PUBLIC HEALTH ASSESSMENT
A. O. POLYMER
SPARTA TOWNSHIP, SUSSEX COUNTY, NEW JERSEY
The A.O. Polymer site is an inactive resin and plasticizer manufacturing plant, approximately four acres in size, located at 44 Station Road in the Township of Sparta, Sussex County, New Jersey. The site is bounded to the north and east by Station Park, a municipal recreation area, to the southeast by Station Road, and to the south and west by the New York, Susquehanna and Western Railway (NYS&R). Several small businesses and three homes are located near the site on the Station Road. The Sparta High School is approximately one-half mile to the north-northeast and a private gun club is located 500 feet northwest of the site. The Wallkill River flows 500 feet southeast of the site.
In 1973, residents began to complain of chemical odors in domestic well water and air. In December 1978, the Sparta Health Department and the New Jersey Department of Environmental Protection (NJDEP) conducted an investigation of the site and began collecting water samples from domestic potable wells in the vicinity of the site. Analysis of these water samples revealed the presence of volatile organic compounds in three private domestic wells located along Station Road. In January 1980, these homes were connected to the public water line.
A partial remediation of the site was performed in 1980 through 1981 by the NJDEP. The site was placed on the National Priorities List on September 1, 1983. The Remedial Investigation and Feasibility Study was completed in April 1991. Volatile organic compounds have been detected at levels of public health concern in on-site soils and groundwater. In 1991, the United States Environmental Protection Agency (USEPA) assumed the site from the New Jersey Department of Environmental Protection (NJDEP). A Record of Decision (ROD) was signed by the USEPA on June 28, 1991, detailing the final remedy for remediation of soil and groundwater contamination. Activities described in the ROD include the treatment of the contaminated groundwater and remediation of the on-site subsurface soil, the source of groundwater contamination.
The A.O. Polymer facility has been the subject of numerous complaints to local health authorities throughout its operational history. The community concerns associated with the site centered on the chemical odors emanating from the site, the possibility of future exposures to site related contaminants and health problems. Just prior to the cessation of plant operations, a fire occurred at the site.
Municipal water supplies have been available to residents since 1980. A total of about 70 people may have been exposed to contaminated groundwater in the past, including the residents and workers on Station Road and the A.O. Polymer employees. The site is no longer an active production facility. Based on current site data and information, the NJDOH and the ATSDR consider the A.O. Polymer site to currently present no apparent public health hazard as site conditions have changed due to numerous removal actions, and on-going treatment of residual soil contamination between 10 to 20 feet below the former disposal lagoons with a vapor extraction system. These contaminants, currently being removed by this system, are the source of groundwater contamination. Access to all buildings on the A.O. Polymer property has been secured by USEPA eliminating the physical hazards to trespassers. The odor complaints have been eliminated by the on-going remediation at the site. The A.O. Polymer site currently poses no apparent public health hazard. However, the A.O. Polymer site has been evaluated to represent a public health hazard based upon toxicological analyses of past human exposure to contaminants in domestic well water.
Health outcome data for the site were not reviewed because the population size was too small for the application of relevant data bases to yield statistically significant results. The Health Activities Recommendation Panel (HARP) determined that no follow up actions are indicated at this time. According to the Public Health Action Plan, the ATSDR will reevaluate the site annually for any indicated follow-up. The New Jersey Department of Health (NJDOH) conducted a comment period for the public health assessment for the A.O. Polymer site from March 28, 1994 to April 29, 1994. The public health assessment was placed in local repositories to facilitate commentary and reaction from the public at large.
In cooperation with the New Jersey Department of Health (NJDOH), the Agency for Toxic Substances and Disease Registry (ATSDR) will evaluate the public health significance of this site. More specifically, ATSDR will determine whether health effects are possible and will recommend actions to reduce or prevent possible health effects. ATSDR, located in Atlanta, Georgia, is a Federal agency within the U.S. Department of Health and Human Services and is authorized by the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended, to conduct public health assessments at hazardous waste sites.
The four-acre A.O. Polymer site is an abandoned industrial operation located in Sparta Township, Sussex County, New Jersey (see inset). It is situated in a semi-rural area near the Wallkill River, about one-quarter mile from the commercial district of Sparta and one-half mile from the Sparta High School. The site is bounded to the north and east by Station Park, a municipal recreation area, to the southeast by Station Road, and to the south and west by the NYS&W railway. A road through the site provides for access to a gun club. A wetland area is located about a quarter of a mile northeast of the site.
From the early 1960's until 1977, the plant was owned and operated by Mohawk Industries Inc. In 1977, the facility was purchased by the A.O. Polymer Corporation. Some of the manufacturing/mixing processes of Mohawk Industries were continued by A.O. Polymer (e.g., the production of specialty polymers, plasticizers, paper coatings, as well as polyketone and acrylic resins). A site map of the A.O. Polymer facility is contained in Appendix A.
A.O. Polymer was identified as a source of environmental contamination and was the subject of water quality and odor complaints for approximately fifteen years. In the late 1970's, the A.O. Polymer Corporation accepted waste circuit board cleaner solvents and freon isopropyl alcohol for recycling.
The United States Environmental Protection Agency (USEPA) has identified other responsible parties for the A.O. Polymer site and noticed them of their liability under CERCLA. They are:
- National Cash Register (NCR)
GTE Operation Support Incorporated (GTEOSI)
The first complaints of odors in domestic well water and air were made by an area resident in 1973. Complaints intensified in 1978 and resulted in an investigation by the Sparta Health Department and the New Jersey Department of Environmental Protection (NJDEP). Samples from off-site potable wells demonstrated contamination with VOCs. In 1980, NJDEP began investigating reports of drum stockpiling at the site. These investigations identified on-site waste disposal and storage practices as the source of the groundwater contamination. Waste handling practices included disposal of liquid chemical waste into unlined lagoons (northern portion of property), improper storage of deteriorating drums and the burial of crushed and open drums containing waste materials. Suspected pollutants included numerous VOC's, phenols, phthalate esters, acetone, freon, and formaldehyde.
An extensive remediation was performed between 1980 and 1981 by the NJDEP which included the removal of surface drums and the excavation and removal of contaminated soil in the lagoon area to a depth of approximately 10 feet. After excavation of this lagoon area, the area was backfilled with clean soil. This cleanup resulted in the removal of 1,150 drums, 1,700 cubic yards of contaminated soils, and 120 cubic yards of crushed drums and debris. In addition, 86 drums of waste alcohols were voluntarily removed by a responsible party in October 1981. In 1982, NJDEP's Division of Water Resources installed eleven monitoring wells. The site was included on the National Priority List in 1983.
The Occupational Safety and Health Administration (OSHA) investigated the A.O. Polymer site from April to August 1983, as a result of a referral regarding exposure of workers to toluene diisocyanate (TDI), formaldehyde, and resin dust. As a result of this investigation, citations were issued to A.O. Polymer for failure to: 1) Maintain a clean and orderly workplace; 2) Provide eye drenching facilities for the laboratory workers; and 3) Provide training to workers on fire management.
Throughout this period, A.O. Polymer was the focus of a variety of regulatory actions by Local, State, and Federal authorities. A.O. Polymer was cited by the NJDEP for failing to have a State discharge permit for process water discharged to the on-site cooling pond in November 1981. In January 1982, the NJDEP issued a directive order to redress a situation by which plant waste water was being discharged into the plant septic system. This was dropped when A.O. Polymer insisted that the cooling pond was lined and was only used to recycle cooling water for the reactor. As a result of odor complaints, the NJDEP's Division of Air Quality issued three administrative orders to A.O. Polymer to come into compliance with air quality standards.
The site was transferred to NJDEP's Division of Hazardous Site Mitigation in 1984. In 1986, a contract was issued to a private consulting company for a Remedial Investigation and Feasibility Study (RI/FS). The Sparta Fire Department documented numerous violations of the fire code by A.O. Polymer. As a partial response to these violations, the Sparta Emergency Management Program was established on April 3, 1989. An emergency response program was developed to help the community deal with an industrial accident/fire scenario.
In 1991, the United States Environmental Protection Agency (USEPA) assumed the site from the New Jersey Department of Environmental Protection (NJDEP). A Record of Decision (ROD) was signed by the USEPA on June 28, 1991, detailing the final remedy for remediation of soil and groundwater contamination. Activities described in the ROD include the treatment of the contaminated groundwater and remediation of the on-site subsurface soil, the source of groundwater contamination.
On July 21, 1993, a public meeting was held to determine if a nearby site was suitable to build a new school. Although it was determined that there would be little likelihood that there would be any danger from the A.O. Polymer site, the school board decided in favor of another site to avoid the public concern. Just prior to the cessation of plant operations, a fire occurred (October 1993).
By December 7, 1993, an estimated 23,620 gallons of hazardous waste liquids and 100 cubic yards of non-hazardous solids were removed from the facility by A.O. Polymer Corporation under USEPA oversight. Under a follow-up USEPA response action, additional materials including 11 (55 gallon drums containing lab-pack containers), 8 (1 cubic yard hazardous materials boxes), and 61 (55 gallon and 85 gallon containers of material) were segregated and removed from a shed located on the adjoining rail road property by USEPA in June of 1994. On-going remediation at the site since these two removal actions have resulted in the removal of an additional 6,024 gallons of liquid hazardous waste, 60 cubic yards of asbestos, 74 drums of solid waste, and 13 drums of contaminated soils.
Under USEPA's long term cleanup plan, a soil vapor extraction system has been built and placed into operation at the site to eliminate residual soil contamination between 10 to 20 feet below the former disposal lagoons. These contaminants, currently being removed by this system, are the source of groundwater contamination. Construction of soil vapor extraction system was completed in November 1994 and the system has captured over 1,000 gallons of contaminants from the soils below the former lagoon area. A groundwater remediation system is currently under design.
The New Jersey Department of Health (NJDOH) has conducted several site visits at the A.O. Polymer facility starting in 1988. The most recent site visit was conducted on May 11, 1995, by Bruce Wilcomb and Narendra P. Singh of the NJDOH accompanied by the USEPA Remedial Project Manager, On-Site Coordinator (Removal Action Branch - USEPA), NJDEP Case Manager (Bureau of Federal Case Management) and the Health Officer of Sparta Township Health Department. The site visit included a formal presentation by the USEPA. Conditions at the A.O. Polymer site have changed considerably due to on-going remedial activities and the cessation of operations at the A.O. Polymer facility. Odors were not detected off-site during the site visit. No noticeable odors were detected on-site. Under USEPA's long term cleanup plan, a soil vapor extraction system has been built and placed into operation at the site to eliminate residual soil contamination between 10 to 20 feet below the former disposal lagoons. These contaminants, are the source of present groundwater contamination. A groundwater remediation system is currently under design. On-going groundwater sampling and analysis is being conducted by a responsible party with oversight by EPA. The result of these sampling episodes shows a general decrease in concentration of contaminants over time. Groundwater has not sampled since the installation of the soil vapor extraction (SVE) system but the SVE system is expected to contribute to the decreasing trends. Constuction of the groundwater treatment system is expected to begin in the fall of 1996.
The following observations were made during the site visit:
- The A.O. Polymer site is situated at the end of a short side road leading from Main Street. There are several residences, a few small businesses, and a town recreation area close to the site. The principal features of the site are the railroad tracks bordering one side, and a steep but negotiable embankment along the other side of the plant area. The facility resides largely on dirt and sparse grassy areas;
- Several buildings occupy the site and approximately 10 storage tanks have been cleaned of sludge are located on-site. Excavated underground storage tanks were observed on site;
- The new soil vapor extraction system has been installed in the area of former lagoon;
- The site is fenced with an entrance gate along the eastern site boundary, and is also fenced along northern side facing the Station Park. The site is posted with no trespassing and hazard signs. The site is accessible to trespassers as there is no barrier to access on railroad side of the property;
- Nearby Rt. 517 bypass is under construction;
The A.O. Polymer site is located approximately one-third of a mile from a busy commercial area, and one-half of a mile from a public high school. The population of Sparta Township is estimated to be 15,000 according to the 1990 United States Census, with a population density of approximately 342 persons per square mile. Users of Station Park include 1,200 members of the Sparta Soccer and Softball clubs. Sparta High School athletic fields are about 0.5 mile from the site.
The primary public health concern associated with the site in the past was the odor emanating from the active production facility (which is now closed), and residences located on Station Road with contaminated domestic wells. The potentially exposed population included employees and trespassers on the site and residents with contaminated domestic wells. There are three houses on Station Road with domestic wells that were contaminated by the A.O. Polymer site. The estimated number of people exposed to contaminated well water would not be expected to exceed 70, including 8 residents (3 residences X 2.5 persons/household), perhaps 40 people working at a building on Station Road, and up to 22 people who worked at the site. The A.O. Polymer workers could have also been exposed to the contaminated soil. The residential population living within a half mile of A.O. Polymer is estimated to be 183 people (73 residences x 2.5 persons/ household). Of this number, up to 18 residences are close to the site and could have been negatively impacted via odors. However, the population that repeatedly comes within a mile of the site is much larger due to the use of Station Park and Sparta High School.
Land use adjacent to A.O. Polymer varies between residential, recreational, educational, and undisturbed areas. A.O. Polymer is bordered by Station Park, a business office, and a railroad. Station Park is a public recreational area, with baseball fields, soccer fields, and short trails to the river and the High School. During the winter, a hill within the Park is used for sledding. A gun club is located on the opposite side of the railroad tracks. There are residences and a private office on Station Road, which leads up to the facility. The East Seep area is a marsh-like wetland, located past the baseball field. Apparently, groundwater contamination is responsible for the presence of low levels of VOC's in the wetlands. Although accessible, the East Seep is not an inviting area, and it is unlikely that residents would repeatedly access or ingest water from the East Seep area.
The high density population areas, which are located to the south and west of the site, are connected to the public water supply. The water is supplied by the Lake Mohawk Water Company and Sparta Water District, and is a blend of surface water and groundwater. Contaminated domestic wells located on Station Road were closed in 1979 and the residences were connected to public water lines. In July 1987, potable wells on the opposite side of the Wallkill were sampled and no contaminants were detected. Private wells that are north and east of the site are being used for potable purposes and have not been impacted by the site and have not been closed. This includes the Sparta High School well. Currently, groundwater contamination from the A.O. Polymer site is unlikely to present a direct threat to existing potable water supplies. All affected existing wells along Station Road, have been replaced with municipal water supplies.
The water table beneath the A.O. Polymer property is between 20 to 30 feet below grade. Depth to the water table decreases to the north and east of the property, until it is only 2.6 feet below the surface in Station Park next to the Wallkill River. The water table aquifer extends down to the top of the bedrock at a depth ranging from 17 to 123 feet. In addition to being highly fractured and weathered, the bedrock also has locally significant solution cavities. This bedrock, also known as the Allentown Formation, is a source of potable water in the Wallkill Valley. Groundwater contamination in the water table aquifer consists primarily of volatile organic compounds including carbon tetrachloride, chlorobenzene, methylene chloride, 1,1,1-trichloroethane. The compounds were detected at levels above the Federal and New Jersey Maximum Contaminant Levels (MCLs). RI data show that both the water table and bedrock aquifers are hydraulically interconnected, and that groundwater contamination from the site has moved downward through the glacial overburden, and migrated from the site through the shallow portions of the Allentown formation. The RI data have defined the extent of the groundwater plume. The northernmost boundary of the plume is 400 feet north of the site. The southern boundary of the plume emanates from the former disposal lagoon area and extends to the Wallkill River in the east/northeasterly direction. The plume is confined to relatively shallow portions of the groundwater flow system and is discharged to the river along with the normal groundwater flow. The downgradient extent of the plume from the former lagoon area is limited by the Wallkill River. Transport past the river is not indicated by the data and appears to be unlikely given present hydrologic conditions.
Surface water bodies in the vicinity of the site include the Wallkill River, a small wetland area located downstream of the site, and an unnamed tributary to the Wallkill River which is located approximately 500 feet to the north of the site. The A.O. Polymer facility lies on the surface water divide between the Wallkill River and the unnamed tributary, which joins the Wallkill River about one mile northeast of the site. The Wallkill River is a groundwater discharge area. Contamination in the deep wells on the east side of the river (opposite the site) has not been detected, suggesting that the plume is confined to relatively shallow portions of the flow system and is thus discharged to the river along with the groundwater. The Wallkill River is stocked with trout and is used for recreational purposes. The river may also be used to water livestock. Hunting is also popular in the area near the site. The Wallkill River feeds into the Franklin Reservoir, which is approximately three miles downstream of the site. The Reservoir is used for both drinking water and recreation. The site has no apparent impact to these surface water features.
There are multiple sources of health outcome data in the state of New Jersey. State and local data for health outcome information include the New Jersey State Cancer Registry, Birth Defects Registry, Vital Statistics Records, Renal Dialysis Network and Hospital Discharge Reports. Federal databases such as those maintained by the agencies within the US Department of Health and Human Services (i.e., National Cancer Institute, National Institute for Occupational Safety and Health) are not site-specific, but may be used for comparison or evaluation purposes.
Cancer might be possible from long-term exposure to one of several of the site contaminants. Please refer to the Toxicological Evaluations subsection of the Public Health Implications section for more information on cancer.
In order to gather information on community health concerns, NJDOH contacted the Sparta Health Department and the NJDEP. The NJDEP conducted a public meeting on May 9, 1991, on the selected remedial alternative at which the community voiced their concerns. The NJDEP compiled the responses of letters and telephone calls that it received following the meeting. Community concerns centered on: 1) Odor complaints; 2) The threat of contamination of the high school drinking well (especially with formaldehyde); 3) Contamination of the Wallkill River; 4) Health impacts from using Station Park ball fields; 5) The safety of the public supply well; and 6) the sampling of wells during the sale of property.
Another public meeting was held on July 21, 1993 to discuss the construction of a public school near the site. This public meeting was attended by the NJDOH. Community concerns focused on: 1) Odor complaints; 2) The threat of contamination of the school drinking well; and 3) Health impacts from using Station Park ball fields.
The primary public health concerns related to exposure to contaminants (primarily via the air) from A.O. Polymer's former operations. The identity and amounts of the chemicals allegedly released are unknown. Complaints regarding odors continued for almost twenty years. Reports usually came from the east side of the plant, although one resident informed representatives of the New Jersey Department of Health (NJDOH) that people on the other side of the site had also complained about odors. Area residents reported that odors were produced intermittently. Some complaints alleged that odors were worse on weekends and off-shift times. Citizens associated respiratory irritation and other medical symptoms with odors emanating from the site. Community health concerns associated with the A.O. Polymer site in the past include:
1) Do the odors pose a health problem? What is the quality of the ambient air?
2) Is the water in existing private potable wells, or in the supply water supply safe for drinking?
3) Why are the wells of homes that are sold not sampled for formaldehyde and other chemicals?
4) Isn't inhalation of volatiles from the groundwater a concern for recreational users of Station Park?
5) If there are chronic effects associated with the active facility or the site, wouldn't a health study be appropriate?
These concerns are addressed in the Public Health Implication Section. The community health concerns have been minimal since the facility was closed. The New Jersey Department of Health (NJDOH) conducted a comment period for the public health assessment for the A.O. Polymer site from March 28, 1994 to April 29, 1994. The public health assessment was placed in local repositories to facilitate commentary and reaction from the public at large.