HEALTH CONSULTATION
Follow up Evaluation of Soils at Properties Located Near Raymark Industries Waste Disposal Areas
RAYMARK INDUSTRIES, INCORPORATED
STRATFORD, FAIRFIELD COUNTY, CONNECTICUT
The conclusions and recommendations in this health consultation are based on the data and information made available to the Connecticut Department of Public Health and the Agency for Toxic Substances and Disease Registry. The Connecticut Department of Public Health and the Agency for Toxic Substances and Disease Registry will review additional information when received. The review of additional data could change the conclusions and recommendations listed in this document.
BACKGROUND AND STATEMENT OF ISSUE
In February 2003, the U.S. Environmental Protection Agency (EPA) requested that the Connecticut Department of Public Health (CTDPH) review soil investigations and make public health determinations for four properties in Stratford that were initially investigated by EPA 10 years ago as part of environmental studies of the Raymark Industries disposal sites. CTDPH has already responded to a similar request from EPA to review soil data for 104 properties. CTDPH prepared a health consultation in July 2002 on the review of 104 properties (ATSDR 2002). That health consultation is included in Attachment A and should be referred to for full details on the background and methods for this evaluation.
CTDPH reviewed the files provided by EPA for each of the four properties. The review focused on soil data collected at depth that had not been previously reviewed by CTDPH as part of its original Health Impact Statement.(1) CTDPH evaluated data using the health-based residential property cleanup levels for lead, PCBs, and asbestos developed for Stratford by EPA (ATSDR 2002). The cleanup levels are 400 mg/kg for lead, 1 mg/kg for PCBs, and 1% for asbestos. CTDPH also checked each file to confirm that there was follow up on prior recommendations to collect depth data. A discussion of potential exposure pathways and potential health impacts from exposure to Raymark waste is presented in the Public Health Assessment for the Raymark Industries site (ATSDR 1996). The health basis for the residential property cleanup levels for lead, PCBs, and asbestos is presented in the 2002 health consultation included in Attachment A (ATSDR 2002).
CONCLUSIONS AND RECOMMENDATIONS
CTDPH has reviewed files provided for four properties in Stratford which were identified by EPA as missing final Health Implication Statements. Based on the information provided by EPA, CTDPH has determined that there is no public health threat for each of the following four properties. Recommendations regarding follow up actions are provided below.
50 Clinton Avenue and 1318 Elm Street
Elevated concentrations of lead are present in soils at depth at
these two properties. However, the concentrations do not meet the definition
of Raymark waste (refer to ATSDR 2002 for a definition of Raymark Waste). Therefore,
no further EPA actions are needed. These properties have been referred to the
local health department which will follow up with a letter, reminding residents
about the presence of lead in soils at depth and advising them about ways to
minimize exposure.
800 Housatonic Ave. Extension
Elevated concentrations of lead in surface soils at this property
appear to be related to possible lead paint, rather than Raymark waste. No further
EPA actions are needed. However, this property has been referred to the local
health department for follow up regarding the lead in surface soils.
Fourth Avenue Pond
This property does not have elevated levels of contaminants
in soils. No further actions are necessary.
Public Health Assessment for Raymark Industries, Stratford, Connecticut, Agency for Toxic Substances and Disease Registry, September 25, 1996.
Health Consultation - Evaluation of Soils at Properties Located Near Raymark Industries Waste Disposal Areas, Agency for Toxic Substances and Disease Registry, July 31, 2002.
The Health Consultation for FOLLOW UP EVALUATION OF SOILS AT PROPERTIES IN STRATFORD LOCATED NEAR RAYMARK WASTE DISPOSAL AREAS was prepared by the Connecticut Department of Public Health under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the health consultation was initiated.
Greg V. Ulirsch
Technical Project Officer, SPS, SSAB, DHAC
The Division of Health Assessment and Consultation (DHAC), ATSDR, has reviewed this Health Consultation and concurs with its findings.
Chief, SSAB, DHAC, ATSDR
PREPARER OF HEALTH CONSULTATION
Margaret L. Harvey, MPH
Epidemiologist
Environmental Epidemiology and Occupational Health
Connecticut Department of Public Health
ATSDR Regional Representative:
William Sweet
EPA/New England
ATSDR Technical Project Officer:
Greg V. Ulirsch
Superfund Site Assessment Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry
ATTACHMENT A: HEALTH CONSULTATION: EVALUATION OF SOILS AT PROPERTIES LOCATED NEAR RAYMARK INDUSTRIES WASTE DISPOSAL AREAS - JULY 2002
HEALTH CONSULTATION
Evaluation of Soils at Properties Located Near Raymark Industries Waste Disposal Areas
RAYMARK INDUSTRIES, INCORPORATED
STRATFORD, FAIRFIELD COUNTY, CONNECTICUT
EPA FACILITY ID: CTD001186618 
July 31, 2002
Prepared by:
Connecticut Department of Public Health
Under a Cooperative Agreement with the
Agency for Toxic Substances and Disease Registry
BACKGROUND AND STATEMENT OF ISSUE
CONCLUSIONS AND RECOMMENDATIONS
PREPARER OF HEALTH CONSULTATION
The conclusions and recommendations in this health consultation are based on the data and information made available to the Connecticut Department of Public Health and the Agency for Toxic Substances and Disease Registry. The Connecticut Department of Public Health and the Agency for Toxic Substances and Disease Registry will review additional information when received. The review of additional data could change the conclusions and recommendations listed in this document.
BACKGROUND AND STATEMENT OF ISSUE
In March 2002, the U.S. Environmental Protection Agency (EPA) requested that the Connecticut Department of Public Health (CTDPH) review soil investigations and make public health determinations for approximately 104 properties in Stratford that were initially investigated by EPA ten years ago as part of environmental studies of the Raymark Industries disposal sites. In the early and mid-1990s, EPA conducted site investigation activities at over 500 properties in Stratford that were suspected to have received waste materials from Raymark Industries, Inc. EPA defined Raymark waste as material containing two of three compounds indicative of Raymark materials (lead, polychlorinated biphenyls [PCBs], asbestos) at concentrations exceeding levels of concerns for those compounds (400 mg/kg, 1 mg/kg, 1%, respectively) (Stratford CT Residential Property Investigation and Excavation Protocol, 1994).
At the time the EPA investigations were conducted, CTDPH reviewed data for most of the 500 properties and issued Health Implication Statements for each property. Each Health Implication Statement outlined the public health implications for the specific property and made recommendations for further actions, as needed. For a number of properties, the Health Implication Statement concluded that current conditions posed no health threat but recommended additional sampling to determine the extent of contamination at depth. For most of these properties, additional samples were collected by EPA but a final Health Implication Statement evaluating the depth data and potential future exposures was not issued.
In order to reach closure on the properties identified by EPA as missing final Health Implication Statements, CTDPH was asked by EPA to review soil data for each property and issue a final Health Implication Statement. In providing information to CTDPH, EPA placed each of the properties into one of four categories, depending in part on what the initial Health Implication Statement indicated for the property. The list of properties was provided to CTDPH in tabular form, with each category of properties presented in a separate Table (Table 6a, 6b, 6c, 6d). A file of relevant data was provided for each property. Although the categories are not relevant for the health evaluation per se, CTDPH has retained the categorization scheme developed by EPA for the sake of consistency.
CTDPH reviewed the files provided by EPA for each property. CTDPH's review focused on soil data collected at depth that had not been previously reviewed by CTDPH as part of the initial Health Impact Statement. CTDPH evaluated data using the health-based residential property cleanup levels for lead, PCBs and asbestos developed for Stratford by EPA 1993, in consultation with ATSDR and CTDPH (Stratford CT Residential Property Investigation and Excavation Protocol, 1994). The cleanup levels are 400 mg/kg for lead, 1 mg/kg for PCBs and 1% for asbestos. CTDPH also checked each file to confirm that there was follow up on recommendations made to collect depth data. If depth data were never collected, CTDPH reevaluated the need for collecting such data.
A discussion of potential exposure pathways and potential health impacts from exposure to Raymark waste is presented in the Public Health Assessment for the Raymark Industries site (ATSDR 1996). The health basis for the residential property cleanup levels for lead, PCBs and asbestos is presented in three ATSDR Records of Activity (ATSDR 9/8/93; ATSDR 11/10/93; ATSDR 9/30/97).
CONCLUSIONS AND RECOMMENDATIONS
CTDPH has reviewed files provided for approximately 104 properties in Stratford which were identified by EPA as missing final Health Implication Statements. Based on the information provided by EPA, CTDPH has reached the following conclusions regarding public health implications from exposure to soils at these properties.
Health Implication Statements
Based on the information provided by EPA, CTDPH has determined that the properties listed in Appendix A to this health consultation pose no public health threat at this time. No further actions are needed at this time for the properties listed in Appendix A.
For the following two properties, CTDPH has concluded that there is no public health threat at this time. However, CTDPH recommends that if digging is anticipated, depth sampling will be necessary to determine if a health threat could be created.
Condo Association Property/4th Avenue Empty Lot (EPA Table 6a)
605 Broad Street/CT Business Institute (EPA Table 6a)
For the following two properties, CTDPH has concluded that there is no public health threat at this time. Some depth sampling has been conducted at these properties but it is insufficient to support a conclusion about public health threat. Therefore, CTDPH recommends that if digging is anticipated, more extensive depth sampling will be necessary to determine if a health threat could be created.
50 Clinton Avenue (EPA Table 6d)
1318 Elm Street (EPA Table 6c)
Properties listed in Appendix B are those properties which CTDPH referred to the Local Health Department after EPA sampling found lead without either of the other two constituents indicative of Raymark waste. Lead may be present because of lead-based paint and will be investigated as such. CTDPH is working with the local health department to confirm that all necessary public health actions were taken at these properties. CTDPH will report to EPA on the status of these properties when the followup work has been completed.
Agency for Toxic Substances and Disease Registry Record of Activity, September 8, 1993.
Agency for Toxic Substances and Disease Registry Record of Activity, November 10, 1993.
Agency for Toxic Substances and Disease Registry Record of Activity, September 30, 1997.
Public Health Assessment for Raymark Industries, Stratford, Connecticut, Agency for Toxic Substances and Disease Registry, September 25, 1996.
Stratford Connecticut Residential Property Investigation and Excavation Protocol, August 30, 1994.
APPENDIX A: PROPERTIES THAT CTDPH HAS DETERMINED POSE NO PUBLIC HEALTH THREAT AT THIS TIME AND NO FURTHER ACTIONS ARE NECESSARY
|
PROPERTIES IN EPA TABLE 6a |
PROPERTIES IN EPA TABLE 6c |
PROPERTIES IN EPA TABLE 6d |
APPENDIX B: PROPERTIES THAT WERE REFERED TO THE LOCAL HEALTH DEPARTMENT FOR FOLLOW UP BECAUSE OF LEAD
PROPERTIES IN EPA TABLE 6b
48 Blakeman Place
106 Blakeman Place
146 Blakeman Place
80 Clinton Avenue
750 East Broadway
1618/1620 Elm Street
1 Harris Court
390 Patterson Avenue
640 Stratford Avenue
The Health Consultation for SOILS AT PROPERTIES LOCATED NEAR RAYMARK INDUSTRIES WASTE DISPOSAL AREAS was prepared by the Connecticut Department of Public Health under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the health consultation was initiated.
Gregory V. Ulirsch
Technical Project Officer, S.P.S., SAAB, DAC
The Division of Health Assessment and Consultation (DAC), ATSDR, has reviewed this Health Consultation and concurs with its findings.
Roberta Erlwein
Chief, SAAB, DAC, ATSDR
PREPARER OF HEALTH CONSULTATION
Margaret L. Harvey, MPH
Epidemiologist
Environmental Epidemiology and Occupational Health
Connecticut Department of Public Health
ATSDR Regional Representative:
William Sweet
EPA/New England
ATSDR Technical Project Officer:
Greg V. Ulirsch
Superfund Site Assessment Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry
