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1. ATSDR > Public Health Assessments & Consultations

Figure 1.

Figure 2.

Figure 3.

Figure 4.

Figure 5.

Figure 5A.

Figure 6.

Figure 7.

Figure 8.

Figure 9.

Adapted from: Scrudato, R.J. et al.; undated.

Table 2.

The following table 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,
MS E-56
1600 Clifton Road NE, Atlanta, Georgia 30333

Source: Adapted from URS Company, Inc.; January 1988.

*Contaminant selected for further evaluation.
**Indicates that this compound was not detected in other samples collected.
+No distinction between either 1,1,1-trichloroethane or 1,1,2-trichloroethane was indicated in the data reported.

Source: URS Company, Inc.; January 1988.

Notes: + Data were reported in units of milligrams per liter (mg/L) or milligrams per kilogram (mg/kg). However, for the data reviewed, no distinction was made between those results reported as mg/L or mg/kg.
¹BHC = hexachlorocyclohexane
²PCB = polychlorinated biphenyls

Source: URS Company, Inc.; January 1988.

Notes: Reported results for metals are based on wet weight analysis. To maintain consistency among the units referenced throughout this public health assessment, the concentrations listed in this table were converted from reported units of micrograms per gram to milligrams per kilogram.

Source: Golder Associates, Inc.; August 1993.

Notes:	+	=	does not include levels reported at estimated concentrations.
	D	=	indicates concentration calculated from secondary dilution.
	B	=	indicates compound found in associated quality control method blank

Source: de maximus, Inc.; September 1992

Blank space indicates "not reported over the detection limit."

Refer to Figure 6 (Appendix A) for sample locations (leachate collection wells [LCW] 1 and 2).

Source: Adapted from URS Company, Inc.; January 1988.

Note: Reported results are for a dryweight basis. To maintain consistency among the units referenced throughout this public health assessment, the concentrations listed in this table were converted from reported units of micrograms per gram for metals and nanograms per gram for organic compounds to milligrams per kilogram.

Source: Golder Associates, Inc.; August 1993.

Notes: + does not include estimated concentrations as reported in the Final Supplemental Remedial Investigation Report.

Source: Adapted from URS Company, Inc.; January 1984.
*Contaminant selected for further evaluation.

Source: URS Company, Inc.; January 1988.

Notes: Blank space indicates "not detected".
*Contaminant selected for further evaluation

Source: Golder Associates, Inc.; August 1993.

Notes: + does not include data reported as estimated concentrations below the detection limit as reported in the Final Supplemental Remedial Investigation Report
J indicates estimated concentrations above detection limit

Source: Adapted from URS Company, Inc.; January 1984.

Source: URS Company, Inc.; January 1985.

Notes: Blank space indicates "not detected".

Source: Golder Associates, Inc.; August 1993.

Notes: + does not include estimated concentrations below the detection limit or other laboratory qualified data as reported in the Final Supplemental Remedial Investigation Report.
Blank space indicates "not detected".

Source: Adapted from URS Company, Inc.; January 1984.

Source: Golder Associates, Inc.; August 1993.

Notes: + does not include estimated concentrations reported below the quantitation limit.
Blank space indicates "not detected".

Source: Golder Associates, Inc.; August 1993.

Notes:	+	does not include estimated concentrations below the detection limit as reported in the Final Supplemental Remedial Investigation Report. Concentrations reported are for dissolved phase only.
	-	indicates "not detected".
	J	indicates estimated concentration

Source: Adapted from URS Company, Inc.; January 1984.

Source: Golder Associates, Inc.; August 1993.

Notes: + does not include estimated concentrations below the detection limit as reported in the Final Supplemental Remedial Investigation Report

Source: Adapted from URS Company, Inc.; January 1984.

*Contaminant selected for further evaluation.

Source: Adapted from URS Company, Inc.; January 1984.

Source: Golder Associates, Inc., August 1993.

Notes: + does not include data reported as estimated concentrations or qualified as being found in the associated laboratory method blank.
D indicates concentration calculated from secondary dilution
¹DDE = 4,4'-dichlorodiphenyldichloroethene

Source: Golder Associates, Inc.; August 1993.

Notes: + does not include data qualified as "estimated".

Source: URS Company, Inc.; January 1988.

Notes:	1dichlorodiphenyltrichloroethane
	2dichlorodiphenyldichloroethane
	3dichlorodiphenyldichloroethene
	4beta-hexachlorocyclohexane

Adapted from: Toxic Chemical Release Inventory (TRI), Calendar Year 1992.

Note: All emissions data reported in pounds/year (lbs/yr).
      # Indicates estimated worst case emissions based on reported data.

*Comparison values for noncancer risk from organic chemicals are determined for a 21 kilogram child whose arms, hands, legs, feet and trunk are exposed to surface water for 1 hour per day, 2 days per week for 3 months per year and who swallows 0.05 liters of surface water per day, 2 days a week for 3 months per year. Noncancer comparison values for metals are determined for a 21 kilogram child who swallows 0.05 liters of surface water per day, 2 days a week for 3 months per year. Cancer comparison values for organic chemicals are determined for a 70 kilogram adult whose arms, hands, legs, feet and trunk are exposed to surface water for 1 hour per day, 2 days per week for 3 months per year and who swallows 0.05 liters of surface water per day, 2 days a week for 3 months per year. Cancer comparison values for metals are determined for a 70 kilogram adult who swallows 0.05 liters of surface water per day, 2 days a week for 3 months per year.

**EPA CPF = US EPA Cancer Potency Factor
EPA RfD = US EPA Reference Dose
EPA HEAST = US EPA Health Effects Assessment Summary Tables
ATSDR MRL = ATSDR Minimal Risk Level
NYS RfG = NYS Department of Health Risk Reference Guideline

*Cancer and noncancer comparison values for organic chemicals are determined for a 70 kilogram adult whose arms and hands are exposed to leachate for 1 hour per day, 2 days per week for 6 months per year and who swallows 0.05 liters of leachate per day, 2 days a week for 6 months per year. Cancer comparison values for metals are determined for a 70 kilogram adult who swallows 0.05 liters of leachate per day, 2 days a week for 6 months per year.

**EPA CPF = US EPA Cancer Potency Factor
   EPA RfD = US EPA Reference Dose
   EPA HEAST = US EPA Health Effects Assessment Summary Tables
   NYS CPF = NYS Department of Health Cancer Potency Factor
   NYS RfG = NYS Department of Health Risk Reference Guideline

The following section 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,
MS E-56
1600 Clifton Road NE, Atlanta, Georgia 30333

To evaluate the potential health risks from contaminants of concern associated with the Pollution Abatement Services (PAS) site, the New York State Department of Health assessed the risks for cancer and noncancer health effects.

Increased cancer risks were estimated by using site-specific information on exposure levels for the contaminant of concern and interpreting them using cancer potency estimates derived for that contaminant by the US EPA or, in some cases, by the NYS DOH. The following qualitative ranking of cancer risk estimates, developed by the NYS DOH, was then used to rank the risk from very low to very high. For example, if the qualitative descriptor was "low", then the excess lifetime cancer risk from that exposure is in the range of greater than one per million to less than one per ten thousand. Other qualitative descriptors are listed below:

An estimated increased excess lifetime cancer risk is not a specific estimate of expected cancers. Rather, it is a plausible upper bound estimate of the probability that a person may develop cancer sometime in his or her lifetime following exposure to that contaminant.

There is insufficient knowledge of cancer mechanisms to decide if there exists a level of exposure to a cancer-causing agent below which there is no risk of getting cancer, namely, a threshold level. Therefore, every exposure, no matter how low, to a cancer-causing compound is assumed to be associated with some increased risk. As the dose of a carcinogen decreases, the chance of developing cancer decreases, but each exposure is accompanied by some increased risk.

There is general consensus among the scientific and regulatory communities on what level of estimated excess cancer risk is acceptable. An increased lifetime cancer risk of one in one million or less is generally considered an insignificant increase in cancer risk.

For noncarcinogenic health risks, the contaminant intake was estimated using exposure assumptions for the site conditions. This dose was then compared to a risk reference dose (estimated daily intake of a chemical that is likely to be without an appreciable risk of health effects) developed by the US EPA, ATSDR and/or NYS DOH. The resulting ratio was then compared to the following qualitative scale of health risk:

Noncarcinogenic effects unlike carcinogenic effects are believed to have a threshold, that is, a dose below which adverse effects will not occur. As a result, the current practice is to identify, usually from animal toxicology experiments, a no-observed-effect-level (NOEL). This is the experimental exposure level in animals at which no adverse toxic effect is observed. The NOEL is then divided by an uncertainty factor to yield the risk reference dose. The uncertainty factor is a number which reflects the degree of uncertainty that exists when experimental animal data are extrapolated to the general human population. The magnitude of the uncertainty factor takes into consideration various factors such as sensitive subpopulations (for example, children or the elderly), extrapolation from animals to humans, and the incompleteness of available data. Thus, the risk reference dose is not expected to cause health effects because it is selected to be much lower than dosages that do not cause adverse health effects in laboratory animals.

The measure used to describe the potential for noncancer health effects to occur in an individual is expressed as a ratio of estimated contaminant intake to the risk reference dose. If exposure to the contaminant exceeds the risk reference dose, there may be concern for potential noncancer health effects because the margin of protection is less than that afforded by the reference dose. As a rule, the greater the ratio of the estimated contaminant intake to the risk reference dose, the greater the level of concern. A ratio equal to or less than one is generally considered an insignificant (minimal) increase in risk.

The enclosed pages have been copied from the March 1992 Public Health Assessment Guidance Manual (U.S. Department of Health and Human Services, 1992) and summarize the criteria that are evaluated when assigning a public health hazard category to a site.

This responsiveness summary was prepared to address comments and questions on the draft Public Health Assessment (PHA) for the Pollution Abatement Services (PAS) site. The public was invited to review this document during the public comment period which ran from October 19, 1995 to December 1, 1995. Public review comments were received by only one party. Similar comments were consolidated or grouped together. Some statements were reworded to clarify the comment. If you have any questions about this responsiveness summary, contact the New York State Department of Health's (NYS DOH) Health Liaison Program at the toll-free number 1-800-458-1158, extension 402.

Comment #1

Any references and discussion of the NYS DOH cancer investigation at the Eastside Wastewater Treatment Plant (EWTP) should be deleted. This cancer investigation is not related to the PAS Oswego site and it should not be discussed in the PHA. Any reference to the EWTP as being near the PAS site should be deleted because the EWTP has nothing to do with the PAS site.

Response #1

As stated in the NYS DOH report "Incidence of Cancer Among Workers in the Eastside Sewage Treatment Plant," the major concern of the person who requested the study was the possibility of a cancer excess among Eastside Plant workers that might be due either to the processing of industrial wastes or to the location of the plant near the Pollution Abatement site. The Public Health Assessment Guidance Manual (ATSDR, March 1992), states that "the health assessment is an evaluation of relevant environmental data, health outcome data and community concerns associated with a site where hazardous substances have been released." Health outcome data are community specific and may include medical records, morbidity and mortality data, tumor and disease registries, birth statistics and surveillance data. The NYS DOH considers the cancer incidence study among workers in the Eastside Treatment Plant as relevant health outcome data related to past community concerns about the PAS site. The text has been revised to clarify that the cancer incidence study was completed in response to community concerns. These changes have been made in the Summary, Background (subsection B - "Actions Completed During the Public Health Assessment Process" and subsection E - "Health Outcome Data") and the Conclusions sections.

Comment #2

Clarify the time period that the site may have posed a public health hazard in the past. Does the statement "Past remedial actions have eliminated the potential for exposure to contaminants on-site" refer to the time period before 1986, when the New York State Department of Environmental Conservation (NYS DEC) completed construction of the on-site containment system?

Response #2

The text has been revised to clarify the time period that the site posed a public health hazard in the past. The statement, "Past remedial actions have eliminated the potential for exposure to contaminants on-site," is a general conclusion of the PHA. This statement refers collectively to the remedial actions that were completed at the site between 1977 and 1995 to minimize, reduce or eliminate exposure to site contaminants. The Site Description and History section of the PHA includes discussions of the various remedial actions that were completed at the site.

Comment #3

The conclusion that on-site workers were most likely exposed to on-site wastes at levels of public health concern is unsubstantiated and should be deleted. The conclusion that on-site workers, residents and people working near the site were most likely exposed to contaminants in air should be deleted as there is insufficient information to characterize these past exposures. The use of "likely" or "most likely" should be avoided in the discussions of completed exposure pathways for wastes and leachate, surface soil and air without appropriate documentation to support such statements.

Response #3

As discussed in the Environmental Contamination and Other Hazards section of the PHA, (subsection A - On-Site Contamination), contaminants were detected in samples collected from the on-site waste lagoons in 1977 as well as in liquid waste and sludge samples collected between December 1985 and August 1986 from the on-site underground storage tanks. The Background section of the PHA discusses that (subsection A - Site Description and History), PAS operated a chemical waste incinerator at the site from 1970 to 1977 and liquid wastes were collected and stored on-site in drums, open lagoons and above ground storage tanks. NYS DOH representatives who visited the site in 1979 (subsection C - Site History) found drums that were punctured, leaking and unsealed at the PAS site; chemical odors were noted and leachate was visible. Consistent with ATSDR guidelines and the Public Health Assessment Guidance Manual, NYS DOH has evaluated available historical information about past site operations, site conditions and contaminant concentrations from sampling data to characterize an exposure pathway that probably existed in the past.

Comment #4

The draft PHA states that "If remedial measures are not taken to address groundwater contamination, people who install and use private wells downgradient of the site could be exposed to contaminants at levels of public health concern." The draft PHA does not properly characterize potential groundwater remediation issues at the site associated with the US EPA's 1993 Record of Decision (ROD). Based on studies required by and performed subsequent to the 1993 ROD, US EPA and the NYS DEC determined that remediation of groundwater downgradient of the site was not required. Furthermore, the 1993 ROD requires that institutional controls be placed on properties downgradient of the site. The potential for installation of any new private wells downgradient of the site would be eliminated by these controls. The reference to additional remedial measures being required to prevent off-site contamination of groundwater is misleading and suggests that additional remedial actions need to be taken when US EPA and NYS DEC have determined that additional actions are not required.

Response #4

The text has been revised (Background section).

Comment #5

The draft PHA indicates that people could be exposed to contaminants in surface water and sediment during recreational use of White and Wine Creeks and Lake Ontario. Currently, Roux and Associates is performing an investigation under US EPA guidance to identify all potential sources of surface water and sediment contamination identified in White and Wine Creeks near the PAS site. Any discussion of sediment contamination or possible exposure to contaminants in sediment and surface water in the creeks should be qualified to include data collected at other nearby sites.

Response #5

The text clearly states that contaminants in surface water and sediments may be from sources upgradient of the site. The text has been revised to clarify that a supplemental pre-remedial design study was completed to evaluate contaminants in surface water and sediments in nearby creeks and wetlands. The NYS DOH reviewed the findings of this study which are included in this revised PHA.

Comment #6

Any conclusion or implication that people could be exposed to contaminants in Lake Ontario from the site should be deleted as there is no supporting documentation. This statement is also inconsistent with the conclusion that: "Currently, the site poses no apparent public health hazard."

Response #6

The text has been revised.

Comment #7

The cause of the reduced fish populations is discussed in the draft PHA (page 9, paragraph 4) as part of the findings of the 1984 RI. Without supporting data, it is uncertain that the reduced fish population was site-related, especially considering the other potential source areas near the PAS site. We are not aware of any subsequent fish population studies in the area and, this discussion should be clarified to indicate that the source associated with any reductions in fish populations identified in the 1984 RI is unknown. The discussion should also reflect whether an appropriate reference site was used in the study.

Response #7

The text has been revised. A discussion of the findings and uncertainties of these findings is included in the Environmental Contamination and Other Hazards section of the PHA (subsection B - Off-Site Contamination) under the heading "Biota".

Comment #8

The second sentence of paragraph two on page 12 should be revised as follows: "Prior to May 1991, during the period in which NYS DEC operated the containment system, periodic overflows of the slurry wall occurred near slurry wall wells (SWW) 11 and 12."

Response #8

The text prior to this statement has been revised to clarify that NYS DEC operated and maintained the leachate collection system between 1986 and October 1991.

Comment #9

The discussion (in paragraph 4 on page 12) of the Phase I supplemental pre-remedial design study that was completed in January 1995 should include a clarification of the objectives of the Phase I study to be consistent with the 1993 ROD. The PHA should reference the decision by the US EPA and the NYS DEC that pumping of the bedrock aquifer downgradient from the site was not required, based on their review of the Phase I study results.

Response #9

The text has been revised (Background section) in accordance with similar concerns expressed in Comment #4.

Comment #10

Paragraph 5 on page 18 should be qualified to include a discussion which indicates that the option of using the EWTP for treatment of leachate from the PAS site has since been eliminated from further consideration and that no wastes of any kind from the PAS site have ever been sent to the EWTP for treatment.

Response #10

The text has been revised to eliminate the discussion of non-health related concerns since they were addressed in a responsiveness summary to the Record of Decision.

Comment #11

The discussion about the results of the groundwater investigation performed during the supplemental pre-remedial design study (SPRDS) in paragraph 2 on page 23, does not properly characterize the scope of that investigation (i.e., the number of bedrock wells sampled, etc.). This investigation was the basis for the US EPA and NYS DEC decision that remediation of groundwater downgradient of the site is not necessary.

Response #11

A discussion of the scope of the supplemental pre-remedial design study is included in the Background section of the PHA (subsection A - Site Description and History). The discussion of off-site groundwater contamination (subsection B - Off-Site Contamination) has been revised to reflect that off-site monitoring wells (MW) OD4, MW21, MW23, MW24, MW25 and MW26 were also sampled. The on-site monitoring wells that were sampled are identified in subsection A - On-Site Contamination, under the heading "Groundwater".

Comment #12

The discussion of iron and manganese concentrations detected in private well samples in the Smith's Beach area (Environmental Contamination and Other Hazards section, subsection B, Off-Site Contamination) should be clarified to describe that these constituents are naturally occurring and not related to the PAS site. The initial detection of acetone in a well sample, which was not duplicated in the follow-up sampling, should be qualified as a lab artifact.

Response #12

The text has been revised to reflect that iron and manganese occur naturally in groundwater. The presence of iron and manganese at elevated levels in this well is attributed to local geologic conditions. The NYS DOH Wadsworth Center for Laboratories and Research did not report the occurrence of acetone in this water sample as a laboratory artifact nor was it reported as laboratory-introduced contamination. The text has been revised to reflect that acetone was initially reported at 11.0 micrograms per liter (mcg/L), which is slightly above the analytical detection limit of 10.0 mcg/L and that this result may have been a laboratory artifact.

Comment #13

The discussion of potential exposure to contaminants in air is misleading and implies that site workers may not follow the health and safety requirements contained in the approved US EPA workplan for conducting site remedial operations. We are not aware of any information that suggests that workers may still be exposed to site contaminants as stated in the PHA. The PHA should qualify such statements and reference the basis of these inferences.

Response #13

The text has been revised to clarify that the site has been remediated and that exposure to contaminants in air at the site is limited. The text also discusses that use of appropriate work practices and personal protective equipment in accordance with the site-specific health and safety plan will minimize possible exposure to VOCs in air by on-site workers.

Comment #14

The discussion of "Data Gaps" in paragraphs 1 and 2 on page 33 indicates that insufficient information exists to evaluate possible exposures to contaminants in soil gas or surface soils at the site that may have occurred in the past. This discussion contradicts statements elsewhere in the PHA referring to past exposures that "likely" or "most likely" occurred at the site.

Response #14

There is no information about contaminants in soil gas at or near the site, before it was capped. The PHA does not characterize past exposure(s) to soil gas as a completed, potential or eliminated pathway. As discussed in the Pathways Analysis section (Completed Exposure Pathways subsection), past exposures to surface soils by people working at or visiting the site are believed to have occurred based on observations of site conditions by NYS DOH personnel during past site visits. The text has been revised to clarify the basis for this comment.

Comment #15

In paragraph 3 on page 33, it is stated that "...exposures to contaminants in air at and near the site are believed to have occurred." Without proper technical justification, such statements should be deleted.

Response #15

The text has been revised throughout the document to clarify the basis for this statement. Also refer to the response to Comment #3.

Comment #16

The elevated manganese concentrations detected in private wells is not related to the PAS site and is very likely due to naturally occurring constituents in groundwater. There is no basis to discuss exposure to manganese in the draft PHA for this site and this discussion should be deleted.

Response #16

The text has been revised to reflect that iron and manganese occur naturally in groundwater and that the concentrations detected in private wells may reflect local geologic conditions. The discussion on manganese exposures has been eliminated.

Comment #17

The NYS DOH procedure for evaluating potential health risks for contaminants of concern is extremely conservative and should be deleted. According to the NYS DOH risk ranking procedure in Appendix D, a high risk is equivalent to one in a thousand to one in ten risk. This risk range is substantially higher than the total groundwater cancer risk estimate for the residential reasonable maximum exposure (RME) of 2.1 x 10^-4 calculated in the baseline risk assessment by US EPA. This discrepancy is due to the use of the maximum concentrations of benzene and vinyl chloride by the NYS DOH instead of the upper confidence limit (UCL) used in the baseline risk assessment.

Response #17

This discussion has been eliminated.

Comment #18

The draft PHA should serve as a tool for risk communication. NYS DOH has not included any description of uncertainties with the results of the draft PHA, therefore the reliability of these findings are unknown.

Response #18

The Conclusions section of the PHA has been revised to reflect information about data gaps and insufficient information related to the PHA. We also recognize the limitations of risk assessment methodology and the text and Table 28 have been revised to reflect assumptions about past exposures to contaminants in leachate and on-site waste lagoons. Appendix D of the PHA (NYS DOH Procedures for Evaluating Potential Health Risks for Contaminants of Concern) includes a discussion of the uncertainties related to estimates of cancer risk and non-carcinogenic health effects.

Comment #19

The discussion of public health concerns regarding potential ingestion, dermal and inhalation exposure to inorganic contaminants in drinking water (Public Health Implications section, subsection A, Toxicological Evaluation) should consider that compounds such as manganese, iron, magnesium and sodium in area soils, groundwater and surface waters are naturally occurring.

Response #19

This discussion has been eliminated from the text.

Comment #20

The discussion of past potential ingestion, dermal and inhalation exposures of workers and trespassers at the PAS site to leachate and waste lagoons should be revised to reflect more realistic assumptions that can be technically supported and documented. The discussion of chronic exposures in the past to the highest contaminant concentrations detected in on-site waste lagoons and leachate seeps does not properly characterize past exposures, if any.

Response #20

Our response to Comment #3 includes a discussion for the basis of characterizing these past exposures. Our response to Comment #18 includes a discussion of the NYS DOH procedures for evaluating potential health risks. Please refer to those responses. Also, Table 28 which provides health comparison values for workers exposed to wastes in the lagoons has been revised to reflect more realistic exposure scenarios.

Comment #21

The statement, "Currently the site poses no apparent public health hazard", should be presented as the first and foremost conclusion of the draft PHA.

Response #21

The text has been revised.

Comment #22

The recommendation in paragraph 3 on page 39 should also reference the decision by US EPA and NYS DEC that remediation of groundwater in the bedrock aquifer downgradient of the site is not necessary. This decision is based on the results of the Phase I supplemental pre-remedial design investigation completed in 1995.

Response #22

This information is included in the Background and Conclusions sections of the PHA. The purpose of the recommendations section of the PHA is for:

1. implementing actions to protect public health;
   
2. obtaining additional health information;
   
3. conducting public health actions; and
   
4. obtaining additional site characterization information.

Agency for Toxic Substances and Disease Registry, 1825 Century Blvd, Atlanta, GA 30345
Contact CDC: 800-232-4636 / TTY: 888-232-6348 

Department of Health and Human Services