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Site Location Map
Figure 1. Site Location Map

Site Map
Figure 2. Site Map

Demographic Map
Figure 3. Demographic Map

Ambient Air Sampling Locations: Winter
Figure 4. Ambient Air Sampling Locations: Winter

Ambient Air Sampling Locations: Spring
Figure 5. Ambient Air Sampling Locations: Spring

Ambient Air Sampling Locations: Summer
Figure 6. Ambient Air Sampling Locations: Summer

Table 1. Summary of Exposure Pathways for Brookfield Avenue Landfill

Pathway Name Exposure Pathway Elements Time of Exposure Comments
Source of Contamination Environmental Medium Point of Exposure Route of Exposure Exposed Population


AirVolatilization ofcontaminants fromwaste in the landfillAirAmbient airInhalationOn-site and off-siteresidents, securityguards, recreationalusers, trespassers Past
Little information is available concerning pastlevels of contamination in ambient air. Airsampling during the RI includedupwind/downwind ambient sampling, fluxbox sampling, and passive vent sampling. Some modeling was also done. There aremany other sources in the area. Levels ofcontaminants detected in the RI samplingpose no apparent public health hazard.


Groundwater --Cretaceous(Deeper) AquiferLeaching ofcontaminants fromwaste in landfillWater supplyWells, Great Kills SwimClub Pool Ingestion
Dermal contact
On-site and off-siteresidents Past
Groundwater on Staten Island has not beenused for public supply since 1970, and iscurrently not used for drinking water. Fournon-potable wells within a mile of the landfilluse groundwater for automobile washing,lawn irrigation, and filling the Great KillsSwim Club pool. They are all screened inthe Cretaceous aquifer. The three closest ofthese were sampled during the RI. Levels ofcontamination detected pose no apparentpublic health hazard.
Off-site Soil Waste in the landfill Soil Surface soil
Wind-blown dust from landfill
Dermal contact
Off-site residents Past
Limited off-site surface soil sampling was conducted in the past and during the RI. Low levels of contamination found pose no apparent public health hazard.
"Hot Spot" 5 Illegally dumped hazardous waste Soil Surface seep Dermal contact Trespassers Past Hot Spot 5 is near the location where a break in the perimeter fence existed until it was fixed in May 1998. ATSDR concluded that the limited exposures that may have occurred at this location were not likely to cause adverse health effects.
Food Chain Contamination of surface water and sediment by landfill leachate Fish
Consumption of fish/shellfish caught in Richmond Creek Ingestion Recreational users Past Recreational fishing and shellfishing may have occurred in Richmond Creek, which is adjacent to the site. In 1998, signs were erected in the vicinity of the creek and the landfill prohibiting fishing, shellfishing, and crabbing in the area. New York State has issued fish consumption advisories for all freshwaters in the state and for the Arthur Kill, which Richmond Creek flows into. No biota sampling data are available to evaluate this pathway.
Surface Water and Sediment in Richmond Creek Leaching of contaminants from waste in landfill Surface water
Richmond Creek Ingestion
Dermal contact
Recreational users Past
Recreational users of the creek might come into contact with sediments or incidentally ingest water, both of which are impacted by landfill leachate. This limited exposure to the levels of contamination detected poses no apparent public health hazard.
Migration of Landfill Gas Generation of methane by decomposition of wastes in landfill; volatilization of compounds in waste Soil gas Migration of landfill gas into basements of adjacent residences Inhalation On-site and off-site residents Past
A passive methane venting system was installed at the landfill from 1983-1985. In connection with the RI, basements of twenty-five nearby homes (on Arthur Kill Road and Colon Avenue) were tested in late 1993 and early 1994, and no evidence of explosive levels of landfill gas was found. Results suggested that no landfill gases are entering the home basements. However, gas probes at the perimeter of the landfill have had sporadic detections of methane exceeding the Lower Explosive Limit. ATSDR concurs with the RI recommendation that further sampling be conducted to confirm that landfill gas is not migrating south of Arthur Kill Road.


Groundwater -- Upper Glacial Aquifer Leaching of contaminants from waste in landfill Water supply Wells Ingestion
Dermal contact
None None No wells were found to be drawing from this aquifer in the vicinity of the landfill.
Leachate Seeps Leaching of contaminants from waste in the landfill Seeps Seeps, including around the perimeter of the landfill Dermal contact None None The landfill is fenced, posted, and guarded by two security guards, twenty-four hours a day, seven days a week. Fencing makes exposure to the seeps highly unlikely. No children live on site. ATSDR assumes that security guards and on-site residents do not access the contaminated portion of the site.
On-site soil, including Hot Spots 1 -4 Waste in the landfill Soil Surface soil
Wind-blown dust from landfill
Dermal contact
None None See above.
On-site surface water and sediment Leaching of contaminants from waste in landfill Surface water
On-site drainage features Ingestion
Dermal contact
None None See above.

Table 2: Historical Data, was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch E-56
1600 Clifton Road NE, Atlanta, Georgia 30333

Table 3. Brookfield Avenue Landfill: Chemicals Not Detected in Ambient Air With Lowest Detection Limits Higher Than Comparison Value

Chemical Units Range of Detection Limits Number of Valid Samples CV Type of CV
ETHYLENE DIBROMIDEppbv 0.1-1.6310.0007CREG


ppbv = parts per billion by volume
CREG = Cancer Risk Evaluation Guide
CV = Comparison Value

Source: NYCDEP, 1998.

Table 4. Brookfield Avenue Landfill: Ambient Air Summary Table

Chemical Units Detection Limit Range No. Valid Samples No. Detects Minimum Detection Maximum Detection Maximum Location:
Up-, Down-, or Sidewind?
Arithmetic Mean No. Over CV CV Type of CV
1,2,4-TRIMETHYL BENZENEppbv0.1-1.631220.183.6Side0.6531.3RBC-N
ARSENIC, TOTAL µg/m30.003-0.03252820.03090.0343NA0.011420.0002CREG
CHROMIUM, TOTAL µg/m30.002-0.007328200.00210.0095NA0.0038200.00008CREG FORCHROMIUM (VI)
HYDROGEN SULFIDEppbv4-5024155Up19090I-EMEG
METHYLENE CHLORIDEppbv0.1-1.631120.141.8Side0.3830.9CREG
Particulates smaller than 10 microns in diameter (PM10) µg/m3 NA 28 28 6.7481 110 NA 53.2 15 50 NAAQS--
0 150 NAAQS- 24-HOUR
TETRACHLORO-ETHYLENE ppbv 0.1-1.6 31 6 0.13 0.42 Side 0.22 2 0.3 CREG
0 40 C-EMEG
TRICHLOROETHYLENE ppbv 0.1-1.6 31 8 0.13 2.3 Up 0.32 8 0.1 CREG
0 100 I-EMEG


A-EMEG, I-EMEG, C-EMEG = Environmental Media Evaluation Guide (Acute, Intermediate, or Chronic)
ppbv = parts per billion by volume
CREG = Cancer Risk Evaluation Guide
CV = Comparison Value
NA = Not Applicable (For Detection Limit Range column, chemical was always detected; for Maximum Location column, PM10 and metals were not sampled on a wind-activated basis)
NAAQS = National Ambient Air Quality Standard
RBC-N = EPA Region III Risk-Based Concentration - Non-Cancer
RfC = Reference Concentration (EPA)
µg/m3 = micrograms per cubic meter

  • Chemicals presented in this table are only those with at least one detection exceeding the CV.
  • To calculate arithmetic means, nondetect results were replaced with a value equal to one-half the detection limit. Therefore, the arithmetic mean statistic becomes less meaningful as thenumber of detections decrease. For a chemical that was only detected once, the arithmetic mean is essential equal to one-half the average detection limit.
  • Duplicates and replicates were included as valid samples in the data analysis.
  • The first CV shown for each chemical is the screening value used to select chemicals of concern. If this CV is based on cancer risk, the most conservative CV for noncancer effects is alsoshown. (For PM10, the 24-hour and annual standards are shown.)
  • Chemicals denoted with an asterisk (*): Because these chemicals were detected in so few samples (less than 7%), ATSDR does not expect significant exposures to these chemicals, on thebasis of this limited data set. Hydrogen sulfide, however, is discussed briefly in the text in response to community concerns.
  • Source: NYCDEP, 1998.

Table 5. Brookfield Avenue Landfill: Upper Glacial Aquifer Summary Table

Chemical Units Detection Limit Range Number of Valid Samples Number of Detections Minimum Detected Value Maximum Detected Value Number of Samples Exceeding CV CV Type of CV
ANTIMONY, TOTALppb14-24.971320.128.534RMEG-CHILD
AROCLOR 1232ppb16614.54.510.033RBC-C
AROCLOR 1254ppb16611.91.910.2C-EMEG-CHILD
ARSENIC, TOTALppb2.5-307173.127.170.02CREG
BARIUM, TOTALppb16.2717022.913703700RMEG-CHILD
DIELDRIN ppb 0.1 66 2 0.01 0.021 2 0.002 CREG
GAMMA-CHLORDANE ppb 0.05 66 1 0.086 0.086 1 0.03 CREG (CHLORDANE)
IRON, TOTAL ppb 46.2 71 66 50.6 67600 29 11000 RBC-N
LEAD, TOTAL ppb 1-4.8 71 46 1 295 8 15 EPA action level
MANGANESE, TOTAL ppb NA 71 71 16.1 14200 68 50 RMEG-CHILD
METHYLENE CHLORIDE ppb 1-10 86 4 2.2 5.3 1 5 CREG
N-NITROSODI-N-PROPYLAMINE ppb 10-12 66 1 20 20 1 0.005 CREG
N-NITROSODIPHENYLAMINE ppb 10-12 66 1 8 8 1 7 CREG
SULFATE ppb 0-10,000 66 55 1,100 1,540,000 4 500,000 MCL (PROPOSED VALUE)

ppb = parts per billion
A-EMEG, I-EMEG, C-EMEG = Environmental Media Evaluation Guide (Acute, Intermediate, or Chronic)
CREG = Cancer Risk Evaluation Guide
CV = comparison value
EPA = Environmental Protection Agency
MCL = Maximum Contaminant Level for drinking water (EPA)
RBC-C, RBC-N = EPA Region III Risk-Based Concentration (Cancer or Non-Cancer)
NA = Not Applicable (chemical was always detected)
RMEG = Reference Dose Media Evaluation Guide
SMCL = Secondary MCL

  • Chemicals presented in this table are only those with at least one detection exceeding the CV.
  • Source: NYCDEP, 1998.

Table 6. Brookfield Avenue Landfill: Deep (Cretaceous) Aquifer Summary Table

Chemical Units Detection Limit Range Number of Valid Samples Number of Detections Minimum Detected Value Maximum Detected Value Number of Samples Exceeding CV CV Type of CV
LEAD, TOTALppbNA55442.6115EPA action level
ZINC, TOTALppb26.5-41.253122593013000C-EMEG-CHILD


ppb = parts per billion
A-EMEG, I-EMEG, C-EMEG = Environmental Media Evaluation Guide (Acute, Intermediate, or Chronic)
CREG = Cancer Risk Evaluation Guide
CV = comparison value
EPA = Environmental Protection Agency
NA = Not Applicable (chemical was always detected)
RMEG = Reference Dose Media Evaluation Guide

  • Chemicals presented in this table are only those with at least one detection exceeding the CV.
  • Source: NYCDEP, 1998.

Table 7. Private Well Sampling Results

Well Location Date Chemical Value (ppb) CV (ppb) CV Type
Lead3.515EPA action level
Sulfate38,700500,000MCL (proposed value)
Lead 42.6 15 EPA action level
Sulfate48,000500,000MCL (proposed value)
Zinc 5,930 3,000 C-EMEG-child
Di-n-butyl phthlate11,000RMEG-child
Diethyl phthlate18,000RMEG-child
Great KillsSwim Club7/19/93Barium510700RMEG-child
Manganese 70 50 RMEG-child
Sulfate33,400500,000MCL (proposed value)
Methylene Chloride0.75CREG
m,p-Xylene0.62,000I-EMEG-child (total xylenes)
Great Kills Little League 9/1/93 Barium 400 700 RMEG-child
Chloride 60,000 250,000 SMCL
Chromium 10 30 RMEG-child
(hexavalent chromium)
Iron 300 11,000 RBC-N
Manganese 50 50 RMEG-child
Nitrate (as N) 600 20,000 RMEG-child
Sulfate 35,700 500,000 MCL (proposed value)
1,1-Dichloroethane 0.6 800 RBC-N
1,1,1-Trichloroethane 2.2 200 MCL


ppb = parts per billion
A-EMEG, I-EMEG, C-EMEG = Environmental Media Evaluation Guide (Acute, Intermediate, or Chronic)
CREG = Cancer Risk Evaluation Guide
CV = comparison value
EPA = Environmental Protection Agency
MCL = Maximum Contaminant Level for drinking water (EPA)
RBC-C, RBC-N = EPA Region III Risk-Based Concentration (Cancer or Non-Cancer)
RMEG = Reference Dose Media Evaluation Guide
SMCL = Secondary MCL

  • Chemicals presented in this table are all of those detected.
  • Source: NYCDEP, 1998.

Table 8. Brookfield Avenue Landfill: Richmond Creek Surface Water Summary Table

Chemical Units Detection Limit Range Number of Valid Samples Number of Detections Minimum Detected Value Maximum Detected Value Number of Samples Exceeding CV CV Type of CV
ANTIMONY, TOTALppb17-24.98127.627.614RMEG-CHILD
ARSENIC, TOTALppb2.5-10823.23.420.02CREG
LEAD, TOTALppbNA887.242.1315EPA action level
SULFATEppbNA88174,000525,0002500,000MCL (PROPOSEDVALUE)
THALLIUM, TOTALppb2-38222.420.4LTHA


ppb = parts per billion
CREG = Cancer Risk Evaluation Guide
CV = comparison value
EPA = Environmental Protection Agency
LTHA = Lifetime Health Advisory for drinking water (EPA)
MCL = Maximum Contaminant Level for drinking water (EPA)
NA = Not Applicable (chemical was always detected)
RMEG = Reference Dose Media Evaluation Guide
SMCL = Secondary MCL

  • Chemicals presented in this table are only those with at least one detection exceeding the CV.
  • Comparison values used were developed for drinking water.
  • Source: NYCDEP, 1998.

Table 9. Brookfield Avenue Landfill: Richmond Creek Sediment Summary Table

Chemical Units Detection Limit Range Number of Valid Samples Number of Detections Minimum Detected Value Maximum Detected Value Number of Samples Exceeding CV CV Type of CV
IRON, TOTALppmNA443550050400423000RBC-N


ppm = parts per million
CREG = Cancer Risk Evaluation Guide
CV = comparison value
RBC-N = EPA Region III Risk-Based Concentration (Non-Cancer)
NA = Not Applicable (chemical was always detected)

  • Chemicals presented in this table are only those with at least one detection exceeding the CV.
  • Comparison values used were developed for surface soil.
  • Source: NYCDEP, 1998.


Quality Assurance

In preparing this report, ATSDR relied on the information provided in the referenced documents. ATSDR assumes that adequate quality assurance and control measures were taken during chain-of-custody, laboratory procedures, and data reporting. The validity of the analyses and conclusionsdrawn in this document are determined by the availability and reliability of the information.

Human Exposure Pathway Evaluation and the use of ATSDR Comparison Values

ATSDR assesses a site by evaluating the level of exposure in potential or completed exposurepathways. An exposure pathway is the way chemicals may enter a person's body to cause a healtheffect. It includes all the steps between the release of a chemical and the population exposed: (1) achemical release source, (2) chemical movement, (3) a place where people can come into contactwith the chemical, (4) a route of human exposure, and (5) a population that could be exposed. In thisassessment, ATSDR evaluates chemicals in the soil and groundwater that people living in nearbyresidences may consume or come into contact with.

Data evaluators use comparison values (CVs), which are screening tools used to evaluateenvironmental data that is relevant to the exposure pathways. Comparison values are concentrationsof contaminants that are considered to be safe levels of exposure. Comparison values used in thisdocument include ATSDR's environmental media evaluation guide (EMEG), the reference dosemedia evaluation guide (RMEG), and cancer risk evaluation guide (CREG). When an ATSDRcomparison value was unavailable, the U.S. Environmental Protection Agency (EPA) risk-basedconcentration (RBC) served as the comparison value. Comparison values are derived from availablehealth guidelines, such as ATSDR's minimal risk levels and EPA's cancer slope factors andreference doses.

The derivation of a comparison value uses conservative exposure assumptions, resulting in valuesthat are much lower than exposure concentrations observed to cause adverse health effects, thusensuring the comparison values are protective of public health in essentially all exposure situations.That is, if the concentrations in the exposure medium are less than the CV, the exposures are not ofhealth concern and no further analysis of the pathway is required. However, while concentrationsbelow the comparison value are not expected to lead to any observable health effect, it should not beinferred that a concentration greater than the comparison value will necessarily lead to adverseeffects. Depending on site-specific environmental exposure factors (for example, duration ofexposure) and activities of people that result in exposure (time spent in area of contamination),exposure to levels above the comparison value may or may not lead to a health effect. Therefore,ATSDR's comparison values are not used to predict the occurrence of adverse health effects.

The comparison values used in this evaluation are defined as follows: The CREG is used to evaluatepotential cancer effects. The CREG is the most conservative of comparison values because itassumes that there is no threshold for the effects of chemical carcinogens. The resulting CREG istherefore often below typical background levels and common detection limits. CREGs do not definelevels of actual hazard (e.g., a 1-in-a-million "risk" level) and cannot be used to predict actualcancer incidence under specified conditions of exposure. As stated in EPA's 1986 Cancer RiskAssessment Guidelines, "the true risk in unknown and may be as low as zero." The EMEG andRMEG represent concentrations at which daily exposure for a lifetime is unlikely to result in adversenoncancerous effects.

Selecting Contaminants of Concern

Contaminants of concern (COCs) are the site-specific chemical substances that the health assessorselects for further evaluation of potential health effects. Identifying contaminants of concern is aprocess that requires the assessor to examine contaminant concentrations at the site, the quality ofenvironmental sampling data, and the potential for human exposure. A thorough review of each ofthese issues is required to accurately select COCs in the site-specific human exposure pathway. Thefollowing text describes the selection process.

In the first step of the COC selection process, the maximum contaminant concentrations arecompared directly to health comparison values. ATSDR considers site-specific exposure factors toensure selection of appropriate health comparison values. If the maximum concentration reported fora chemical was less than the health comparison value, ATSDR concluded that exposure to thatchemical was not of public health concern; therefore, no further data review was required for thatchemical. However, if the maximum concentration was greater than the health comparison value, thechemical was selected for additional data review. In addition, any chemicals detected that did nothave relevant health comparison values were also selected for additional data review.

Comparison values have not been developed for some contaminants, and, based on new scientificinformation, other comparison values may be determined to be inappropriate for the specific type ofexposure. In those cases, the contaminants are included as contaminants of concern if currentscientific information indicates exposure to those contaminants may be of public health concern.

The next step of the process requires a more in-depth review of data for each of the contaminantsselected. Factors used in the selection of the COCs included the number of samples with detectionsabove the minimum detection limit, the number of samples with detections above an acute or chronic health comparison value, and the potential for exposure at the monitoring location.


Contaminants of Concern Detected in Ambient Air

Toxicologic Evaluation

Table 4 of this public health assessment (PHA) provides a summary of the chemicals detected inambient air during the remedial investigation (RI) of the Brookfield Avenue Landfill at levelsexceeding health-based comparison values. As discussed in the PHA, for most of these contaminants,landfill emissions are thought to account for only a very small fraction of the levels detected. Manyof the contaminants are typically found in urban air from a variety of sources at levels comparable orabove those detected in air during the RI. The purpose of this appendix is to provide a brief publichealth evaluation of the detected levels of these chemicals, regardless of source.

It should be emphasized that the data set on which this evaluation is based represents only a snapshotof air conditions in 1994 and 1997. Little is known about possible air exposures during the years oflandfill operation and immediately following landfill closure (i.e., 1966 through the mid-1980s).Where possible, ATSDR presents its evaluation of the limited historic data to provide additionalhealth perspective.


Low levels of benzene were consistently detected in air samples collected during the BrookfieldLandfill RI, at concentrations ranging from 0.24 to 6.4 parts per billion by volume (ppbv), with anaverage concentration of 1.3 ppbv. These levels pose no apparent health hazard. Detected levels aresimilar to those found in most urban areas and comparable to levels detected during the New YorkCity Department of Health (NYCDOH) 1982 investigation at the Brookfield Landfill (4.5 ppbv)(NYCDEP, NYCDOH, NYCDOS, 1982) and during the New York State Department ofEnvironmental Conservation (NYSDEC) 1994-1995 investigations of the nearby Fresh KillsLandfill (<0.04 to 2.58 ppbv) (ATSDR, 1998a). Sources of benzene may include automobileexhaust, refueling activities, cigarette smoke, and industrial emissions, with the most significantsource being the combustion of gasoline (ATSDR, 1997a).

Benzene is a known human carcinogen, but most studies show that benzene-related cancer effects areseen only with cumulative exposures of 200 ppmv-years or more (e.g., 5,000 ppbv for 40 years)(Wong, 1995). Levels detected in the landfill studies were much lower than this. In addition, noshort-term (or acute) effects are expected because benzene is acutely toxic only at concentrationswell above 50,000 ppbv in air (ATSDR, 1997a). For example, people exposed over a 1- to 21-dayperiod to 60,000 ppbv benzene in air exhibited respiratory irritation and skin irritation (Midzenski etal., 1992).


1,2,4-Trimethylbenzene was detected at levels slightly exceeding its comparison value for noncancereffects, by a factor of less than 3, in only 3 of the 22 samples collected during the RI. Estimatedaverage concentrations (less than 0.6 ppbv) during each sampling event were lower than comparisonvalues. Based on these data, 1,2,4-trimethylbenzene levels are not expected to result in adversehealth effects.

Trichloroethylene (TCE) and Tetrachloroethylene (PCE)

At detected levels, exposure to TCE and PCE in ambient air is not expected to pose a public healthhazard. Maximum detected TCE and PCE levels (2.3 and 0.42 ppbv, respectively) are just slightlyabove comparison values for cancer effects. It should be emphasized, however, that cancercomparison values for these chemicals (the Cancer Risk Evaluation Guides [CREGs]) are set verylow and are based on animal studies in which lung-related cancers were seen at air concentrations atand above 100,000 ppbv, which is more than 40,000 times higher than maximum levels detected inthe Brookfield air samples (ATSDR, 1997b,c). Furthermore, TCE and PCE were detected in only afew samples, which means that people were not consistently exposed to the maximum detectedlevels, assuming that the RI results are representative of area conditions over time. Averageconcentrations of TCE and PCE fall at or below comparison values for chronic effects, includingcancer. Also, maximum detected TCE and PCE concentrations are 100 to 1000 times less than thecomparison values for acute effects.

A compilation of U.S. ambient air monitoring data for PCE (prior to 1981) showed averageconcentrations ranging from 0.16 ppbv (rural/remote), 0.79 ppbv in urban and suburban areas, and1.3 ppbv in areas near emission sources (ATSDR, 1997b). The levels of TCE detected in theBrookfield RI air sampling program are generally comparable to ambient air levels detected in the1994-1995 NYSDEC study of the Fresh Kills Landfill (<0.2-0.33 ppbv) (ATSDR, 1998a).

Methylene Chloride

The levels of methylene chloride detected in RI samples pose no apparent public health hazards.Methylene chloride was detected (at a maximum concentration of 1.8 ppbv) in fewer than 50% ofthe air samples collected. Concentrations exceed the CREG of 0.9 ppbv in only three samples. Inavailable animal and human studies, cancer (in animals only), other chronic effects, and acute effectshave not been documented at methylene chloride levels in air below 50,000 ppbv, with mostobserved effects at much higher levels. Maximum and average concentrations of methylene chloridedetected in air at and around the Brookfield site (1.8 and 0.38 ppbv, respectively) fall well belowthis level and are, therefore, not likely to result in any adverse health effects (ATSDR, 1998d). Foradditional comparison purposes, the maximum level of methylene chloride to which workers may beexposed is 25,000 ppbv.

Carbon Tetrachloride

Carbon tetrachloride was detected at maximum and average concentrations of 0.4 ppbv and 0.21ppbv, respectively. While these values exceed ATSDR's CREG of 0.01 ppbv, it should be noted thatno studies exist establishing a clear association between inhaling carbon tetrachloride and the risk ofcancer. The CREG was conservatively derived on the basis of cancer studies looking at ingestion ofcarbon tetrachloride in animal studies. Reported concentrations at and around the BrookfieldLandfill site are well below ATSDR's intermediate and acute comparison values for carbontetrachloride of 50 and 200 ppbv, respectively. Furthermore, detected levels are hundreds tothousands of times lower than concentrations shown in the literature to result in acute or chronicnoncancer health effects (ATSDR, 1994). It should also be noted that typical ambient airconcentrations of carbon tetrachloride reported worldwide average approximately 0.1 ppbv, withslightly higher levels often found in cities (averaging approximately 0.2-0.3 ppbv). Typical levels ofcarbon tetrachloride measured in indoor air in homes in several U.S. cities (from building materials,pesticides, cleaning agents) are 0.16 ppbv, with some levels up to 1.4 ppbv (ATSDR, 1994).


Acrolein is used to make other chemicals and pesticides. Small amounts of acrolein can be formedand enter the air when tobacco and fuels, such as gasoline and oil, are burned. Acrolein was detectedat concentrations ranging from 2.2-12 ppbv in about 30% of the air samples, with the highestconcentrations detected in "upwind" samples. These concentrations are higher than Camp Dresser &McKee's (CDM's) models predicted would be emitted from the Brookfield Landfill and are higherthan acrolein levels detected in 1994 and 1995 by NYSDEC as part of its study of the nearby FreshKills Landfill (detected up to 0.03 ppbv) (ATSDR, 1998a).

The levels of acrolein detected in the vicinity of the Brookfield Landfill, however, are more than 100times lower than the levels of acrolein that have been shown to irritate the eyes, nose, and throat(170 ppbv and higher) (Weber-Tschopp et al., 1977). Studies looking at longer-term exposures toacrolein in air are available for animals only and suggest that effects to the lung and other systemsare only seen at levels above approximately 200 ppbv (ATSDR, 1990). Less is known about long-term low level exposures in humans; that is why such large margins of safety are used in derivingcomparison values for acrolein. Acrolein is considered a "possible human carcinogen" based on verylimited animal data showing evidence of cancer in rats who ingested acrolein in drinking water(IRIS, 1999).

Arsenic and Chromium

Arsenic, a human carcinogen, was detected in only 2 of the 28 RI samples at concentrations of approximately 0.03 µg/m3. Chromium, a probable human carcinogen, was detected in most samples at levels ranging from 0.0021 to 0.0095 µg/m3. These concentrations exceed ATSDR's CREGs for these two metals, but upon closer examination of the toxicity of these metals, detected levels are not at concentrations expected to result in adverse health effects.

Detected arsenic levels in ambient air are significantly lower than those shown to result in harmful effects in occupational and animal studies. Cancer effects in humans have not been linked with exposures to less than 10 µg/m3 in air. The allowable exposure level for workers (8-hour time weighted average) is also 10 µg/m3 (ATSDR, 1998b). The maximum level of arsenic reported in air in the Brookfield Landfill area is 300 times lower than this.

Chromium is a little more difficult to evaluate because it exists naturally in two different forms:hexavalent chromium (or chromium VI) and trivalent chromium (or chromium III). The scientificliterature indicates that hexavalent chromium is more toxic than trivalent chromium and thatinhalation exposure to hexavalent chromium is much more likely to exhibit cancer effects thanequivalent inhalation exposures to trivalent chromium (ATSDR, 1998c). Detected chromium levelsare lower than comparison values for noncancer effects for more toxic hexavalent chromium,indicating that exposure to detected levels would not result in adverse noncancer effects.

The RI results do not distinguish which form of chromium was detected, but instead reports concentrations of "total" chromium. Depending on the source(s) of the chromium, the expected mix of hexavalent and trivalent chromium will vary. EPA has estimated, for example, that chromium from the combustion of fuel, refuse incineration, and cement production generally contain low percentages of the more toxic hexavalent chromium (i.e., 0.2-0.3%). Emissions from industries such as chromium chemical manufacturing, textile manufacturing, and petroleum refining, on the other hand, may emit higher levels of hexavalent chromium (up to 100%). EPA assumes that environmental samples generally contain hexavalent and trivalent chromium in a 1:6 ratio. Regardless of the mix, however, it should be noted that the concentration of total chromium measured in the RI air samples are comparable to those generally reported in urban air (between 0.01 and 0.03 µg/m3). Furthermore, even in the unlikely event that samples contained 100% hexavalent chromium, detected levels (maximum of 0.0095 µg/m3) in the vicinity of the Brookfield Landfill are thousands of times lower than lowest levels shown to be associated with lung cancer in human occupational studies (>40 µg/m3) (ATSDR, 1998c).

Hydrogen Sulfide

Hydrogen sulfide was detected in only one of the 24 air samples collected during the RI at a lowconcentration of 5 ppbv. The measured level of hydrogen sulfide is below the ATSDR intermediateand acute comparison values of 90 and 500 ppbv. Therefore, this one low measurement is notexpected to be associated with any adverse health effects.

Even though levels of hydrogen sulfide provided in the RI data do not indicate a public healthhazard, community members have expressed concerns regarding foul odors in the past (especiallyduring excavations). Because landfills can produce the odorous hydrogen sulfide, it is possible thathydrogen sulfide contributed to reported odors. Only limited past air data are available at andaround the Brookfield site. The extent, if any, of past exposures is therefore not known. Limitedhistoric data available for ATSDR review revealed that hydrogen sulfide was not detected during a1982 air sampling during trench excavation activities (NYCDEP, NYCDOH, and NYCDOS,1982); however, the limit of detection on the sampling device was 10,000 ppbv, meaning that levelsin present in the air below 10,000 ppbv would have been reported as "not detected."

The following compilation of exposure and health data on hydrogen sulfide is provided todemonstrate (even in the absence of data) that hydrogen sulfide levels would have had to have been relatively high over an extended period of time to result in any long-term health effects.

  • Hydrogen sulfide is a common decomposition product in landfills. It is also foundnaturally in crude petroleum, natural gas, volcanic gases, swamps, and hot springs,and is produced from animal waste.

  • Hydrogen sulfide emissions vary depending on the age and condition of the landfill.Sulfide production decreases after most of the wastes have decomposed (usually after20 years of being dumped).

  • People can smell hydrogen sulfide (which is known for its characteristic rotten eggsmell) at very low levels (0.5-25 ppbv) (ATSDR, 1997d; IRIS, 1999).

  • Smelling hydrogen sulfide at low levels may pose nuisance conditions and possibleacute effects such as headaches and nausea. Exposure to these levels, however, is notexpected to be associated with any long-term adverse health effects.

  • Accounting for the most sensitive individuals, acute effects are not considered likely at concentrations below 500 ppbv (ATSDR, 1997d). The World HealthOrganization (WHO) set 108 ppbv as a 24-hour air guideline value. This is the levelat which extremely sensitive people may begin to experience eye irritation.

  • One limited study of asthmatics concluded that exposure for a relatively short time to hydrogen sulfide concentrations appreciably higher than those existing in ambient air do not cause noticeable effects on respiratory function. (Jappinen et al., 1990).

  • Some scientists feel that effects are not likely in humans at concentrations less than 1,000 ppbv based on their understanding of how hydrogen sulfide acts in the humanbody (Kerger and Barfield, 1992).

  • The Occupational Safety and Health Administration does not allow workers to beexposed to hydrogen sulfide at levels higher than 20,000 ppbv.

  • Concentrations of hydrogen sulfide in the air around a landfill are typically less than 15 ppbv, well below levels documented to result in health effects (CTDPH, 1996).


Particulate matter in air is composed of solid particles and liquid droplets. Particles of greatest healthconcern are small particles-those less than 10 microns in diameter-because they can penetrate tosensitive areas of the respiratory tract. These small particles are composed of "coarse" particles(those that are larger than 2.5 microns) and "fine" particles (those less than 2.5 microns). Coarseparticles tend to come from sources such as windblown dust and grinding operations and are linkedto health effects such as aggravated asthma. Fine particles result from fuel combustion (e.g., motorvehicles, industrial facilities) and residential fireplaces and wood stoves. Fine particles can penetratedeep into the lungs and, at levels above established air standards, have been shown to contribute tohealth effects such as increased hospital visits, increased respiratory symptoms and disease, chronicbronchitis, and decreased lung function, especially among the elderly, children, and individuals withpre-existing heart or lung disease (U.S. EPA, 1997a,b).

The RI air monitoring program measured for particles less than 10 microns (i.e., PM10), but it didnot separately measure the finer (<2.5 micron) particles. It wasn't until 1997 that EPA called forquantifying and developed standards for fine particles (i.e., PM2.5). Further evaluation of healtheffects would be possible if information on the size distribution of particles in ambient air wereavailable. It should be noted, however, that the Brookfield Landfill does not currently appear to be alikely significant source of particulates in air because the landfill is covered with vegetation reducingthe possibility of wind erosion, dust generation, etc. Furthermore, landfills in general are not thoughtto be a major source of PM2.5 (U.S. EPA, 1997b).

The available PM10 data does indicate that all maximum concentrations measured in each of the eight sampling stations were less than the NYSDEC 24-hour average standard for PM10 of 150 µg/m3 (this concentration is "not to be exceeded more than once per year")(1). This indicates that short-term exposures to measured particulate levels would not be expected to result in adverse respiratory effects.

NYSDEC also has an annual PM10 guideline of 50 µg/m3, which represents the level of particulates that people can be exposed to over the longer term without risk of adverse health effects. Ideally, the guideline value should be compared to the arithmetic average of 24-hour samples collected for a period of 1 year, averaged over 3 consecutive years. This extensive a data set does not exist for the Brookfield Landfill. The overall average concentration for all PM10 samples collected during the RI is 53.2 µg/m3, with average concentrations exceeding the annual guideline at four of the eight monitoring stations (Stations 1, 2, 4, and 8, shown in Figures 4-6). Average concentrations are estimated based on data from only four days of sampling, however (in 1994 and 1997). It is therefore uncertain how representative these measurements are of particulate levels over the longer term. Data from NYSDEC's 1994-1995 ambient air study for the nearby Fresh Kills Landfill provide some additional perspective. PM10 levels were measured over an extended period of time in the general vicinity of the Brookfield Avenue Landfill as part of that study. Average PM10 levels were reported below relevant health standards (ATSDR, 1998a). Based on that data set, ATSDR concluded that adverse health effects from exposure to coarse particles are unlikely.

ATSDR also reviewed site-related particulate data from 1984. Samples were collected over a 2-day period and measured for total suspended particulates (TSP). The TSP measurement preceded the current PM10 methodology and measures larger particles (those greater than 10 microns). TSP levels measured at the landfill gate ranged from 83.8 to 242.2 µg/m3 and from 46.8-67.4 µg/m3 in the "community" (NYCDEP, 1984). These levels all fall below EPA's 24-hour average standard for TSP of 260 µg/m3. The levels at the gate exceeded the annual average TSP standard of 75 µg/m3, but interpretation of these results is difficult for the following reasons: (1) comparing results obtained from a brief one-time sampling event to annual standards is speculative; it assumes that measured air concentrations were representative of long-term conditions and did not vary over time, and (2) based on more current research, measuring TSP is not the best indicator of potential long- or short-term health effects.


General Terms

The process of taking in, as when a sponge takes up water. Chemicals can be absorbed through the skin into the bloodstream and then transported to other organs. Chemicals can also be absorbed into the bloodstream after breathing or swallowing.

Occurring over a short time, usually a few minutes or hours. An acute exposure can result in short-term or long-term health effects. An acute effect happens a short time (up to 1 year) after exposure.

Surrounding. For example, ambient air is usually outdoor air (as opposed to indoor air).

Background Level:
A typical or average level of a chemical in the environment. Background often refers to naturally occurring or uncontaminated levels.

Any substance that may produce cancer.

Central Nervous System:
The part of the nervous system that includes the brain and the spinal cord.

The Comprehensive Environmental Response, Compensation, and Liability Act of 1980,also known as Superfund. This is the legislation that created ATSDR.

Occurring over a long period of time (more than 1 year).

The amount of one substance dissolved or contained in a given amount of another. For example, sea water contains a higher concentration of salt than fresh water.

Any substance or material that enters a system (the environment, human body, food, etc.) where it is not normally found.

Referring to the skin. Dermal absorption means absorption through the skin.

Disease Registry:
A system for collecting and maintaining in a structured record, information on persons having a common illness or adverse health condition.

The amount of substance to which a person is exposed. Dose often takes body weight into account.

Environmental contamination:
The presence of hazardous substances in the environment. From the public healthperspective, environmental contamination is addressed when it potentially affects the health and quality of life of people living and working near the contamination.

Contact with a chemical by swallowing, by breathing, or by direct contact (such as through the skin or eyes). Exposure may be short term (acute) or long term (chronic).

A source of risk that does not necessarily imply potential for occurrence. A hazard produces risk only if an exposure pathway exists, and if exposures create the possibility of adverse consequences.

Health Investigation:
Any investigation of a defined population, using epidemiologic methods, which would assist in determining exposures or possible public health impact by defining health problems requiring further investigation through epidemiologic studies, environmental monitoring or sampling, and surveillance.

Swallowing (such as eating or drinking). Chemicals can get in or on food, drink, utensils, cigarettes, or hands where they can be ingested. After ingestion, chemicals can be absorbed into the blood and distributed throughout the body.

Breathing. Exposure may occur from inhaling contaminants because they can be deposited in the lungs, taken into the blood, or both.

Soil, water, air, plants, animals, or any other parts of the environment that can contain contaminants.

All the chemical reactions that enable the body to work. For example, food is metabolized (chemically changed) to supply the body with energy. Chemicals can be metabolized and made either more or less harmful by the body.

Parts Per Billion Volume (PPBV):
The expression of the concentration of gasses and vapors expressed on a volumetric basis.

A system for collecting and maintaining, in a structured record, information on specific persons from a defined population. Preliminary analyses and reviews are performed.

In risk assessment, the probability that something will cause injury, combined with the potential severity of that injury.

Route of Exposure:
The way in which a person may contact a chemical substance. For example, drinking(ingestion) and bathing (skin contact) are two different routes of exposure to contaminants that may be found in water.

Another name for the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), which created ATSDR.

Volatile organic compounds (VOCs):
Substances containing carbon and different proportions of other elements such as hydrogen, oxygen, fluorine, chlorine, bromine, sulfur, or nitrogen; these substances easily become vapors or gases. A significant number of the VOCs are commonly used as solvents (paint thinners, lacquer thinner, degreasers, and dry cleaning fluids).

ATSDR-Specific Terms

Comparison Values:
Estimated contaminant concentrations in specific media that are not likely to cause adverse health effects, given a standard daily ingestion rate and standard body weight. The comparison values are calculated from the scientific literature available on exposure and health effects.

Health Consultation:
A response to a specific question or request for information pertaining to a hazardous substance or facility (which includes waste sites). It often contains a time-critical element that necessitates a rapid response; therefore, it is a more limited response than an assessment.

Health Outcome Data:
A major source of data for public health assessments. The identification, review, and evaluation of health outcome parameters are interactive processes involving the health assessors, data source generators, and the local community. Health outcome data are community specific and may be derived from databases at the local, state, and national levels, as well as from data collected by private health care organizations and professional institutions and associations. Databases to beconsidered include morbidity and mortality data, birth statistics, medical records, tumor and disease registries, surveillance data, and previously conducted health studies.

Minimal Risk Level (MRL):
An MRL is defined as an estimate of daily human exposure to a substance that is likely to be without an appreciable risk of adverse effects (noncancer) over a specified duration of exposure. MRLs are derived when reliable and sufficient data exist to identify the target organ(s) of effect or the most sensitive health effect(s) for a specific duration via a given route of exposure. MRLs arebased on noncancer health effects only. MRLs can be derived for acute, intermediate, and chronic duration exposures by the inhalation and oral routes.

No Apparent Public Health Hazard:
Sites where human exposure to contaminated media is occurring or has occurred in the past, but the exposure is below a level of health hazard.

No Public Health Hazard:
Sites for which data indicate no current or past exposure or no potential for exposure and therefore no health hazard.

Petitioned Public Health Assessment:
A public health assessment conducted at the request of a member of the public. When a petition is received, a team of environmental and health scientists is assigned to gather information to ascertain, using standard public health criteria, whether there is a reasonable basis for conducting a public health assessment. Once ATSDR confirms that a public health assessment is needed, thepetitioned health assessment process is essentially the same as the public health assessment process.

Potential/Indeterminate Public Health Hazard:
Sites for which no conclusions about public health hazard can be made because data are lacking.

Potentially Exposed:
The condition where valid information, usually analytical environmental data, indicates the presence of contaminant(s) of a public health concern in one or more environmental media contacting humans (i.e., air, drinking water, soil, food chain, surface water), and there is evidence that some of those persons have an identified route(s) of exposure (i.e., drinking contaminated water, breathing contaminated air, having contact with contaminated soil, or eating contaminated food).

Public Comment:
An opportunity for the general public to comment on Agency findings or proposed activities. The public health assessment process, for example, includes the opportunity for public comment as the last step in the draft phase. The purposes of this activity are to 1) provide the public, particularly the community associated with a site, the opportunity to comment on the public health findings contained in the public health assessment, 2) evaluate whether the community health concerns have been adequately addressed, and 3) provide ATSDR with additional information.

Public Health Action:
Designed to prevent exposures and/or to mitigate or prevent adverse health effects in populations living near hazardous waste sites or releases. Public health actions can be identified from information developed in public health advisories, public health assessments, and health consultations. These actions include recommending the dissociation (separation) of individuals from exposures (for example, by providing an alternative water supply), conducting biologic indicators of exposure studies to assess exposure, and providing health education for health care providers andcommunity members.

Public Health Assessment:
The evaluation of data and information on the release of hazardous substances into the environment in order to assess any current or future impact on public health, develop health advisories or other recommendations, and identify studies or actions needed to evaluate and mitigate or prevent human health effects; also, the document resulting from that evaluation.

Superfund Amendments and Reauthorization Act (SARA):
The 1986 legislation that broadened ATSDR's responsibilities in the areas of public health assessments, establishment and maintenance of toxicologic databases, information dissemination, and medical education.

Toxicological Profile:
A document about a specific substance in which ATSDR scientists interpret all knowninformation on the substance and specify the levels at which people may be harmed if exposed. The toxicological profile also identifies significant gaps in knowledge on the substance, and serves to initiate further research, where needed.


In 1983 and 1984, air quality monitoring was conducted on behalf of the New York City Departmentof Environmental Protection (NYCDEP) by York Research Corporation at and near the BrookfieldAvenue Landfill. ATSDR did not receive copies of these reports from NYCDEP in time for evaluationin the Public Comment Release of this PHA. This evaluation is being included in the Final Release ofthe PHA as a separate appendix to provide readers with additional information.

As is true for the more recent air monitoring data from the remedial investigation (RI), this data setrepresents only a snapshot of conditions in 1983 and 1984. Little is known about possible air exposuresduring the years of landfill operation and immediately following landfill closure. However, this dataset can provide some perspective on possible exposures during the 1980s.

Sampling Programs

York Research Corporation sampled ambient air, vent emissions, and surface emissions at the landfillin November 1983 (Phase I), June and July 1984 (Phase II), and September 1984 (Phase III). Thisanalysis will focus on ambient air sampling, with some qualitative discussion of the results of theemissions sampling. Also, this analysis focuses only on ambient air sampling from sites that were eitherat or downwind from the landfill.

In Phase I, York sampled ambient air at two sites for volatile and semi-volatile organics, particulates,and metals. These sites were designated as Sites 2 and 7; see Figure 1 for site locations. In Phase II,York sampled ambient air for volatile and semi-volatile organics at the following sites: Site 5; Site 7;a site designated as "DWV" because it was downwind of the landfill vents; and a site designated as"RTP" located just off an extension of the Richmond Town Parkway overpass of Richmond Avenue (seeFigure 2 for site locations). At the RTP site, wind-activated sampling operated only when the wind wasblowing from the direction of the landfill. In Phase III, wind-activated samplers at the RichmondtownRestoration Center and two sites near the edge of the landfill sampled only when the wind was blowingfrom the landfill (see Figure 3). The sites near the edge of the landfill were near two newly createdlandfill vent trenches. The "Berm" site was on the berm between the trenches, and the "DWT" site wasdownwind of them at the landfill fence line. In Phase III, only a group of 15 volatile organic compoundswas sampled for; the compounds selected had been identified during Phases I and II as being emittedfrom the landfill.

In general, because most of these sites were on or immediately adjacent to the landfill, levels ofcontaminants found in air were probably higher than levels people near the landfill were actuallyexposed to. The one exception was the Richmondtown Restoration Center, which is in the communitya short distance from the landfill to the northeast.

During each sampling phase, ambient air samples were collected for one 24-hour period. Because thewind-activated samplers sampled only when the wind was blowing from a certain direction, somesamples were collected for only a portion of this 24-hour period.

Nature and Extent of Ambient Air Contamination and Health Implications
Compounds detected above ATSDR comparison values in ambient air during these investigations are shown in Tables 1-3. These compounds were arsenic, benzene, carbon tetrachloride, methylene chloride, tetrachloroethylene, tetrahydrofuran, and trichloroethylene. The only compounds detected during more than one sampling event were benzene, tetrachloroethylene, and trichloroethylene. (Note, however, that metals were only sampled for during Phase I).

In general, levels detected were comparable to those found during the RI. The main exception was atSite 7 during Phase I; this sampling found levels higher than those seen in the RI. This site was locatednear a fissure from which landfill gas was escaping; this fissure was apparently plugged before PhaseII and Phase III sampling. Thus, although it was intended to be an ambient air monitoring site, Site 7during Phase I was more similar to an emissions monitoring site, like the vent pipes. Emissionssampling and upwind/downwind comparisons in Phases I, II, and III generally indicated that, althoughsome volatile organic compounds were being emitted from the landfill, these emissions did not resultin ambient levels in the surrounding area that would pose health hazards. This conclusion is the sameone reached during the RI.

Because the chemicals found in the York sampling were some of the same compounds detected in theRI and were found at similar levels, ATSDR reached the same conclusions about the health effects ofthese compounds as for the compounds detected in the RI. Although some Cancer Risk EvaluationGuides were exceeded, these screening values incorporate such a large margin of safety that the slightexceedances seen at some sites on some days are very unlikely to pose a health hazard. In addition, thelevels detected were typical of those found in urban air and may have reflected emissions from sourcesother than the landfill. See the body of the PHA and Appendix C for more information on ATSDR'sevaluation of compounds detected during the RI.

Thus, the sampling by York Research Corporation does not provide any indication that the landfill poseda health hazard in the past. However, ATSDR still considers past air data to be insufficient to fullyevaluate past health hazards. Therefore, the evaluation of these data does not change ATSDR'sconclusion that the Brookfield Avenue Landfill posed an indeterminate health hazard in the past.

Table 1. Ambient Air Summary Table: York Phase I Investigation

Chemical Units Detection Limit CV CV Type Site 2 Concentration Site 7 Concentration

Notes for Tables 1 through 3:

C-EMEG, I-EMEG = Environmental Media Evaluation Guide (Chronic or Intermediate)
CREG = Cancer Risk Evaluation Guide
CV = Comparison Value
ND = Not Detected
ppbv = parts per billion by volume
RBC-C = EPA Region III Risk-Based Concentration - Cancer
µg/m3 = micrograms per cubic meter

  • Chemicals presented in these tables are only those with at least one detection exceeding the CV.
  • See text and figures for sampling site descriptions and locations.
  • Source: NYCDEP 1984, 1985a, 1985b.

Table 2. Ambient Air Summary Table: York Phase II Investigation

Chemical Units Detection Limit CV CV Type Site 5 Concentration Site 7 Concentration DWV


RTP Wind-Activated Sampling Concentration

Table 3. Ambient Air Summary Table: York Phase III Investigation

Chemical Units Detection Limit CV CV Type DWT From Landfill Concentration Berm Concentration RTC From Landfill Concentration

York Phase I Air Monitoring Locations
Figure 1. York Phase I Air Monitoring Locations

York Phase II Air Monitoring Locations
Figure 2. York Phase II Air Monitoring Locations

York Phase III Monitoring Locations
Figure 3. York Phase III Monitoring Locations


Table 1 in Appendix F was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch E-56
1600 Clifton Road NE, Atlanta, Georgia 30333

Permanent Gas Probes Map and Summary of Exceedances
Figure 1. Permanent Gas Probes Map and Summary of Exceedances


Public Comment Section

ATSDR provided an opportunity in the final draft stage of this document for the general public tocomment on Agency findings or proposed activities from August 3, 1999 - September 1, 1999. Asummary of the comments received are addressed below:

Page 4- We agree with your conclusion that it is unlikely that anyone had trespassed or would trespass onto the contaminated areas of the site. It should be noted, however, that the unfenced area where the unused highway crosses Richmond Avenue has been fenced. In addition, an older section of fencing along Holtermann's Bakery has been replaced with new fencing.

ATSDR Response
This new information has been noted in the document.

Page 7 - We agree with your conclusion that current air emissions from the site pose no apparent health hazard. However, while referencing a 1982 investigation by New York City agencies that involved air monitoring at neighborhood location, it should be noted that the detection of VOCs does not necessarily provide the basis for concluding that the Brookfield Avenue landfill was the source, especially when Benzene was the compound detected.

ATSDR Response
ATSDR addresses this concern in the sections entitled "Contaminant Source Evaluation", and "Data Limitations". In these sections, ATSDR explains how the source of contaminants were evaluated and discusses the difficulty in identifying the source of contaminants as being emitted solely from the landfill due to various confounding factors such as vehicle emissions and other activities in the area. For public health purposes, ATSDR is interested only in the presence of the contamination and the potential for human exposure, not the source of the contaminant.

Page 8 - It should be noted that ATSDR has been provided data from York and TRC studies conducted on behalf of DEP in 1983 and 1984.

ATSDR Response
This information is noted in the document. The provided data are discussed in detail in Appendix E.

Page 8 and Page 9 - In the section on page 8 relating to Contaminant Source Evaluation, the statement is made that relatively limited ambient air sampling was conducted. On page 9, in the section entitled Data Limitations the theme is that not enough air monitoring was conducted to determine what is truly representative. These statements belie your overall conclusion that there is no need for concern due to air emissions. We believe that it should be pointed out, at a minimum, that the procedures and sampling plan used in the Remedial Investigation were reviewed and approved by both the NYSDEC and the USEPA and were industry standard.

ATSDR Response
ATSDR considers the available air sampling data sufficient to conclude that the emissions from the Brookfield Avenue Landfill pose no apparent health hazards. It is not possible, however, to draw firm conclusions about past exposures due to the limitations in the data.

Page 9 - Regarding the sentence in the middle of the page, a rewrite is suggested "The modeling results, and the absence of clear significant upward or downward differences...

ATSDR Response
This change has been made in the document.

Page 12 - Regarding the generation and migration of landfill gas, data lead us to believe that the alleged illegal disposal of toxic waste in the landfill is not associated with landfill gas generation to any meaningful extent. The gas likely results from the decaying solid waste. As stated earlier, we have conducted a series of tests that have revealed no significant gas migration away from the landfill. Since March 1999, three additional rounds of soil gas monitoring have been completed. Included in this monitoring were all permanent soil gas probes along the perimeter of the landfill, as well as seven newly installed probes. The new wells were installed in February 1999 near wells where 100% LEL exceedances has previously been recorded. Based on these latest results, there is no evidence of landfill gas migration beyond the perimeter of the landfill. Furthermore, we are proposing a remedy in the Feasibility Study to prevent such an occurrence in the future.

ATSDR Response
ATSDR received the Permanent Soil Gas Probe Results (Rounds 13 - 16) and the accompanying permanent gas probes map and summary of SCG exceedances from Camp Dresser and McKee (CDM) on August 31, 1999. After our review of the data we agree that based on these latest results, landfill gas does not appear to be migrating beyond the site perimeter. This new information is reflected in the final Public Health Assessment Document.

Page 19 - Regarding the detection of arsenic and benzo-a-pyrene in some off-site samples, we believe this is not related to the alleged illegal dumping of toxic material in the landfill.

ATSDR Response
ATSDR investigates all contaminants that exceed its health based comparison values regardless of their source. As explained in the document, the presence of both arsenic and benzo(a)pyrene are not uncommon in an urban environment and were not found at levels associated with doses that would cause adverse health effects.

Page 19- On the topic of hot spots, we wish to clarify that there are not five hot spots. There were five areas that warranted investigation. Of these, it has been determined that two areas are indeed hot spots for which interim remediation is planned or has been implemented. A landfill gas extraction system has been designed to remedy one hot spot. The system includes an enclosed gas flare and extraction wells. At the other, an oil boom has been installed around a seep area and will be maintained until the final remediation plan is implemented.

ATSDR Response
These five areas have been referred to as hot spots in the RI/FS. Community members have also referred to these areas as "hot spots". In order to maintain readability and consistency among the various documents, we will continue to refer to the five areas as "hot spots". However, your clarification is noted.

Page 27 - The feasibility study proposes leachate collection as a final remedy. Therefore, the recommendation to continue perimeter and off-site groundwater monitoring will be eclipsed by a better control remedy.

ATSDR Response
ATSDR agrees that leachate collection is a good control remedy; however, ATSDR recommends perimeter and off-site monitoring continue to ensure the protection of off-site groundwater users.

1. The NYSDEC air guideline values are based on EPA's National Ambient Air Quality Standards.

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