Comment submitted by A. Robertson

Document ID: EPA-HQ-SFUND-2008-0579-0006
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: September 09 2008, at 04:12 PM Eastern Daylight Time
Date Posted: September 19 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: September 3 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: November 3 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 806fb845
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This is comment on Proposed Rule

National Priorities List, Proposed Rule No. 49

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As Brooks so aptly stated in The Pursuit of Wilderness (1971), "In America today you can murder land for private profit. You can leave the corpse for all to see, and nobody calls the cops." In 2003 the Curtis Paper Mill in Milford, New Jersey, permanently shut down production, and now stands abandoned, "the corpse left for all to see". On Wednesday, September 3, 2008, the Environmental Protection Agency (EPA) announced a proposal to add the Curtis Paper Mill to its National Priorities List as a Superfund site. Well, five years later, it's about time! I pass that eyesore mill almost every day and cringe every time I think of the contaminants that lurk there in the buildings, the soil and the stretch of Delaware River right next to the facility. I've done some research. Contained within that property are remnants of toluene, chlorine gas, asbestos, lead and polychlorinated biphenyls (PCBs), as well as numerous bacterial concerns. I'd like to pass along the information that I learned. Toluene was used in a separate coating facility that stands directly behind the Delaware Valley Health Center. It is a solvent, and was used to coat paper for food packaging. In the mill's active days, residents downwind would be treated to the smell of the toxic fumes. Chlorine gas was used in the paper bleaching process. According to a study done by Blanc (2007), "chlorine bleaching produces a wide variety of persistent toxic wastewater contaminants that can reach deep aquifers and degrade the environment." An interview with a long-time mill worker who still resides in one of the mill houses directly south of the facility states that the mill, built in the 1920's, contains massive amounts of asbestos in its walls and structure. As parts of the mill degrade, as is readily noticed on a drive-by, the asbestos crumbles and remains, posing a hazard to the surrounding residents. Standing in front of the mill is a small fenced-in area that served as the power plant for the facility. There was a fire there that destroyed many of the capacitors, which were made with lead for its insulating properties. The remaining parts and ashes just lie there leeching into the soil. And last-but-not least of the chemical concerns- the PCBs. A study conducted by Lundqvist, et al, reported some of the effects of PCB's from other studies included low birth weight, lower IQ, cleft lip and palate, depressed immune systems, endocrine abnormalities and cancer. These are only some of the hundreds of chemical contaminants at our local mill site. As far as the bacteria goes, a study by Muihko, et al (2004) found that many bacteria were present in several mills indicating a common contamination source such as paper making chemicals. In addition, there are many openings within the abandoned buildings of the paper mill through which birds and rodents can travel. H. capsulatum grows in soil and material contaminated with bat or bird droppings. Spores become airborne when contaminated soil is disturbed, and can cause histoplasmosis. The mill has been vandalized and tresspassers have been in the mill, causing potential release of these bacteria into the air. The EPA has already removed the three radioactive paper-thickness measuring devices from the mill, as well as any drums of chemicals that were left. But with the degredation of the abandoned mill, the removed chemical drums and piping, it's a sure bet that those chemicals and hazards are still within the soil and the water surrounding the mill. And in 2005, the landfill dumping site a half mile south of the mill site, known as the Crown Vantage Landfill, became a Superfund site and was remediated. The tests on that site revealed hundreds of chemical contaminants. Per the US. Dept. of Health and Human Services report released March 8, 2006, "Soil samples contained, "semi-volatile organic compounds, PCBs, and metals, including barium, chromium, and lead at elevated concentrations." So they inspected, classified and remediated the landfill site, but NOT the primary source of the dumped materials, the paper mill. Now do you know why I say, "It's about time"?

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