PUBLIC HEALTH ASSESSMENT
CPS CHEMICAL/MADISON INDUSTRIES
OLD BRIDGE TOWNSHIP, MIDDLESEX COUNTY, NEW JERSEY
Figure 2 - Site Location (Detail)
Figure 3 - Monitoring Well Locations
Figure 4 - Groundwater Plume Map
Response Summary
This response summary represents those comments and reactions to the Public Health Assessment received during the Public Comment Period described in the Community Concerns Evaluation section. In some cases, similar commentary was received from various sources, while other concerns are specific to individuals or groups. Comments and concerns have been grouped by content where possible and are followed by the consequent response.
The following comments were received. Only those comments directly relevant to the Public Health Assessment have been addressed:
Comment:
Several comments were received which stated that the Public Health Assessment ignores the fact that there are other sources of contamination of the Perth Amboy well field. Specifically mentioned were: 1) the Evor Philips Superfund site ; and, 2) improper sludge handling practices by the City of Perth Amboy.
Response:
A Site Review and Update (SRU) was prepared by ATSDR (September 3, 1992 and revised December 5, 1995) for the Evor Philips Superfund site. That SRU concluded that the Evor Philips Superfund site was impacting on the Sayreville well field and in fact was having little impact on the Perth Amboy well field.
The theory that improper sludge handling practices by the City of Perth Amboy resulted in additional contamination of the Perth Amboy well field has been discounted (NJDEP Site Manager, Personal communication).
No changes made to Public Health Assessment regarding these issues.
Comment:
The NJDOH received numerous comments regarding Occupational Health and Safety Administration (OSHA) compliance and wanted the Public Health Assessment to reflect that Madison Industries is in full compliance with all OSHA health, safety and personal monitoring requirements.
Response:
Insuring compliance with occupational standards is outside the scope of the ATSDR Public Health Assessment. This document, however, will be shared with occupational agencies by the ATSDR.
Comment:
A respondent suggested the Public Health Assessment more clearly reflect that outside storage piles at Madison Industries were not composed of metals in their purest form, rather that they only contained zinc, lead and cadmium. In addition, it should be noted that the piles have been removed.
Response:
Change made to Public Health Assessment to reflect this comment.
Comment:
A respondent suggested the background section of the Public Health Assessment more clearly note the fact that Madison Industries conducted a Remedial Investigation (RI) at the site.
Response:
Change made to Public Health Assessment to reflect this comment.
Comment:
The respondent has challenged the accuracy of a finding in an old Preliminary Health Assessment (PHA) for the CPS/MI Site was prepared for the Agency for Toxic Substances and Disease Registry (ATSDR), on January 19, 1989. The PHA noted that human exposure pathways were associated with groundwater and surface water at the site. In addition, it noted the sludge piles, if not properly attended, could allow off-site migration of contaminants via erosion and atmospheric dispersion. Potential human exposure pathways to site related contaminants included: ingestion; dermal contact; and inhalation (the volatile components) of groundwater. Also of concern was dermal contact and ingestion of surface water and sediments, and inhalation of particulates originating from the sludge piles on site.
Response:
The NJDOH/ATSDR was not soliciting comments on this document which was written using conditions at the site as they existed over 7 years ago. NJDOH/ATSDR maintain that statements and conclusions in the 1989 PHA are accurate, as written.
Comment:
A respondent suggested the Public Health Assessment note the fact that Madison Industries is completely fenced and provides 24-hour security at the site.
Response:
Change made to Public Health Assessment to reflect this comment.
Comment:
The respondent made several comments that the Public Health Assessment should note the fact that the storage piles, while classified by NJDEP as a hazardous waste, were comprised of "micronutrient fertilizer" which Madison Industries sold to the fertilizer industry. They also wanted it noted that the piles had been removed.
Response:
Change made to Public Health Assessment to reflect that the storage piles, while classified by NJDEP as a hazardous waste, were comprised of "micronutrient fertilizer". In addition, the document already makes reference to the fact that the piles have been removed.
Comment:
A respondent felt that since "no visible signs of terrestrial or aquatic life associated with Prickett's Pond or Prickett's Brook" were observed during our 3/1/95 site visit, ingestion of fish was not possible.
Response:
The NJDOH/ATSDR does not agree that because fish were not observed during a cursory visual inspection of Prickett's Pond and Prickett's Brook, that fishing and ingestion of fish is impossible or unlikely.
Comment:
A respondent made several comments that the Public Health Assessment should note the fact that Perth Amboy well # 5 was used more frequently than indicated in the report.
Response:
Change made to Public Health Assessment to reflect this comment.
Comment:
A respondent was concerned that the Public Health Assessment found that no further action was necessary regarding areas of stressed vegetation and the issue of soluble organics in the groundwater plume at the site.
Response:
When the Public Health Assessment speaks of "no further action" it is referring to health assessment actions of the NJDOH/ATSDR and not remedial actions that are or may be performed by other agencies such as the NJDEP. The NJDOH/ATSDR has recommended that the environmental agency continue to investigate the areas of stressed vegetation. Specifically, recommendation number one (Site Characterization) states: "Investigation should continue in order to determine the cause of the vegetative stress in the noted off-site areas."
Regarding the issue of the soluble organics in the groundwater plume, all of the soluble organic contamination found is within the capture zone of the existing ground water recovery system. In addition, the NJDEP has abandoned plans to recharge treated groundwater into the Runyon Watershed aquifer. This eliminates the possibility that reinjected soluble organics would contaminate the municipal water supply wells.
Comment:
A respondent suggested the background section of the Public Health Assessment more clearly note the fact that Tennant's Pond and Prickett's Pond are within and part of the operation of the Perth Amboy well field not adjacent to it.
Response:
Change made to Public Health Assessment to reflect this comment.
Comment:
A respondent made several comments that the Public Health Assessment should address issues related to the current operations of the two facilities including whether or nor CPS Chemical or Madison Industries have the proper operating permits.
Response:
Operating permit compliance of the two facilities is outside the scope of this Public Health Assessment.
Comment:
A respondent wanted to know "the impact of ½" of the grey dust on the entire site?".
Response:
The Public Health Assessment noted that during our site visit to Madison Industries (1/13/95) much of paved area was covered with a grey paste (up to 1/2" deep). This material was purported to be a mixture of zinc dust and water. No reference was made to ½" of grey dust.
It should also be noted that the grey pasty material has been cleaned up and the Madison Industries facility has a new sweeper to prevent future accumulation (NJDEP Site Manager, Personal communication).
Comment:
A respondent wanted to know the basis for the statement in the Public Health Assessment that noted that many of the metals detected in the soils at CPS Chemical were known to occur naturally in the area.
Response:
The above referenced statement came from the results of the Phase II Remedial Investigation (RI) for the CPS Chemical Site on December 8, 1994. The report was prepared by Dan Raviv Associates, Millburn, New Jersey.
Comment:
A respondent felt that the Public Health Assessment noted there was a break in the berm surrounding the Madison Industries facility, and asked what was the risk associated with this break in the berm.
Response:
The Public Health Assessment does note that at Madison Industries contaminated groundwater appears to be discharging to the southern reach of Prickett's Brook and the northern portion of Prickett's Pond. The contamination measured in surface water and sediment is possibly a combination of discharge from contaminated groundwater and surface run-off. There is, however, no evidence, nor was it stated in the report, that there was a break in the berm. In fact, it was noted during our site visit to Madison Industries (1/13/95) that the area around the operational area appeared to be completely paved and bermed to prevent surface water from leaving the site. In particular, it did not appear that surface water from the bermed area could reach Prickett's Brook.
Comment:
A respondent made numerous related comments regarding the potential health effects of various future scenarios such as: what would the effect of shutting down the air stripping tower?; what would happen if the current use of the watershed property changes?; and, what would happen if recovery well RW-2 malfunctions?
Response:
These types of questions are outside the scope of this Public Health Assessment. As noted in the Recommendations and PHAP sections of the document, certain changes in conditions at the site may determine the need for other additional future actions by the NJDOH/ATSDR.
Comment:
A respondent wanted to know the basis for the statement in the Public Health Assessment that noted that all soluble organic contamination found is within the capture zone of the existing groundwater recovery system.
Response:
The above referenced statement is the result of a careful review of site related documents and through conversations with the NJDEP Site Manager for the CPS/MI site. The CPS/MI groundwater recovery system is currently working as designed, and recovery well PA 6 is acting as a "sink" by collecting the groundwater contamination before it reaches the municipal wells.
Comment:
A respondent wanted to know the timeframe and procedure for response regarding the Public Health Assessment's recommendation that because of potential occupational exposures of site workers to on-site contaminants this site should be referred to the Occupational Safety and Health Administration (OSHA).
Response:
The NJDOH/ATSDR will refer the CPS/MI site to Occupational Safety and Health Administration (OSHA) after finalization of this Public Health Assessment.
