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Congressional Testimony
ATSDR's Progress in Meeting Congressional Mandates
Testimony by
Barry L. Johnson, Ph.D.
Assistant Surgeon General
Assistant Administrator
Agency for Toxic Substances and Disease Registry
Public Health Service
U. S. Department of Health and Human Services
Before the
Subcommittee on Investigations and Oversight
Committee on Public Works and Transportation
House of Representatives
June 9, 1992
As part of our briefing, we will respond to your request to describe the Agency's public health assessment process, our relationship with EPA, and the role state and local health agencies play in determining the risk posed by Superfund sites. We will close our testimony by commenting on improvements in health assessments.
The Agency for Toxic Substances and Disease Registry (ATSDR) was created by the Superfund legislation in 1980 (more formally known as the Comprehensive Environmental Response, Compensation and Liability Act, or CERCLA). Our understanding of the Congressional intent in creating ATSDR was to establish an independent health and science advisor for EPA, the States, and of course Congress, concerning the public health hazards associated with Superfund sites and emergencies involving hazardous substances. Moreover, we consider communities around Superfund sites to be our primary constituencies. Specifically we were charged in 1980 with determining the relationship between exposure to toxic substances and human illness, in addition to such specific activities as creating an exposure and disease registry, an inventory of health information on toxic substances, a listing of sites closed to the public because of toxic contamination, and providing medical assistance in public health emergencies involving toxic substances.
The 1986 Superfund Amendments gave ATSDR greater responsibilities in several areas. We were mandated to provide public health assessments of all National Priorities List (NPL) sites, with the added provision for follow-up health activities such as health studies, health surveillance, or registries as needed. We were also given responsibility for determining which substances posed the greatest health hazard and for writing toxicological profiles for each of those substances. As a consequence of writing these profiles we were also charged with determining where there were major gaps in information about the health effects of these substances, and for establishing an applied research agenda to fill the most critical information needs. Finally, we were also given the task to develop educational materials for health professionals, primarily physicians, concerning the diagnosis and treatment of patients exposed to toxic substances.
Over time, additional legislation has added to the authorities of ATSDR. The Resource Conservation and Recovery Act Amendments of 1985 mandated us to conduct public health assessments at RCRA sites at the request of EPA, states, or individuals. The Medical Waste Tracking Act of 1988 directed us to prepare a Report to Congress on the Health Effects of Medical Waste. The Great Lakes Critical Programs Act directs us to collaborate with EPA to conduct a study on the health effects from eating contaminated sport fish from the Great Lakes.
We have successfully undertaken all of the mandates given us over the short ten years of our existence. I would like to briefly outline some of our accomplishments in ATSDR's major program areas:
PUBLIC HEALTH ASSESSMENTS: One of our most important activities is to conduct public health assessments at all Superfund sites. These assessments are an evaluation of data and information on the release of hazardous substances into the environment to 1) assess any current or future impact on public health, 2) develop health advisories or other health recommendations, and 3) identify studies or actions needed to evaluate and mitigate or prevent human health effects.
Public health assessments of the original 951 NPL sites were completed by the congressionally mandated deadline of December 10, 1988. Since that time, ATSDR has revised its format for conducting public health assessments to put a much heavier emphasis on the collection and evaluation of health data of the population living around each site. Since January, 1989 the Agency has completed more than 350 additional public health assessments. Many of ATSDR's public health assessments are done under cooperative agreement by state health departments. Currently, ATSDR funds 23 states (covering approximately 80% of all NPL sites) to draft public health assessments which are then reviewed and approved by Agency staff. This partnership with state health departments enables us to greatly increase our output while at the same time strengthening needed expertise in the states.
These public health assessments have proved valuable in determining the potential or actual public health threat posed by these sites. For example, of the 80 public health assessments completed last fiscal year, 47% were deemed to pose a public health hazard, 37% were judged to pose an indeterminate health hazard, and the remaining l6% had no apparent or no health hazard. Hazards described in the public health assessments potentially affected approximately l,600 persons per site (with a range of fewer than l5 people to as many as 47,500 people affected by individual sites).
There were more than 400 recommendations contained in the completed 80 public health assessments done in the last fiscal year; more than 90% of which were accepted by EPA; 47% of the recommendations were for further, off-site environmental characterization; and 25% of the recommendations involved preventing human exposure to site contaminants. Other recommendations included actions such as additional on-site environmental characterization and follow-up health activities.
In the past year, ATSDR has committed a large portion of our staff to conducting public health assessments at federal facilities. In fiscal year 1991, ATSDR conducted site visits for 96 Department of Defense NPL sites, and initiated drafts of public health assessments for 16 of those sites thought to present the greatest health threat. In seven of these 16 sites groundwater was found to be the most serious threat of human exposure, with more than 120,000 people having water supplies contaminated with volatile organic compounds.
A mechanism exists whereby the public may directly petition ATSDR to conduct a public health assessment at a site that is not a part of the NPL. To date, the Agency has been petitioned 190 times to conduct these public health assessments. The Agency was petitioned by a member of Congress in 27 of these requests. Seventy-two petitions have been accepted, 41 rejected, and 77 are pending a site visit to determine whether to accept the petition.
HEALTH INVESTIGATIONS: Another significant mandate for ATSDR is to increase our understanding of the relationship between exposure to hazardous substances and adverse human health effects through epidemiologic, surveillance and other studies of toxic substances and their effects.
To date, ATSDR has initiated 93 separate health studies. An additional 20 health studies are planned for registry sites. These health studies, conducted by ATSDR staff or supported by ATSDR funding, have yielded important findings -- both documenting adverse health outcomes and documenting the lack of adverse health problems.
For example, our study at the California Gulch site in Leadville, Colorado revealed that the average blood lead level of children aged 6 months to 6 years old was almost twice the average level of children at high risk of lead exposure in Denver.
Another study sponsored by ATSDR of workers and their families at the Olin Chemical Company in Charleston, Tennessee found high (though not toxic) mercury exposure among the families of workers, with some causes found to be from contaminated clothing from the factory, housekeeping activities, and household air concentrations.
A study of heavy metal exposure in the Globeville, Colorado area identified 50 children with abnormal initial cadmium urine levels that are now being followed up with medical monitoring.
ATSDR conducted an arsenic exposure study in conjunction with the Harris County Health Department in the area around the Crystal Chemical site in Houston, Texas. The study found 3 of 5 children under 10 years of age with urine arsenic levels above 50 mg/g of creatinine (a level indicating exposure had occurred). Following clean-up efforts by EPA, the children were retested several months later and all were found to have urine arsenic levels well below 50 mg/g.
Other studies' results alleviated fears that adverse health effects were occurring. For example, findings from three lead exposure studies completed last year in Alabama, Colorado, and Pennsylvania found that children around a site in each state had mean blood lead levels below the Centers for Disease Control's level of concern. However, these studies yielded significant new information about the importance of correlating blood lead levels with lead levels in the home environment, and confirmed the fact that exposure to lead continues to be an important public health problem due to extensive amounts of contamination from multiple sources. (ATSDR's 1988 Report to Congress on The Nature and Extent of Lead Poisoning in Children in the United States indicates that 3 to 4 million children are at risk of adverse health effects from lead poisoning).
The national extent of adverse human health effects associated with hazardous wastes in the environment remains unknown. ATSDR commissioned a study by the National Research Council (NRC) to assess the published scientific literature on health effects of hazardous wastes. The NRC in their 1991 report Environmental Epidemiology: Public Health and Hazardous Wastes concluded "Although current public health burdens from hazardous-waste sites appear to be small, the future risk might be greater insofar as materials already in the groundwater can migrate into areas where exposure potential is greater. ... Despite the lack of adequate data with which to characterize the effects of hazardous wastes on public health in general, the committee does find sufficient evidence that hazardous wastes have produced serious health effects in some populations. We are concerned that populations may be at risk that have not been adequately identified. ..."
EXPOSURE AND DISEASE REGISTRY: One of the original mandates for ATSDR was to establish and maintain a registry of persons exposed to hazardous substances and a registry of serious diseases and illnesses in persons exposed to hazardous substances in the environment.
After very careful planning, with significant public involvement, ATSDR began its exposure registry effort in 1989. Since then, ATSDR, in conjunction with affected state health departments, has established 3 national exposure subregistries for people exposed to 1) trichloroethylene (TCE) in well water, 2) dioxin in soil, and 3) benzene in drinking water. The TCE and benzene subregistries each contain nearly 5,000 people exposed to these substances. Overall, the voluntary participation rate for these subregistries has averaged 99% -- a phenomenally successful response rate. These subregistries allow us to pool data from several states to give us critical information about the health consequences of low-level, long-term exposures to select hazardous chemicals identified at Superfund sites.
EMERGENCY RESPONSE: Through ATSDR's consultation and emergency response program we provide health-related support to states, local agencies, and health care providers in public health emergencies involving exposure to hazardous substances, including health consultations on request and training for first responders.
Nine states have now joined with ATSDR in compiling an important database of emergency surveillance which will enable us to analyze and describe the risk factors associated with emergency events involving toxic chemicals, and develop strategies to reduce subsequent morbidity and mortality. Reports for 1990 and 1991 showed that approximately 17% of all emergency events resulted in at least one person being injured. There appears to be no difference in the likelihood of injuries when multiple chemicals are released compared with events in which only one chemical is released. First responders sustained approximately 20% of all injuries. This is of concern, since this group should be the best trained and equipped of the potentially exposed population.
ATSDR has played a major role in the removal and response actions conducted by EPA and the U.S. Coast Guard, which has led to health advisories, exposure studies, and the relocation of residents The public health impact of this emergency response service is significant.
An example of ATSDR's activities occurred at the Forest Glen site in New York. This Niagara Falls community consisted of 51 mobile homes with about 150 residents, including one family which had been displaced years ago from Love Canal. Before Forest Glen became a mobile home park during the late 1970s and early 1980s, the area had been used as a landfill for chemical waste containing hazardous substances (e.g., aniline, phenothiazine, benzothiazole). Residents reported seeing discharges of resinous materials on the surface of the ground, and high concentrations of contaminants were detected in surface soils.
ATSDR and the New York State Health Department found several actual and potential health hazards at this site. Normal daily activities of residents, such as gardening or playing in the yard, led to contact with contaminated soil which could result in adverse health effects (allergic contact dermatitis, phototoxic skin reactions, and cancer). The physical stability of the landfill was uncertain, and the public water supply was at risk of being contaminated under certain conditions. Because of the urgency of health risks at this site, ATSDR issued a preliminary health assessment for the site on July 21, 1989 and a public health advisory ten days later, both recommending that residents of this mobile home park be relocated immediately and that the site be added to the NPL.
In response to these recommendations, EPA and the Federal Emergency Management Agency (FEMA) temporarily relocated Forest Glen residents and started a voluntary buy-out program for their mobile homes when Forest Glen was added to the NPL.
ATSDR has sponsored emergency response training for state and local health officials for several years at the Louisville/Jefferson County Demonstration Program. Since 1987, this program has provided training to 2,100 persons covering such issues as contingency planning, toxic emergency health management, necessary responder equipment, and public affairs.
TOXICOLOGICAL PROFILES: In addition to identifying the most hazardous substances, ATSDR was directed by Congress to prepare toxicological profiles on these substances which summarize and make available to the public data on the health effects of hazardous substances, identify significant gaps in knowledge, and initiate research in toxicology and health effects where needed.
To date, final or draft toxicological profiles are available for 130 hazardous substances. Nearly one million copies of these toxicological profiles have been distributed for use by EPA, State and local officials, academia, and the public.
The impact and wide external use of the toxicological profiles have exceeded original expectations. ATSDR staff, state, and local health agencies, and EPA staff all report that the toxicological profiles are extremely helpful sources of information for addressing site-specific health concerns. Numerous colleges and universities, as well as safety, health, and training consultants, have used the toxicological profiles as course material for toxicology classes. Several national and international organizations, including the International Programme on Chemical Safety and the Pan American Health Organization, have used the toxicological profiles as the key resource for preparing their own documents.
HEALTH EDUCATION: Another of ATSDR's mandates is to develop and disseminate to physicians and other health care providers materials on the health effects of toxic substances, establish and maintain a publicly accessible inventory of hazardous substances, and maintain a list of sites closed or restricted to the public because of hazardous substance contamination.
One of the most successful series of documents that ATSDR has produced is the Case Studies in Environmental Medicine. These self-study courses designed for practicing physicians guide the reader through the diagnosis and treatment of illness related to exposure to a specific hazardous substance.
In the last fiscal year alone, more than 75,000 case studies were disseminated. The American Academy of Pediatrics mailed the self-instructional case study on lead toxicity to its membership of more than 30,000. These case studies are also being used to develop environmental health courses and curricula. The Mayo Clinic, which has the largest medical residency program in the United States, announced plans to use these case studies in the training of all residents. Several dozen other residency programs are also using the case studies.
ATSDR also works closely with state health departments in developing educational materials for health care professionals. During the last fiscal year 20 state departments of health or environment were given cooperative agreements to develop such programs, and together trained more than 3,700 health professionals during the course of the year.
APPLIED RESEARCH: The last major mandate of ATSDR is to conduct or sponsor research to increase scientific knowledge about the effects on human health of hazardous substances released from waste sites or of other releases into the environment.
ATSDR has two major efforts underway in applied research. The first is for substance-specific research. In October 1991, The Agency announced in the Federal Register approximately 140 data needs for an initial 38 priority substances. These priority data needs represent essential information required by ATSDR and state agencies to perform public health assessments of persons at risk of exposure to substances released from hazardous waste sites. Research to fill these data needs will contribute to determining the types and/or levels of exposure that may present significant risks of adverse health effects in humans exposed to the subject substances. ATSDR anticipates, as directed by the 1986 amendments to Superfund, that many of the individual priority data needs will be referred to EPA for pursuit under the Toxic Substances Control Act. Additionally, Congress directed $4 million be provided to the Association of Minority Health Professions Schools for research grants to fill data needs.
ATSDR is also focusing research on 7 priority health conditions that are considered most important for evaluation by public health officials for populations living near hazardous waste sites. These 7 conditions are: birth defects and reproductive disorders, cancer (selected sites), immune function disorders, kidney dysfunction, liver dysfunction, lung and respiratory disease, and neurotoxic disorders.
I would now like to turn to the issues raised by the committee regarding ATSDR's overall relationship with EPA, and the specific distinctions between the ATSDR public health assessment and the EPA risk assessment.
The relationship that exists between ATSDR and EPA is one of both sharing common goals and complementing the missions of one another through activities that are specific to each. There are numerous program areas where the sharing of information between ATSDR and EPA is evident. ATSDR has developed HAZDAT, a scientific and administrative database on the release of hazardous substances from Superfund sites or from emergency events and on the health effects of hazardous substances on human populations. We worked with EPA in developing this database, and plan to make the data available to EPA and others.
The working relationship between ATSDR and EPA is greatly enhanced by the placement of ATSDR regional representatives in all EPA Regional Offices. There are currently at least two, and in some regions three, ATSDR representatives co-located with EPA personnel. These regional representatives provide a critical link and liaison not only with EPA personnel and programs, but with state departments of health and state environmental agencies.
Another important aspect to the working relationship between ATSDR and EPA is the establishment of the Mid-Level Managers' Forum. Both EPA and ATSDR have supported and participated in this group for the past three years. This quarterly forum is made up of managers from each agency and regional staff. The purpose of the forum is to allow the two agencies to discuss site-specific issues and accompanying policies and procedures.
The importance and necessity of this forum has increased in recent months due to ATSDR's desire to make its public health assessments of more use to EPA. Toward that end, the Mid-Level Managers' Forum has undertaken a needs assessment of EPA staff to determine the answers to such questions as:
In the coming months, the forum will be working to identify needs and develop specific strategies to address identified EPA needs.
Before discussing the respective characteristics of the ATSDR public health assessment as compared to the EPA risk assessment, I think it would be helpful to define more precisely what the ATSDR public health assessment is.
An ATSDR public health assessment gathers information about hazardous substances at a site and evaluates whether exposure to those substances might cause harm to people. Public health assessments consider: what the levels of chemicals are at the site; whether people on or near the site might be exposed to the substance and how; what harm the substance at the site might cause to people; and whether working or living near the site might affect people's health.
To make these determinations, ATSDR looks at three primary sources of information:
The public health assessment is, of course, very important to ATSDR for the identification of appropriate public health follow-up. The public health assessment advises EPA and states on actions to reduce or prevent possible exposure to hazardous substances. They are also used to develop Public Health Advisories and other recommendations to protect the public's health. Possible public health actions that can be recommended through the public health assessment process include:
An ATSDR public health assessment of a waste site is different from an EPA risk assessment for the same site. ATSDR's is a qualitative assessment, while EPA's is quantitative. It is our view that these two kinds of assessment complement each other, each serving a useful purpose to their parent agency. Thus, the key differences between the public health assessments and risk assessments can be summed up in five areas.
First, the ATSDR public health assessment is qualitative, site-specific and uses environmental contamination as well as health outcome, and community health concerns data. The EPA risk assessment is quantitative, compound-oriented and does not utilize community health concerns data.
Second, the public health assessment weighs medical and public health perspectives to assess health hazards while the risk assessment uses statistical and/or biologic models to calculate numerical estimates of health risks.
Third, the public health assessment is used to evaluate human health impact and to identify public health interventions, whereas the risk assessment is used to facilitate remediations or other risk management actions.
Fourth, the public health assessment may lead to pilot health effects studies, surveillance, epidemiologic studies, or exposure registry activity. The Risk Assessment may lead to the selection of a particular type of remediation measure at a site.
Finally, the ATSDR public health assessment is advisory, while the EPA Risk Assessment has regulatory authority.
The Crossley Farms site in Berks County, Pennsylvania illustrates how the public health assessment process both assists EPA in their work and derives an outcome that is exclusive to the work of ATSDR.
There were reports dating back to the mid-1960's from this site that barrels of industrial waste were illegally dumped into an abandoned quarry. Groundwater had been contaminated and trichloroethylene (TCE) and tetrachloroethylene (PCE) had also been detected. The private wells of some of the approximately 250 people living downgradient from the site were contaminated.
In 1986, EPA asked ATSDR to prepare a health consultation concerning TCE contamination at the site. ATSDR recommended discontinuing use of contaminated water, and conducting further sampling of potentially contaminated private wells.
A regional groundwater investigation was begun, and in 1991 the site was listed on the National Priorities List. As a result of this listing, ATSDR began the public health assessment process in September of 1991. ATSDR recommended further sampling of wells, which was conducted by EPA in October and November of 1991.
Because 15 residential wells showed contamination at levels greater than EPA's safe drinking water level, ATSDR decided to include persons living around the site on ATSDR's TCE exposure subregistry. This population has now been surveyed and is a part of this subregistry. ATSDR has also recommended health education for health professionals in the community and for the community itself.
In 1986, ATSDR was given a very important mandate to conduct public health assessments of NPL sites and respond to petitions for health assessments. The Government Accounting Office, in a 1990 study of the Agency's health assessments, criticized ATSDR for uneven quality and questionable usefulness of the health assessments to EPA. We agree with most of GAO's criticisms, and have improved the quality and timeliness of our health assessments. ATSDR recognizes the principal improvement remaining to be made in our work with EPA is to get involved earlier in the site investigation. Earlier involvement would permit ATSDR's consultation on site priorities, intervention in community health problems, and provide health advice on remedial technologies. Both ATSDR and EPA are seeking ways to achieve this earlier involvement of ATSDR on site investigations.
To conclude my testimony, I would like to outline for the subcommittee ATSDR's activities at the three sites in which you have expressed interest - Smuggler Mountain, White Chemical and Taracorp.
Smuggler Mountain, Aspen, Colorado
In 1986 EPA requested that we review the Remedial Investigation/Feasibility Study (RI/FS) and
the Endangerment Assessment (EA) and make recommendations to correct possible adverse
public health effects to residents living near the Smuggler Mountain Site, Pitkin County,
Colorado.
We were subsequently asked to review a risk assessment conducted by EPA that focused on airborne particulates that could result during remedial activities at the site. The EPA risk assessment addressed potential risks to a sensitive subpopulation (children less than 7 years of age) from exposure to lead via the inhalation route. Specifically, we were asked to determine if the critical action level of total suspended particulates was protective of public health. Our determination was that the action level chosen by EPA was, in fact, protective of human health.
Following the public health assessment process, ATSDR began a Smuggler Mountain lead exposure study. The Smuggler Mountain lead exposure study consisted of three phases. Phase I included the development of community relations conducive to the accomplishment of the study objectives. Phase II consisted of a complete census of all individuals residing within the site boundaries. Phase III entailed the collection of biological specimens and questionnaire data from a subset of individuals identified in Phase I.
During the 1980's, high concentrations of lead were documented in the soil and mine tailings on the Smuggler Mountain Superfund site. Concerns about the possible exposure of individuals, especially children, to the lead prompted a health study to assess the extent of lead exposure. The primary objective of the study was to determine whether the Smuggler Mountain Superfund site residents had elevated blood lead levels. Other objectives were to determine the factors (environmental, behavioral, socioeconomic) which contributed to lead exposure in this community, and to compare the results of this study to other mining sites.
There were no cases of lead poisoning in children less than 6 years of age as defined by the current (1991) Centers for Disease Control criteria for lead poisoning. One adolescent had a blood lead level which was within the Colorado Department of Health range of concern (10 to 15 mg/dl). The arithmetic mean blood lead level for children from 6 months through 6 years of age was 3.0 mg/dl (median 2.55) and 2.5 mg/dl for children from 6 through 14 years of age (median 2.0). Blood lead levels for children had a range from <1 mg/dl to 13.4 mg/dl (median 2.2). The arithmetic mean soil lead concentration for children's yards (children <6 years of age) was 1,370 parts per million (ppm) with a range from 135 to 11,676 ppm (geometric mean of 641 ppm and median of 660 ppm). An increase in blood lead level in children was not seen with a corresponding increase in soil lead concentrations.
Several factors, such as not washing the child's hands before eating and allowing pets to go in and out of the home explained 36% of the variability in the observed blood lead levels of children less than 6 years of age.
ATSDR concluded that:
The following recommendations are proposed based on findings suggested by this study:
NL Industries/Taracorp NPL Site, Granite City, Illinois
The Taracorp Lead Site is an NPL site on which ATSDR completed a public health assessment in 1989. The site contained a waste pile, composed of blast furnace slag, lead bearing fines in 55-gallon drums, and battery case material. Groundwater in the vicinity of the site was contaminated with elevated levels of sulfates, dissolved solids, and manganese. The waste piles on site were sampled; analyses revealed elevated levels of lead, arsenic, copper, and iron.
ATSDR concluded that this site was considered to be of public health concern because of the risk to human health caused by the likelihood of exposure to hazardous substances via inhalation, ingestion, and direct contact exposures to contaminated soil. There was also the possibility that the human population in the area was being exposed via ingestion of contaminated groundwater. Currently the Illinois Department of Public Health, under a Cooperative Agreement with ATSDR, is preparing an updated public health assessment.
This site is one of several sites being studied as part of the multi-state lead study. ATSDR along with the Illinois Department of Public Health collected blood samples from 1,000 residents for lead analysis. Preliminary results indicated elevated levels in a few residents, but no clear pattern of elevated rates. It is possible that the elevated blood lead levels may be attributable to lead-based paint in residential units.
The purpose of this study was to measure evidence of biological exposure to lead and cadmium through analysis of blood and urine, and to determine blood lead levels for children. Children between the ages of 9 months and 6 years old and all pregnant women were the primary focus of the study. Eligible participants were selected from a 60 square block target area where soil lead concentration is greater than 500 parts per million. Approximately 800 people from the target and comparison areas participated in the study. Data management and laboratory analysis is continuing.
These two sites that I have just discussed are examples of ATSDR work at sites that were listed on the NPL and in need of remedial action. In contrast, the White Chemical Site is an example of how ATSDR health advice to EPA initiated emergency removal action to protect public health, but also led to the listing of the site on the NPL.
White Chemical Company, Essex, New Jersey
On September 27, 1990, the EPA Region II Office requested that ATSDR review information and data regarding the White Chemical Company Site in Newark, New Jersey, and to characterize the threat to the public health posed by the site. ATSDR responded to this request by providing EPA with a health consultation. We concluded that the threat of catastrophic release posed by the uncontrolled storage of hazardous substances and conditions of ongoing release at the White Chemical Company site posed an imminent and substantial threat to the public's health.
ATSDR determined that a public health advisory was warranted for the White Chemical Company Site. The public health advisory was issued to alert EPA, the State of New Jersey, and the public of a serious threat to human health from a threatened catastrophic release of hazardous substances. On the basis of the ATSDR public health advisory, EPA was able to "quick-list" the site.
The White Chemical Company Site is located on approximately 4 acres of land in a heavily populated residential and industrial area of Newark, New Jersey. Approximately 12,000 people are estimated to live and work within a 1/4 mile radius of the site. The Newark International Airport is within 1 mile of the site. Immediately west and adjacent to the site are a feather bedding manufacturer and a sportswear manufacturer that collectively employ approximately 225 individuals. Within 1/4 mile of the site is a public park and several large housing projects. Immediately north of the site another garment manufacturer employs approximately 200 workers. To the east and adjacent to the site is a major commuter rail line.
The New Jersey Department of Environmental Protection had requested that EPA assess the site for Comprehensive Environmental Response Compensation and Liability Act (CERCLA) removal consideration. The EPA noted the presence of approximately 9,000 drums, several hundred cylinders and tanks, fiberpacks, carboys and several hundred lab size containers, improperly stored and precariously stacked throughout the four acre site. Drums and other containers were reported to be in varying stages of deterioration and leaking onto pallets, other containers, and the soil. The chemicals reported to be stored on-site included flammable liquids (toluene and xylene), oxidizers, corrosives (hydrobromic acid, hydrochloric acid, phosphoric acid, phosphorus tribromide, hydriatic acid, sulfuric acid), acid chlorides (capryloyl chloride, pivaloyl chloride, valaroyl chloride), and a variety of organic acids. Storage of these chemicals was reported to be without regard to chemical compatibilities. Most of the chemicals are stored outside without protection from weathering.
Based on our observations of storage conditions on-site, and the presence of large quantities of reactive chemicals, improperly segregated, and in badly deteriorated containers, ATSDR concluded that:
ATSDR recommended that EPA:
The Administrator, EPA Region II, initiated a Removal Action under the authority of CERCLA. ATSDR continues to coordinate with EPA and other Federal health agencies regarding the site. Most recently, the ATSDR assisted EPA contract workers in obtaining information on the potential effects of bromide after an accidental release at the site.
ATSDR has assisted the EPA in their community public relations efforts at this site. The combined efforts of ATSDR and EPA have led to an increased credibility of federal agencies among the affected communities.
Mr. Chairman, this concludes my testimony. My colleagues and I will be pleased to answer any questions about the Agency.
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