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PUBLIC HEALTH ASSESSMENT

METACHEM PRODUCTS, LLC
(a/k/a STANDARD CHLORINE OF DELAWARE, INCORPORATED)
NEW CASTLE, NEW CASTLE COUNTY, DELAWARE


CONCLUSIONS

ATSDR classifies the Standard Chlorine/Metachem NPL site currently as no apparent publichealth hazard for local residents because they are not exposed to the chemicals on the site.

On-site air monitoring should continue until remediation is completed. Workers should continueto wear personal protective equipment as indicated by monitoring of site conditions.

ATSDR does not know if the site was a health hazard during the two large spills in the 1980s and during the containment and removal activities after the spills. It is possible that during those times, the air may have contained contaminants at levels above the guidelines set by the Occupational Safety and Health Administration. Some of the employees probably came in contact with the spilled chemicals during the spills or while cleaning them up. Therefore, workers on the site and employees of nearby companies or workers involved with the responses to the spills may have been exposed by the inhalation and dermal pathways–i.e., through breathing vapors from and physical contact with the spilled chemicals. However, ATSDR does not have any monitoring data to determine what exposures may have occurred.

From the limited data ATSDR has reviewed, it appears that the OxyChem ball field area is notcontaminated with Metachem chemicals; therefore, use of the ball field should not be a publichealth hazard.

ATSDR agrees with EPA's decision in the Record of Decision that restrictions should be placedon the property deed to prevent future activities at the site that would disturb any contaminatedareas that are left in place and capped to prevent future exposures. ATSDR also agrees with EPAthat measures are needed to prevent the use of the Columbia aquifer near the site for drinkingwater.

If these measures are put in place and the site remediation is completed, the Metachem site will not be a future public health hazard.


RECOMMENDATIONS AND PUBLIC HEALTH ACTION PLAN

The public should comply with the State of Delaware fishing advisories for Red Lion Creek andthe Delaware River.

State officials should periodically check to make sure that the signs warning the public not to eatfish from Red Lion Creek or the Delaware River are present and clearly visible at locationswhere people are likely to fish or enter the water, such as boat ramps, bridges, piers, and parks.

Monitoring of air on the site and at the perimeter of the site should continue until the chemicalproducts and other wastes are removed from the site and contaminated soil and sediment isexcavated and treated. If the air monitoring at the fence lines indicates the presence of chemicalsat levels of health concern, Air Products employees should be notified and anyone using theOxyChem ball field should be warned to evacuate the area.

During future off-site soil sampling, ATSDR recommends that samples be taken in the ball fieldarea to confirm that area is not contaminated with site-related chemicals.

ATSDR staff should continue to work with EPA and the Delaware Department of NaturalResources and Environmental Control to provide consultation and assistance regarding publichealth issues, as needed, during the removal of the chemicals and wastes, closure anddecontamination of the facility, and remediation of the site.


PREPARERS OF REPORT

Betty C. Willis, MS
Environmental Health Scientist
ATSDR/Division of Health Assessment and Consultation

Lora Siegmann Werner, MPH
Regional Representative, Region III
ATSDR/Office of Regional Operations

Technical Review by
Allan S. Susten, PhD, DABT
Toxicologist/Assistant Director for Science
ATSDR/Division of Health Assessment and Consultation

Coordination by
Capt. John A. Steward, MPH, REHS
Petition Coordinator
ATSDR/Division of Health Assessment and Consultation

Community Relations by
Youlanda R. Outin
Health Communications Specialist
ATSDR/Community Involvement Branch


REFERENCES

  1. Agency for Toxic Substances and Disease Registry. Health assessment for StandardChlorine of Delaware, Delaware City, New Castle County, Delaware. Atlanta: USDepartment of Health and Human Services; 1989.

  2. U.S. Environmental Protection Agency, Region III, Philadelphia, Pennsylvania. Record ofdecision, Standard Chlorine of Delaware Site. 1995 Mar 1.

  3. Delaware Department of Natural Resources and Environmental Control. Computerprintouts of wells within 4 mile radius of Metachem. 2002 Jul.

  4. Map of the Metachem Products, LLC area. Environmentally sensitive areas near MotivaRefinery--Delaware City, DE. Philadelphia: EPA R3 GIS Team. Project SIG1013, map#1579; 2001 Oct 5.

  5. Agency for Toxic Substances and Disease Registry. Standard Chlorine of Delaware, Inc.intro map. GIS demographic map & data. JVA091202; 2002 Sep.

  6. Montgomery J. Metachem to shut down plant. The News Journal April 30, 2002.Available at URL: http://www.delawareonline.com/newsjournal/local/2002/04/30metachemtoshutd.html .

  7. U.S. Environmental Protection Agency, Region III, Philadelphia, Pennsylvania. StandardChlorine of Delaware: current site information (NPL Pad). EPA Superfund Web site.Available at URL: http://www.epa.gov/reg3hwmd/super/DE/standard-chlorine-de/index.htm . Last accessed April 30, 2002.

  8. Superior court of the state of Delaware in and for New Castle County civil case number00C-10-140 HLA. Di Pasquale, secretary of the Department of Natural Resources andEnvironmental Control, plaintiff, v. Metachem Products, LLC, defendant. 2000 Oct 19.

  9. Montgomery J. Plant needs permit–Metachem made changes illegally. The News Journal May 13, 2001. Available at URL: http://www.delawareonline.com/newsjournal/local/2001/05/13metachem.html .

  10. U.S. Environmental Protection Agency, Office of Inspector General. Memorandum toBradley M. Campbell from Carl A. Jannetti concerning citizen complaint on Metachem.Philadelphia. 2000 Aug 22.

  11. U.S. Environmental Protection Agency, Engineering and Science Staff. Memorandum toCarl A. Jannetti from Pete Eagen concerning their technical review of Metachem'schlorobenzene manufacturing process. Washington, DC; 2000 Jul 26.

  12. U.S. Environmental Protection Agency, Region III. POLREP 13 Standard Chlorine ofDelaware Site (a.k.a. Metachem Site). Pollution report by Michael Towle, On-SceneCoordinator. Philadelphia; 2002 Jul 25.

  13. Agency for Toxic Substances and Disease Registry. Draft preliminary health assessmentfor Standard Chlorine of Delaware, Delaware City, Delaware. Atlanta: US Department ofHealth and Human Services; 1998 Aug 16.

  14. Agency for Toxic Substances and Disease Registry. Letter to petitioner from Robert C.Williams. Atlanta: 2001 Jul 3.

  15. Agency for Toxic Substances and Disease Registry. Petitioned public health assessmentMetachem Products, LLC (a/k/a Standard Chlorine of Delaware, Inc.) New Castle, NewCastle County, Delaware. Atlanta: US Department of Health and Human Services; 2002Dec 23.

  16. U.S. Environmental Protection Agency. EPA AIRData–NTI facility emissions report, Delaware NTI air pollution point sources–all HAPs summed (1996). Available at URL: http://www.epa.gov/air/data/ntisumm.html?st~DE~Delaware . Last accessed May 30, 2002.

  17. Delaware Department of Natural Resources and Environmental Control, Air QualityManagement Section. Delaware annual air quality report–2000. Dover, Delaware.

  18. U.S. Environmental Protection Agency, Region III. 1999 Toxics Release Inventory– Delaware. Philadelphia; 1999.

  19. Delaware Department of Natural Resources and Environmental Control, Air SurveillanceBranch. Email from Betsy Frey to Betty Willis at ATSDR with attached Excel file ofVOC data from Delaware City. Dover, Delaware. 2002 Sep 10.

  20. U.S. Environmental Protection Agency, Region III. E-mail from Michael Towle, On-Scene Coordinator, to Timothy Walker at ATSDR regarding review of the draft PublicHealth Assessment for the Standard Chlorine Site. Philadelphia; 2002 Oct 21.

  21. U.S. Environmental Protection Agency. Superfund innovative technology evaluation, theDelaware SITE study, 1989. Research Triangle Park, North Carolina; 1991 Jan.

  22. Pleil JD, et al. Spatially resolved monitoring for volatile organic compounds using remotesector sampling. 1993 Atmospheric Environment, Vol. 27A, No. 5, pp. 739-747. GreatBritain.

  23. Delaware Department of Natural Resources and Environmental Control, Air SurveillanceBranch. Email from Betsy Frey to Betty Willis at ATSDR with attached Excel file of2002 VOC air monitoring data for Delaware. 2003 Jun 03.

  24. U.S. Environmental Protection Agency. Standard Chlorine site data tables (January2003). Available at URL: http://www.epaosc.net/doc_list.asp?site_id=03H6. Last accessed September 4, 2003.

  25. Metachem Products, LLC. Dioxin and furan testing data compiled for the state ofDelaware Department of Natural Resources and Environmental Control. New Castle,Delaware; 2001 Mar 29.

  26. Conestoga-Rovers & Assoc. Status report of ecological risk assessment–Standard Chlorine of Delaware superfund site--prepared for Metachem Products. Delaware City, Delaware. 2002 Jan.

  27. Delaware Division of Fish and Wildlife Web site. Fish consumption advisories. Availableat URL: http://www.dnrec.state.de.us/fw/advisory.htm . Last accessed August 19, 2003.

  28. Metachem Products, LLC. Quarterly monitoring report–groundwater recovery system operation. Delaware City. 2002 Jan 16.

  29. Delaware Division of Public Health, Office of Drinking Water. Letter from Edward G.Hallock to Christina Wirtz with DNREC, regarding sampling of domestic wells invicinity of Metachem Facility. 2003 Feb 24.

  30. Agency for Toxic Substances and Disease Registry. A record of activity by Betty Willisregarding conversation with Edward Hallock with Office of Drinking Water, DelawareDivision of Public Health. Response to ATSDR questions regarding sampling of drinkingwater wells near Metachem. 2003 May 1.

  31. Agency for Toxic Substances and Disease Registry. ATSDR ToxFAQs–chlorobenzene CAS # 108-90-7. Atlanta: U.S. Department of Health and Human Services; 1999 Jul.

  32. U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. OPPT chemical fact sheets–Chlorobenzene (CAS No. 108-90-7). EPA 749-F-95-007 and 007a. 1995 Jan.

  33. Agency for Toxic Substances and Disease Registry. ATSDR ToxFAQs 1,4-Dichlorobenzene CAS # 106-46-7. Atlanta: U.S. Department of Health and HumanServices; 1999 Jun.

  34. Agency for Toxic Substances and Disease Registry. Toxicological profile for 1,4-dichlorobenzene. Atlanta: U.S. Department of Health and Human Services; 1998 Dec.

  35. U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. OPPTchemical fact sheets, 1,2,4-Trichlorobenzene (CAS No. 120-82-1). EPA 749-F-95-020and 020a. 1994 Nov.

  36. Agency for Toxic Substances and Disease Registry. Medical management guidelines(MMGs) for acute chemical exposures, version 2001, hydrogen chloride (HCl) CAS7647-01-0. ATSDR Web site. Available at URL: http://www.atsdr.cdc.gov/MHMI/mmg173.htmlLast accessed Aug 2002.

  37. American Conference of Governmental Industrial Hygienists (ACGIH®). 2002 TLVs®and BEIs®. Cincinnati, Ohio.

  38. Agency for Toxic Substances and Disease Registry. ATSDR ToxFAQs Benzene CAS #71-43-2. Atlanta: U.S. Department of Health and Human Services; 1997 Sep.

  39. Agency for Toxic Substances and Disease Registry. Medical management guidelines(MMGs) for acute chemical exposures, version 2001, Benzene (C6H6) CAS 71-43-2; UN1114. ATSDR Web site. Available at URL: http://www.atsdr.cdc.gov/MHMI/mmg3.html. Lastaccessed Aug 2002.

  40. Delaware Public Health, Epidemiology Branch. Cancer epidemiology, age-adjustedincidence rates per 100,000 for all cancers SEER and Delaware: 1980-98. Delaware Website. Available at URL: http://www.delaware-epi.org/tccr.htm . Last accessed June 21, 2002.

  41. Delaware Department of Natural Resources. Executive summary groundwater sampling2002. New Castle. 2002 Sep.

  42. MapQuest. Aerial photograph of Metachem Products, LLC and surrounding area.Downloaded from http://www.mapquest.com. Last accessed August 27, 2003.

  43. U.S. Environmental Protection Agency, Region III. E-mail from Hilary M. Thornton,Remedial Project Manager, to Lora Werner at ATSDR transmitting soil samplingsummary report and data in Excel spreadsheets. Philadelphia; 2003 May 30.

APPENDIX A: FIGURES

GIS Demographic Map
Figure 1. GIS Demographic Map (5)

Spills in 1981 and 1986
Figure 2. Spills in 1981 and 1986 (2)

Wilmington Air Toxics Concentrations–Annual Averages
Figure 3. Wilmington Air Toxics Concentrations–Annual Averages (17)
Notes: Insufficient data in 1995 to calculate annual average. New method used in 2000.

Groundwater Contamination Plume
Figure 4. Groundwater Contamination Plume
September 2002 Groundwater Sampling Event Isoconcentration Map (41)

Aerial Photograph of Metachem Products, LLC and OxyChem Ball Field Outlined in Blue
Figure 5. Aerial Photograph of Metachem Products, LLC and OxyChem Ball Field Outlined in Blue (42)

Cancer Incidence Rates for 1980-1998
Figure 6. Cancer Incidence Rates for 1980-1998 (40)


APPENDIX B: FISH CONSUMPTION ADVISORIES (27)

Delaware Division of Fish & Wildlife
Fish Consumption Advisories

Fishing is an important activity in Delaware's inland and coastal waters. Among the benefitsprovided by fishing are quality recreational opportunities, direct and indirect input to the localeconomy, food for recreational anglers and food for the commercial marketplace.

Fish are a good source of readily digestible protein, they are low in fat and sodium, and theunique type of fats found in fish are believed to provide cardiovascular benefits. Despite thegeneral benefits of fishing and fish consumption, there has been a growing concern regarding thepresence of chemical toxins in the flesh of finfish and shellfish taken from Delaware waters andthe associated health risk to anglers and their families who consume their catch. The existence ofchemicals in the edible portion of some fish has resulted in the public advisories listed in thetable below. These advisories are as a result of joint action taken by the Department of NaturalResources and Environmental Control and the Department of Health and Social Service'sDivision of Public Health.

The advisories were deemed necessary because of the nature of pollutants such aspolychlorinated biphenyls (PCBs). Even when present in the water in extremely small amounts,some chemicals tend to build up over time in fish tissue because fish can absorb and concentratecontaminants from food they eat, or to a lesser extent, directly from the water. The amount ofcontaminants fish accumulate depends on the species, size, age, sex, and feeding area of the fish.Generally speaking, older larger individual fish accumulate the most contaminants, although insome cases contaminants are shed each time the fish spawn. Since fish accumulate manycontaminants in their fatty tissues, certain species with higher oil content can pose more risk thanothers when both inhabit polluted areas.

More information concerning health advisories for Delaware waters can be obtained bycontacting the Department of Natural Resources and Environmental Control at (302) 739-4506,and/or by phoning the Division of Public Health at (302) 739-4071 or (302) 739-5617.

Delaware Fish Consumption Advisories as of February, 2002
Waterbody Species Geographical Extent Contaminants of Concern* Advice
Becks Pond All Finfish Entire Pond PCBs, Mercury No more than six 8-ounce meals per year
Delaware River All Finfish Delaware State Line to the C&D Canal PCBs, Arsenic, Dioxin, Mercury, Chlorinated Pesticides No Consumption
Red Lion Creek All Finfish Rt 13 to the Delaware River PCBs, Dioxin No more than three 8-ounce meals per year
Lower Delaware River and Delaware Bay Striped Bass, Channel Catfish, White Catfish, American Eel, White Perch C&D Canal to Delaware Bay Mouth PCBs, Mercury, Dieldrin No more than one 8-ounce meal per year.
Tidal Brandywine River All Finfish River Mouth to Baynard Blvd. PCBs No Consumption
Non-Tidal Brandywine River All Finfish Baynard Blvd. To Pennsylvania Line PCBs, Dioxin No more than two 8-ounce meals per year
Shellpot Creek All Finfish Rt. 13 to the Delaware River PCBs, Chlordane No Consumption
Tidal Christina River All Finfish River Mouth to Smalley's Dam PCBs, Dieldrin No Consumption
Non-tidal Christina River All Finfish Smalley's Dam to I-95 PCBs No more than six 8-ounce meals per year
Little Mill Creek All Finfish Creek mouth to Kirkwood Highway PCBs No Consumption
Tidal White Clay Creek All Finfish River Mouth to Route 4 PCBs No Consumption
Non Tidal White Clay Creek All Finfish Rte. 4 to Paper Mill Road PCBs No more than one 8-ounce meal per month
Red Clay Creek All Finfish State Line to Stanton PCBs, Dioxin, Chlorinated Pesticides No Consumption
Chesapeake & Delaware Canal All Finfish Entire Canal in Delaware PCBs No Consumption
Appoquinimink River All Finfish Tidal Portions PCBs, Dioxin No More than one 8-ounce meal per year
Drawyers Creek All Finfish Tidal Portions PCBs, DDT No More than one 8-ounce meal per year
Silver Lake Middletown All Finfish Entire Lake PCBs, Dieldrin, DDT, Dioxin No More than one 8-ounce meal per year
St. Jones River All Finfish River Mouth to Silver Lake Dam PCBs, Dioxin, Mercury, Arsenic No More than two 8-ounce meals per year
Moores Lake All Finfish Entire Pond PCBs, DDT No More than two 8-ounce meals per year
Silver Lake Dover All Finfish Entire Pond PCBs, Dioxin, Mercury No More than two 8-ounce meals per year
Wyoming Mill Pond All Finfish Entire Pond PCBs, Dioxin, DDT No More than two 8-ounce meals per year
* The pollutant listed first is of the greatest concern in this system.

National Methylmercury Fish Consumption Advisory

On January 12, 2001, EPA and the Food and Drug Administration (FDA) issued concurrentnational fish consumption advisories recommending restricted consumption of freshwater coastaland marine species of fish due to methylmercury contamination. EPA's advisory targeted womenof childbearing age and children who may be consuming noncommercial freshwater fish caughtby family or friends. The advisory specifically recommends that women who are pregnant orcould become pregnant, women who are nursing a baby, and their young children, should limitconsumption of freshwater fish caught by family and friends to one meal per week unless thestate health department has different advice for the specific waters where the fish are caught. Foradults, one meal is six ounces of cooked fish or eight ounces uncooked fish; for a young child,one meal is two ounces of cooked fish or three ounces of uncooked fish.

FDA issued advice on mercury in fish bought from stores and restaurants, which includes oceanand coastal fish as well as other types of commercial fish; FDA advises that women who arepregnant or could become pregnant, nursing mothers, and young children not eat shark,swordfish, king mackerel, or tilefish. FDA also advises that women who are pregnant or couldbecome pregnant may eat an average of 12 ounces of fish purchased in stores and restaurantseach week. EPA recommends that women who are or could become pregnant, nursing mothers,and young children follow the FDA advice for coastal and ocean fish caught by family andfriends. EPA and FDA both recommend that the public check with state or local healthauthorities for specific consumption advice about fish caught or sold in the local area. The EPAand FDA advisories are available through the EPA fish advisory website.

Cutting Out The Risks

Avoid eating fish from the waters listed in the above table.

Eat smaller fish of a species as long as it is of legal length.

Eat smaller portions of fish and eat fewer meals of fish.

Women of child bearing age and children may want to avoid eating any species of fishsuspected to be a problem.

Dress and cook the fish in a manner that reduces contaminants.

fish illustration

Toxic chemicals tend to concentrate in the fatty tissue found in the:

  1. Dorsal Area
  2. Lateral Line
  3. Belly Flaps

When cleaning fish, always skin it and trim away fatty areas as shown below:

fish illustration


APPENDIX C: RESPONSE TO PUBLIC COMMENTS

This appendix summarizes the comments received at the public meetings on March 12 and May1, 2003, or submitted during the comment periods January 1-30 and May 1-16, 2003. Thecomments and the agency's responses are provided below. All of the references in the commentsto specific pages refer to the initial release of this public health assessment for public comment.The page numbers (and reference numbers) in some cases are different in this final document.However, in ATSDR's replies the references to specific pages, etc. are to this the final document.

  1. The health assessment references an EPA memorandum that erroneously reportedthat upon exposure to sunlight chlorobenzene products break down tohydrocarbons and HCl. The World Health Organization says that chlorobenzenesform PCBs when exposed to sunlight.

The EPA memorandum provided the source of its information: Nigel Bunce, Environmental Chemistry, Winnipeg, Canada: Wuerz Publishing Ltd, 1991, pages 293-294. The breakdown of organic chemicals in the environment is well documented in the literature. In fact, the World Health Organization's 1991 Environmental Health Criteria 128–Chlorobenzenes Other than Hexachlorobenzene document in Section 1.3.1 Degradation says, "Chlorobenzenes are removed from the environment principally by biological, and, to a lesser extent, by non-biological mechanisms; ... In air, chemical and photolytic reactions are presumed to be the predominant pathways for chlorobenzene degradation, with residence times in the range of 13-116 days...."

The commenter provided no specific citation to support his contention that chlorobenzenes formmore complex chemicals (PCBs) when exposed to sunlight, rather then degrading. In fact, theWorld Health Organization supports ATSDR's position that chlorobenzenes degrade in theenvironment.

  1. The original data that the Chlorobenzene Producers Association (CPA) supplied toATSDR (sic: when ATSDR requested data which it used to prepare theChlorobenzene Toxicological Profile) was based on the Kirk Othmer process andchlorobenzene chemicals purchased from a laboratory supply house. That datarepresents the standard manufacturing process. Standard Chlorine/Metachem useda hybrid manufacturing process, thereby contaminating all their products with2,3,7,8-tetrachlorodibenzo-p-dioxin and related compounds.

The health assessment used the Dioxin and Furan Testing Data supplied to the DelawareDepartment of Natural Resources and Environmental Control (DNREC) by Metachem (25) andrecent dioxin analyses by EPA (24), not the CPA data, to draw conclusions about the level ofdioxin exposure. The dioxin data used (see Tables 9 and 10) were from analysis of StandardChlorine and Metachem products, and waste water treatment effluent, activated carbon filters onthe waste water treatment plant, outdoor air, and indoor air samples at the Metachem facility. Thecommenter provided no data or information to show that the actual data used in the healthassessment are not representative of dioxin concentrations at Metachem or in its products.ATSDR has received and included in the final health assessment additional dioxin analysesperformed by EPA and its contractors. The new data do not change our conclusions.

  1. Isolate and remove potential problems. If you find people are exposed at a certainplace, isolate the area and remove the contamination or prevent exposures so therewon't be the potential for health problems.

ATSDR evaluates all the Superfund sites to determine if people are being exposed. If exposure isoccurring, ATSDR provides advice to EPA and the communities on how they can preventexposures and thus prevent potential health problems. EPA and state environmental agencieshave the regulatory authority and responsibility to isolate or remove contamination fromSuperfund sites.

  1. The former owners should be made to pay for the clean-up. Does ATSDR/HHS haveauthority to hold the former owners of Metachem and Standard Chlorine criminallyresponsible?

No. ATSDR and DHHS do not have regulatory authority over chemical plants. Congress hasgiven that authority and responsibility to EPA.

  1. The pre-mailing did not clarify the protocol for meeting (i.e., one-on-one concerns).

ATSDR apologizes for the confusion that occurred. The notice could have been written to betterconvey that message. The notice said, "Your discussion is confidential." If you had to stand up ina public meeting type format to discuss your concerns, your discussion would not be confidential.The only way ATSDR can provide confidentiality is to talk to each individual one-on-one.Although the protocol was not what you expected, ATSDR hopes you appreciated theopportunity to speak privately with staff.

  1. ATSDR sheets read too much like what a company would put out in response tocitizen concerns and complaints.

ATSDR tried to be straightforward in its Fact Sheets to provide clear answers to the community'sconcerns. It is unfortunate that the commenter thought that the Fact Sheets sounded like companypropaganda. ATSDR does not condone the actions of Standard Chlorine or Metachem thatresulted in leaks and spills that have heavily contaminated the site. Because residents do not liveclose to this facility and industrial complex, the community has not been exposed to thecontamination caused by these companies. If people are not exposed to the chemicals insufficient amounts to cause illness, they will not have adverse health effects.

  1. The "chemical smell" paragraph discusses direct anecdotal observations on the odorby persons who smelled it at the time.

This is correct. The paragraph does discuss anecdotal observations of local residents and what could be the source(s) of the smell.

  1. I have a 15-year-old son with cerebral palsy and my 43-year-old wife died of cervicalcancer in 1998. I'm 50 years old and have had stomach pains for several years. I hadmy gallbladder removed in the spring of 2002 but the stomach problems (pain) stilllingers. My girl friend and son have had skin rashes on their feet lately and we allhave headaches and upset stomach. I don't know if these health problems arerelated to the site or not. We have lived in the Llangollen area for 10 years.

To the best of ATSDR's knowledge, cerebral palsy, gall stones, and cervical cancer are notrelated to exposure to any of the chemicals used or manufactured by Standard Chlorine orMetachem Products. ATSDR encourages you to see your family doctor regarding yourcontinuing stomach pains. The headaches and the skin rashes on your son's and girl friend's feetcould be related to exposure to any of a number of different chemicals. ATSDR recommends thatyour girl friend and son work with your family doctor or a dermatologist to determine what iscausing their skin rashes, so that they can avoid future exposures to the products or chemical towhich they are allergic.

  1. I know we live in an industrial area so our air is probably contaminated by all theindustries around here, but we work in this area, so we can't move. What do yourecommend about living in a chemical and industrial area? In your final documenttell us what more we can do besides not eating local fish. I would like the healthdepartment to give us practical advice on what we should do based on what you allknow about what we are exposed to in this area.

When you live in an industrial area, you cannot avoid some degree of exposure to chemicalswhen breathing the outside air. However, Delaware has several air monitoring stations in thearea, and the levels of chemicals they have found are only occasionally high enough to causerespiratory problems, therefore local residents should not be overly concerned. During thesummer whenever the state issues an ozone alert, ATSDR recommends that residents stayindoors as much as possible to reduce your exposure. One of the main contributors to theformation of ozone is vehicular emissions, so anything you can do to reduce or eliminate caremissions and emissions from lawn mowers, boat motors, and other combustion engines willbenefit your health.

Maintain good health by eating a healthy diet, getting plenty of sleep and exercise, and avoidingsmoking. Stress can also affect your health and resistance to diseases. If you have a high level ofstress in your life, ATSDR recommends that you learn how to manage the stress. Do not beoverly concerned about living in Delaware.

If you work in an industrial plant, obey the safety rules and wear all the personal protectiveequipment that is recommended by the company or union. Your health is more important thenribbing by fellow employees. Be proactive if you think employee exposures are occurring.

Work with your local zoning officials and DNREC permitting staff to maintain buffers betweenindustrial and manufacturing complexes and residential areas, when they exist. Because of ourlifestyles and the conveniences we all want, it is unrealistic to expect "zero" pollution; however,you can encourage companies to upgrade their facilities with new or better equipment thatproduces less pollution. There has been a decline in air pollution in Delaware over the last 7-10years (see Figure 3). Encourage your regulatory agencies to keep this decline going whilemaintaining the economic stability that industry provides.

  1. We live in the Llangollen Green area and get our water from the ArtesianCompany. Last year they found BCEE (a gasoline additive) in their wells. It iscoming from the Army Creek and Delaware Sand and Gravel sites. Artesian put inan expensive treatment system to filter out the BCEE and they say the water is OKnow. We also put a reverse osmosis filter system on the water in our kitchen. LatelyI have noticed a white film on top of the water when we boil it to make coffee. Whatis causing this film? Is the water safe to drink? Should we put on a whole housewater filter?

ATSDR put this person in contact with the Delaware Office of Drinking Water. The state staffhave been working with the Artesian Company on the treatment system to remove the BCEEcontaminants. The state staff agreed to sample this family's water and to advise them regardingthe in-house filter.

  1. This site will never be cleaned up. The spills of finished product was more like 1,100,000 to 1,400,000 gallons–not what you have in your report. I worked there–I know. There were lots of other smaller spills too. Because these chemicals are heavier then water they have contaminated the whole area below and east of the plant–past the river.

From what ATSDR staff have read and heard about Standard Chlorine and Metachem Productsand pictures the staff have seen, ATSDR agrees with you. There were lots of leaks and spills overthe years, and it may not be possible to remove all the contamination. The EPA and DNREC datashow that the soil at the site and sediments in Red Lion Creek and its tributary are contaminated.The Columbia aquifer is contaminated, and it has a layer of chlorinated benzene products on thebottom in some areas under the site. However, recent ground water sampling data show that thesite-related contaminants have not migrated north across Red Lion Creek or east to the DelawareRiver.

  1. I worked at Standard Chlorine for years and they had meta-chloronitrobenzenewhich I haven't seen mentioned in yours or any of EPAs reports. If you dig down inthe tiled area in the back of the plant you will find it. If you dig a hole any where onsite, I bet you won't be able to go into it without a protective mask.

ATSDR staff members talked to EPA and DNREC staff about this comment. They are nowanalyzing for nitrobenzene in soil samples on the site. ATSDR does not have any information atthis time regarding chloronitrobenzene contamination.

  1. Autism is high in Delaware and New Jersey. Is this caused by Metachem chemicals?

ATSDR staff have not seen studies that link autism with the chlorobenzenes manufactured byStandard Chlorine or Metachem Products. More research is needed on what causes autism.

  1. I don't think you have enough information to determine if health effects areoccurring in the community due to Metachem. If you don't have enoughinformation, you should have NO conclusions rather then saying there are no"apparent" health hazards.

ATSDR's approach is to first determine IF residents are being or have been in the past exposedto any chemicals from the site in sufficient doses to cause adverse health effects. If no exposureis occurring or has occurred, then no health effects can occur that are due to the site. ATSDR hasdata from recent ground water and drinking water samples at and around the site that show thecommunity is not being exposed to the contaminated ground water. The Delaware air samplingdata going back to the early 1990s show chlorobenzene levels below concentrations known tocause health effects. The only pathway ATSDR found that residents might have been exposed tois if they ate fish from Red Lion Creek in spite of the warnings against doing that. ATSDR foundthat sufficient data exist to determine that exposure to site chemicals has not occurred in thecommunities around the site, and therefore, health effects occurring in the community are not dueto Metachem. As discussed in the previous release of this document, ATSDR does think thatworkers at the site may have been exposed to the chemicals and therefore may have the potentialfor health effects related to their employment.

  1. Standard Chlorine used titanium and ferrous chloride as a catalyst in the process.Sometimes the river ran red when they dumped the ferrous chloride. Do you knowwhat they do to the water?

For many years there have been warnings by all the states along the Delaware River advisingagainst eating fish caught in the river, because it is so polluted. Dumping titanium and ferrouschloride into the river adds to the contamination and reinforces ATSDR's warning against eatingfish caught in the Delaware River.

  1. You say the Metachem site is a really contaminated site, but your document sounds like you are supporting Metachem–you say the site isn't a public health hazard. If you are not supporting what Metachem did then SAY IT in your document!

ATSDR does not support the way Standard Chlorine and Metachem Products have polluted thesite, groundwater, and sediments and water in the Red Lion Creek and its tributary. They did notproperly maintain their equipment, with the result of several large spills and numerous leaks andspills that have heavily contaminated the area. Both companies left a legacy of environmentalcontamination.

However, ATSDR cannot ignore the fact that the community has not been exposed to thecontamination caused by these companies. If people are not exposed to the chemicals insufficient amounts to cause illness, they won't have adverse health effects. It is ATSDR's duty tolet the community know whether members are exposed to contaminants from Superfund sites.ATSDR tried to be straightforward in the health assessment and the fact sheets to provide clearanswers to the community's concerns about health effects caused by this site. It is probablydifficult for local residents to accept that a site as polluted as this one is could be classified as nopublic health hazard, but if the residents don't come in contact with the chemicals by somemeans, they won't be affected. Fortunately, the residents do not live close to the facility andindustrial complex. The buffer between residential areas and the facility has prevented exposuresthat could cause adverse health effects.

 
  1. My husband worked at Motiva and he died at age 58 from bone cancer frombenzene exposure. My son works at Motiva too. I wonder if he has or will get cancertoo.

ATSDR hopes not. Encourage your son to take care of his health and wear any personalprotection equipment furnished or recommended by Motiva or his union. He should be aware ofhis surroundings and minimize his exposure to the chemicals as much as possible.

  1. I am concerned about benzene exposures in the area. I have diabetes and high bloodpressure, probably from benzene. My daughter developed leukemia 2-3 years aftermoving into the area.

Diabetes and high blood pressure are not known to be caused by benzene exposure. Leukemiacan be caused by long-term exposure to high levels of benzene; however, it does not usuallyoccur so rapidly (within 2-3 years). In the data ATSDR's staff reviewed, the maximumconcentration of benzene measured at any of the air monitoring stations in your area (see Tables5, 6, and 7) was 2.17 ppb, well below levels expected to cause leukemia.

  1. There are a lot of problems in this area. Over on Rutledge off Hwy 71 landfill gas is migrating into their homes from the huge landfill across the street. A lot of the homes on that street have monitors in their basements for the gas. Metachem left a mess and Motiva needs better regulating–they've had some big spills too. Industry should be regulated from the beginning so they won't pollute. Also they should have to clean up their plant before they can sell it so others don't get stuck with their mess.

ATSDR does not have regulatory authority over industrial facilities, so that the agency cannotaddress these concerns. The commenter should direct these concerns to state and federalenvironmental protection agencies (EPA and DNREC).

  1. Your research was inadequate. Figures generated by self-reporting are completelyunreliable. Dig deeper. All of us know people affected by this petrochemicalcomplex. If you cannot separate out what harm comes from this particular facility,draw no conclusions, because to say that it causes no harm flies in the face of reason and logic to the entire public.

The only figure in the public comment release of this document that was generated by Metachemself-reporting was Figure 4. That figure has been replaced in the final document with a figureprepared by EPA and DNREC contractors based on their recent ground water sampling.

ATSDR has separated the chemicals used or produced by Standard Chlorine and MetachemProducts from the rest of the chemicals found in environmental samples and evaluated thosechemicals as if this facility was responsible for the whole concentrations. ATSDR evaluated datafrom samples taken in the past, as well as recent samples of air, soil, sediment, fish, and groundwater. The data clearly show that even though the site itself is VERY contaminated, the localresidents have not been exposed to the chemicals at concentrations that could cause adversehealth effects. See also the replies to comments 6 and 16.

  1. Your data is old. Why don't you include and discuss the latest data released by EPAand DNREC?

The most current data available at the time the document was written was reviewed and includedin each release of this public health assessment. Unfortunately, it takes four to six weeks for ahealth assessment to go through internal review and approval, printing, and mailing, so any datareleased while the document is being processed can't be included in that edition of the document.The environmental agencies released several important data packages between the time thepublic comment release of this health assessment was written and mailed out to the communityand we had several meetings with the public. That data has been included in this edition.

The same thing happened this time. This document was completed in mid-August. In late Augustand early September, EPA released data from a major soil and sediment sampling effort, so wehave added this discussion at the last minute. The recent EPA data include dioxin sampling inselected locations, as well as chlorinated benzene sampling both onsite and offsite. Those dataare not included in this edition, however, we have reviewed the new EPA data and concludedthat it does not change any of our conclusions or recommendations, so it is not necessary to stopthe publication of this document to include the new data. The concentrations of chlorinatedbenzenes detected in the soil and sediment samples is about the same (actually less) then themaximum values found earlier that are discussed in the text already. It does appear (as would beexpected) that over the years the contaminants have continued to migrate deeper and spreadfurther, so there will be more material to be remediated, but the contamination is not in areaswhere the public will come in contact with it. Since the community is not exposed to thecontaminated soils and sediments, their health will not be adversely affected by the chemicalspresent in the environment.

ATSDR is aware that one of the dioxin samples taken on-site did show a much higherconcentration then previously found anywhere on the site. However, the community does nothave access to this area, so exposure is not possible. ATSDR staff will maintain contact withstaff from EPA and DNREC regarding their activities at the Metachem Products NPL Site evenafter this public health assessment is released.

  1. Wind factors must be considered in monitoring sites.

Yes, ATSDR agrees. Wind speed and direction were included in the air sampling reports fromDNREC and Battelle that ATSDR reviewed.

  1. Water does not stay in Red Lion Creek; it travels down the DE River to oceanresorts. The people of New Jersey are probably more threatened by this operationthan we are.

Yes, the Red Lion Creek does flow into the Delaware River, which flows into the ocean. Theriver is contaminated by industry in several states before it gets to Delaware and New Jersey,both of which allow their industry also to discharge waste waters to the river. The people ofDelaware and New Jersey are impacted to some extent by the chemicals from all the industry.

  1. The newspaper says you don't have enough information about exposures from Metachem. The Delaware Air Program has lots of data. In 1985 they began non-criteria pollutant monitoring. Get a copy of the January 1994 report that was presented to the 1994 Cancer Task Force, An Analysis of Delaware's Non-Criteria Air Concentrations and ask the DE Engineering Compliance Group for source sampling done at Standard Chlorine and Metachem. In 1987 they did fence line sampling and found 86 of the 100 organics analyzed for–I think benzene was at 1 ppm at the fence line, others were around 0.05 ppm.

ATSDR obtained the 1994 report to the Cancer Task Force as well as the Battelle study thatincluded fence line and community air samples. The Battelle data are provided in Table 6 anddiscussed in the Inhalation Pathway section. The maximum fence line benzene concentration inthe Battelle samples was 0.051 ppm. The average benzene concentration in the community airsamples was 0.58 ppb or 0.00058 ppm. ATSDR staff also looked at recent EPA air monitoringdata on site and concluded that there are no data indicating that local residents' health has beenaffected by air emissions from the Standard Chlorine/Metachem site, in the past or currently.

  1. I would like to see you do a risk assessment using the air data for the last 15 years for the area–not just Metachem.

The Delaware air program Web site contains several reports that the state has done to summarizethe previous year's air data, as well as historical trends (see Figure 3 and reference 16). ATSDRsuggests that the commenter contact the Delaware air program to see if staff there would do anarea risk assessment. ATSDR's focus in this public health assessment is to determine whether the local residents are affected by chemicals from the Standard Chlorine and Metachem site.

  1. The cancer rate in DE is the highest in the nation. What portion of the cancerincidences are from occupational exposures?

ATSDR does not know what portion of the cancer incidences in Delaware are due tooccupational exposure, genetics, personal life styles, or environmental exposures.

  1. They need a remediation system immediately to extract dioxin in the Columbiaaquifer. The Columbia is closer to the surface in low lying areas. There it is about15-18 feet, not 30-60 feet as you say on page 18.

There is already a remediation system that is pumping the Columbia aquifer and treating thewater before it is discharged into the Delaware River. The weekly reports by the EPA On-SceneCoordinator (OSC) provide a running total on the gallons of water pumped and treated and thegallons of chlorinated benzenes recovered. The OSC reports are available on the EPA Web siteat: http://www.epaosc.net/site_profile.asp?site_id=03H6 . The monitoring reports are underDocuments at the bottom of the page. EPA and DNREC are evaluating the system to determinewhat upgrades are needed to improve its effectiveness. ATSDR added to the text that theColumbia aquifer is closer to the surface in low-lying areas.

  1. ATSDR should recommend a complete cleanup of groundwater contamination.

EPA specified in its Record of Decision for this site how the ground water should be remediated.So far, only a portion of the plan has been implemented. Cleaning up ground watercontamination is a slow and difficult process. It is too early to say if it would actually be possibleto "completely cleanup" the Columbia aquifer. The best that can be achieved with knowntechnologies may be to contain the contaminated groundwater under the site, so that it does notspread to other wells; to prohibit drilling of wells in the contaminated areas; to monitor the site tomake sure the contamination is not spreading off-site; and to reduce the toxicity of the groundwater by continuing to pump and treat the water. ATSDR only makes recommendations to assurethe public is not being exposed. EPA can prevent exposures by containing the contamination orremediating it.

  1. ATSDR should oppose the "restart" of Metachem because it will cause additionaltoxic emissions. On-site incineration should be ruled out as a remediationtechnology.

EPA has been operating a portion of the facility since July 17, 2003. As of the time of this reply(late-August), the air monitors have not detected emissions that would cause health effects in thecommunity.

It is ATSDR's understanding that tests have shown that biological treatment (which wasoriginally proposed for cleaning up the site) will not work. EPA is re-evaluating feasibletreatment options. They recently announced that they are studying the use of in-situ chemicaloxidation, not incineration.

  1. They need to continue air monitoring.

ATSDR agrees. ATSDR recommended continued air monitoring in the initial release of thispublic health assessment, as well as in this, the final document.

  1. Are private wells near Metachem monitored periodically?

Yes, private wells on-site, on neighboring properties, and on the north bank of Red Lion Creekhave been sampled this last year. All public and private drinking water wells within a 1.5-mileradius of the site were also sampled in December 2002 and January 2003. So far, thecontamination has not spread beyond the industrial area.

  1. MSDS sheets for the chemicals used at the facility should be available as handoutsat meetings.

ATSDR staff use other references (not MSDSs) as sources of health information andtoxicological studies, so ATSDR does not have MSDS sheets for the chemicals used atMetachem. EPA may have MSDS sheets for the chemicals if you want to ask that agency. TheToxicity of Site-Related Chemicals section of this health assessment discusses the predominantchemicals used or manufactured at the plant and the health effects they can cause.

  1. Workers drank from the contaminated onsite well for a long time, until a workergot the water tested and they found out it was definitely contaminated.

ATSDR identified Standard Chlorine and Metachem workers as probably exposed in the past.ATSDR does not have data showing the concentrations of the various chemicals that workerswere exposed to in the air and well water before the plant was closed, so that ATSDR cannot sayfor sure whether they might have health effects.

  1. Why aren't you doing a "registry" at this site?

ATSDR sometimes establishes a registry of individuals identified as receiving a known dose of achemical or a unique combination of chemicals. The purpose is to study what health effects mayoccur in the individuals as a result of the exposure. At this site, the communities have not beenexposed to chemicals from the site (if they obeyed the fish advisories), so a registry would notprovide useful information.

  1. Why aren't there more fish advisory signs posted near the site?

In the initial release of this public health assessment, ATSDR recommended that the state postwarning signs at locations where people are likely to fish or enter the water, such as boat ramps,bridges, piers, and parks, if signs were not already present. Delaware staff told us they visitedthese locations and put up new signs if the signs were missing or difficult to read due toweathering.

  1. I would like my private well tested.

The following information was copied from the Delaware Office of Drinking Water Web page at: http://www.state.de.us/dhss/dph/hsp/odwhomeowner.htm . If you would like to talk to staff in theOffice of Drinking Water's main office, the telephone number is (302) 739-5410. Additionalinformation is available on the Delaware Web site:

Private water supplies should be tested annually for nitrate and coliform bacteria to detectcontamination problems early. Test them more frequently and for more potentialcontaminants, such as radon or pesticides, if you suspect a problem. Water test kits areavailable for a charge of $4.00 each at any of the environmental health field officesserving the three respective counties. If you use a private laboratory to conduct thetesting, nitrate and bacteria samples will typically cost between $10 and $20 to complete.Testing for other contaminants will be more expensive. For example, testing forpesticides or organic chemicals may cost from several hundred to several thousanddollars.

EPA does not test individual homes and cannot recommend specific labs to test yourdrinking water, but states such as Delaware do certify water testing labs within theirrespective borders. Many laboratories are available to test water quality, as are cited on"List of Delaware's Certified Private Water Testing Laboratories". Most laboratories mailback the sample results within days or several weeks.

If a contaminant is detected, the results will include the concentration of the contaminantand an indication of whether this concentration exceeds a drinking water quality standard.If a standard is exceeded in your sample, retest the water supply immediately and contactyour public health department for assistance. Some problems can be handled quickly. Forexample, high bacteria concentrations can sometimes be controlled by disinfecting a well.Filters or other on-site treatment processes may also remove some contaminants. Otherproblems may require a new source of water, or a new, deeper well. If serious problemspersist, you may need to rely on bottled water until a new water source can be obtained.

Environmental Health Field Services offices are located in the three respective countiesand are open daily from 8:00 a.m. until 4:30 p.m. Those offices are:

New Castle County Environmental Health Field Services
2055 Limestone Road, Suite 100
Wilmington, DE 19808
Phone: (302) 995-8650
Fax: (302) 995-8323

Kent County Environmental Health Field Services
805 River Rd., Third Floor
Dover, DE 19901
Phone: (302) 739-5305
Fax: (302) 739-7013

Sussex County Environmental Health Field Services
546 S. Bedford St., Room 1001
Georgetown, DE 19947
Phone: (302) 856-5496
Fax: 302-856-5065

List of Delaware's Certified Drinking Water Testing Laboratories

Bacteriology

Atlantic Coast

City of Wilmington Water Division Laboratory

ENVIROCORP, Inc.

McCall Laboratories

United Water Delaware

Chemistry

Atlantic Coast

Batta Laboratories

ENVIROCORP, Inc.

McCall Laboratories

Mid-Atlantic Environmental Laboratories

  1. I ate the fish from the creeks near Metachem regularly (1-2 fish a week from Springto Fall) in the 1980s. Could this have affected my health? What should I tell mydoctor?

Obtain a copy of the Delaware Fish Consumption Advisories and show your doctor from whichcreeks you ate fish. The advisory lists the contaminants of concern in the various bodies of water.Once your physician knows what chemicals you may have been exposed to and what illnessesyou have, the physician should be able to advise you on whether any illnesses are related toeating the fish. If your physician needs information on any of the chemicals, he/she can contactthe Delaware Division of Public Health at 302-739-4071 or 302-739-5617 or ATSDR at 888-422-8737.

The fish advisories are updated periodically. You can get a current copy of the Fish ConsumptionAdvisories from the Delaware Division of Public Health, the Division of Fish and Wildlife orfrom their Web site at http://www.dnrec.state.de.us/fw/advisory.htm .

  1. Is anyone following up on the workers from Metachem?

Not that we know of. The Occupational Safety and Health Administration (OSHA) regulateswork place conditions. Workers can contact the nearest OSHA office if they have questionsabout exposures in the work place.

  1. Are workers on site protected now?

EPA uses several continuous air monitoring stations on-site and hand-held air samplingequipment to determine what kind of respiratory protection equipment the workers need to wear.

  1. It is important to consider both cancer mortality and incidence data.

ATSDR agrees that it may be important to consider both cancer mortality and incidence datawhen evaluating communities that have been exposed to carcinogens at concentrations likely tocause health effects. However, the local residents have not been exposed to carcinogens by thissite. ATSDR included a brief discussion of cancer incidence rates in Delaware because thecommunity is concerned about cancer.

  1. Should we be concerned that local restaurants serve locally caught shellfish and fishall the time? Does anyone sample these food products so we know they are safe toconsume?

It is ATSDR's understanding that the Delaware Division of Fish and Wildlife catches variousspecies of fish in Delaware bodies of water. The fish are analyzed for a variety of chemicals, andthe fish advisories are updated as needed. ATSDR recommends that you ask the restaurant wherethe shellfish or fish you plan to eat were caught, and decide how much you should eat based onthe Fish Consumption Advisories.

  1. Be clear about who caused what contamination–Standard Chlorine or Metachem Products.

Both companies caused contamination of the site. The two large spills occurred while StandardChlorine owned the site, but from pictures, inspection reports, and reports by former employees,Metachem Products continued Standard Chlorine's legacy of environmental pollution. It doesn'tmatter which company caused what contamination; the primary concern of ATSDR staff iswhether local residents have been exposed to any of the chemicals.

  1. ATSDR should establish a community assistance panel to allow participation of thecommunity in soil and body burden testing, a community health study, and anexposure investigation.

ATSDR staff found no evidence that the community has been exposed to concentrations ofchemicals from this site that could cause adverse health effects; therefore, body burden testing, acommunity health study, or an exposure investigation is not recommended, so ATSDR does notneed a community assistance panel at this site.

EPA is conducting the environmental (including soil) sampling for the Metachem site. ContactEPA regarding community participation in the environmental studies.

  1. We started smelling paradichlorobenzene in Llangollen Estates in July 1977. When I called DNREC to complain a DNREC employee came to my house and he confirmed that he smelled the odor too. He said there was a large mound of the chemical sitting outside exposed to the elements. The paradichlorobenzene causes immediate uncomfortable symptoms like "headache, burning of all respiratory mucous membranes, burning of the eyes–then comes dizziness and disorientation and fatigue." My children are often quite ill with respiratory problems and lack of energy; the pediatricians were perplexed.

The symptoms you attribute to paradichlorobenzene are what one would expect when exposed to high concentrations–not concentrations that are likely to exist in ambient air about three miles from a spill of this chemical. If your pediatrician would like to consult with one of the ATSDR physicians or toxicologists regarding chemical exposures, he/she can contact ATSDR at 888-422-8737.

  1. The Battelle Study took air samples in Llangollen Estates and found "molecules ofthe chlorinated benzene" in the air three houses away from me. I have also detectedthe odor outside on route 9 at the intersections of routes I-295 and I-95.

ATSDR obtained the Battelle study and has included a discussion of that study's data in thishealth assessment. Unfortunately, the study's authors did not included the actual concentrationsof chemicals found in the samples taken in Llangollen Estates. However, they characterized theconcentrations as typical background concentrations. None of the chemicals from StandardChlorine that Battelle detected at off-site locations were at levels that would cause adverse healtheffects.

  1. Your report should recognize the additional vulnerabilities of children andpregnant women.

ATSDR has. The health comparison values that ATSDR uses take into account the uniquevulnerabilities of children and pregnant women. See the Children's Susceptibility section.

  1. Your document is worthless. It is based on incorrect information and outright lies.An example of the lies by your "scientist" is: a community member told me thatyour "scientist" told her the company's products do not cause cancer. Thecommenter wrote, "The chlorobenzenes themselves…present major health concerns.In animal tests, they are considered hepatotoxic due to their effects on the liver,kidney and thyroid. All chlorobenzenes tested except monochlorobenzene induced areduction in plasma thyroxine, some more than others."

Hepatotoxic means "causing injury to the liver." Thyroxine is an iodine-containing hormoneproduced by the thyroid gland. None of the chlorinated benzene products manufactured byStandard Chlorine or Metachem Products are classified by any US government agency as ahuman carcinogen.

ATSDR has reviewed all the toxicological data available on chlorinated benzenes and preparedthe peer-reviewed summary of the current knowledge on their potential to cause health effects inToxicological Profile for 1,4-Dichlorobenzene (34) and Toxicological Profile for Chlorobenzene(31). Chlorobenzene and 1,4-Dichlorobenzene, the companies' primary products, are notcarcinogens.

EXAMPLES of other lies in your document are:

  1. On page 1, "Statement: 'According to the 2000 census…144 individuals…one mile.'

For consistency, ATSDR policy requires staff to provide in the Site Description section of apublic health assessment the number of people living within one mile of the facility beingevaluated. In the Discussion section of the health assessment, ATSDR discusses the various waysthe public is or might have been exposed. The authors are required to discuss in that section thenumber of people believed to be exposed by the various routes of exposure regardless of thedistance from the facility.

  1. On page 2 [4], "An August 22…"

The memo does exist and ATSDR's quotations are accurate and not out of context. EPA hasreviewed the draft health assessment and did not comment that the quotations incorrectlyrepresented the opinions and conclusions made in their memo.

  1. On page 5, "One allegation the engineering and science staff investigated waswhether the chlorobenzene emissions from the manufacturing process could beconverted by sunlight into dioxins and furans."

The paragraph is a discussion of an EPA memo regarding allegations about the site that EPAinvestigated. The commenter disagrees with the references EPA and ATSDR used to draw theirconclusions on the issue of whether sunlight degrades chlorobenzene into hydrocarbons andhydrochloric acid; or sunlight causes chlorobenzenes to combine into more complex compoundslike dioxins and furans. See comment number 1 for further discussion of this issue.

  1. On page 5, your quotation from the EPA memo says that the Metachem productsare used as intermediates whose final products are distributed nationally. This is nottrue, paradichlorobenzene is used directly in consumer application.

ATSDR believes that EPA meant that Metachem did not sell its chemicals directly to the consumers or local residents; rather the company sold its chemicals to other companies who then used the chemicals to manufacture consumer products–thus, the chemicals Metachem manufactured were "intermediate products", not final products. Other companies made products such as moth balls and room deodorizers from paradichlorobenzene or used the chemicals in their manufacturing processes to manufacture other chemicals–that is, as a "chemical intermediate."

  1. On Page 10, you discuss an EPA air sample inside the warehouse taken months afterthe plant was shut down which showed very little dioxins, as would be expected.Recent samples by EPA found the soil indicated a level of 1,800,000 ppt, quite acontrast.

ATSDR obtained the recent EPA soil sampling data and included it in the Dermal Pathway section. It is true that EPA did find dioxins on-site in the parts per million range (1,000,000 ppt is the same as 1 ppm). However, the public is not exposed to on-site soils–or to the air inside the warehouse.

  1. On Page 16, the Crops section is wrong. Fact: The crops grown around the plant arepart of the nation's food supply which is already contaminated with dioxins fromsystemic migration from air and contaminated pesticide such as Banvel which used1,2,4-trichlorobenzene as a solvent.

The commenter states that it is a fact that the crops are contaminated with dioxin; however, heprovided no analytical data to support his allegation. It is still ATSDR's opinion that theMetachem facility has not contaminated the crops grown in the fields near the site. See the Cropssection for further discussion.

  1. On Page 17, why restrict the consumption of fish if no health effect. The fish do notstay in Red Lion Creek. Three eight ounce meals amount to less than three fish peryear, ridiculous.

The referenced section says "If people comply [emphasis added] with the Delaware fishadvisories, we do not expect any adverse health effects due to eating fish caught nearMetachem." The state fish advisories say not to eat ANY fish from the Delaware River. If thecommenter is concerned that fish from the Delaware River migrate into the Red Lion Creek, thenATSDR advises that he not eat even three fish from the creek.

  1. On Page 18, it says, "Product recovered from the water was burned in the facility'sboiler." It is a fact that there are warnings in national and international documentsagainst such burning.

The fact that there are warnings in documents against burning chlorinated benzene products does not mean that the company did not burn its waste products. In fact, this was the only comment that raised the issue of not burning waste products–all other community members were concerned because they think Metachem did burn its waste products in the boiler. ATSDR believes that Metachem did burn wastes in its boiler, and therefore this sentence has not been changed.

  1. On Page 20, it says, "In air 1,4-dichlorobenzene breaks down to harmless productsin about a month (26, 27)." Fact: Wrong. Breaks down to PCBs and dioxins.

PCBs and dioxins are larger, more complex chemical compounds then 1,4-dichlorobenzene.Therefore, 1,4-dichlorobenzene can not "break down to PCBs and dioxins." The commenter didnot provide documentation to support his theory that the vapors from moth balls and deodorizers(made of 1,4-dichlorobenzene) form more complex chemicals (PCBs and dioxins) when exposedto the air. ATSDR is not aware of any scientific evidence that supports this theory. Also, see thereply to comment 1.

  1. On Page 21 it says that 1,2,4-trichlorobenzene breaks down photochemically with an estimated half-life of approximately 18.8 days (28). Fact: Trichlorobenzene does not break down photochemically–it forms PCBs and dioxins; as discussed above.

As discussed above and in the reply to comment number 1, ATSDR disagrees with thecommenter. He provided no references to support his theory.

  1. On Page 20 it is misleading and irresponsible to discuss the case of a pregnantfemale who had a craving for the taste of paradichlorobenzene. No one in their rightmind would even suggest human ingestion of such a chemical. The pregnant womanwas the only case [of someone ingesting paradichlorobenzene] and it did not go onfor years.

ATSDR has added a statement warning that people should not ingest any of these chemicals tomake sure people understand that serious adverse health effects can occur if they ingest thesechemicals. In the next sentence on page 20 of the health assessment, the discussion said thatthese people had adverse health effects, including skin blotches and lower numbers of red bloodcells. ATSDR thought people would realize they were not being advised to eat it, but a warninghas been added to make sure the meaning is clear.

Actually, ATSDR describes two cases of documented ingestion of paradichlorobenzene in theToxicological Profile for 1,4-Dichlorobenzene (34): the 21-year-old pregnant woman whoconsumed 1-2 toilet bowl deodorizer blocks per week throughout pregnancy and a 19-year-oldblack woman who ingested 4-5 pellets of moth balls daily for about 2.5 years. The black womanhad symmetrical lesions with a bizarre pattern of increased skin pigmentation over most of herbody. After she discontinued this practice, the skin discolorations and lesions graduallydisappeared over the next 4 months.

  1. In the discussion on Benzene on page 24 it is misleading to compare the benzeneemissions from this site to gasoline fumes or gasoline engine exhaust.

The document lists sources of benzene to which people are exposed. Gasoline fumes and exhaustare just two of the sources mentioned. There are no comparisons between the site and these othersources.



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