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Figure 1. Site Features and Surrounding Area

Figure 3. Site Location Map with Watershed Delineations



The Tibbetts Road Public Health Assessment was available for publicreview and comment from April 1, 1993, through April 30, 1993. Thepublic comment period was announced in the Foster's Daily Democrat. Copies of the public health assessment were made available forreview at the public library in Barrington, and in the U. S. EPARecords Center in Boston. In addition, the public healthassessment was sent directly to 14 individuals who attended ATSDR'sPublic Availability Meetings, and interested parties. Commentswere received from three submitters including two individuals, andthe New Hampshire Division of Public Health Services (NHDPHS). Comments from the submitters, and our responses are summarized inthis section.

Comment:My father probably died of emphysema in 1977, and mymother of ovarian cancer in 1991. I wonder whethertheir deaths and my severe eye irritations and frequentheadaches could have been caused by exposure tochemicals in my drinking water.

Response:Your private well was sampled and found to containacetone, iron, manganese, and propylene glycol. It ispossible that your eye irritation, and headaches couldbe related to your exposure to acetone and manganese inwell water. However, based on the current scientificknowledge, there are no reports to suggest that thechemicals detected in your well water have been shown tocause cancer. A history of smoking is important in thedevelopment of emphysema. Although no specifictoxicants have been linked to the development ofemphysema, epidemiologic surveys have shown an increasedprevalence of emphysema in heavily industrialized urbanareas. It is therefore unlikely that the chemicalsdetected in your well water caused the health problemsthat lead to the deaths of your parents. If you need todiscuss some aspects of your health and those of yourother family members with one of the Agency'sPhysicians, please contact Mr. Gregory Ulirsch at404/639-0627, to arrange an appointment for you.

Comment:The statement "... 337 55-gallon drums of which 201contained various materials" in the third paragraph ofthe Background section on page 3 is not true. Allbarrels and drums brought to the site were eitherremoved in 1953 or were used in the packaging andtransportation of scrap metals to the market in Boston,Massachusetts.

Response:The statement in the document is based on credibleinformation and data ATSDR received during the course ofwriting this public health assessment. The statementhas therefore not been changed in the document.

Comment:The health problems reported by some residents to bepresent in some former occupants of the Tibbetts Roadresidence (stated in item #4 of the Community HealthConcerns Evaluation section) are false. The formerowner of the site and his wife raised eight children atthe Tibbetts Road site, having had lost their eldestchild by drowning in October, 1944. The wife of theformer owner also died of childbirth complications twoyears later. The children are all above average inintelligence, and most of them were valedictorians atgraduation. The children raised at the site residencenow have 32 children, 62 grandchildren, and 3 greatgrandchildren. Moreover, none of the children raised atthe site residence have any mental or physical defects. It is also unlikely that the children who grew up at thesite would suffer health problems because of theirexposures contrary to what is stated in the CommunityHealth Concerns Evaluation section.

Response:In the absence of hospital records and other medicalhistory, it is difficult to determine whether or not anyhealth problems occurred in former residents of thesite, and what were the types and severity of thosehealth problems. The statement in the documentregarding probable occurrence of adverse health effectsin those same individuals is based on the evaluation ofdata and information, using current scientificknowledge. However, the manifestation of an adversenoncarcinogenic and carcinogenic health effect wouldalso be determined by other factors in addition toexposure. These other factors include life style,nutritional status, sex, age, family traits, and stateof health. The document has not been changed.

Comment:Concerning the presence of rodents, and a fire incidencein the building on site, and the lack of any sampling ofthe interior of the building (item #2, under CommunityHealth Concerns Evaluation), a sampling of the interiorof the house was done and found to be clean. Moreover,the interior of the house was treated for pests using arodent bait. However, no rodent was ever found insidethe house.

Response:Data and other information evaluated for preparing thisdocument do not indicate that the interior of thebuilding has been sampled or treated for pests,including rodents. However, as stated in the document,information about possible presence of rodents insidethe building was given to ATSDR officials during thesite visit, and at the availability meeting. Thedocument has not been changed.

Comment:Contaminants found in the residential well one-half milefrom the site did not originate from the site. Testshave shown water from the well on site to be "pure." TheEPA should therefore look elsewhere for sources of thosecontaminants.

Response:Evaluation of data and other information receivedindicates that some of the contaminants may be partlysite- related. The probability of this being the caseor not is outlined in the Summary, and in the PublicHealth Implications sections of the document. You arecorrect that the one well on the site has not been shownto be contaminated. This is because of the peculiarnature of the hydrogeological feature of the aquifer, inwhich the well is situated, diverts on-site contaminatedgroundwater away from the well. The document has notbeen changed.

Comment:In the last paragraph of the second page of the Summarysection, reference to "The New Hampshire Departments ofEnvironmental and Public Health Services .." should bechanged to the Department of Health and Human Services,Division of Public Health Services (NHDPHS).

Response:The change has been made. In addition, similar changeshave been made in other areas of the document.

Comment:Our Department does not agree with ATSDR's conclusionthat "residents who were exposed to TCE in the mostcontaminated well water or in soil have no risk ofdeveloping excess cancer over a lifetime" (under PublicHealth Implications section). It is our understandingthat the EPA considers the animal evidence sufficient,not limited and though TCE is currently under review, ithas been considered a B2 carcinogen previously. Therefore, until a final determination is made, ourDepartment would not concur that the residentsexperienced "no" cancer risk. In the Community HealthConcerns Evaluation section reference is made to TCE ashaving "limited" evidence of carcinogenicity in animals. Our Department has a similar comment about thetetrachloroethylene discussion

Response:According to the EPA, the weight of evidence is on C-B2continuum (C = Possible Human Carcinogen, B2 = ProbableHuman Carcinogen) for both TCE and PCE. Theclassification of "Possible Human Carcinogen" is basedon no human, and limited animal studies. As pointed outin the Public Health Implications section of thedocument, neither the International Agency for Researchon Cancer (IARC) nor the National Toxicology Program(NTP) of the Department of Health and Human Services(DHHS) has classified TCE as a carcinogen. Estimatesbased on data and information provided to ATSDR indicatethat adults and children who were exposed to TCE in themost contaminated soils or well water for periodsbetween 10 and 30 years would have no apparent risk (orno significant risk of developing excess cancer) overtheir lifetime. The document has been changed toclearly reflect this finding.

Comment:Our Department questions why the Lifetime HealthAdvisory of 1,2-Dichloroethene (1,2-DCE) referred to inTable 5 was not used to evaluate exposures, and why theconcern is for future as opposed to current exposure to1,2-DCE (in the Public Health Implications section).

Response:The Lifetime Health Advisory of 1,2-DCE is not dose-based or a measure of intake. It is concentration-based; and it is therefore inappropriate to compare itwith an estimated ingestion dose for an adult or achild. Since there is as yet no chronic healthguideline for 1,2-DCE, we used additional toxicologicaldata to evaluate past, present, and future levels ofexposure. The future potential exposure to contaminantswas addressed because of ATSDR's concern for probablepotential health effects that may be associated withexposure of humans to contaminants in wells that havebeen shut as well as contaminants contained within theaquifer. The document has not been changed.

Comment:Discussion of exposures to certain contaminants (forexample, cadmium and toluene on (under Public HealthImplications section) suggests that exposures weredocumented instead of estimated. In addition, it doesnot matter whether the children who played on the sitewere exposed to contaminants in surface subsoil, thefact remains that they were exposed depending on theextent of their contacts with soils.

Response:An exposure to a contaminant is documented when that contaminant has been detected in residential drinkingwater or in soils where children play. However, thedegree of exposure to contaminants in surface soils ishigher than that in surface subsoils or subsoils forchildren playing on the surface of soils in residentialyards. The document has not been changed.

Comment:For consistency, it would be better to report the dioxinequivalent concentrations detected both on and off sitein the same unit of either ppb or ppm (under Off- SiteContamination section, and in Table 1 for on-sitesoils).

Response:The units have been reconciled, and the document hasbeen changed accordingly.

Comment:The fourth sentence in paragraph 3, under PastResidential Setting Pathway of the Completed ExposurePathway, requires some clarification. For residentialexposures, our Department assumes a typical soilexposure occurs 160 days in a year.

Response:ATSDR estimated possible exposure period of about 6months in a year (as stated in the third paragraph,under the Public Health Implications section) which isnot significantly different from the 160 days assumed bythe submitter's Department. The statement in theCompleted Exposure Pathway section of the document hasbeen changed to reflect the exposure period of 6 monthson which estimation of exposure doses of contaminants insoils were based as stated in the Public HealthImplications section.

Comment:Acetone and manganese were also detected above levels ofconcern in the residential well one-half mile away fromthe site. However, this additional information was notincluded in the sentence "Benzene and TCE were the onlychemicals analyzed for in residential wells within thevicinity of the site." (item #5 under CommunityConcerns Evaluation section).

Response:It is correct that benzene and TCE were the onlycontaminants analyzed for in residential wellssurrounding the immediate vicinity of the site. However, after the initial release of the public healthassessment, acetone, manganese, iron, and propyleneglycol were detected in the residential well one-halfmile away from the site. It is uncertain whether allthese contaminants were site-related as pointed out inthe Summary section of the document. It would beincorrect and probably also unfair, to include acetoneand manganese in a discussion related to health concernsof people whose well water have not been shown tocontain acetone and manganese. The document hastherefore not been changed.

Comment:Our Department questions the relevance of the discussionof chlorinated dibenzofurans, in terms of site-relatedexposure to PCBs. Why is the PCB discussion at thissite linked with the Japan study?

Response:PCB mixtures are related to higher levels of chlorinateddibenzofurans and polychlorinated quarterphenyls (PCQs). The development of chloracne in PCB exposed workers forexample, is often related to high levels of chlorinateddibenzofurans and PCQs. The 1968 Japanese study is usedto explain the possibility of a manifestation of anysymptoms in former occupants of the site building whowere probably exposed to PCBs that might or might nothave been contaminated with PCDFs and PCQs. Thedocument has not been changed.

Comment:Shouldn't conclusion #3 be qualified as to what type andduration of exposure would be likely to cause adversehealth effects?

Response:The occurrence and type of any specific health effectswould depend on the concentrations of the contaminantsin groundwater, and the duration of exposure in thefuture. The document has not been changed.

Comment:Concerning item #2 under Public Health Actions section,it may be appropriate to qualify that our Departmentwill be evaluating residential wells currently in use. However, our Department will be willing to evaluateother data if provided.

Response:You are correct. The statement in the document hastherefore been changed to include this vital role of theNew Hampshire Department of Health and Human Services,Division of Public Health Service (NHDPHS).

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