Inc., Southington, CT, contract #68-W8-0117, October 1990.
Roy F. Weston, Inc. - Century Laboratories TID Number: 0l-88-07-06,Solvent Recovery Services, Southington, Connecticut. 1989.
Roy F. Weston, Inc. - Data Chem, Inc.; Case 980l, SDGAL463 TIDNumber 0l-88-07-5 Site: Solvents Recovery Service, Southington,Connecticut Soil Sampling Data VOCs, pesticides and PCB analysis,August 22, l988.
Solvents Recovery System - DTE and In-Stream Study Review, State ofConnecticut Department of Environmental Protection, WaterCompliance Unit Interdepartment Message. To: Bob Kaliszewski,Department of Environmental Protection, Water Compliance Unit;From: Traci Jordon, Department of Environmental Protection, WaterCompliance Unit; l22 Washington Street, October 3, l989.
U.S. Environmental Protection Agency, Purgeable Organic Analysisfrom Southington, Connecticut, From: Richard Siscnaw To: EdwardTayler, Chief Chemistry Section, March 26, l980.
United States Environmental Protection Agency Region I, InspectionReport, February 1-2, 1989. Solvents Recovery Service of NewEngland, Lazy Lane Southington, CT 06489.
United States Department of Environmental Protection Agency (TEAM). The Total Exposure Assessment Methodology (TEAM) Study Summary andAnalysis: Volume I. Lance, Wallace A. Office (ED.) Office ofResearch & Development. USEPA Wash., D.C., 20460. EPA/600/6-87/002, June 1987.
Waryzn Engineering, Inc. November l980. HydrogeologicInvestigation, Town of Southington, Connecticut.
Water Works Department files for Town Production Wells 4, 5, and 6.65 High Street, Southington, Connecticut.
Werhan Engineering Consulting Engineers Final Report: The SRSNEsite Southington, Connecticut; "A Hydrogeologic Assessment Preparedfor Solvents Recovery Services of New England, Inc." Southington,Connecticut, October l982.
YWC, Inc. "Primary and Secondary Lagoon Sites Drum Handling Areasand Incinerator Site Corrective Measures Plan, Solvents Recovery ofNew England". Project Number 0l-6l63, May l5, l986.
YWC, Inc. and ERM-Northeast Inc. "Concept Engineering ReportOff-Site Groundwater Interceptor System Alternative Proposal."Solvents Recovery of New England, Inc." YWC project number0l-6l63; March 26, l986.
YWC, Inc., "Discharge Toxicity Evaluation", prepared for SolventsRecovery Services of New England, Lazy Lane, Southington, CT,January, 1989.
|Age group||Connecticut bladder cases||Southington bladder cases||Expected no. bladder in Southington||Connecticut bladder incidence||Southington bladder incidence||Lower 95% Confidence Interval on Southington Incidence||Upper 95% Confidence Interval on Southington Incidence|
|OBSERVED||EXPECTED||SIR = OBS/EXP||LOWER 95% CI||UPPER 95% CI|
* Significant at the P=0.05 Level
|Age group||Connecticut testis cases||Southington testis cases||Expected no. testis in Southington||Connecticut testis incidence||Southington testis incidence||Lower 95% Confidence Interval on Southington Incidence||Upper 95% Confidence Interval on Southington Incidence|
|OBSERVED||EXPECTED||SIR = OBS/EXP||LOWER 95% CI||UPPER 95% CI|
Prevalence Rates for Learning Disabled (LD) = # LD Students / Total # of Students * 100
|Connecticut State percent prevalence rate||= 6.55% (1987-1988)|
|Southington||= 6.66% (1987-1988)|
|School District 7||= 6.53% (1987-1988)|
|School||#LD||Total # of Students||% Prevalence Rate|
|7 South End||14||290||4.80|
|10 North Center||15||261||5.70|
|51 De Paolo J.H.||58||660||8.78|
|53 Kennedy J.H.||42||730||5.75|
|62 Southington H.S.||66||1,300||5.07|
Note: 102 special ed students are served outside of district. 26 are LD.
APPENDIX 5: FREQUENCY TABLE OF BIRTH DEFECTS IN SOUTHINGTON, CONNECTICUT, 1983, 1985, AND 1986
|Year of birth||Affected infants||Number of defects||Total number of defects|
|ICD code||Type of birth defect||Number diagnosed||Expected 1986|
|746||Other heart anomalies||1||4||2||2.5|
|747||Blood vessel anomalies||-||6||9||3.7|
|748||Respiratory system anomalies||1||1||1||1.0|
|749||Cleft lip and palate||-||1||1||0.9|
|750||Alimentary tract anomalies||2||1||2||1.6|
|751||Digestive system anomalies||-||-||-||1.1|
|752||Genital organ anomalies||3||3||5||4.2|
|753||Urinary system anomalies||1||-||3||1.2|
|754||Dislocation of hip, etc.||-||1||6||3.1|
|Total Defects Diagnosed||20||30||43||33.7|
The following is a compilation of all public comments on theSolvents Recovery Services of New England (SRSNE) public healthassessment that were received between November 1 and December 31,1991 during the Public Comment period. All public comments havebeen included with an appropriate response following. Several ofthe comments that were similar in nature were grouped together.
A. Comments by AARON Environmental Specialists, Plantsville, CT
Re: Public health assessment of Solvents Recovery Services (SRS)Public Comments
After careful review of the 45 page report entitled "HealthAssessment of Solvents Recovery Service of New England" released byyour department, we would like to submit the following comments:
- Although the report is comprehensive in nature the StandardIncidence Ratio (SIR) for tumors, infant mortality, learningdisabilities and birth defects of Southington versus otherConnecticut communities, we believe that the report does notadequately address the specific adverse health risk effectson the Southington citizens residing within the immediatearea of SRS. We would recommend that the Dept. of HealthServices:
- utilize the local health data provided by members of the SAFE group.
- expand the scope of the SAFE health survey by conducting your own health survey within the immediate area.
- compare adverse health risks of residences in the immediate area to that of the greater Southington community.
- consider the immediate SRS area as a "Town Within Itself" and statistically compare the adverse health risks of this specific area to that of other communities in the State.
- A study conducted by the CT DEP identified heavy metal(lead, etc.) contamination of soils and vegetation onneighboring properties from the SRS open pit incinerator. Because of bioaccumulation properties of heavy metals in thehuman system, we recommend that the CT DEPT. of HealthServices performs blood testing of neighbors who wouldparticipate on a voluntary basis to help determine the longterm chronic risk exposure inflicted by the SRS operation.
- We applaud the Public Health Action Plan as detailed on page33 of the report and encourage the Department of HealthServices to work closely with the concerned citizens ofSouthington.
CT DHS RESPONSE TO THE AARON ENVIRONMENTAL SPECIALIST CONSULTANTS
The document is not a "Risk Assessment" study. The Agency forToxic Substances and Disease Registry's (ATSDR) public healthassessments are not designed to calculate health risk. There is adifference between a "Public Health Assessment" and a "RiskAssessment". Hopefully the following paragraphs will clarify thedifferences between them and what they both try to achieve.
A risk assessment estimates the statistical probability that someharm will come to an individual or a population as a result ofexposure to a substance or a situation. It is comprised of four(4) steps:
- It assesses whether a particular hazardous substance can contribute to cancer, birth defect or a health problem.
- It estimates the quantity of the chemical received by aperson or group of persons and the health effect that aspecific quantity of chemical or dose would cause. This isreferred to as "dose-response relationship".
- The substances's potency for each specific health effect ofconcern also needs to be assessed. This information isusually taken from animal studies.
- Finally the risk assessment expresses what the probabilityis that an adverse health effect will occur as a result ofthe exposures that were measured.
In an EPA risk assessment biological statistical models are used tocalculate estimates of the health risk in order to facilitateremediation and to set regulatory guidelines and standards.
ATSDR Public Health Assessment:
While a risk assessment conducted under EPA's RemedialInvestigation/Feasibility Study process is used to support theselection of a remedial measure, an ATSDR health assessment is amechanism to provide a community with information on the publichealth implications of a specific site, identifying thosepopulations for which further health actions or studies are needed. The health assessment also makes recommendations for actions neededto protect public health, which may include issuing healthadvisories.
CONNECTICUT DEPARTMENT OF HEALTH SERVICES (CT DHS) RESPONSE TO AARON ENVIRONMENTAL SPECIALIST'S RECOMMENDATIONS NOS. 1(a), 1(c) and 1(d):
Most of the local health data (cancer case listings) that have beenprovided periodically by SAFE have been used to help design thefocus of the separate health study CT DHS is conducting. However,of the data provided by SAFE only those cases that are recorded inthe Connecticut (CT) Tumor Registry could be included in the healthstudy.
The health study is entitled "Cancer Occurrence in Southington,CT." Information on the persons who have had cancer in Southingtonwas obtained from the CT Tumor Registry. By state law, a physicianwho diagnoses a tumor in a Connecticut resident must report thatdiagnosis to the CT DHS. The CT Tumor Registry is considered to bethe best and most complete source of information on cancerincidence in the country. The information on the number of cancercases which occurred in Southington was compared with what would beexpected based on cancer incidence in the entire state ofConnecticut controlling for sex and age (two of the most importantcancer risk factors). While the preliminary results from thisanalysis indicate that no overall increase in cancer cases occurredin the town of Southington during the past 10 years the observednumber of testicular cancer cases in the 20 to 29 year age groupand the observed number of bladder cancer cases in the 40-49 agegroup was elevated. An expanded study is being conducted to focuson bladder and testicular cancer in smaller neighborhoods/regionswithin the town rather than the entire town to address concernsthat health effects are being experienced in specific locationswithin the town.
This expanded study is relying on newly developed GeographicInformation System (GIS) technology where the precise address ofthe person can be mapped with computer assistance along withinformation on water supply, proximity to dump sites and censusdata on the number of individuals living in an area, their age andsex. It is hoped that the results from this analysis will moredefinitively answer the question of whether neighborhoods withinSouthington are having more cases of cancer than would be expected.
A risk assessment is presently being conducted by the United StatesDepartment of Environmental Protection (USEPA) on the SRSNEfacility as part of the Remedial Investigation and FeasibilityStudy (RI/FS). This risk assessment will compare Southington withother communities.
CT DHS RESPONSE TP AARON ENVIRONMENTAL SPECIALIST'S RECOMMENDATIONSNO.1(b):
At the present time the CT DHS does not have plans to conduct ahealth survey.
CT DHS RESPONSE TO AARON ENVIRONMENTAL SPECIALIST'S COMMENT NO. 2:
Although blood is most commonly measured as a marker of exposure,it only shows relatively recent exposures and therefore would notbe useful in assessing metal exposures that occurred approximately20 years ago. Lead, which is the primary metal contaminant ofconcern with respect to SRS incinerator emissions, bioaccumulatesin bone for up to 20 years and that would therefore be the tissuewhere lead could be measured. The amount of lead stored can bemeasured through X-ray analysis. However, this measurement doesnot show nor predict the effects that lead has had on the organs ofconcern. These are the brain, cardiovascular system and the kidney. There are no biomarkers that can measure or assess the effects ordamage that past exposures to lead (approximately 20 years ago)could have had on these organs.
Other biologic monitoring of the surrounding community is not beingconsidered at this time. However, it may be considered in thefuture if an epidemiologic investigation warrants it.
B. CT DHS RESPONSES TO COMMENTS MADE AT A PUBLIC FORUM HELD BY SAFEMEMBERS IN SOUTHINGTON, CT IN DECEMBER, 1991:
- Many articles written about the study say there is a healththreat but "no pattern of illness" is noted. If 12 cancer casesout of 15 houses (now there are 13 out 15) next to the SRSNEplant are not a red flag, then the study has not been donethoroughly enough and the people doing the study have not lookedor spoken with the ill residents.
- The National Institute for Occupational Safety and Health(NIOSH) conducted 61 investigations of apparent clusters during1978-1984. A review of those investigations showed that most ofthe clusters contained five (5) or fewer cases and no plausibleoccupational cause. We in Southington have over 100 cases andvery definite plausible causes. Our numbers are so much biggerthan what would seem like the "usual" smaller cluster.
CT DHS Response to Public Comments Nos. 1, and 2:
The public health assessment cannot identify a causal link to aparticular disease of concern in Southington. Unless achemical/substance is well known to produce a specific disease inhumans (such as asbestos and asbestosis of the lung) it is almostimpossible to establish plausible cause. Even epidemiologicstudies by themselves are insufficient to provide or establishdefinitive evidence that the disease we are investigating wascaused by an exposure to a toxic chemical.
Cancer is not one disease, but many. It can start in manydifferent organs in the body. There may be several differenttissues within each organ that can be affected. Thus, cancers ofdifferent tissues in the same organ may have different causes. Ifthe cluster includes cancers of different sites, it may not be atrue cluster and may be difficult to link to a specific cancercausing agent.
The purpose of the public health assessment is not to conduct an epidemiologic investigation nor a risk assessment but rather to look for any current or future impact on public health.
The public health assessment tries to identify the need foradditional health information and health studies (i.e. largeepidemiologic studies, door to door surveys, etc.) from theinformation reviewed.
The occurrence of cancer in Southington is currently undergoingfurther study by CT DHS. Also it is important to keep in mind thatthere are many types of cancer in Southington and that a truecluster is only when the cancers occur in the same body locationsuch as several cases of brain cancer.
- The residents are concerned that there are such varied cases(different types) of cancer because the combinations of allthese chemicals over the last 30 years has been so unpredictable(unusual). SRS mixed anything and everything. Residents saythe place used to "glow" at night.
- A resident reported that she had experienced bladder infectionswhile living on Curtiss Street (1962-1967.) Her daughter wasdiagnosed with thyroid cancer a few years ago. The residentbelieves that there is a relationship.
CT DHS Response to Nos.4 and 5:
Your concerns are warranted. It is no secret that SRSNE didgenerate and mishandled a large quantity of chemicals and waste. The environment that we live in affects each of us differently,with some of us responding more sensitively and badly to it. Howthe human body responds to exposures to chemicals, bacteria,viruses, etc., is dependent on the individual. It is unfortunatethat the public health community does not have the knowledge at thepresent time to either prove or refute your theories.
Public Comment NO. 6:
- Please question doctors (especially urologists) in Southington,New Britain, Meriden, Plainville, and Waterbury about the numberof patients from Southington.
CT DHS RESPONSE TO NO. 6:
The CT Tumor Registry receives cancer case information from theentire state.
PUBLIC COMMENT NO. 7:
- Residents requested that the CT DHS speak with two doctors thathave cancer patient information.
CT DHS RESPONSE TO NO. 7:
Unless follow-up studies to the Cancer Occurrence in SouthingtonStudy is recommended, CT DHS does not have plans at the presenttime to talk to physicians concerning cancer patient information.
PUBLIC COMMENT NO. 8:
- The discrepancy in the Tumor Registry must be addressed. Ofthe first 50 cases brought to the attention of theDepartment of Health Services, 25 did not show up on theregistry. This clouds everything that this assessmentstands for. Does this mean that possibly half of our cancercases are not being counted?
CT DHS RESPONSE TO NO. 8:
Actually 45 of the cases reported were identified in the registry. This demonstrates very good case findings on the part of interestedcitizens. Cases sometimes are not in the registry if the case wasdiagnosed out of state or if the case was very recently diagnosed.
PUBLIC COMMENT NO. 9:
- On page 28 of the Public health assessment the TumorRegistry has no one in the 0-19 age group with testicularcancer. We do have a case in that age and time group. He'sprobably not on the tumor registry yet.
CT RESPONSE TO NO. 9:
This is quite possible if he was recently diagnosed.
PUBLIC COMMENT NO. 10:
- Two new cases of cancer have been diagnosed since thissummer on Lazy Lane, one pancreatic (which is related tohazardous waste sites) and one brain. Both women live rightnext door to the SRS plant.
- We know of more bladder cases in Southington since thereport has been issued. We would like these kept on record.
CT DHS RESPONSE TO NO. 10 AND 11:
CT DHS does not keep a record of cancer cases.
PUBLIC COMMENT NO. 12:
- We would like to sit down with someone from the tumorregistry and verify our ill people on the registry.
CT DHS RESPONSE TO NO. 12:
The list of names has been verified with the CT Tumor Registry andthis has been discussed with members of SAFE.
Public Comments NO. 13, 14, 15, 16, and 17:
- This is a public health assessment. You must speak withpeople and ask them about their illnesses. Written reportsdo not speak the way people can tell it. The people aroundthe plant have a saga to tell if only someone would listen.
- This document is called a "Health Assessment". The site hasbeen assessed very well. Please assess the people asthoroughly as you have assessed the site. Let this documentbe a model for the whole country. People living near thehazardous waste sites will be seeing the development ofcancer or disease clusters arise and they will be lookingfor a guide to follow.
- A comprehensive and indepth study (like Woburn) must be doneon the residents living near the SRS plant. If the Statedoes not have the money, then the federal government throughATSDR should take on this task. If this is not done, thenan independent health study from an outside state ororganization (from some kind of grant money) might be agoal.
- Along with the above an independent door to door surveyshould be done of the 1 to 1.5 mile radius surrounding SRS.
- A resident asked that strokes be looked into.
CT DHS RESPONSE TO 13,14,15,16 and 17,:
The CT DHS is in the process of completing a Study of the Occurrence of Cancer in Southington. This epidemiologic study islooking at groups of people and populations rather thanindividuals. The study is evaluating several small regions inSouthington where environmental exposures may have occurred. Themethods used and the results of this study will be reviewed byscientists from other states who have also been involved in theinvestigation of cancer clusters.
Depending on the findings of the study and the recommendations madefrom other out-of-state reviewers, further larger epidemiologicinvestigations (such as door to door surveys and a study like"Woburn's") may be performed.
PUBLIC COMMENT NO. 18.
- A nurse stated that non-Hodgkins lymphoma is very prevalentin Southington. She stated it should be looked into.
CT DHS RESPONSE TO NO. 18:
In response to number 17, Non-Hodgkin lymphoma was evaluated in theinitial cancer survey and the number in Southington was less thanexpected.
PUBLIC COMMENT NO. 19:
- We read page after page of what we have been exposed to andthen we are told that "such an association is not sufficientto establish a causal link" between chemical exposures anddisease outcomes. Then we need the help of the Almighty !
CT DHS RESPONSE TO 19:
It is unfortunate that at the present time we do not have the"tools" to work with that can definitively establish a link betweenhealth problems experienced in the community and exposure toenvironmental contamination from hazardous waste sites.
Epidemiologic studies by themselves are insufficient to establishor provide evidence that the disease we are looking at was causedby an exposure to toxic chemicals unless the chemical is known fromprevious toxicology studies to produce the disease we are concernedwith. An example of this would be asbestos and asbestosis of thelung.
Even if the CT DHS study of cancer occurrence in Southington founda correlation between the number of cancer cases and geographiclocation, this would not definitively establish a link between having cancer and the exposures that happened. The results wouldonly suggest that a relationship exists.
We can never really say that those people with cancer living inclose proximity to SRSNE got their disease from exposures tocontaminants from the site. Unfortunately the epidemiologictechniques available to us to investigate your question lack thepower needed to detect any increases in disease.
PUBLIC COMMENT NO. 20:
- The Tumor Registry says there is not a cancer epidemic inSouthington (no one ever said there was). We would like toknow if there are more incidence of cancer the closer youget to the Superfund site (sites)?
CT DHS RESPONSE TO 20:
The Cancer Occurrence in Southington study used the GeographicInformation System (GIS) technology to map information on cases ofbladder and testicular cancer. Hopefully, this study will helpanswer your question.
PUBLIC COMMENT NO 21:
- The learning disabilities studies was not done for thecorrect period of time. Records dating back to the early70's should have been looked at. There were probably norecords in the 60's but testing for L.D. began in the early70's. We know of quite a few students living near the plantthat are learning disabled.
CT DHS RESPONSE:
Because several parents that live in close proximity to SRSNEexpressed concern with respect to learning disabilities the CT DHSconducted a preliminary investigation to see if there was anunusual number of children in the town with learning disabilities.However, the state chose not to pursue this investigation furtherfor the following reasons.
- During the investigation the state found that the total numberof children in Southington with LD is not unusual when comparedto other towns in the state and the U.S..
- The criteria for diagnosing learning disabilities have not beenstandardized and have changed throughout the years. Thereforerecords dating back to the early 1970's may not be comparableand accurate time trend analyses are not possible.
- The causes of specific reading, writing or mathematicdifficulties remain unknown. Unfortunately despite the growingconcern for learning disabilities in children, research studiesinvestigating the cause(s) are limited.
- In order for epidemiologist to be able to assess whether anassociation exists between exposure to a chemical and a learningdisability, it is essential to understand the environmental andhereditary factors that cause the specific disability.
Public Comments Received by CT DHS on the Findings of the SRSNEPublic health assessment.
- The off-site testing must be redone. To dig 18" and sayeverything is fine is a travesty to the residents ofSouthington. Poisons were buried 30 years ago in swampyareas and gravel pits. Eighteen inches after 30 years isnot sufficient testing.
The Queen Street Diner property has been determined to fall withinthe study area of the Solvents Recovery Service National PriorityList site and is included as part of the Phase III RemedialInvestigation/Feasibility Study (RI/FS).
The Mastrianni Gravel Pit (a.k.a. The Meadows Condominiums),Angilillo Property, and the Marek Property were entered into theU.S. Environmental Agency (EPA) pre-remedial evaluation processesunder the federal Superfund (CERCLA) program in 1991.
The CT DEP, under cooperative agreement with EPA, was assigned thetechnical lead to conduct a Preliminary Assessment (PA) at eachsite under the federal program. A PA is the first step in thefederal pre-remedial evaluation process. CT DEP conducted anassessment at the Meadows Condominiums which included tests beyondwhat is routinely performed in a PA. The CT DEP conducted a soilgas study of the property, and sampled soils and nearby privatewell water supplies for laboratory analysis in order to determinewhether or not pollutants exist which could pose a threat to theenvironment or public health. Based on the findings in thatassessment, no evidence was found to indicate that the site is athreat to the public's health. The site will remain active in thefederal Superfund pre-remedial program for further evaluation andtesting.
- A resident requested that all soil be tested for 1/4 milearound the plant.
CT DHS RESPONSE to 23:
The CT DEP is presently conducting (see response #22) of potentialsatellite disposal areas . The soil testing being done by DEP ispart of those investigations. Testing to determine any migrationof contaminants from the SRSNE site is being done by the federalEPA. They will continue to conduct soil, air and water samplingnecessary to locate and remediate any such contaminant migration.
- Educate the teenage boys and young men to check fortesticular cancer.
CT DHS RESPONSE to 24:
As part of the CT DHS environmental health education program,physicians will be encouraged to educate the male population inSouthington on self examination for testicular cancer.
- Offer free testing for people with private wells.
CT DHS RESPONSE to 25:
The CT DEP has been testing and is monitoring those private wellsthat could be impacted from pollutants migrating in the groundwatersystems.
- Why was the Minnesota protocol not carried out? Confidentiality could have been kept by using a blind (givethe residents number or code names.) Other states have donethis. The neighborhood needs to be looked at.
CT DHS RESPONSE TO 26:
Based on the case information received by the state of ConnecticutDHS from a local resident and a review of the CT Tumor Registry, itwas not necessary to conduct a public survey of those casesidentified in Southington. The information submitted by the localresident was complete and accurate. In addition the state ofConnecticut has an advantage over other states, because it has theoldest cancer tumor registry in the United States.
Interestingly, the Minnesota Department of Health's cancer clusterprotocol (1990) does not routinely encourage public surveys sincethere are always questions regarding the completeness and accuracyof the data collected by the resident individual who reported theexcess cancer.
The CT DHS cluster protocol uses all the epidemiologicalinvestigative methods and tools that are known at the present timefor the detection of a cancer cluster.
A resident wanted it to be known that an environmental impactstatement was not done on the aquifer and one should be required. His question was "do we know if the solvents have gotten into theaquifer and if so what are the health hazards that this couldpose."
CT DHS RESPONSE:
There is sufficient ground water chemistry data in the publichealth assessment to show that the aquifer surrounding the SRSNEplant and at least as far south as the public water supply wellfield (well 4 and 6) is contaminated. Phase III of the RI/FS willcharacterize the extent and degree of aquifer contamination. Asdiscussed in the "Public Health Implication Section of the publichealth assessment, wells 4 and 6 were contaminated and residentsdrank water contaminated with volatile organic compounds for anunknown period of time. The wells were shut down in 1979 and 1980. The health hazards that these past exposures to VOCs in thedrinking water might pose are unknown.
PUBLIC COMMENT 28:
Ask the DEP to shut the air stripper down until the new one is inoperation.
CT DHS RESPONSE:
The operation of the air stripper is required by a consent decreebetween EPA, CONN Fund for the Environment, the water company, andSRSNE. The CT DHS did not ask EPA or the CT DEP to shut down theair stripper because they cannot unilaterally change therequirements of the consent decree. In addition, shutting down theair stripper would require that the groundwater recovery systemwould have to be shut down. The groundwater recovery system is toprevent migration of contaminants off-site. The CT DEP willinstall a new groundwater water treatment system by June 1992. Thesystem will treat the groundwater without volatilizing thecontaminants into the air, thus there will be no opportunity forair releases once the new system is in operation.
PUBLIC COMMENT NO. 29:
In closing, the general consensus of the participants at the forumon the public comment was that they do not believe or accept thefact that illness does not exist in Southington near the SRS plantbecause there was no personal contact with any ill residents. Trees were studied the air was studied, water was studied, thesoil, now study the people.
CT DHS RESPONSE TO NO. 29:
Depending on the findings of the Cancer Occurrence in Southingtonstudy and recommendations made from out-of-state reviewers, furtherlarger epidemiologic investigations (such as door to door surveysand a study like "Woburn's" ) may be performed.
C. COMMENTS RECEIVED IN LETTERS FROM INDIVIDUAL RESIDENTS
LETTER NO. 1:
After careful examination of the Public health assessment ofSolvents Recovery Services (SRS) I wish to make the followingcomments:
- In order to obtain a more accurate picture of the populationaffected during the 1970's and 1960's, it is crucial that aneffort be made to track the people actually living in the areaat the time. Therefore, I feel that it is absolutely crucialthat a case control epidemiology study be conducted so that atrue picture of actual cancer and health risks can beascertained.
- It appears that your conclusion regarding the health risk ratesposed by exposure to Solvents Recovery contamination is basedupon a comparison of the general population with that ofSouthington as a whole. Since only 5% of the town resideswithin a mile and a half of the plant, a more accurate analysisof the health risks could be obtained by comparing the levels ofdisease suffered by the population of those residing within aclose radius of the plant.
CT DHS RESPONSE:
In response to your first comment, depending on the findings of thehealth study entitled "Cancer Occurrence in Southington, CT" aswell as comments and recommendations made from reviewers fromoutside the state of Connecticut, investigations such as a casecontrol study may be performed.
The potential human cancer risks associated with exposures tospecific chemicals will be measured in the Risk Assessment Studybeing performed by the Environmental Protection Agency (EPA).
In response to your second comment, no health risk rates werecalculated in the SRSNE Public Health Assessment. But rather, thedisease rates (or proportions) that were calculated were used tocompare disease in Southington to disease in the state ofConnecticut and the U.S.. This was done to see if the proportionof certain diseases in Southington are higher with respect to thestate and the U.S..
A comparison of the number of specific cancer cases, (i.e. bladder,and testicular) and geographic residence is addressed in the CancerOccurrence Study of Southington, CT.
LETTER NO. 2:
"I moved to Southington with my family in 1974. In that same yearmy wife had a heart attack. She was only 35 years old. Ten yearslater she had emphysema, in 1984. In 1989, at age 49, she died asa direct result of this emphysema. She was not a smoker.
It is my belief that she may have contracted this disease due toairborne contaminants from this site.
My major concern is that there is continued air contamination dueto air stripper operations. Further, I don't see why excavation ofcontaminated ground should not take place immediately."
CT DHS RESPONSE:
We are sympathetic with you in your belief that your wifecontracted emphysema from air borne contaminants generated from thesite and are truly sorry for your loss. It is unfortunate that thebiological causes of this disease are poorly understood. We doknow that in addition to cigarette smoking, air pollution andhereditary factors have been shown to play a role in somepatients. Also the number of cases of emphysema is on the rise inthose urban areas throughout the world where air pollution is aproblem. Unfortunately, it is impossible to prove that your wife'semphysema was caused by air emissions from the SRSNE plant.
In response to your concern over the air emissions generated fromthe air stripper, the operation of the air stripper is required bya consent decree between EPA the Connecticut Fund for theEnvironment, the water company, and SRSNE. The CT DHS did not askEPA or the CT DEP to shut down the air stripper because they cannotunilaterally change the requirements of the consent decree. Inaddition, shutting down the air stripper would require that thegroundwater recovery system would have to be shut down. Thegroundwater recovery system is necessary to prevent migration ofcontaminants off-site. The CT DEP will install a new groundwatertreatment without volatilizing the contaminants into the air, thusthere will be no opportunity for air releases once the new systemis in operation.
Plans for the excavation of those areas that pose a potentialhealth threat such as the drainage ditch located on the easternside of the SRSNE site grounds are underway by the US EPA.
LETTER NO. 3:
"My main concern at the moment is the air stripper and potentialdanger. The area residents breathing the air every day. I thinkthe stripper should be shut down now rather then in months from nowwhen a pollution control system will be installed. Just havingthat system installed is not enough. That only shows me there isa hazard to us now. If there was no problem, you would not begoing to the expense of installing the system. Another concern ofmine is Lupus, and the possibility of chemicals being absorbed inthe skin."
CT DHS RESPONSE:
In response to your concern over the air emissions generated fromthe air stripper, the air stripper was not shut down because the CTDHS did not feel that the emissions generated for the air stripperposed an imminent health threat to the local community. Inaddition, the operation of the air stripper is required by aconsent decree between EPA the Connecticut Fund for theEnvironment, the water company, and SRSNE. The CT DHS did not askEPA or the CT DEP to shut down the air stripper because they cannotunilaterally change the requirements of the consent decree. Inaddition, shutting down the air stripper would require that thegroundwater recovery system would have to be shut down. Thegroundwater recovery system is necessary to prevent migration ofcontaminants off-site. The CT DEP will install a new groundwatertreatment without volatilizing the contaminants into the air, thusthere will be no opportunity for air releases once the new systemis in operation.
In response to your concern with dermal exposures and the diseaseof lupus. We do not have any evidence at the present time tosuggest that the exposures that occurred caused or couldpotentially cause lupus.
Dermal exposures to water contaminated with volatile organiccompounds (VOCs) from town wells 4 and 6 occurred while bathing andwashing for an unknown period of time.
LETTER NO. 4:
Trees, fungus-died. House, vinyl siding - side facing Solvents aircurrent travels contour of street siding sludged. Houses onKnowllwood Road developing fungus on lower portion of houses, woodand around windows - decks.
Survey veterinarians for animals with cancer. Government should supply drinking water to residents in area or entire town. bought up property and excavated toxins out - Love Canal. 50 ft. circle-no vegetation grows, scum-black area.
Severe health problems related to drinking polluted water from thecity. I am willing to offer personal documentation to HealthDepartment. My wife and I have severe respiratory ailments.
CT DHS RESPONSE:
In response to your concern with fungus, and the trees dying, airpollution does not create fungus. However, severe air pollutioncan make trees more susceptible to the effects of fungus and othermicroorganisms.
The fungus that you have observed on the lower portions of thehouses, wood, around windows and decks is not the result of the aircurrents traveling from SRSNE site but rather is caused by normalclimatic conditions.
At the present time the CT DHS does not have plans to surveyveterinarians for animals with cancer because our focus is on humanhealth issues.
All those private wells that could have been impacted bycontaminants from SRSNE have been tested. Those wells found to becontaminated have been provided with bottled water or have beenhooked to the public drinking water supply. The public drinkingwater supply in the town of Southington at the present time meetsfederal and state drinking water guidelines.
We at the CT DHS are concerned with you and your wife's healthconditions, and recommend that you go to an occupational healthclinic. Occupational health clinics are familiar with the healtheffects of chemical exposures.
LETTER NO. 5:
A respond to your news release, DuPonte designed the incineratorthat was installed at SRSNE in Southington, CT. We were notforewarned of the dangerous consequence that would be generatedfrom this type of open pit burner.
It was DuPonte's failure to take all presentations on air pollutionof noxious odors and flyash that were oust from the incinerator bythe auger. The operation was a 24 hrs a day, seven days a week,all year long.
DuPonte has neglected responsibilities for not considering thehealth and well-being of the people and putting us all through thisordeal!
There were more than 6 people that had heart attacks in that timeperiod of the incinerator, one kidney failure, one liver case, andthere is nausea and eye irritations.
We feel we should have had more support, from the health dept andDEP. In one instant we were told that we have to learn to livewith it. This remark was made by the health department ofSouthington CT.
When this new air stripper is installed and if it turns out to bea white horse, will it be shut down or permitted to be operated?
CT DHS RESPONSE:
The new ground water treatment system (UV Peroxide TreatmentSystem) that CT DEP will install by June 30, 1992 to replace theold air stripper will treat the groundwater directly, withoutvolatilizing contaminants into the air. This will eliminate anypotential for air releases from this system. This new pollutioncontrol system is equipped with devices that are sensitive to anyproblems or failures that may occur with the system. Once aproblem has been detected, an autodial device will call theconsultant and the problem will be corrected as soon as possible.
The CT DEP selected a system that is both reliable and does not generate air releases. The town's environmental group SAFE and AARON Environmental Consultants have reviewed various pollution control systems and are pleased with the CT DEP's selection.
The CT DEP and CT DHS are committed to ensuring that the publichealth is not endangered.
COMMENTS FROM THE TOWN OF SOUTHINGTON DEPARTMENT OF HEALTH:
I would like to comment on your extensive and rather completereport. My major comment is actually a question. Myinterpretation of the data shows that there is no significantadverse affects demonstrated in the community. However, you ratedthe site as a category B, which is the second highest level ofPublic Health Hazard. Does this site truly deserve really acategory B?
Even the age specific bladder cancer cases shows a significance inthe 0 to 19 age group and once again, in the 40 to 49 age group. The overall incidence of bladder cancer was within the expectantrange.
CT DHS RESPONSE:
In response to your first comment, in order for a site to receivethe category of Public Health Hazard evidence exists that exposuresto chemicals occurred in the past, are occurring or are likely tooccur in the future.
SRSNE was considered a public health hazard because exposuresoccurred in the past through contaminated drinking water and air. Although the major exposure route (the public wells and theincinerator) have been eliminated, there is still concern among theresidents over exposures to air emissions from the air stripper onthe ground water recovery system.
In addition, given that contaminants are migrating off-site throughthe ground water, the potential exists for future exposure to thesecontaminants if they get into drinking water wells.
In response to your second comment, it was felt that the higherthan expected number of bladder cancer cases in the 40-49 year agegroup warranted further investigation.