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PUBLIC HEALTH ASSESSMENT

NYANZA CHEMICAL WASTE DUMP
ASHLAND, MIDDLESEX COUNTY, MASSACHUSETTS


SUMMARY

The Nyanza site is located in Ashland, Massachusetts, approximately 22 miles west of Boston. The site was formerly the location of the Nyanza Company, one of the first and largest dye manufacturers in the United States. More than 100 different chemicals (mainly dyes, but additionally a number of semi-volatiles including benzidine, dianisidine, o-tolidine, and 2-napthylamine) have been detected at the site, which encompasses a 35-acre area. The Nyanza site consists of the former Nyanza, Inc. property and includes the northern flank of Megunko Hill, the low lying industrial area, the northwest wetland, and the Trolley Brook Wetlands. The site is bounded by the New York Railroad tracks to the north, an abandoned trolley bed to the southeast and east, and by MCL Development Corporation property lines to the south and west. To the north and northwest are commercial properties that face onto the southern side of Pleasant Street. Between the Sudbury River and the northern side of Pleasant Street are residential and commercial properties. Currently, the land to the south is undeveloped forest land. Areas to the west of the site are currently under development for residential use.

Liquid wastes from Nyanza have been discharged into the environment in several different ways including into the underground vault, unlined lagoons, and nearby brooks and wetlands. Surface water and soil on-site are known to have been contaminated. Groundwater beneath and downgradient of the site is known to be contaminated. Releases into the ambient air are known to have occurred historically. These releases have included oleum, bromine, and nitric acid. Opportunity for human exposure in the past was high and included exposures to children playing in the soils and lagoons on-site as well as in the Chemical Brook. In addition, there is documentation of exposures to the general public on several occasions when fires and/or explosions caused releases of hazardous substances into the ambient environment in Ashland.

Community concerns over suspected elevations in cancer incidence had been voiced by a number of residents for some time. As part of this public health assessment, a review of relevant health outcome data was undertaken. Cancers having a plausible relationship to the contaminants of concern at the site were investigated. Cancers of both the bladder and kidney diagnosed between 1982 and 1986 were found to be geographically concentrated to the south and northeast of the site. Based upon preliminary data analyses, the Massachusetts Department of Public Health (MDPH), Bureau of Environmental Health Assessment (BEHA) determined that further investigation was warranted in order to determine the likelihood that cancer incidence and historical environmental exposures might be associated. After an exhaustive review of all relevant information (including in-depth interviews with either cancer cases or their next of kin) by a panel of experts convened by the BEHA, an association seemed unlikely. Subsequent evaluation of overall bladder and kidney cancer incidence from 1982-1989 did not reveal significant elevations or an unusual geographic distribution of cancer cases in Ashland.

This site is a public health hazard because humans have probably been exposed to hazardous substances at concentrations that may result in adverse human health effects. Human exposure has occurred due to (1) ambient air emissions from the site via inhalation, (2) contaminated on-site media via dermal contact, and perhaps, incidental ingestion and inhalation, and (3) contaminated fish, surface water, and sediments. Possible current human exposures include (1) ingestion of contaminated fish, and (2) dermal contact, incidental ingestion, and inhalation of on-site contaminants most likely by remedial workers.

The MDPH has performed community health education and has investigated the community health concerns related to increased adverse health effects. The Health Activities Recommendation Panel (HARP) of the Agency for Toxic Substances and Disease Registry (ATSDR) and the MDPH determined that no additional public health actions are indicated at this time.


BACKGROUND

A. Site Description and History

Site Location and Current Physical Appearance

The Nyanza National Priority List (NPL) site is located on Megunko Road in Ashland, Middlesex County, Massachusetts, about 22 miles west of Boston (Figure A-1). The site was placed on the U.S. Environmental Protection Agency (EPA) NPL in 1982. The site is the location of the former Nyanza, Inc. which operated a dye manufacturing facility from 1965 until 1978. Currently, the site is an approximately 35-acre, partially fenced area.

Within the site boundaries are the following (Figure A-2):

  • The northern flank of Megunko Hill: The 14-acre western portion of the Nyanza site, located on the northern flank of Megunko Hill, has been fenced since 1981. The hill (also known as Megunko Hill) has a maximum elevation of 400 feet above mean sea level (AMSL), but the highest on-site elevation is 278 feet AMSL. Historically, this undeveloped area was owned and utilized by the dye manufacturing facility for the surface and subsurface disposal of sludge, barrels, process wastes, and debris [27]. Two open lagoons, originally constructed as sludge disposal pits, are contained within this area of the site. Apparently, these lagoons were never used, but as part of the on-going remediation efforts have been enlarged into two "cells" in order to store hazardous material excavated from other areas of the site.
  • The low lying industrial area: This area, located on the eastern portion of the site, is the location of the former Nyanza, Inc. dye manufacturing facility. Although dye manufacturing no longer occurs here, industrial activity still exists in this area. An active railroad line runs along the northern edge of the site parallel to an intermittent stream named Chemical Brook. At the northeast corner of this area, Chemical Brook and Trolley Brook merge and then leave the site.
  • The northwest wetland: This wetland was found to contain disposed wastewater treatment sludge and contaminated sediment from runoff originating at Megunko Hill. Chemical Brook has its origins in this wetland area.
  • The Trolley Brook Wetlands: This wetland area received septic and waste effluent from settling lagoons, and runoff from the Megunko Hill area [13]. The Trolley Brook Wetlands area is physically separated from a larger off-site wetland area by an abandoned trolley bed. However, the two wetlands are hydrologically connected. A man-made earthen berm runs from north to south through the off-site wetland area and a culvert drains the eastern portion of the off-site wetland [67]. A spring originating on the Megunko Hill drains in this wetland area and the headwaters of Trolley Brook originate here.

Bordering the site are the following properties (Figure A-2): (1) the New York Railroad (Conrail) tracks to the north, (2) an abandoned trolley bed to the southeast and east, (3) MCL Development Corporation to the south and west, (4) commercial properties facing Pleasant Street to the north and northwest, and (5) residential properties to the northeast and east near the center of Ashland. Currently, the area to the south of the site is undeveloped. Areas to the west of the site are currently under development for residential use.

Site History and Remediation History

    Operational Activities

Nyanza, Inc. was established in 1965 as a dye manufacturing company. The facility operated until the company's bankruptcy in 1978. Between 1917 and 1965, various chemical manufacturing intermediates and pigments were located at the site. Currently, the property houses various industrial and commercial facilities including auto body, fuel, equipment, and engineering companies [3,67].

In 1967, Nyanza produced 76 different types of dyes and 48 dye intermediates. The previous companies located at the site were also involved in the production of the same types of dyes and pigments including azo and anthraquinone dyes. The raw materials utilized by Nyanza include acids, bases, aniline, chlorinated benzenes, nitrobenzene, benzidine, 1-naphthylamine, 2-naphthylamine, o-dianisidine (3,3'-dimethoxybenzidine), p-cresidine, o-tolidine (3,3'-dimethylbenzidine), phosgene, cobalt, chromium, mercury, benzoic acid, dichloroaniline, nitroaniline, phenol, bromine, and acrylate monomers.

Nyanza, Inc. maintained several systems to handle the wastes from the various manufacturing processes. Acidic wastewater containing organic and inorganic chemicals was collected in an underground vault and pumped to a neutralization tank on the hill where sludge precipitated out of the wastewater. Sludge was also allowed to settle in unlined lagoons and ponds and effluent was discharged to Trolley Brook and the Trolley Brook Wetlands. The sludges were either disposed of on the Megunko Hill surface or in pits. Part of the solid waste from chemical precipitations and from dye pigment filtering processes was put in 55-gallon drums and buried in different areas of the site. Recovered solvents (e.g., nitrobenzene and phenol), catalysts (e.g., mercuric sulfate), residues from the recovery processes, and bad batches of dyes were disposed throughout the site [13].

During the period of plant operation, chemical emissions into the ambient air were common occurrences. Between 1918 and 1938, three fires are known to have occurred at the dye manufacturing facility. Numerous instances of chemical releases into the air are known to have occurred based on citizen complaints to the town and investigations of odor, smoke, and fume releases [49]. Releases are known to have occurred due to faulty equipment, bad batches of dyes, human error, malfunctioning scrubber systems, and the lack of scrubbers. Chemicals known to have been released include oleum (fuming sulfuric acid and free sulfate), nitric acid, bromine, sulfur dioxide, sulfide, methyl methacrylate, ethyl acrylate, and benzyl chloride [49]. Property damage has resulted from the emission of dye dusts and on at least one occasion, blue snow fell on Ashland [40].

    Site Regulatory History

Due to continual noxious odors, the Town of Ashland and the Massachusetts Department of Public Health (MDPH) became involved with the site. In 1964, a sulfur dioxide scrubber system was installed on some vats and kettles utilized during the manufacturing process. However, complaints of odors continued [49]. In 1974, the MDPH issued an order to Nyanza to abate the odor nuisance which resulted in the installation of an acrylate scrubber [49].

During 1962 and 1963, two fires occurred in the dumping area of Megunko Hill. In 1967, Nyanza sought permission to burn in the Megunko Hill dumping area. During the 1970's, Nyanza, Inc. hired contractors to haul some of its waste to the Howe Street Dump. According to fire department logs, nitrates were found in the rubbish in 1970 and the chemical waste resulted in a benzene fire in 1972 [49].

Under orders from the Massachusetts Department of Water Pollution Control (MDWPC) to abate pollutant releases to Massachusetts waters, Nyanza, Inc.'s wastewater treatment system was tied into the MDC sewer system between 1970 and 1973. The MDC required that a pH control system be installed to monitor the effluent discharge, the wastewater bypass lines leading to Chemical Brook be removed, and the mercury content of the wastewater be reduced [13,40,49].

Due to MDWPC orders, Nyanza, Inc. contracted Camp, Dresser & McKee, Inc. (CDM) to develop a plan for ending groundwater pollution. In 1974, CDM submitted a plan that was never implemented [13,38,40]. In 1979, a firm was hired by a partial site owner unaffiliated with Nyanza, Inc. to implement the CDM plan, however, the work was never completed because the newly created Department of Environmental Quality Engineering (DEQE), now the Department of Environmental Protection (DEP), required additional site investigations. In 1982, the DEQE fenced portions of the site and the fenceline was expanded in 1985.

In 1986, because of the elevated mercury levels in fish, the MDPH in coordination with the DEQE and the Massachusetts Division of Fish and Wildlife (MDFW) issued a health advisory warning against the consumption of fish from the Sudbury River and associated reservoirs [15]. This advisory encompassed the portion of the Sudbury River extending from Ashland to its confluence with the Assabet River in Concord.

In 1988, the Commissioner of the MDPH issued a health advisory recommending that private well owners within a proscribed region of Ashland not use their private well water for drinking or cooking purposes until the safety of the water could be confirmed. The health advisory was lifted in April 1989 because monitoring indicated that nearly all of the wells were not contaminated. The two wells containing bacterial contamination and the one well containing chemical contamination (unrelated to the Nyanza site) were referred to the local Board of Health for follow-up.

In the summer of 1989, dimethylmercury was discovered in on-site wetland soils [60]. Later during monitoring for baseline levels in perimeter zone ambient air samples, dimethylmercury was detected sporadically [61]. One of the samples had dimethylmercury levels above the Agency for Toxic Substances and Disease Registry (ATSDR) recommended action level [62-65]. The site was closed until an appropriate dimethylmercury monitoring program could be developed and concerns for worker, emergency responder, and public safety could be addressed [69].

    Site Remediation History

Between 1970 and 1972, several environmental assessments performed for the EPA and MDWPC indicated that the mercury contamination in the Sudbury River, groundwater, and nearby areas originated from the site [13,38,40]. The next remedial action occurred in 1980 when the DEQE released a Preliminary Site Assessment report [13]. In 1981, several hydrogeologic and pollution assessment studies were performed and the fish in the Sudbury River were monitored for mercury. The site was placed on the NPL in the following year.

A Remedial Action Master Plan (RAMP) was completed in 1982 after the site was placed on the NPL. As part of the RAMP, the site was divided into three operable units (OU I-III) [38]. A draft Environmental Impact Report, assessing the impact of mercury contamination on the use of reservoirs as a drinking water supply, was completed in 1982.

Between 1984 and 1985, a draft Remedial Investigation (RI) and Feasibility Study (FS) were completed for OU I and the Record of Decision (ROD) was signed. The ROD recommended excavation of hot spot areas, stabilization, landfilling in the cells on Megunko Hill, the capping of Megunko Hill, and the installation in bedrock of a groundwater and surface runoff diversion trench upgradient of the cap. From 1985 to 1987, further monitoring of Sudbury River sediment, fish, and surface water was conducted [38]. The DEQE culverted the Chemical Brook in 1985, and shortly thereafter placed one foot of clean fill over the yard of a nearby residence [40]. The excavation of contaminated soils from the Tilton Avenue residential properties was completed during OU I remedial activities. The first operable unit remedial action was completed in September 1992.

In 1986, the DEQE discovered an underground cement vault that was used as a settlement basin for wastewater [32]. After review of the soil samples collected by the DEQE and the EPA, the ATSDR notified EPA's Oil and Hazardous Materials Section that a release of chemicals was occurring. An Interim Remedial Measure was completed in June 1988. It involved off-site disposal of 2,500 tons of solidified sludge from the vault and treatment of about 14,000 gallons of water [29]. Of the approximately 665 tons of soil adjacent to the vault that were removed, 309 tons were incinerated with disposal of the ash on Megunko Hill and 356 tons were shipped off-site to an approved landfill.

In 1987, the EPA Environmental Response Team conducted monitoring of on-site soils in wetland areas, as well as surface water, sediment, and fish from the Sudbury River [38]. Between 1986 and 1987, water and air monitoring was conducted in residential basements around the site [20,28,53-57]. Indoor air screening was also conducted by the EPA in residential basements in 1990.

Between 1988 and the present, a draft Preliminary Summary of Site Characterization for OU II (part of the RI) was completed. OU II addresses groundwater contamination within the site and its migration off-site. The second phase of this RI was completed in September 1991. The ROD was signed in the September 1991. Because private bedrock water supply wells may be impacted by contaminants from the site in the future, the OU II remedy includes institutional controls in the form of private well permit restrictions to limit the potential exposure to site related contaminants. If excavation activities are proposed in the lower industrial park portion of the site, additional monitoring of on-site soils as a component of an institutional control program is planned to be implemented as part of the OU II remedy for the Nyanza site. According to the Ashland Board of Health, neither of these institutional controls has been implemented to date [95]. OU III addresses the impact of Nyanza related contamination on the Sudbury River watershed [38]. In April 1993, the EPA and the DEP selected a remedy to address the third phase of cleanup at the Nyanza site [94]. This remedy involves the removal of mercury-contaminated sediments from drainageways between the property formerly owned by Nyanza, Inc. and the Sudbury River. Dewatered sediment would be disposed of under the on-site cap constructed as part of an earlier cleanup. Under this action, the EPA will also maintain signs on the Sudbury River warning anglers against consumption of fish and will work with affected communities to increase public awareness regarding contamination in the river. In addition, the ROD creates a fourth phase of cleanup under which the EPA will conduct further studies to assess a final remedy for the Sudbury River [94].

B. Site Visit

Two site visits have been conducted for the Nyanza site. On November 2, 1988, participants of the first visit included four representatives of the ATSDR, the EPA Remedial Project Manager (RPM), two representatives of the MDPH, two members of the Ashland Citizens Advisory Committee (CAC), and a representative from U.S. Senator Kennedy's office. The purpose of the site visit was to familiarize individuals from the health agencies (ATSDR and MDPH) with the site in preparation for the night's CAC meeting (pertaining to the community's health concerns). During this site visit, observations noted were the disposal areas, evidence of surficial soil transport, areas of past remedial activities, site security, and places where past human exposure occurred.

On December 14, 1988, a second site visit was conducted by the EPA RPM, the EPA Region I hydrogeologist, the DEQE site manager, and a MDPH Environmental Analyst. This site visit was conducted after reviewing the available information pertaining to the site. During this visit, the above topics were observed in greater detail. Additional observations included the wetland where the Chemical Brook discharges into the Raceway (Outfall Creek) and the presence of physical hazards. Information gathered during the site visits is incorporated into pertinent sections of the health assessment.

Present site conditions are best described in the U.S. Army Corps of Engineer's "Remedial Action Report" for OU I of the Nyanza site. According to this report, remediation of OU I began in May 1990. Contaminated material was excavated and hauled from the source areas to the cells in the landfill areas of Megunko Hill. Exploratory soil sampling was also done in areas outside the defined source areas to determine if other areas of contamination existed. In April 1991, the construction of the landfill cap began. Remediation of OU I was completed in May 1991, with completion of the landfill cap in August.

According to the "Remedial Action Report", the landfill constructed as part of the OU I remediation is operational and functional. The level of groundwater in every monitoring well was lower than the lowest level of contamination placed in the landfill cell. A visual inspection of the groundwater interceptor trench revealed that water was freely flowing from the groundwater's upgradient side of the trench, but no flow was coming from the other side. Contamination has been removed from all outlying source areas and is no longer contributing to pollution problems in the Sudbury River or the groundwater. During the summer of 1992, maintenance had been limited to the reseeding of grass in thin areas and the replanting of some wetland vegetation.

C. Demographics, Land Use, and Natural Resource Use

Demographics

The Nyanza site is located in the central section of Ashland approximately 2.25 miles north of Hopkinton and Holliston, 3 miles west of Sherborne, 3 miles east of Southborough, and 1.75 miles south of Framingham. The 1980 U.S. Census indicated that 9,165 individuals live within the Town of Ashland [70]. The 1986 population has been estimated to be 10,870 persons [38]. The closest residences are located approximately 100 to 150 feet to the north/northeast of the site perimeter fence on Pleasant Street.

The Town of Ashland currently obtains its drinking water from a wellfield on Howe Street, located approximately 3.7 miles west and upgradient of the site [30]. The Ashland water distribution system supplies potable water to approximately 10,700 people through the three gravel packed wells in the wellfield [30].

Four schools in Ashland (Ashland High School, David Mindness Middle School, William Pittaway School, and New Covenant Christian School) are located within a one-mile radius of the site. The William Pittaway School was reopened in September 1988 after having been closed since 1981.

Two nursing homes and two retirement apartment complexes are located in Ashland. The two nursing homes, located on Central Avenue and Myrtle Street, are approximately 1/2 mile from the northeastern site boundary. The two retirement apartment complexes are located on Main Street and Park Road between 500 and 1,000 feet east of the site.

Land Use

Currently, portions of the Nyanza site are fenced to prevent access by unauthorized personnel. It has been reported that children, until the early 1980's, had used the site (particularly Megunko Hill, the lagoons, and the wetlands) as a recreational area. Activities have included biking, swimming, wading, skating, and building forts. Senior High School students have also been reported to use the site as a shortcut walkway from Pleasant Street to the school on West Union Street. Land use in the vicinity of the site is a mixture of residential and commercial/industrial areas. A variety of industrial activities are practiced in the site vicinity including chemical production, auto repair, and fuel storage. More than 60 residences are located in the vicinity of the site, many of which have basements that are below the water table. Residential properties are located north of the site between the Conrail Railroad tracks and Pleasant Street and between Pleasant Street and the Sudbury River (Mill Pond). The closest residential area is located 100 to 150 feet north of the railroad tracks near the northeastern site boundary. Other residences are located northeast and east of the site toward the downtown area. A baseball field is also present less than 150 feet north of the northern wetland area, adjacent to the Conrail tracks. Stone Park and a neighboring playground area are located on Summer Street approximately 1/4 mile southeast of the site.

Within the Department of Environmental Protection (DEP) "List of Confirmed Disposal Sites and Locations to be Investigated, March 1991," eleven sites are listed within the Town of Ashland. The sites closest to Nyanza are: Sharon Bolt and Screw/Fenwal Corporation and Three C Electrical Company located to the north of the site between Pleasant Street and the Conrail Railroad tracks, and the Perini Corporation on Cordaville Road.

Natural Resource Use

The Town of Ashland has obtained municipal water from the Howe Street wellfield since 1955 [30]. The Ashland water distribution system provides water to 10,700 individuals. The wellfield is located within 75 feet of the Hopkinton Reservoir, 3.7 miles west and upgradient of the site. The reservoir recharges the Howe Street Wellfield [30]. The water system delivers an average of 1,450,000 gallons of water per day. Regular testing of the water supply indicates that the distribution system is relatively free of contaminants [12].

Historically, three other wellfields have been utilized by the Town of Ashland. The first wellfield, which went on-line in 1911, is located immediately north of Mill Pond on Cordaville Road [73]. The second wellfield went on-line in 1919 and is located on High Street south of the confluence of Indian Brook and the Sudbury River [73]. These two wellfields serve as auxiliary and emergency wells, respectively. The third wellfield, which went on-line in 1942, is located off Cedar Street near Lake Waushakum Pond [74]. Another well site located on Spring Street near the Ashland Reservoir was installed in 1982 [74]. However, this well was never hooked into the municipal water system because of organic compound contamination [30].

Many residents within the Town of Ashland obtained water from private wells due to a DEP moratorium which prohibited new permits for water hookups in the town. The DEP moratorium was lifted on August 28, 1989. According to the Ashland Board of Health, there were 145 well permits issued between August 1986 and November 1988. Requests for private well permits were likely between November 1988 and August 1989. The closest known well to the site is located less than 1/2 mile to the west. Most of the newer wells are located east of the site and most of the older wells are located to the west. Details pertaining to well installation are generally not known, however, most of the newer wells appear to be installed in bedrock. Three industrial wells are known to exist near the site on Main Street. These wells are not connected to the municipal water system [33]. Historically, another industrial well was located at the Timex Clock Company but it was dismantled in 1984 [48].

Minimum sanitation standards for private and semi-public water supply wells exist for the Town of Ashland. Although required by state law to report the installation of private domestic water supply wells to the local Board of Health, it should be emphasized that the ownership of these wells is self-reported and that other wells may exist. Enforcement of this law among towns within the state is variable. Older private wells are likely to be unreported.

The Ashland Reservoir, the Sudbury River, and associated water bodies have been used for recreational purposes such as swimming, fishing, wading, and boating. In 1986, a health advisory pertaining to mercury contaminated fish was issued by the MDPH in conjunction with the DEQE and the Massachusetts Department of Fish and Wildlife (MDFW) and recommended against the consumption of fish from the Sudbury River and associated reservoirs. Warning signs were reposted by the EPA in 1992 with warnings written in English, Spanish, and Cambodian. The Mill Pond served as a source of water for a nearby municipal pool until sometime in the 1970's.

D. Health Outcome Data

Relevant health outcome data reported were obtained from the Massachusetts Cancer Registry. Cancer incidence data for the years 1982-1986 included types of cancer determined to be of concern based on the available scientific literature and on community concerns. Analyses were made at the town-wide level. Population data were obtained from the Regional Office of the U.S. Census. An evaluation of the health outcome data reviewed is contained in the Public Health Implications Section.


COMMUNITY HEALTH CONCERNS

Community concerns regarding the Nyanza site are evident because of various groups' involvement with site related issues, the numerous newspaper articles regarding alleged health impacts, records and minutes of state and local meetings, correspondence received by state and federal regulatory and health officials, telephone calls to the MDPH, and the involvement of various state and federal legislators.

Topics especially expressed as being of public health concern to the citizen and private sector groups include: (1) past, current, and future exposures to site related contaminants that might result in adverse health effects, and (2) the perceived increase of certain diseases within the community. Concerns regarding specific exposures have been obtained from various sources and include:

  • Children playing on-site (swimming and skating in the lagoons and wetland areas, building forts, playing with sludge, playing in the brooks, and using a shortcut walkway) often came home with discolored clothing and skin, and blistered skin if they came in contact with the sludge. (Past concern)
  • Occupational exposure of facility workers. (Past concern)
  • Exposure to contaminants in residential yards and from consumption of garden produce due to flooding of Chemical Brook. (Past concern)
  • Seepage of groundwater (historically discolored) into the basements of homes, and exposure to contaminants by contact with the water and inhalation of volatile contaminants. (Past, current, and future concern)
  • Inhalation of smoke, fumes, and odors originating from the facility or site by individuals in the Pleasant Street and downtown areas. (Past concern)
  • Exposure during recreational use of the brooks discharging from the site, and the Raceway, Sudbury River, and MDC Reservoirs located downstream of the site. Recreational use of these waterways consisted of swimming, wading, boating, and fishing. Citizens have stated that up until the early 1980's, the Sudbury River downstream of the Raceway had a pink cast. (Past, current, and future concern)
  • Consumption of contaminated fish originating from the Sudbury River and associated reservoirs. (Past, current, and future concern)
  • Exposure to remedial workers and nearby workers and residents during remediation, especially to air contaminants and contaminants tracked from the site. (Current and future concern)
  • Ingestion of water from private drinking water supply wells which could potentially become contaminated. (Future concern)

Based on available information, health concerns have been expressed by a number of groups. In 1982, concern was initially expressed about a perceived increase in cancer and the possibility that the cancers were related to exposures to contaminants originating at the Nyanza site [40]. In addition, mention of miscarriages and birth defects was also made [40]. The health concerns originated from: (1) a health survey of neighbors of the Nyanza site by the Ashland Advocates for a Clean Environment (AACE), and (2) the unrelated activity of the Ashland Board of Health (BOH) [40]. A citizen notified the BOH of the existence of five cases of cancer in residents living near the site. The BOH forwarded this information to the MDPH. At that time, the MDPH reported that the cancer mortality rate for Ashland was not elevated and that the types of cancer reported were not likely to be caused by a common factor.

On August 12, 1993, in the Middlesex News, the MDPH invited public comments on the public health assessment for the Nyanza Chemical Dump site. During the public comment period from August 13, 1993 until September 12, 1993, no comments were received.



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