# Public Health Advisory

E.C. ELECTROPLATING

(a/k/a GARFIELD CHROMIUM GROU NDWATER CONTAMINATION SITE)



## GARFIELD, BERGEN C OUNTY, NEW JERSEY

EPA FACILITY ID: NJD002006773

SEPTEMBER 29, 2010

U.S. DEPARTMENT OF HEAL TH AND HUMAN SERVICES

Agency for Toxic Substances and Disease Registry

Division of Health Assessment and Consultation

Atlanta, Georgia 30333

## Table of Contents

Introduction (Statement of Purpose)

........................................................................................... .... 1

Background

.................................................................................................................... ................. 2

Basis for the Public Health Advisory

........................................................................................... ... 3

Public Health Implications of Completed Exposure Pathways

...................................................... 6

Noncancer Health Effects—Incident al Ingestion of Surface Dust

............................................. 6

Low Use Basements

............................................................................................................. ... 6

High Use Basements

............................................................................................................ ... 7

Cancer Health Effects - Incident al Ingestion of Surface Dust

.................................................. 10

Low-Use Basements

............................................................................................................. 10

High-Usage Basements

......................................................................................................... 11

Inhalation Exposure Evaluation

............................................................................................ 12

Dermal Exposure Evaluation

................................................................................................ 12

Conclusions

................................................................................................................... ................ 12

Recommendations

............................................................................................................... .......... 13

Public Health Action Plan

..................................................................................................... ........ 14

References

.................................................................................................................... ................. 16



## Tables and Figures

Table 1 : Summary of Hexavalent Chromium Concentrations in Wipe Samples

........................... 3

General Exposure Assumptions............................................................................19

Location Specific Assumptions: Low Usage Scenario for Basements................................19

Location Specific Assumptions: High Usage Scenario for Basements...............................20 Photograph 1 : Photo taken by U.S. EPA Region 2 On Scene Coordinator of basement where

maximum detection of hexavalent chromium oc curred. The yellow staining indicates chromium

precipitate

................................................................................................................... ..................... 5

Photograph 2 : Another photo ta ken by U.S. EPA Region2 OSC of adjoining room in basement

where maximum detection of hexavalent chromium occurred. This area of the basement has a

couch (bottom of photo), air c onditioner, and paneling.

................................................................. 5

Table 2 : Comparison of Ingested Exposure Dose to Hexavalent Chromium (Cr +6 

### ) in Surface

Dust with Health Guideline Comparison Valu es (CVs) for Noncancer Health Effects

................. 8

Table 3 : Calculated Lifetime Excess Cancer Ri sk Based on Ingestion Exposures to haxavalent

Chromium (Cr +6 

### ) in Surface Dust..........................................................................11

Appendix A. Noncancer Exposure Assumptions......................................................

.. 18

Cancer Exposure Assumptions...........................................................................

.. 21

## Introduction (Statement of Purpose)

On July 21, 2010, the United States Environm ental Protection Agency (EPA) advised

both the New Jersey Department of Health and Senior Services (NJDHSS) and the Agency for

Toxic Substances and Disease Registry (ATSDR) th at they had preliminar y data indicating that

elevated levels ( 2 ,640,000 micrograms per square meter (μg/m 2 

### )) of hexavalent chromium were

found in a basement at a mixed use (comme rcial/residential) property near the E.C.

Electroplating site in Garfie ld, New Jersey. On August 5, 2010, U.S. EPA provided ATSDR and

NJDHSS with the validated data. That data provide d a basis for a health consultation as well as

an evaluation of the public health implications of exposures to hexavalent chromium in surface

dust. 1



### ATSDR has determined that the current exposures emanating from or near the E. C.

Electroplating site warrant the issuance of a P ublic Health Advisory. U.S. EPA found that

groundwater contaminated with high levels of hexavalent chromium had entered the basements

of some of the properties locate d above a contaminated groundwater plume. The one basement at

the mixed-use property referenced above contai ned highly elevated le vels of hexavalent

chromium. Thus ATSDR and NJDHSS concluded that children and adults accessing any

property basements in the area of the E.C. Elect roplating site were and still are exposed to

hexavalent chromium in surface dust at levels th at may pose an immediate and significant threat

to human health. If actions are not taken, these exposures will likel y continue in the future. Note

that people can be exposed to the harmful le vels of hexavalent ch romium by accidentally

swallowing and inhaling contaminated dust.

The observed concentration of hexavalent ch romium in basement dust at the mixed-use

property where the maximum level was detected es tablishes the presence of an urgent public

health hazard. In addition, while not all properties within the plum e area have been evaluated, the

finding of a high concentration of hexavalent chro mium in basement dust at this one property is

an indicator that all residences in the immediate vicinity have bee n, are presently, or in the future

will be at risk of contamination. The degree of th at contamination could pose a significant health

risk to residents, whether the base ment is frequently used (high-us e) or lesser used (low-use).

ATSDR and NJDHSS recommend that U.S. EPA ta ke short- and long-term measures to

dissociate persons—whether in residential or co mmercial properties in the area of the

contaminant plume—from hexavalent chromium exposures resulting fr om infiltration of

contaminated groundwater into the basements of these properties. Acting on ATSDR’s and

NJDHSS’s recommendation, U.S. EPA has already taken steps to remediate the one property

where the highest levels of surface-dust hexavale nt chromium were found in the basement.

Over the longer term, however, U.S. EPA should move to remediate permanently the

source of the hexavalent chromium in the Garf ield, NJ area groundwater-c ontamination plume.

1 The interpretation, advice, and recommendations provided in this public health advisory are based on the data and

information evaluated and referenced here and in the NJDHSS health consultation prepared under cooperative

agreement with ATSDR (ATSDR 2010b). The conclusions, recommendati ons, and public health actions in this

advisory are site-specific and are not intended as generally applicable to any other situation.

1

### In the absence of a permanent solution, all residents within th at groundwater contamination

plume could continue to be exposed to hexavale nt chromium. And that exposure could be at

levels that present an immediate and significan t health threat. Until a permanent groundwater

contamination solution is in place, the U.S. EPA should continue with actions to prevent

hexavalent-chromium contaminated groundwater from entering any and all residences within the

groundwater plume.



## Background

The E.C. Electroplating site (a.k.a. Garfield Chromium Groundwater Contamination site)

is located at 125 Clark Street in Garfield, Bergen County, New Jers ey. The site occupies a 3⁄4 acre

(approximate) parcel in a mixed residential and commercial area of Garfield. In December 1983,

approximately 3,640 gallons of chromium pla ting solution (chromic acid) containing 5,441

pounds of chromium were discharged from a pa rtially below-ground storage tank. In response,

five monitoring wells and one recovery well we re installed to monito r groundwater and to

recover discharged product. Background reports indicate that by May 1984, 1,044 gallons of

product and 1,600 pounds of chromium were recove red. The tank leak and subsequent spill of

chromic acid solution likely impacted the overburden and bedrock aquifers.

In May 1985, the New Jersey Department of Environmental Protection (NJDEP) allowed

E.C. Electroplating to cease contaminant rec overy efforts. Rather, NJDEP directed E.C.

Electroplating to seal four of the groundwater wells and to continue groundwater monitoring

from two on-site wells. E.C. Electroplating, however, failed to comply with this monitoring

directive. In June 1993, chromium-contaminated groundwater and crystals were discovered in

the basement of the nearby Garfield Fire House #3. The fire house was subs equently taken out of

service. In November 1993, NJDEP and E.C. El ectroplating entered into a Memorandum of

Agreement to comply with regulatory investig ation requirements, including full delineation of

the chromium-contaminated groundwater plume (NJDEP 2002a). Between November 1994

through April 2000, four groundwater monitoring we lls were installed to comply with the

agreement’s delineation requirements. As of April 2000, groundwater samples at one on-site

monitoring well indicated maximum concentrations of total chromium and hexavalent chromium

at 1,500,000 and 1,490,000 micrograms per liter ( μ g/L), respectively (NJDEP 2002b).

The groundwater sampling results prompted an additional, October 2000 investigation

that revealed chromium-contaminated groundwat er within the basement sumps of several

residences and commercial properties in the i mmediate vicinity of the discharge site. In

September 2002, the NJDEP issued a Notice of Viol ation to E.C. Electroplating for failing to

comply with continued investigation and for fa iling to initiate remedi al actions. The company

cited financial difficulty as the reason for its inability to conduc t continued remedial

investigations and actions. Also in October 2002, the NJDEP reque sted that U.S. EPA evaluate

the site. 2

2 In addition to E.C. Electroplating, U.S. EPA is inves tigating other potential sources of chromium that may have

contaminated groundwater. Th ese potential sources include a nearby tannery, a chemical plant, and another

electroplating facility within the Garfield area (USEPA 2008).

2

### In September 2007, in response to a request by U.S. EPA Region 2, NJDHSS and

ATSDR completed a health consultation for the Ga rfield, New Jersey, E.C. Electroplating site.

The September 2007 health consultation was base d on limited environmenta l data; the health

consultation, however, did recommend additiona l sampling to better assess potential public

health threats to residents in the vicinity of the site (ATSDR 2007).

In April 2010, NJDHSS and ATSDR completed an additional site health consultation.

This consultation assessed poten tial hexavalent chromium expos ures to area residents based on

U.S. EPA Region 2’s 2009 sampling investigat ions (ATSDR 2010a). The April 2010 health

consultation conclude d in part that

 Because of ingestion of hexavalent chromium dust in limited-use basements, a public

health hazard exists;

 If any of the basements with high levels of hexavalent chromium were used more

frequently, an urgent public health ha zard could exist in the future; and

 Ingestion of dust from the Roosevelt Elem entary School was not expected to harm

people’s health.

During February and March 2010, the U.S. EPA collected dust-wipe samples from a total

of 92 residential/commercial pr operties (USEPA 2010a). In July 2010, the U.S. EPA collected

dust-wipe samples from an addi tional 13 residential/commercial properties (USEPA 2010b). The

U.S. EPA identified these proper ties for evaluation based on re sident survey responses and

property location in relation to the contaminated groundwater plume. The purpose of the

investigations was to determine whether hexava lent chromium in groundwater had affected the

interior of these basements. An NJDHSS health consultation evaluated these most recent data,

and that health consultation forms the basis fo r this public health a dvisory (ATSDR 2010b).



## Basis for the Public Health Advisory

Concentrations of hexavalent chromium were detected in surface dust within 41 sampled

basements. The detections ranged from 1 to 2,640,000 micrograms per square meter (μg/m 2 

### ).

The following table summarizes the 2010 inve stigation dust-wipe sampling results:

Table 1: Summary of Hexavalent Chromium Concentrations in Wipe Samples

U.S. EPA Investigations: Februa ry, March, June and July 2010

Sample

Locations Number of

Samples Number of

Detections Number of

Residences with

Detections Range of Detected

Concentrations

(μg/m 2 )

105 properties 405 65 41 1

– 2,640,000

ug/m2= micrograms per meter squared.



### 3

### The method for assessing the presence of a heal th hazard in a community is to determine

whether a completed exposure pathway connects a contaminant source to a receptor population,

and whether exposures to that co ntamination are sufficiently high to be of health concern. As

described in the April 2010 Hea lth Consultation (ATSDR 2010a), an exposure pathway was and

is complete for ingestion of—and dermal c ontact with—surface dust containing hexavalent

chromium. The recent basement data confirm the existence of this pathway for the 41 properties

evaluated during the February through July 2010 inve stigation. Exposed persons may include

children and adults occupying or working in struct ures identified as c ontaminated. In addition,

anecdotal evidence suggests that residents may periodically use a broom to sweep up the yellow

chromium crystals. If surface crystals are di sturbed and become airborne, inhalation of

hexavalent chromium becomes a potential exposur e pathway. Persons exposed in this pathway

may also include children and adul ts living or working in structures identified as contaminated.

In this health advisory, basement usage at sa mpled residences is characterized as either

“high use” or “low use.” The general assumption is that the high-use category is applied to

basements that serve as an extra living space an d where area usage would be intensive (e.g., for

playing, sleeping, working) and on a daily basi s. For the low-use category, the general

assumption is that these are basements used only intermittently (e.g., for laundry or storage).

Given these high-use and low-use exposure scen arios, site-specific exposure doses were

calculated and compared with health guideline comparison values (CVs) as shown in Table 2.

U.S. EPA data verify that contaminated groundw ater can infiltrate into basements. That

contaminated groundwater can then leave behind a high-level residue of hexavalent chromium in

surface dust and crystals. The maximum concentra tion of hexavalent chromium detected in

surface dust was 2,640,000 μg/m 2 

### in the mixed-use, low-use basement identified by U.S. EPA

(see Photographs 1 and 2 below). This detected he xavalent chromium value was used to evaluate

exposure scenarios for both high- and low-use basements for properties within the immediate

vicinity of the E.C. Electroplating site. Because the basements of properties in the immediate

vicinity of this property fall within varying degr ees of both high- and low-use scenarios, we used

the maximum concentration.

Environmental sampling can only show contam inant concentration at a point in time.

Resident actions such as cleani ng can influence sampling results in ways that could lead to an

underestimation of actual exposures and risks. Furthermore, high concentrations may recur

following new water infiltration events. In this area of Garfield NJ, water infiltration events are

common. Therefore, all properties in the vicinity of the E.C. Electro plating site are considered at

risk of similar concentrations in basement surface dusts. Conservatively estimated, 15 to 20

unsampled properties are within in the immediate vicin ity of that part of the groundwater plume

area exhibiting the highest concentrations of hexavalent chromi um in groundwater.

4

### Photograph 1: Photo taken by U.S. EPA Re gion 2 On Scene Coordinator of basement

where maximum detection of hexavalent chromi um occurred. The yellow staining indicates

chromium precipitate.

Photograph 2: Another photo taken by U.S. EPA Region2 OSC of adjoining room in

basement where maximum detection of hexavalen t chromium occurred. This area of the

basement has a couch (bottom of ph oto), air conditioner, and paneling.

5

## Public Health Implications of Completed Exposure Pathways

Appendix A contains the site-specific exposure assumptions (USEPA 1997; 2003; 2008)

used to calculate exposure doses to child and ad ult residents and to adul t employees. Appendix

A also contains a statement regarding the uncer tainty introduced by the assumptions used in

calculating the non-cancer dose from incidental i ngestion of surface dust from the formula used

in the U.S. EPA World Trade Center Indoor Environment Assessment study (USEPA 2003).

Noncancer Health Effects—Incident al Ingestion of Surface Dust

Exposure dose estimates were calculated using the exposure assumptions outlined in the

April 2010 health consultation. For this evaluati on, we used the maxi mum concentration of

hexavalent chromium detected in surface dust at 2,640,000 μg/m 2 

### the mixed-use, low-use

basement target property. That concentration wa s then used to construc t exposure scenarios for

both high- and low-use basements for properties within the immedi ate vicinity of the target

property. We used the maximum concentration because the basements of properties in the

immediate vicinity of this property and the groundwater “hot-spot” area fall within high or low

usage. Moreover, U.S. EPA data verify that contaminated groundwater can infiltrate into

basements and leave behind very high levels of he xavalent chromium residue in surface dust. As

stated, environmental sampling can only show the concentration of a contaminant at a point in

time, and resident actions such as cleaning can influence sampling results. These conditions,

then, could lead to an underest imation of actual exposures and risks. Furthermore, following new

water infiltration events, high con centrations may recur. In suppor t of this assumption, the three

residences, previously evaluated in the April 2010 health consultation, within the groundwater

“hot-spot” plume area showed that concentrations of hexavalent chromium in surface dust had

created conditions in which exposure doses could exceed the margin of safety represented by the

chronic and intermediate health CVs. Additionally and as discusse d further in this document, the

most recent U.S. EPA sampling results show that exposure doses for one of these three

properties also exceeded the chro nic, intermediate, and acute lo west-observed-adverse-effect

levels (LOAELs) based on recent animal studies. From a public health standpoint, exceeding the

LOAEL is important—it represents a level at whic h harmful (adverse) health effects have been

seen in either animals or humans.

Low-Use Basements

Hexavalent Chromium. The intermediate oral ATSDR Minimal Risk Level (MRL) for

hexavalent chromium is 0.005 milligrams of cont aminant per kilogram of body weight per day

(mg/kg/day). That MRL is based on the health eff ect of microcytic, hypochromic anemia in male

rats intermediately exposed to sodium dichromate dihydrate in drinking water for 22 days to 6

months. An uncertainty factor of 100 and the Benchmark Dose Level (BMDL) 2sd 

### of 0.52

mg/kg/day were used to calcu late the intermediate oral MRL (ATSDR 2008; NTP 2008). The

chronic oral MRL for hexavalent chromium of 0.001 mg/kg/day is based on the health effect of

diffuse epithelial hyperplasia of the duodenum observed in male and female mice chronically

exposed to sodium dichromate dihydrate in drin king water for 1 to 2 years. The chronic oral

MRL was calculated using an uncerta inty factor of 100 and the BMDL 10 

### of 0.09 mg/kg/day

(ATSDR 2008; NTP 2008).

6

### Given the maximum concentration of hexavale nt chromium detected in surface dusts, the

exposure dose calculated for ch ildren (1–6 years) at 0.54 mg/kg/ day, children (1–18 years) at

0.31 mg/kg/day and adults at 0.25 mg/kg/day sign ificantly exceeded the margin of safety

represented by the ATSDR intermediate a nd chronic MRLs of 0.005 and 0.001 mg/kg/day,

respectively (see Table 2 below). They also met or exceeded effect levels shown in animal

studies, as detailed below.

Compared with toxicological studies, th e calculated exposure doses based on the

maximum hexavalent concentration in surface dust

 Exceed the lowest-observed-adverse-effect level (LOAEL) of 0.38 mg/kg/day in female

mice and are near the LOAELs of 0.77 and 1.4 mg/kg/day in male rats and female mice

for intermediate exposures known to cause hematological effects (NTP 2008);

 Exceed the LOAEL of 0.38 mg/kg/day fo r chronic exposures known to cause

gastrointestinal and hepa tic effects in male and female mice (NTP 2008); and

 Exceed the benchmark dose level (BMDL 10 

### ) of 0.09 mg/kg/day for chronic exposures

known to cause diffuse epithelial hyperplasia of the duodenum observed in male and

female mice (NTP 2008).

We cite the three intermediate LOAELs to provide the range of exposure doses wherein

health effects were observed for the specific intermediate exposure period. The LOAELs are

based on 2008 studies conducted by the National Toxicology Program (NTP). These studies

examined the health effects of or al exposures in mice and rats in termediately exposed to sodium

dichromate dihydrate in drinking water. The three intermediate LOAELs identified in these

studies are also based on hema tological effects observed for the following: 0.38 mg/kg/day for

female mice after a 22-day exposure; 0.77 mg/kg/da y for male rats after 22-day and 6-month

exposures; and 1.4 mg/kg/day for female mice af ter a 6-month exposure (NTP 2008). Thus for

the property in which the maximum observed con centration of hexavalent chromium in dust was

detected, noncancer adverse health effects could occur in children and adults who have accessed

this low-use basement. This conclusion may al so apply to other pr operties with high-usebasements in the vicinity of and with contamina tion levels similar to the contaminated low-use

basement property described above that exhibited the highest concentration of hexavalent

chromium detected in basement dust.

High-Use Basements

Hexavalent Chromium. Using the maximum observed concentration of hexavalent

chromium, the estimated exposure dose calcula ted for children (1–6 years) at 4.3 mg/kg/day,

children (1–18 years) at 2.2 mg/ kg/day and adults at 1.7 mg/kg/day significantly exceeded the

margin of safety established by the ATSDR in termediate and chronic MRLs of 0.005 and 0.001

mg/kg/day, respectively (see Table 2 below). The exposure dose also exceeded effect levels

shown in animal studies as detailed below.

7ExposureExposurePointExposureDose(milligramsperHealthGuidelineCVsNationalToxicologyLOAELScenarioConcentration(c)(microgramspersquaremeter(μg/m2))kilogramperday(mg/kg/day))(mg/kg/day)ProgramStudyLOAELs(NTP2008)(f)(mg/kg/day)ExceededChild(1–6yrs)Child(1–18yrs)AdultATSDRMRL(d)USEPARFD(e)AcuteIntermediateRangeLowUsageResidentialBasements(a)Cr+62,640,0000.540.310.250.0050.001(I)(C)0.0032.80.38–1.4YesHighUsageResidentialBasements(b)Cr+62,640,0004.32.21.7YesTable 2: Comparison of Ingested Exposure Dose to Hexavalent Chromium (Cr+6) in Surface Dust with Health GuidelineComparison Values (CVs) for Noncancer Health Effects8Cr +6

= Hexavalent chromium

(a) Low Usage Exposure Assumptions (source USEPA 1997, 2003):

1

‐ 2.5 hours per day (hrs/day), 2–5 days/week –(i.e., unfinished basements, laundry use)

Exposure Duration: 18 years (child), 30 yrs (adult)

Body Weight: Child

‐ 16.5 kilogram (kg) (1–6 years), 34 kg (7–12 yrs) and 58 kg (13–18 years); Adult

‐ 70 kg

(b) High Usage Exposure Assumptions (source USEPA 1997; 2003):

365 days/year

‐ i.e. living space

Exposure Duration: 6 and 18 yrs (child), 30 yrs (adult)

Body Weight: Child

‐ 16.5 kg (1–6 yrs), 34 kg (7–12 yrs) and 58 kg (13–18 yrs); Adult

‐ 70 kg

(c) Exposure Point Concentrations (micrograms per square meter) derived using Pro UCL Version 4.00.02 (USEPA

2007).

μg/m 2

= micrograms per square meter

mg/kg= milligrams per kilogram

MRL= ATSDR Minimal Risk Level

(d) ATSDR's Minimal Risk Level (I

= Intermediate 15–365 days; C= Chronic > 364 days)

RFD= EPA Reference Dose

(e) USEPA's Chronic Reference Dose

(f) National Toxicology Program. (NTP) 2008. NTP technical report on the toxicology and carcinogenesis studies of

sodium dichromate dihydrate (CAS No. 7789

‐ 12

‐ 0) in F344/N rats and B6C3F1 mice (drinking water studies).

Washington, DC: National Toxicology Program. NTP TR 546. August 13, 2008.

LOAEL= Lowest observed adverse effect level



### 9

### Compared with toxicological studies, th e calculated exposure doses based on the

maximum hexavalent concentration in surface dust

 Exceeded the LOAEL of 2.8 mg/kg/day for acute exposures known to cause

hematological effects in male rats (NTP 2008 );

 Exceeded all intermediate and chronic LOAELs (0.38 to 1.4 mg/kg/day) and the chronic

BMDL 10 

### of 0.09 mg/kg/day described in the preceding Low Use Basement scenario.

Therefore, in basements considered as high use and at the maximum observed

concentration of hexavalent chromium in dust, noncancer adverse health effects are likely to

occur in children and adults exposed to such hexavalent chromium-contaminated dust. This

conclusion applies to all propert ies with high-use basements in the vicinity of the low-use

basement property with the highest concentration of hexavalent chromium detected in basement

dust, if those basements have similar contamination levels.

Cancer Health Effects—Incidental Ingestion of Surface Dust

The United States Department of Health a nd Human Services (US DHHS), the U.S. EPA,

the U.S. DHSS, National Toxicol ogy Program (NTP) and the Intern ational Agency for Research

on Cancer have determined that regarding inhalation exposure, the cance r class of hexavalent

chromium is listed as a known human carcinogen.

Regarding oral exposure, the NTP has recently completed a 2-year study in which

reliable evidence supported the conclusion that ingestion of hexavalent chromium-contaminated

drinking water caused malignant tumors in mice and rats. A 2-year study on laboratory animals

is considered the primary method to determine the potential for human hazard. Regulatory

agencies have used NTP rodent studies to promul gate regulations to prot ect human health and in

the hazard identification proce ss for risk assessment (NTP 2008).

The cancer risk was evaluated for incidental ingestion of surface dust contaminated with

hexavalent chromium based on the location-specif ic exposure scenarios used to assess noncancer

health effects. Appendix A cont ains the site-specific exposure assumptions for the cancer risk

calculations.

Low-Use Basements

For the property in which the maximum obser ved concentration of hexavalent chromium

in dust was detected, the lifetime excess cancer risks (LECRs) were approximately 4 in 100 for

children and adults who have accessed and who mi ght continue to access this low-use basement.

This is considered an increased risk of cancer when compared with the background risk of all or

specific cancers, and it is of significant concern (see Table 3 below). ATSDR considers as

insignificant estimated cancer risks of less than one additional cancer case among one million

persons exposed (expressed as 1 in 1,000,000). Th is conclusion also applies to similarly

contaminated properties with low-use basements in the vicinity of that property described above

that exhibited the highest concentration of hexa valent chromium detected in basement dust.

10Exposure Scenario Exposure Point Exposure Exposed CSF (d) Lifetime Excess Cancer

Concentration (c) Duration Population [(milligrams per Risk (LECR)

(micrograms per (years) kilogram per

square meter day) ‐ 1

(μg/m 2 )) (mg/kg/day)

‐ 1 ]

Low Usage 2,640,000 30 Adult 0.5 4.1E

‐ 02

Residential

Basements Cr +6 (a) 18 Child 3.4E

‐ 02

High Usage 2,640,000 30 Adult 3.0E

‐ 01

Residential

Basements Cr +6 (b) 18 Child 2.8E

‐ 01 

### High-Use Basements

Using the maximum observed concentration of hexavalent chromium in dusts,

the theoretical LECRs for children and adu lts were approximately 3 in 10, which is

considered an increased risk of cancer a nd is of significant concern (see Table 3

below). This conclusion may also apply to other properties with high-use-basements

in the vicinity of and with contamination le vels similar to the previously referenced,

contaminated low-use basement property. That is, the low-use basement that

exhibited the highest concentr ation of hexavalent chromi um detected in basement

dust.

Table 3: Calculated Lifetime Excess Can cer Risk Based on Ingestion Exposures to

Hexavalent Chromium (Cr +6 

### ) in Surface Dust

Cr +6

= Hexavalent chromium

(a) Low Usage Exposure Assumptions (source USEPA 1997; 2003):

1

‐ 2.5 hours/day,

‐ days/week

‐ i.e. unfinished basements, laundry use, adults only

Exposure Duration: 18 years (child), 30 years (adult); Averaging Time 70 years

Body Weight: Child

‐ 16.5 kg (1–6 years), 34 kg (7–12 years) and 58 kg (13–18 years); Adult

‐ 70 kg

(b) High Usage Exposure Assumptions (source USEPA 1997; 2003):

365 days/year

‐ i.e. living space

Exposure Duration: 18 years (child), 30 years (adult); Averaging Time 70 years

Body Weight: Child

‐ 16.5 kg (1–6 years), 34 kg (7–12 years) and 58 kg (13–18 years); Adult

‐ 70 kg

(c) Exposure Point Concentrations (micrograms per square meter) derived using Pro UCL Version 4.00.02 (USEPA

2007).

μg/m 2

= micrograms per square meter

(d) Source: NJDEP, 2009

11

### Inhalation Exposure Evaluation

No hexavalent chromium air sampling data are available for the basement where the

highest levels of hexavalent chromium were found. Nonetheless, th e potential remains for

exposure to hexavalent chromium via inhalation if the dust/crystals are disturbed and become

airborne. No data are available to conclude whet her the inhalation of hexa valent chromium could

affect people’s health in the mi xed-use, low-use basement where the highest level of hexavalent

chromium was found. That said, ATSDR has esta blished an intermediate inhalation MRL for

hexavalent chromium particles of 0.0003 milligra ms per cubic meter of air. The most common

health problem in workers exposed to chromium involves the respiratory tract. Health effects

include irritation of the lini ng of the nose, runny nose, and breathing problems (e.g., asthma,

cough, shortness of breath, wheezing) inhalation of hexavalent chromium has been shown to

cause lung cancer in workers.

Dermal Exposure Evaluation

No known environmental comparison value relates dermal exposures to hexavalent

chromium in surface dust. Hexavalent chromium , however, is a known skin irritant and can

cause skin ulcers. But the health risks via th e dermal pathway are uncertain; they were not

evaluated quantitatively in the September 2010 health consultation on which this public health

advisory is based.



## Conclusions

ATSDR has determined that the current expos ures warrant the issuance of a Public

Health Advisory. ATSDR and NJDHSS conclude that children and adults accessing basements

of properties in the area of the E.C. Electroplati ng site area were, are, and will continue to be

exposed to hexavalent chromium at levels that may pose an immediate and significant threat to

their health. People can be exposed to the harm ful levels of hexavalent chromium by inhaling

and by accidentally swallowing contaminated dust. The observed concentration of hexavalent

chromium in basement dust at the mixed-use, low-use property where the maximum level was

detected indicates the presence of an urgent public health hazard.

Data for the basement area of one of th e properties sampled indicated hexavalent

chromium was present in dust at high concentr ations due to contaminated groundwater entering

the basement area. Not all properties within the groundwater plume area have been evaluated.

But finding a high concentration of hexavalent chro mium in basement dust at one property is an

indicator that all residences in th is immediate vicinity have been, are presently, or will be at risk

of contamination. And that contamination could be at levels that pose a si gnificant health threat

to residents. Note that this c onclusion applies to all affected residences, whether their basements

are high- or low-use areas.

As long as groundwater remains contaminated with high levels of hexavalent chromium,

that contaminated groundwater may continue to infiltrate into the basements of residences, as

demonstrated by current U.S. EPA data. Children and adults will therefore continue to be at risk

of exposure to levels of hexavalent chromium posing an immediate and significant threat to

12

### human health. This risk affects all residents at properties within the immediate vicinity of the

mixed-use, low-use property with the maximum he xavalent chromium conc entration in basement

surface dust.

Using the concentration of hexa valent chromium detected in basement surface dust, the

risk of noncancer health effect s from ingestion exposures is significantly elevated above a

reasonable margin of safety for children and ad ults. The theoretical lifetime oral excess cancer

risk is calculated as 4 in 100 for low-use baseme nts and 3 in 10 for high-use basements, but note

that both are considered an increased cancer risk and both are of significant concern.

Data are unavailable for the inhalation pathway. ATSDR cannot therefore reach a

conclusion regarding the health e ffects of inhaling hexavalent ch romium particulates in air.

Anecdotal evidence suggests, however, that reside nts may periodically use a broom to sweep up

the yellow chromium crystals. If surface crysta ls are thus disturbed and become airborne,

inhalation of hexavalent chromium is a potential exposure pathway. This is of particular concern

given that hexavalent chromium is consid ered a known human carci nogen via inhalation.

The amount of exposure to hexavalent chromium and consequent health risk depends in

part on the degree to which residents access this contaminated area and the activities they

conduct therein. Under both the high- and low-use scenarios, however, these risks remain very

high. And these risks are considered present for all residents at propert ies within the immediate

vicinity of that property with the maximum hexavalent chromium concentration.



## Recommendations

ATSDR and NJDHSS recommend that U.S. EPA ta ke short- and long-term measures to

dissociate persons (either in residential or commercial properties), who live, work, or both in the

contaminant plume area. This dissociation would be from hexavalent chromium exposures due to

the infiltration of contaminated ground water into the basements of these properties. Acting on

ATSDR’s and NJDHSSs’ recommendation, U.S. EP A has already taken immediate steps to

remediate the property with the highest levels of hexavalent chromium in basement surface dust.

Additionally, U.S. EPA should advise residents in the immediate vicinity of the property

showing the highest contaminant levels not to us e their basements as they otherwise might use

them until after completion of an environmental assessment to determine the presence of a health

hazard. Residents should be advise d to contact U.S. EPA if they observe signs of hexavalent

chromium contamination (e.g., yellow dust or crystals) in the basements of their homes.

In the long term, U.S. EPA should take st eps to remove permanently the source of

hexavalent chromium contamination in the Ga rfield, NJ area groundwater. Until completion of

such permanent solution, all resi dents within the contaminant plum e may continue to be exposed

to hexavalent chromium at levels that present an immediate and signi ficant threat to their health.

And until completion of that permanent solution, U.S. EPA should continue to implement actions

to clean basements where hexavalent chromium is at levels of health concern. U.S. EPA should

also continue to prevent groundwat er contaminated with hexavale nt chromium from entering any

residence within the groundwater plume.

13

### With regard to worker safety, a site-sp ecific health and safe ty plan should be

implemented during any remedial activi ties to ensure such worker safety.



## Public Health Action Plan

The public health actions taken by th e ATSDR and NJDHSS are as follows:

1. The ATSDR and NJDHSS have worked with U.S. EPA to review information and

relevant data and thereafter to evaluate th e potential health implicat ions for exposures to

hexavalent chromium detected in surface dus t at residences within the hexavalent

chromium groundwater plume associated with the E.C. Electroplating site.

2. Two health consultations were complete d by the ATSDR and NJDHSS in September

2007 and April 2010, respectively (A TSDR 2007; ATSDR 2010a).

3. In September 2008, the NJDHSS attended a public meeting hosted by U.S. EPA to

discuss site investigations planned for the residential area within the affected

groundwater plume area.

4. In May 2010, the NJDHSS and ATSDR held a public meeting to di scuss the April 2010,

E C Electroplating site H ealth Consultation findings and recommendations.

5. In September 2010 (ATSDR 2010b), the NJDHS S, under cooperative agreement with

ATSDR, issued a health consultation that evaluated the most recent data and that

provided the basis for this public health advisory.

The public health actions planned by the ATSDR and NJDHSS are as follows:

1. By issuing this Public Health Advisory, AT SDR calls on U.S. EPA to implement shortand long-term actions necessary to prevent expos ures of affected residents to hexavalent

chromium and to address the source of hexa valent chromium in groundwater. Short-term

actions include

 Continued assessment of properties in areas wi th high levels of hexavalent chromium

groundwater contamination,

 Outreach to residents and community memb ers to inform U.S. EPA of any wet

basements, chromium blooms (e.g. yellow dust or crystals) or other evidence of

suspected site-related contamination, and

 Continued monitoring of previously reme diated properties to evaluate possible

recontamination.

Concurrently, in the long-term, U.S. EP A should develop options for addressing the

contaminated groundwater plume, with an emphasis on remediating the area of highest

groundwater contamination as soon as possible.

2. NJDHSS will advise area health care providers, particularly pediatricians and family

practitioners, of this report’s findings. NJDHSS will make available materials on

hexavalent chromium, including the ATSDR Case Study in Environmental Medicine—

14

### Chromium Toxicity and the ch romium ToxFAQ. NJDHSS will al so provide copies of the

report to the New Jersey Poison Informati on and Education System for health care

provider reference and information.

3. NJDHSS will provide additional community health education to advise residents to limit

activities in chromium-contaminated basements. Also, NJDHSS will encourage residents

who see yellow deposits in dust or on thei r floors or walls to contact U.S. EPA.

4. ATSDR is committed to review of additional data or to respond to additional requests

involving the E.C. Electropl ating site as necessary.

15

## References

[ATSDR] Agency for Toxic Substances and Dis ease Registry. 2007. Letter Health Consultation

for the E.C. Electroplating Site. Garfield, Bergen County, New Jersey. US Department

of Health and Human Services, Atlanta, Georgia. September 2007.

[ATSDR] Agency for Toxic Substances and Di sease Registry. 2008. Toxicological Profile for

Chromium (draft). Atlanta: US Depart ment of Health and Human Services;

September.

[ATSDR] Agency for Toxic Substances and Di sease Registry. 2010a. Health Consultation for

the E.C. Electroplating Site. Garfield, Bergen County, New Jersey. Atlanta: US

Department of Health and Human Services; 2010 April 26.

[ATSDR] Agency for Toxic Substances and Disease Registry. 2010b. September 2010 letter

Health Consultation for the E.C. Electropl ating Site. Garfield, Bergen County, New

Jersey. Atlanta: US Department of Health and Human Services.

[NJDEP] New Jersey Department of Environm ental Protection. 2002a. October 7, 2002 fax re:

E.C. Electroplating Site - site description and background summary.

[NJDEP] New Jersey Department of Environm ental Protection. 2002b. Marc h 27, 2002 letter to

Richard Chapin, Chapin Engineering re: E.C. Electroplating Site – Results of

December 12, 2001Aqueous Sampling Event.

[NJDEP] New Jersey Department of Environmen tal Protection. 2009. Derivation of an ingestionbased soil remediation criterion for Cr+6 ba sed on the NTP chronic bioassay data for

sodium dichromate dihydrate. Trenton, NJ: Office of Science; 2009 June.

[NTP] National Toxicology Program. 2008. NTP technical report on the toxicology and

carcinogenesis studies of sodium dichro mate dihydrate (CAS No. 7789-12-0) in

F344/N rats and B6C3F1 mice (drinking water studies). Washington DC: National

Toxicology Program. NTP TR 546. August 13, 2008. Available at:

http://ntp.niehs.nih.gov/ files/546_web_FINAL.pdf . Accessed 2010 September 13.

[USEPA] US Environmental Protection Agen cy. 1997. National Center for Environmental

Assessment. Office of Research and Development. Exposure Factors Handbook.

Washington, DC;. 1997Aug.

[USEPA] US Environmental Protection Agenc y. 2003. World Trade Center Indoor Environment

Assessment: Selecting Contaminants of Potential Concern and Setting Health-Based

Benchmarks. Prepared by the Contaminants of Potential Concern (COPC) Committee

of the World Trade Center Indoor Air Task Force Working Group. New York, NY.

2003 May.

[USEPA] US Environmental Protection Agen cy. 2008. National Center for Environmental

Assessment. Office of Research and Deve lopment. Child-Specific Exposure Factors

Handbook. Washington DC. 2008 September.

16

### [USEPA] US Environmental Protection Agenc y. 2010a. Region 2 June 8, 2010 e-mail re: surface

dust results related to the EC Electroplating site – I nvestigations conducted from

February through March 2010.

[USEPA] US Environmental Protection Agency. 2010b. Region 2 August 5, 2010 e-mail re:

surface dust results rela ted to the EC Electroplating s ite – Investigations conducted

July 2010.

[Weston] Weston Solutions. 2010c. Preliminary Data Package, EC Electropl ating Site, Garfield,

Bergen County, New Jersey. Provided via July 21, 2010 e-mail to the New Jersey

Department of Health and Senior Services through the US Environmental Protection

Agency, Region 2.

17

## Appendix A. Noncancer Exposure Assumptions

Exposures are based on incidental ingestion of surface dust contaminated with hexavalent

chromium during use of residential basement ar eas. Noncancer exposure doses were calculated

using the following formula obtained from the U.S. EPA World Trade Center Indoor

Environment Assessment study (USEPA 2003):

Exposure Dose (mg/kg/day) =

[( ET hard 

### x FTSS hard 

### x CSL hard 

### )  ( ET soft 

### x FTSS sof 

### t x CSL soft 

### )] x SA x FQ x SE

BW



### where mg/kg/day = milligrams of contaminan t per kilogram of body weight per day and;

ET = Exposure Time (hr/day) for ha rd and soft (carpeted) surfaces;

FTSS = Fractions Transferred from Surface to Skin (unitless)

FTSS hard 

### = 50%, FTSS soft 

### = 10%;

CSL = Contaminant Surface Load (mg/cm 2 

### );

SA = Surface Area (cm 2 

### /event);

FQ = Frequency of hand-to -mouth events (events/hr);

SE = Saliva Extraction Factor at 50% (unitless); and,

BW = Body Weight (kg)

Note: The above formula requires multiple assumptions in estimating exposures to surfaces which add uncertainty

to estimating exposure doses. Factors such as surface loading and transfers to skin are likely to be highly variable

as they have not been well studied. Variability of these factors may be influenced by characteristics of different

surfaces, activity patterns related to surface contact, and surface cleaning techniques and frequency (USEPA 2003).

In following the USEPA World Trade Center Indoor Environment Assessment study, this assessment used input

parameters to define reasonably the maximum exposures for both high and low use basement areas.



### 18Exposure Setting Exposed Population Surface Area

(mouthing area) Hand

‐ to

‐ Mouth

(events/hour) Contacts

Child 2 15 to 25 cm 9.5

Resident (1 through 6 years) (Age Adjusted) (Age Adjusted)

Child

(1 through 18 years) 2 15 to 45 cm

(Age Adjusted) 2 to 9.5

(Age Adjusted)

Child/Adult

(1 to 31 years) 2 15 to 45 cm

(Age Adjusted) 1 to 9.5

(Age Adjusted)

Resident/Employee Adult 45 2 cm 1

2 cm = centimeter squared

Exposed Population Body Weight Exposure Time (e) Number

Exposed of Years

(a) Child

(1 through 6 years) 12 to 23 kg

(Age Adjusted) 1

5 hour/day

days/week

6 (b) Child

(7 through 12 years) 26 to 53 kg

(Age Adjusted) 1

2 hour/day

days/week

(c) Child

(13 through 18 years) 56 to 70 kg

(Age Adjusted) 2.5 hours/day

5 days/week

Adult (d) 12 to 70 kg

(Age Adjusted) 2.5 hours/day

5 days/week 30 

### General Exposure Assumptions

Location Specific Assumptions: Lo w Usage Scenario for Basements

19Exposed Po pula t i o n Body Weig ht Exp o sur e Time Number of Ye a r s

Exposed

Child

(1 through 6 years) 12 to 23 kg

(Age Adjusted) 6

Child

(1 through 18 years) 12 to 70 kg

(Age Adjusted) 12 hours/day

365 days/year (b) 18

Child/Adul t

(1 to 31 years) (a ) 12 to 70 kg

(Age Adjusted) 30

(a) Worst

‐ case scenario: child exposed through an d into adulthood in resi denc e

High Usa g e As sumption (i.e. li v i n g space, act i ve ly used are a ) at 12 h ours/day

kg= kilogram



### 20 (a) Ch ild spends less than half the time that an adult does in basement.

(b) School-aged child exposed only during weekend period.

(c) Assumes child 13 to 18 years takes on laundry duties.

(d) Worst-case scenario: child exposed throug h and into adulthood in residence.

(e) Low Usage Assumption (i.e. unfinished basements, laundry use, storage)



### kg= kilogram

Location Specific Assumptions: Hi gh Usage Scenario for Basements

### Cancer Exposure Assumptions

Cancer exposure doses were calculated us ing the noncancer exposure dose and adjusting

for the following formula:

ED 

### Cancer Exposure Dose (mg/kg/day) =Noncancer Exposure Dose x

AT



### Where ED = exposure duration representing th e location-specific scenario (years);

and AT = averaging time (years).

The LECR for adults was calculated by multiplying the cancer exposure dose by the

cancer slope factor (CSF). The CSF is defined as the slope of the dose- response curve obtained

from animal and/or human cancer studies and is expressed as the invers e of the daily exposure

dose, i.e., (mg/kg/day) -1



### .

The CSF regarding ingestion exposure wa s obtained from the NJDEP. The NJDEP

derived a CSF of 0.5 (mg hexavalent chromium/Kg/day) -1 

### using chronic bioassay data of male

mice from the 2008 NTP study and U.S. EPA can cer assessment guidelines (NJDEP 2009).

21