RapidHealthImpactAssessmentMillsboro,DELeahBaskinGraves,MPH,AaronAber,NatalieAgee,BenGrimes,andLionelWilsonMarylandInstituteforAppliedEnvironmentalHealthSchoolofPublicHealthUniversityofMarylandCollegePark

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TableofContentsExecutiveSummary.................................................................................................................................................4Acknowledgements.................................................................................................................................................4HIAIntroduction.......................................................................................................................................................5HIAScreening.............................................................................................................................................................5HIAScoping.................................................................................................................................................................6HIAAssessment.........................................................................................................................................................6GeographicAnalysisofTargetCommunity:Millsboro,DE...............................................................6PopulationandSociodemographicData...................................................................................................7PoultryProcessingOverview.........................................................................................................................7MillsboroHealthStatus.....................................................................................................................................8

Access to Healthcare......................................................................................................................................................8RespiratoryIssues........................................................................................................................................................9Cancer................................................................................................................................................................................9MortalityRatesandBirthWeight........................................................................................................................10

OverburdenofIndustrialFacilities...........................................................................................................11NRGIndianRiverPowerPlant..............................................................................................................................11MountaireMillsboroPoultryProcessingPlant..............................................................................................11NCRSuperfundSite....................................................................................................................................................12MillsboroTCESite......................................................................................................................................................12ThorogoodsConcrete................................................................................................................................................13

OccupationalHealth........................................................................................................................................13AirandWaterQualitynearHarimMillsboro.......................................................................................14

WaterQualityRegulations......................................................................................................................................14WaterQualityProfile.................................................................................................................................................15AirQualityRegulations.............................................................................................................................................16ToxicSubstances.........................................................................................................................................................17AirQualityProfile.......................................................................................................................................................18TrafficConcerns...........................................................................................................................................................19OdorIssues....................................................................................................................................................................19ZoningRegulations.....................................................................................................................................................20MillsboroInhalationandBiomonitoringStudy..............................................................................................20

Chemicals.............................................................................................................................................................21Arsenic.............................................................................................................................................................................23Chloride...........................................................................................................................................................................24Chromium......................................................................................................................................................................25Cobalt...............................................................................................................................................................................26Lead..................................................................................................................................................................................27Nitrates............................................................................................................................................................................28HydrogenSulfide.........................................................................................................................................................29ParticulateMatter(PM)............................................................................................................................................30Trichloroethylene(TCE)..........................................................................................................................................31VolatileOrganicCompounds(VOCs)..................................................................................................................32

HIAReportingandRecommendations........................................................................................................33Reporting.............................................................................................................................................................33

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KeyFindings..................................................................................................................................................................33Recommendations...........................................................................................................................................34

AppendixATablesandFigures...................................................................................................................38Figures...................................................................................................................................................................38Tables.....................................................................................................................................................................49

AppendixBNCRMonitoringWellTCEExceedances.........................................................................51AppendixCBPEnvironmentalWellMonitoringExceedancesfromtheHarimMillsboroSite...............................................................................................................................................................................52AppendixDZoningMap..................................................................................................................................53

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ExecutiveSummaryIn 2013, Allen Harim Foods purchased the former site of a Vlasic Pickle plant in Millsboro, DE, and announced its intent to convert the site into a poultry processing plant that would process approximately two million birds per week. The proposed location of the plant in the Millsboro community has been a controversial issue for many residents. The site has been designated by the EPA as a brownfield due to the presence of existing contaminants, and within a two-mile radius of the site there is a coal-fired power plant, an existing poultry processing plant, two Superfund sites, two schools, a concrete factory, and a veterinary pharmaceutical plant. The community is deeply concerned about the existing adverse health effects and the possibility of the plant causing negative health outcomes for residents. The purpose of this rapid Health Impact Assessment (HIA) is to analyze the potential health impacts of the Harim Millsboro plant and create a report to provide more information to the community and stakeholders about the health status of residents in Millsboro and the status of air and water pollution. Making conclusive statements about the health impacts of the Harim Millsboro plant is challenging due to the rapid nature of the assessment and because the facility has not been constructed, so there is no information available on actual environmental releases. The ultimate goal of this rapid HIA is to highlight potential health impacts and to provide recommendations to community stakeholders that can minimize negative health impacts and implement policies that will maximize positive health impacts. Key findings of this report include:

Residents in the area of interest are overburdened with pollution from multiple sources. The sociodemographic variables for residents in the area of interest are lower than

county, state, or nationwide levels. The health status of the Millsboro community is lower than county, state, and federal

levels. The projected size and amount of poultry to be processed at the Harim Millsboro plant

will likely result in increased levels of air and water pollution. The current odor problem will be exacerbated by the addition of the Harim Millsboro

plant. The placement of the plant will increase air and soil pollution from diesel exhaust, lead to

traffic congestion, and place excessive wear and tear on the roads. AcknowledgementsThe authors would like to acknowledge the following groups and individuals for their contributions to this report by being available for interviews and providing crucial expertise. Maria Payan Socially Responsible Agricultural Project Jay Meyer, Ken & Joanne Haynes, and all Protecting Our Indian River members Barry Goldman John Austin Inland Bays Foundation Michelle Merkel Food and Water Watch Sacoby Wilson, Ph.D. University of Maryland

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HIAIntroductionA health impact assessment (HIA) is a method of assessing the potential effects of a policy, plan, program, or project on the health of a population and the distribution of those effects within the population.[1] A HIA also identifies the appropriate actions to manage the effects. A rapid HIA model aims to seek input from the community about their concerns, and can be utilized when a shorter timeframe (approximately three months) is needed and when fewer resources are available. The steps involved in a rapid HIA are: screening, scoping, baseline assessment, recommendations, reporting, and monitoring. The screening process involves determining if a HIA is feasible, timely, and if it would add value to the decision-making process. Scoping involves creating a timeline for conducting the HIA and identifying an overall plan. The baseline assessment process involves examining existing conditions of the community and evaluating the potential health impacts that could occur if the proposed policy, plan, program, or project was approved. Recommendations are developed to prevent or mitigate the adverse health effects. Reporting involves presenting and communicating the results of the HIA. Monitoring tracks the impacts of the HIA on the decision-making process and health determinants in the community. HIAScreeningSussex County, Delaware is ranked first in the country for amount of broiler chicken production. Each year, over 600 large-scale farms in Sussex County produce approximately 200 million chickens for consumption.[2] The chickens are then transported to one of seven processing plants in the state. In 2013, Allen Harim Foods announced its intent to purchase the former site of a Vlasic Pickle/Pinnacle Foods plant (hereafter referred to as Harim Millsboro) in Millsboro, DE and convert the facility into a poultry processing plant that would process two million birds per week. Residents in the communities surrounding the Harim Millsboro plant have expressed great concerns over how the processing plant will impact the air, water, and their overall health. The residents feel overburdened by the existing pollution sources, such as a coal-burning power plant, two Superfund sites, a poultry processing plant, an animal vaccine facility, and a concrete factory, which all exist within a two-mile radius of the Harim Millsboro site. They feel that adding an additional poultry processing plant would exacerbate the existing adverse health effects. In order for Harim Millsboro to begin operations, the Sussex County Board of Adjustments (BOA) and the Planning & Zoning Commission need to approve Harims application requesting an exception to zone the land use as Potentially Hazardous Use. Although community members submitted over 270 comments in opposition of zoning change to the BOA, the zoning change was approved. Residents felt that the countys efforts to involve the community in the zoning process violated many of the countys codes. A 2013 letter from the Socially Responsible Agriculture Project (SRAP) and Protecting Our Indian River (POIR) community organizations to the Sussex County Planning and Zoning Office noted numerous violations. Some of these violations include a failure to provide written notice of the initial hearing to all parties of interest

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and a failure to notify or seek input from agencies such as the Delaware Department of Health and Social Services Division of Public Health on the potential adverse health effects the plant may have on nearby Millsboro residents (Ballantine, B., Wilton, C., Haynes, K., Diamond, D., Luk, D., and Payan, M., Personal Communication, August 5, 2013). For these reasons, it was determined that a rapid HIA model would benefit the community, as it would identify any potential negative health impacts stemming from the proposed placement of the Harim Millsboro plant and would be feasible within the limited timeframe and resources. The rapid HIA could serve as a guide for citizen concerns as they address county, state, and federal agencies and seek assistance from other organizations. In addition, other communities dealing with similar situations could use the rapid HIA as a guide for addressing health concerns in their own community. HIAScopingIn order to identify the major concerns from residents and narrow the focus of research, the following tasks were conducted for the rapid HIA:

Conference calls and meetings with concerned residents to identify major health concerns.

Review of literature pertaining to poultry processing plants. Interviews with experts on pollution in Millsboro and hazardous waste. Identification of pollutants, assessment of health effects related to exposure,

concentration of pollutants found in the community, and EPA standards on exposure levels.

Utilization of US Census data to assesses sociodemographic statistics. Spatial analysis with QGIS software. Analysis of community health statistics and reports from the Delaware Health and Social

Services Department and Geographic Research, Inc. Review of EPA Toxics Release Inventory (TRI) and Right-To-Know Network data on

emissions from industrial facilities Residents and stakeholders indicated that a disproportionate burden of adverse environmental health exposures, traffic congestion, air pollution, and threats to water quality were some of the primary concerns about placement of the Harim Millsboro plant in the community. HIAAssessmentGeographicAnalysisofTargetCommunity:Millsboro,DEMillsboro, DE, is located along the Indian River in southeastern Delaware, approximately 21 miles southeast of Rehoboth Beach, DE, and 25 miles northwest of Ocean City, MD. The communities within the areas of interest in this report are located in the southeastern portion of Millsboro, DE, and border the Indian River and Whartons Branch stream. These communities, Colonial Estates, Holiday Acres, and Possum Point, are adjacent to the proposed site and lie

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within the zip codes of interest (namely 19966 and 19939) (Figure 1). Within a two-mile radius of the Harim Millsboro site, there are approximately 533 single-family houses, 247 trailer homes, 240 townhouses, 45-60 apartments, and two schools. PopulationandSociodemographicDataIn 2010, the population of Millsboro was 3,877 residents.[3] Age distribution data is presented in Figure 2. Millsboro has gained attention as one of the fastest growing cities in Delaware, especially among retirees. Between 2010 and 2013, the 45 and older age group grew approximately 4%, the highest of any age group. An analysis of the spatial distribution and concentration of poultry farms and processing plants by percent of non-white residents within Delaware census tracts was conducted using QGIS mapping software (Figure 3). Poultry processing plants appear to be located in census tracts where at least 16% of residents are non-white. The median household income of the census block group containing Colonial Estates, Holiday Acres, and Possum Point is $37,434 per year.[4] This is lower than the median household income of Sussex County ($52,710), Delaware ($59,878), and the United States ($53,046) (Figure 4). The percentage of families living below the Federal Poverty Level (FPL) in the census block is 19.89% (Figure 5). This is higher than the FPL of families living within Sussex County (8.9%), Delaware (7.8%), and the United States (11.3%). The unemployment rate within the census block group of the area of interest is 9.7%, which is higher than the states unemployment rate of 8.9%, but equivalent with the U.S. overall unemployment rate for individuals over the age of 16 in the labor force in 2013 (Figure 6). The percentage of homes built in the census block group of the area of interest is 8.68%, which is higher than the Sussex County rate of 7.95%. The homeownership rate in Sussex County (78.95%) is the highest in the state, but the homeownership rate in the area of interest is lower (56.78%) than county, state, and nationwide levels (Figure 7). Education statistics show that the percentage of residents with less than a high school diploma or equivalent in the area of interest is 15.9%, which is higher than county, state, and nationwide levels (Figure 8). PoultryProcessingOverviewThe entire process of poultry slaughter and production, from transporting the chickens to the facility to shipping the processed poultry out of the plant, can greatly impact the health of residents in the surrounding community. During transport, bird crates can be tossed on the roadway during normal driving if they are not properly secured, and an entire load of crated birds can be lost if the truck is overturned.[5] Truck drivers have noted that that the transport trucks feel top-heavy when carrying a full load of chickens. The arrival of poultry trucks to the processing plant can spread harmful bacteria into the environment, thus exposing residents, other drivers, and pedestrians to the bacteria.[5] During transport from the farm to the processing plant, each truck holds up to 10,000 chickens in open-air crates. In a study by Rule et al. (2008), researchers drove in cars with the windows down behind open-air poultry trucks in Salisbury, MD, and tested the air for bioaerosols.[6] Researchers consistently detected increased levels of antibiotic-resistant bacteria in the air and on surfaces inside of vehicles. This study presents the

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possibility of the dispersion of pathogens during poultry transport, thus greatly affecting the public health of anyone living near or traveling along the same route. Research has shown that approximately between 0.25% and 0.86% die before arriving to the processing plant due to extreme temperatures, stress, and poor handling.[7] The processing plant then disposes of the carcasses through composting, incineration, rendering into by-products, or on a landfill. These disposal methods can add to the pollutants in the air, water, and soil. Large quantities of water are used at poultry processing plants, thus presenting community problems with poultry processing wastewater (PPW) treatment, disposal, and the conservation of the communitys water supply. On average, seven gallons of water per bird are used throughout the processes of scalding, washing, and chilling the birds, along with the cleaning and sanitizing of equipment and facilities.[8] For a plant such as Harim Millsboro that expects to process two million birds per week, approximately two million gallons of water will be used per day. The processes of slaughter and evisceration (removal of internal organs) have the greatest impact on PPW because they contribute to the amount of offal produced.[9] Offal refers to the parts not typically used for human consumption such as the blood, head, excreta, and viscera. This comprises approximately 28% of the chickens weight. For an average five-pound chicken, 1.4 pounds of offal are produced, thus Harim Millsboro will produce approximately 200 tons of offal per day. Large quantities of water are used to transport the offal out of the processing areas where the PPW is then discharged in water or applied to lands. The PPW can contain high levels of nitrogen, phosphorus, and chlorine.[10] The use of antibiotics in poultry feed can cause PPW to contain high amounts of antibiotic-resistant bacteria.[11] As the PPW is discharged, runoff into bodies of water and entry into groundwater can cause the antibiotic-resistant bacteria to enter the soil and sources of water that are used for human consumption. During the scoping portion of the HIA, many Millsboro residents strongly expressed their concerns about the odor that will be emitted from the Harim Millsboro plant. During poultry processing, the fats, greases, blood, and carcasses in the PPW act as a medium for the growth of bacteria and are therefore subject to decay.[12] The decaying PPW contains compounds such as hydrogen sulfide, sulfuric compounds such as mercaptans, volatile fatty acids, nitrogenous compounds, and organic particulate matter that are emitted into the air as foul-smelling gases. For example, hydrogen sulfide has a smell similar to rotten eggs. Mercaptan gas is often added to butane or propane gas used for cooking and the odor can be described as similar to rotten cabbage. These noxious odors can become a chronic nuisance for nearby residents. MillsboroHealthStatusAccess to HealthcareThe Health Resources and Services Administration (HRSA) provides data on access to healthcare and designated Sussex County as a medically underserved area (MUA), meaning that the county has been identified as having too few primary care providers per 1,000 residents, high infant mortality, high poverty, or a high elderly population.[13] HRSA also identified that

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Sussex County has a shortage of primary care providers (ratio of more than 3,500 residents to one provider), dentists (ratio of more than 5,000 residents to one dentist), and mental health providers (ratio of more than 30,000 residents to one provider) who provide care to low-income residents. RespiratoryIssuesAn analysis of 2013 physical health status data from Geographic Research, Inc. of the Millsboro zip codes of interest shows that the percentage of residents with cancer, chronic bronchitis, emphysema, and heart disease (all types) is noticeably higher than rates experienced at county, state, and national levels (Table 1).[14] Introducing a second poultry processing plant within the zip codes could possibly increase the rates of these health conditions even more so due to the increase in particulate matter and other chemical emissions from the poultry processing plant. Clean Air Task Force data from 2014 on adverse health effects estimated that 7,500 deaths occur nationwide per year due to particulate matter emissions from power plants.[15] This represented a reduction from 13,000 deaths nationwide per year in 2010, and researchers attributed it to policies such as the Mercury Air Toxics Rule and the Cross State Air Pollution Rule, which contributed to nationwide decreases in sulfur dioxide emissions by 68% and nitrogen oxide emissions by 55%. Data on the Indian River region shows that particulate matter is attributed to a combined 375 cases of deaths, heart attacks, cardiovascular diseases, and respiratory issues, accounting for over $139 million in estimated costs (Figure 9). Estimates for Sussex County are lower at 141 combined cases and an estimated $9.4 million in costs. CancerIn 2007, the Delaware Division of Public Health (DPH) conducted an analysis of cancer incidence rates from 2000-2004 in the Indian River area (six zip codes adjacent to the NRG Indian River power plant) (Figure 10). The study showed that the age-adjusted cancer rate for the Indian River region was 553.9 cases per 100,000, which is significantly higher than the cancer rate for the rest of all of Delaware (501.3), and the entire US (473.6) (Figure 11).[16] A further analysis into types of cancer showed that lung cancer represented a statistically significant percentage of cases (Figure 12). This study lacked data on exposure levels, smoking habits, socioeconomic status, access to healthcare, and not assessing how long residents lived in the Indian River area. In response to the 2007 study, and at the suggestion of the Centers for Disease Control (CDC) and the National Cancer Institute (NCI), DPH administered the Indian River Community-Level Survey (IRCLS) in 2009 to collect data on tobacco use and other risk factor data from Indian River residents (Table 2).[17] The study consisted of 163 participants filling out a self-report survey, of whom 71 had been diagnosed with lung cancer (44%), 86 had not been diagnosed with cancer (53%) and 6 participants (4%) who had a relative die of lung cancer acted as a proxy for lung cancer cases. Of the 71 participants with lung cancer, 34 (44%) were from the Indian River area. The study also examined demographic data from lung cancer cases from the Delaware Cancer Registry (DCR) to supplement the IRCLS findings.

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By incorporating DCR data, it was revealed that males in the Indian River area accounted for nearly all of the elevation in lung cancer incidence rates among Indian River residents. The lung cancer rate for females was not significantly higher in the Indian River area compared to women in Sussex County and all of Delaware. Furthermore, when analyzing the IRCLS responses, the study found statistical significance among smoking status and occupation. For example, current smokers were 17.5 times more likely to develop lung cancer than non-smokers. and residents whom had ever smoked were 10.5 times more likely to develop lung cancer compared to residents whom had never smoked. Ultimately, participants who worked in a high-risk industry (e.g. agricultural, chemical, construction, manufacturing, or pharmaceutical) were found to be 3.4 times more likely to develop lung cancer compared to participants who did not work those industries regardless of smoking . Based on the responses from the IRCLS combined with an analysis of DCR data, the study concluded that Indian River participants were significantly more likely than non-Indian River participants to be heavy smokers and to have worked in a high-risk industry, regardless of cancer status. They believe that these findings from the IRCLS suggest that the Indian River community has a unique lung cancer risk factor profile compared to their non-Indian River neighbors with lower cancer rates. In addition, tobacco use status and occupational exposure may not be limited to the population of Indian River residents already diagnosed with the disease many cancer-free Indian River residents might also have these risk factors, placing them at increased risk for the onset of lung cancer. A few notable limitations of this study are that, although the population of interest was the Indian River area, 100 non-Indian River residents participated compared to 63 Indian River residents. It is possible that such a small sample size underestimated the cancer risk factor for Indian River residents. In addition, the study did not examine any air exposure data for particulate matter or other possible carcinogens, which was a primary concern for many residents. It is possible that there could be an association between smoking status, air pollution, and cancer incidence that the study did not examine such as genetic disposition. MortalityRatesandBirthWeightSussex Countys 2013 infant mortality rate of 6.2 deaths per 1,000 live births ranks the lowest in the state, behind Kent County (6.9) and New Castle County (9.1).[15] Sussex County also ranked lowest in the state for the percentage of infants born at a low birth weight (7.9%), behind Kent County (8.5%) and New Castle County (9.1%). An assessment of 2013 mortality data at zip code level shows that an elevated percentage of residents in the zip codes of interest died from cancerous tumors, chronic lower respiratory diseases, and heart disease compared with statistics at the county, state, and nationwide levels (Figure 13).[15] The percentage of deaths due to all causes was also higher in the zip codes of interest.

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OverburdenofIndustrialFacilitiesWithin a two-mile radius of the Harim Millsboro site, there are two Superfund sites, four industrial facilities, and two schools (Figure 14). This section will provide information on some of the existing hazardous facilities and their emissions in this area of interest. NRGIndianRiverPowerPlantThe NRG Indian River Power Plant (hereafter referred to as the NRG site) is located on Burton Island, approximately two miles east from the proposed Harim Foods site. EPA Toxic Release Inventory (TRI) shows that this coal-fired plant released approximately 279,354 pounds of chemicals into the air and land in 2013. [18] 137,384 pounds of chemicals were emitted into the land, with 73% from barium compounds, 12% from manganese compounds, 10% from vanadium, and 5% from lead. Most of the waste released on land from power plants is in the form of coal ash, which is the waste left over after coal is burned to generate power.[19] Coal ash contains concentrated amounts of heavy metals, such as lead, mercury, arsenic, chromium, and selenium. From 1957-1980, coal ash was disposed of on Burton Island using coal ash berms (tall embankments composed of coal ash) and unlined landfills.[20] In 2005, DNREC observed the active erosion of ash berms into Island Creek and the Indian River, which led to the creation of a voluntary cleanup program agreement between DNREC and the power plant. As part of this cleanup program, NRG hired a consultant to create and evaluate the groundwater quality on the NRG site. This report showed that groundwater samples from the NRG site had levels of arsenic, chromium, and thallium that exceed their MCLs (Table 3). 21 On September 27, 2007 NRG agreed to a consent order that set mercury (Hg), sulfur dioxide (SO2), and nitrogen oxides (NOx) air emissions limits for NRGs four coal-fired operating units, and established penalties for air exceedances.[21] The consent decree was the result of NRGs inability to comply with DNRECs Regulation 1146, Electric Generating Unit (EGU) Multi-Pollutant Regulation, which set emissions limits for coal and gas-fired power plants. As a result of this consent order, NRG agreed to close two of its operating units by 2011. In 2013, NRG agreed to the closure of a third operating unit.[22] Figure 15 shows a trending decrease in NRG air emissions starting in 2010. In 2013, NRG emitted 141,970 pounds of chemicals into the air, with approximately 81% from hydrogen chloride, 8% sulfuric acid, 7% hydrogen fluoride, and 7% ammonia. MountaireMillsboroPoultryProcessingPlantThe Mountaire Farms Millsboro poultry processing plant lies along the Indian River and is located approximately two miles north of the Harim Millsboro site. Approximately 1.5 million chickens are processed per week.[23] The site includes a hatchery, facilities for processing poultry and byproducts, and manufacturers grains to produce poultry feed. In 2013, Mountaire Millsboro produced 61,432 pounds of waste. Of that amount, 3,417 pounds of toxic chemicals were released into the environment and the rest was treated on-site.[26] In total, 3,167 pounds of chemicals were emitted into the air, with 76% of emissions consisting of hydrogen sulfide, zinc, manganese compounds, and copper compounds making up the remaining 24% of releases (Figure 16). The primary contaminant consisted of hydrogen sulfide releases

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into the air. Mountaire Millsboro ranks close to the 70th percentile for the amount of releases and waste compared with all of the releases and waste from the facility to other TRI facilities in 2013 (Figure 17). Between 1991 and 2014, Mountaire Millsboro received 17 violations from DNREC for air and water emissions exceedances for chemicals such as nitrogen oxides, sulfur oxides, carbon monoxide, ammonia, VOCs, and nitrates.[24] NCRSuperfundSiteThe site of the former National Cash Register Corporation (NCR) plant is an 80-acre site located approximately one mile west of Harim Millsboro. The site has been designated as an EPA Superfund site, which is an uncontrolled or abandoned place where hazardous waste is located and can possibly affect local ecosystems or people.[25] Between 1967 and 1981, chromium, lead, and trichloroethylene (TCE) were used to manufacture cash registers and electrical components at the site.[26] During the process of chromium plating, heat-treating, enameling, and degreasing operations, wastewater with high levels of chromium was formed. This wastewater was treated on-site and disposed of in an unlined pit on the northeast corner of the site. During groundwater testing conducted in 1981 after the site was sold to First National Bank of Maryland, chromium and TCE were detected at high levels in groundwater. For example, the highest chromium sample was 0.64 mg/L (monitoring well #11), far exceeding its drinking water MCL of 0.05 mg/L.[27] The highest level of TCE detected at one of the monitoring wells was 115,000 mg/L, which is also exceeding the TCE MCL of 0.005 mg/L (Appendix B). In 1983, consultants noted that a plume of TCE in groundwater was migrating from the northeast corner of the site into the Iron Branch. The NCR site was added to the National Priorities List (NPL) in 1987, which is a list of national priorities among the known releases or threatened releases of hazardous substances, pollutants, or contaminants throughout the United States and its territories.[28] As part of a 1988 consent order between NCR and DNREC, NCR agreed to install a groundwater recovery well to pump and treat the contaminated groundwater and add an air stripper to remove the TCE from the groundwater and prevent future migration of the plume.[29] MillsboroTCESiteThe Millsboro trichloroethylene (TCE) site is located approximately two miles northwest of the Harim Millsboro site, and has been designated as an EPA Superfund site. In October 2005, Delawares Division of Public Health, Office of Drinking Water (DPH-ODW) conducted routine drinking water sampling at the Boys & Girls Club (28154 Lighthouse Crossing, Dagsboro, DE) located approximately four miles southeast of the Millsboro TCE site. [30] Drinking water samples from the Boys & Girls Club had TCE levels of 0.08 mg/L, exceeding the MCL of 0.005 mg/L.[31] Investigations determined that the source of groundwater pollution was due to a TCE plume that originated from the Millsboro TCE site. From 1952-1999, the Millsboro TCE site was the former site of various companies such as Delaware Poultry Labs and Schering Plough that produced poultry vaccines.[32] Before the building was demolished in 1999, one of the companies used TCE during vaccine production as a heat transfer medium within a closed refrigeration system. [33 ] During DNRECs investigation into the source of contamination, leaking underground storage tanks (LUSTs) with

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TCE-contaminated sludge were found at the Millsboro TCE site. The TCE formed a plume approximately 1,500 feet long, 300 feet wide, and 80 feet deep.[32] This TCE plume migrated through the soil, groundwater, and into two public supply wells serving approximately 3,000 residents in the towns of Millsboro and Dagsboro. The public water supply system was taken offline and water usage restrictions were issued on October 24, 2005.[34] The Millsboro Water Department supplied customers with bottled water and water tankers until the water supply could be restored in November and December 2005. As part of the remediation process, DNREC installed granulated activated carbon (GAC) filters at the wellheads to treat groundwater prior to distribution to residents; sampled domestic wells; and removed the LUSTs, pipes, and approximately 209 tons of contaminated soil. A 2010 consent order between the EPA and the presumed responsible parties (PRPs), Mallinckrodt Veterinary and Merck, Inc. agreed to conduct weekly testing of the water supply system, replacement of the GAC filter, and performance of an aquifer pump test to examine the hydraulic properties of aquifers, evaluate well performance, and identify aquifer boundaries. In 2011, the EPA entered into a second consent order that required the PRPs to develop an Engineering Evaluation/Cost Analysis (EE/CA) to examine the nature and extent of contaminants at the Millsboro TCE site that have been released or are currently being released into the environment.[33] The EE/CA would allow DNREC and the EPA to evaluate removal alternatives to ensure that actions taken to address soil and groundwater contamination and possible vapor intrusion will protect the public and the environment. In 2014, the EPA stated that Millsboros public water supply meets federal state drinking water standards.[34] ThorogoodsConcreteThorogoods Concrete is located two miles east of the Harim Millsboro site. No release data was included in the TRI profile for Thorogoods Concrete. OccupationalHealthThe health of workers is important in the poultry processing industry, especially since many of these workers are often of lower socioeconomic status, and might therefore lack information on the potential hazards they face [105]. The Bureau of Labor Statistics note that employees working in poultry plants face demanding conditions, monotonous and repetitive tasks, and a high risk of potential injury from using sharp tools and slipping on wet floors [106]. The Occupational Safety and Health Administration (OSHA) has identified other risks to poultry workers, such as electrical hazards and exposure to avian flu [110]. The risk of injury and infection is particularly acute in poultry slaughter. A study of self-reported poultry slaughterhouse injuries recorded by OSHA found high rates of skin lacerations on the hands and skin infections on workers who handle sharp tools or handle the birds themselves (Kyeremateng-Amoah, et al., 2014). Another major concern is exposure to chemicals. In two studies into the effects of chemical exposure on respiratory function, it was found that lung function declined due to workers inhaling organic dusts, endotoxins, and ammonia (Donham, et al., 2000; Donham, Cumro, and Reynolds, 2002). Finally, musculoskeletal problems have been

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identified in poultry processing workers due to long periods spent on their feet and in awkward positions [105]. AirandWaterQualitynearHarimMillsboroWaterQualityRegulationsThe Clean Water Act (CWA) regulates water quality standards for navigable surface water (lakes, rivers, streams, etc.) and sets standards for regulating discharges of pollutants into U.S. waters. Under the CWA, it is illegal for a facility to discharge a pollutant from a point source into navigable waters without a National Pollutant Discharge Elimination System (NPDES) permit. A point source is defined in the CWA as, any discernible, confined and discrete conveyance, including but not limited to any pipe, ditch, channel, tunnel, conduit, well, concentrated animal feeding operationfrom which pollutants are or may be discharged. The point sources do not include agricultural stormwater discharges and return flows from irrigated agriculture (33 U.S.C. Section 1362(14)). NPDES permits define pollutants to include any type of industrial, municipal, and agricultural waste that is discharged into the water.[34] Pollutants are grouped into three categories: conventional, toxic, and non-conventional. Conventional pollutants are biochemical oxygen demand, total suspended solids, coliform, oil and grease, and pH. Currently, there is a list of 65 toxic/priority pollutants, which include metals and manmade organic compounds. Non-conventional pollutants do not fall under the previous categories, and contain common poultry-related pollutants such as ammonia, nitrogen, and phosphorous. NPDES permits are typically issued for five years. An individual facility can request a NPDES permit, or a general permit can be issued by the permitting authority (i.e. DNREC). A general permit covers multiple facilities within a specific geographical category such as city, county, or state political boundaries; designated planning areas; sewer districts or sewer authorities; state highway systems; standard metropolitan statistical areas; or urbanized areas. To obtain an individual permit, the facility must submit information including its nature of business, types of pollutants, receiving waters, flow of waters, sources of pollution, treatment technologies, and the reason for discharges. The Safe Drinking Water Act (SDWA) established regulations to protect human health from drinking water contaminants. The SDWA applies to public water systems that provide water for human consumption and regulates water quality standards for microorganisms, disinfectants, disinfection byproducts, inorganic chemicals, organic chemicals, and radionuclides.[35] The systems must have at least 15 service connections or provide service for at least 25 individuals. Smaller water systems, private wells, and systems that do not have collection and treatment facilities are excluded from the SDWA. Owners of private wells are responsible for maintaining the well and performing monitoring tests. The SDWA has two sets of regulations, primary and secondary, that are designed to regulate the quality and content of drinking water. The primary standards are legally enforceable and establish maximum contaminant levels (MCL) to limit the levels of contaminants in water. Secondary standards are non-enforceable guidelines that serve to regulate water quality issues,

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such as taste, odor, color, and cosmetic effects from consumption, such as skin or tooth discoloration.[36] States may choose to enforce certain secondary standards. The SDWAs exclusion of small public systems and private wells is a major limitation for residents who obtain their drinking water from private wells. In Delaware, 17.3% of residents obtain drinking water from private wells, which is above the 15% average for the United States.[37],[38] Private wells are the primary source of drinking water for the estimated 80 residents in the Possum Point neighborhood. Contamination from agricultural runoff, oversaturation of groundwater, and lagoon leakage can all contribute to contamination of well water, and the SDWAs exclusion of private wells puts residents at a risk for consuming contaminated water. WaterQualityProfileIt is important that the quality of groundwater in nearby sources is monitored and quality standards are maintained. If a contaminant can dissolve in water, then it will move along with groundwater and potentially reach public or private wells that supply drinking water.[39] When groundwater contamination occurs in a certain area for a continuous period of time, a large plume of contamination forms and moves along with the groundwater. This plume has the potential to contaminate large volumes of groundwater. In March 2013, Harim Foods hired the consultant BP Environmental, to conduct a Phase I site assessment of the Harim Millsboro facility to examine any environmental conditions associated with the site. The 1,057 page document contained a memo from DNRECs Division of Water Resources regarding the hydrogeological review of the spray irrigation field at the Harim Millsboro site. In a memo dated May 1997, officials stated that there were major concerns regarding the contamination of off-site shallow wells by a groundwater plume moving from the site to nearby wells north and northeast of the site.[40] DNREC stated that the two closest wells, Holiday Acres well (105 ft. deep) and the Colonial Estates well (depth unknown) were 500 feet upgradient and 803 feet lateral, respectively, away from the Harim Millsboro facility. A subsequent analysis of the BP Environmental Phase I site assessment conducted by the Inland Bays Foundation noted that the well distance given by DNREC for the Holiday Acres well was incorrect and is actually 125 ft. from the outer pivot track of the sprayfield nozzle.[41] The Inland Bays Foundation also noted that the nozzle from the sprayer wets 40 ft. past the track, within 85 ft. of the Holiday Acres wellhead, which violates Delawares statute on wastewater treatment and disposal systems, which require the following buffer zones for limited public access spray irrigation sites:

A 150 foot buffer must be maintained between the edge of the wetted field area and all property boundaries.

A 150 foot buffer must be maintained between the edge of the wetted field area and the shoulder of internal and external public roads. Buffers from highways must be measured from the outer edge of the shoulder or edge of the highway, if no shoulder.

A 150 foot buffer must be maintained between the edge of the wetted field area and any public supply well, and a 100 foot buffer from any individual domestic well unless other jurisdictions dictate greater distances.

16

Internal roads that are closed to public use do not require buffer zones. A 100 foot buffer is required between the wetted edge of spray fields and the edge of any

perennial lake or stream or ephemeral drain. A 50 foot buffer is required between spray fields and the edge of any channelized,

intermittent watercourse. If an intermittent watercourse were to become perennial, the 100 foot buffer requirement

will apply. A 50 foot buffer is required between the wetted field area and the edge of any

wetlands.[42] BP Environmental conducted a Limited Subsurface Investigation in April 2013 for Harim Foods to evaluate the environmental issues identified in the Phase I site assessment.[43] The investigation included the installation of 18 wells (12 temporary wells (TWs), and 6 screen point (SP) borings) for groundwater analysis and sampling. The Inland Bays Foundation notes that the sampling locations were all within the center of the upgradient boundary of the plant.[43] None of the BP Environmental sampling wells were located near the outer boundaries of the poultry processing plant and closer to the residential communities. In addition, it was also noted that the area where aboveground brine storage tanks were held was not tested for chloride, sodium, or nitrates, although this was likely an area where spills of brine commonly occurred. In samples taken by BP Environmental, levels of chloride, total dissolved solids (TDS), chromium, nitrate, volatile organic compounds (VOCs), and carcinogenic and non-carcinogenic polycyclic aromatic hydrocarbons (PAHs) exceeded their groundwater quality levels. AirQualityRegulationsThe Clean Air Act (CAA) is a major federal law that regulates air emissions from stationary and mobile sources.[44] The 1990 amendment of the CAA authorized the EPA to set National Ambient Air Quality Standards (NAAQS) for hazardous air pollutants that are harmful to public health and the environment.[45] These six pollutants - ozone, particulate matter, carbon monoxide, nitrogen oxides, sulfur dioxides, and lead - are referred to as criteria air pollutants. . The CAA also regulates hazardous air pollutants (commonly referred to as toxic air pollutants or air toxics), which are pollutants that cause or may cause cancer or other serious health effects, such as reproductive effects, birth defects, or adverse environmental and ecological effects.[46] The 1990 amendment also required the issuance of technology-based standards for major sources of pollution and area sources of pollution. A major source is defined as a stationary source or group of stationary sources that emit or have the potential to emit 10 tons per year or more of a hazardous air pollutant or 25 tons per year or more of a combination of hazardous air pollutants.[46] While an area source is any stationary source that is not a major source. States carry out CAA regulations by creating enforceable state implementation plans (SIPs), which translate NAAQS into emission limitations, control measures, monitoring requirements, and schedules for compliance that govern individual sources of air pollution.[47] SIPs establish state permitting programs to regulate individual facilities. Preconstruction permits apply to major new sources or major modifications of an existing source, and describe the facilitys proposed air pollution abatement systems, allowable emission rates, and other requirements. Most major stationary sources are required to obtain operating permits, which

17

specify each sources emission limitations and standards, compliance schedule, reporting requirements, and other conditions. SIPs for Delaware include:[48]

8-hour ozone national ambient air quality standard (NAAQS) for the Philadelphia-Wilmington-Atlantic City, PA-NJ-MD-DE moderate nonattainment area (Philadelphia Area)

Ozone Nonattainment Plan for the Philadelphia-Wilmington-Trenton Ozone

Nonattainment Area

15% Rate of Progress Plan for the Delaware Portion of the Metropolitan Philadelphia Ozone Nonattainment Area

Rate of Progress (ROP) Plan for the Delaware Portion of the Philadelphia 1997 8-Hour

Ozone Moderate Nonattainment Area

Post-1996 Rate of Progress Plan and Contingency Measures for the Delaware Portion of the Philadelphia-Wilmington-Trenton Ozone Nonattainment Area

ToxicSubstancesThe Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly referred to as Superfund, regulates the cleanup of waste sites and handles liability issues. Specifically, CERCLA established prohibitions and requirements regarding closed and abandoned hazardous waste sites, provides for liability of persons responsible for releases of hazardous waste at these sites, and establishes a trust fund to provide for cleanup when a no responsible party could be identified.[49] CERCLA authorizes short-term and long-term responses to waste sites. With short-term removals, actions can be taken to address releases or threatened releases requiring prompt response. Long-term remedial response actions are designed to permanently and significantly reduce the dangers associated with releases or threats of releases of hazardous substances that are serious, but not immediately life threatening. These actions can be conducted only at sites listed on EPA's National Priorities List (NPL). CERCLA amendments in 2002 (42 U.S. Code 9601) defined a brownfield site as, a real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant. Under the EPAs Brownfields Program, grants are provided to designated brownfield sites to support activities that facilitate the environmental assessment, cleanup, and job training necessary to revitalize the sites. The Emergency Planning and Community Right-to-Know Act (EPCRA) governs the emergency response and reporting requirements related to releases of hazardous and toxic chemicals. EPCRA requires that local governments prepare chemical emergency response plans and review them annually.[50] States must coordinate and oversee the planning of response plans. The law also requires that facilities must immediately report accidental releases of extremely hazardous

18

chemicals and hazardous substances in quantities greater than the reportable quantity defined under CERCLA to states and local governments. The details of the releases must be made public. EPCRAs Community-Right-To-Know provisions require that facilities involved in the manufacturing, processing, or storing designated hazardous chemicals must make Material Safety Data Sheets (MSDSs) available to state and local officials and local fire departments. A MSDS is a form that describes the chemical properties and possible health effects due to exposure from a specific chemical. Facilities must also report the inventory of all on-site chemicals for which MSDSs exist. Information about chemical inventories at facilities and MSDSs must be available to the public. EPCRA also requires that facilities complete a toxic chemical release inventory (TRI) Form R for any of the TRI chemicals that they manufacture or use quantities above the thresholds. Under EPCRA, facilities are allowed to withhold trade secret information regarding the chemical composition of a product if their request for an exemption is approved. CERCLA and EPCRA both contain citizen suit provisions, which allow an individual to sue a facility or government agency for violation of any terms regulated under CERCLA and EPCRA. The enactment of the Resource Conservation and Recovery Act (RCRA) allows the EPA to take a cradle to grave approach in how waste can be handled. The law regulates the generation, transportation, treatment, storage, and disposal of hazardous waste. Hazardous wastes are categorized into three groups: (1.) F-list (non-specific source wastes), (2.) K-list (source-specific wastes), (3.) and P-list and U-list (discarded commercial chemical products).[51] RCRA also sets forth a framework for the management of non-hazardous solid wastes by encouraging states to develop plans to manage nonhazardous industrial solid waste and municipal solid waste (waste from homes, businesses, and schools); set criteria for municipal solid waste landfills and other solid waste disposal facilities; and prohibited the open dumping of solid waste.[52] Amendments to RCRA in 1986 allowed the EPA to address environmental problems due to underground tanks storing petroleum and other hazardous substances. AirQualityProfileEPA Toxic Release Inventory (TRI) data was analyzed in order to examine data on toxic releases. The TRI is a database of information about releases and transfers of toxic chemicals from facilities in specific industrial sectors, such as manufacturing, waste handling, mining, and electricity generation. Facilities must report to TRI if they fulfill the following criteria:

Are a manufacturing facility (primary SIC code in 20-39) or will be one of the non-manufacturing industries added for the 1998 reporting year;

Have the equivalent of 10 full-time workers; Manufacture or process more than 25,000 lbs. of the chemical or use more than 10,000

lbs. during the year; Use a chemical on the TRI list of over 600 specific toxic chemicals or chemical

categories.[53] A TRI release is defined as any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment. TRI facilities have to report the amount of toxic chemical released into the air, water, or land, even if

19

the release to land is within a site designed to contain it. Releases to the air, water, land, or underground at the facility are called on-site releases. If a chemical is transferred to another site for disposal, that is referred to as an off-site release. TRI data on the zip codes of interest show that 144,387 pounds of toxic chemicals were released into the air in 2013. This represents a significant reduction from 2011, during which 1.66 million pounds of toxic chemicals were released into the air (Figure 18). It is possible that the reduction in reported TRI releases was related to the closure of two NRG operating units in 2011. TrafficConcernsThe Harim Millsboro plant aims to process two million birds per week, and estimates have shown that this will involve poultry trucks making 47 trips per day to and from the plant.[54] Harim Millsboro plans to hire 700 employees, thus adding an additional 300-700 vehicles per day traveling to and from the facility. Most areas of Millsboro are 60-80%ile in the country for proximity to traffic (Figure 23). This could pose a big health threat to residents of Millsboro as many of the residents live very close to the areas in which these vehicles will be traveling. In order to get to the plant, diesel trucks and vehicles will need to enter from Iron Branch Road (Road 331). Millsboro residents are concerned because additional trucks and vehicles traveling to or from the downtown Millsboro will drive past two schools. During the summer months, the area is already congested with residents and visitors traveling to the nearby beaches. Route 113 is one of the main freeways used to travel to several Delaware beaches and runs directly through Millsboro. Adding the additional trucks and vehicles into the area will likely increase traffic congestion, pose additional abrasion to the roads, degrade air quality, and present safety concerns within the school zones and to residents living along the Iron Branch Road corridor. Increased diesel trucks on the roads will cause residents living near the plant where truck loading and unloading occurs and residents living along the travel corridor to be exposed to higher levels of diesel exhaust, which is known to contain over 40 toxic air contaminants, some of which are known carcinogens (benzene, arsenic, formaldehyde).[55] Thus, concentrations of pollutants such as nitrogen oxides, carbon monoxide, carbon dioxide, and particulate matter in the air due to vehicle emissions and dust from poultry litter will likely increase. More vehicles on the road will also increase runoff pollution due to rainwater or melting snow collecting dirt, dust, antifreeze, engine oil, pesticides, and fertilizers, and washing off into the nearby rivers, streams, and soil.[56] OdorIssuesMillsboro residents already experience odors when wind direction brings foul odors from the Mountaire Millsboro poultry processing plant into their home. They feel that adding an additional poultry processing plant within a two-mile radius of an existing poultry processing plant would greatly increase the strength of the foul odors. One resident remarked how the stench is unbearable on certain days, causing him to avoid being outside . Studies on chronic exposure to noxious odors have shown that residents living near confined animal feeding operations (CAFOs) report lower measures of quality of life assessments and decreased mood because they felt unable to go outside or open the windows in their home to get fresh air. For

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example, Schiffman et al. (1995) researched residents living near a hog CAFO that emitted noxious gases such as hydrogen sulfide.[57] They found that residents living in the vicinity of a hog CAFO reported more tension, depression, anger, fatigue, confusion, and less vigor than residents living outside of the vicinity of a hog CAFO. An assessment of the residents scores on a Total Mood Disturbance survey was also higher among residents living near the CAFO, highlighting the significant psychological impact of exposure to foul-smelling odors. ZoningRegulationsThe Harim Millsboro site is zoned as heavy industrial (see Appendix D), and the company requested an exemption from the Sussex County Board of Adjustments (BOA) for the classification as a potentially hazardous use of the site. The request was approved, however local residents and members of Protecting Our Indian River noted that while an environmental assessment was conducted prior to approving the zoning to allow hazardous land use, a health assessment was not conducted, although a health assessment is required by Sussex County law. The health impacts are especially important to the residents because they live in a community with multiple sources of pollution already in existence and higher rates of cancer and respiratory diseases. In addition, the residents felt that the approval process was rushed and that they were not given sufficient time to make written statements. For example, Delaware Code - Section 6812: Public Hearing And Notice mandates that public notice of a hearing must be given at least 15 days prior to the date of the hearing. A June 3, 2013 Board of Adjustments meeting stated that the public hearing on the zoning was closed, yet the topic was reopened on June 17, 2013 to allow 30 days for agency comments and seven days for public comments. Residents were not notified that the topic was reopened and did not feel that seven days was adequate time to review the material, consult with experts, and prepare a response. MillsboroInhalationandBiomonitoringStudyA 2007 study conducted by the Delaware Department of Health and Social Services reported a significantly higher incidence rate of cancer among residents living near the NRG Indian River plant as compared with other counties in Delaware and the rest of the United States. In response, state officials examined PM2.5 exposure levels among 32 residents during the Fall of 2011 and 2012. The Millsboro Inhalation and Biomonitoring study focused on pollution from local, state, and out-of-state sources that contributed to residents overall exposure levels of PM2.5.[58] During the Season 1 sampling period (Oct.-Nov. 2011), the NRG Indian River plant was not operational due to the installation of pollution-controlling technology. During the Season 2 sampling period (Oct.-Nov. 2012), the plant was operational, but not at 100% capacity. In each sampling period, participants provided biospecimen samples (hair, blood, and urine) and agreed to wear personal air monitors during their normal daily activities. The researchers also employed monitors to assess the level and composition of PM2.5 inside the residents homes and at residential outdoor locations. Four fixed-site outdoor monitors were also placed within a 2.5-mile radius of the NRG Indian River site. Samples were also taken from the Seaford, DE, stationary monitor for comparison. Researchers found that the average PM2.5 concentrations over the two seasons for indoor residential, outdoor residential, ambient air in Millsboro and, DE, were all below the EPA air

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quality standard of 15 g/m3 (Table 4). After assessing the concentration and composition of the PM2.5 samples, the researchers determined that the predominant source of PM2.5 was due to regional and long range transport from cities such as Baltimore (approx. 108 miles), Boston (approx. 420 miles), and New York City (approx. 210 miles). The investigators associated the higher indoor air concentrations with the strength of proximity to sources of PM2.5 such as cooking, cleaning, candle burning, and smoking. ChemicalsDuring discussions with residents about the placement of the Harim Millsboro plant, many voiced concerns about chemicals being emitted from the plant into the air and water, and the health effects associated with exposure to those chemicals. This section will provide an analysis on the chemicals of concern identified by the residents along with chemicals found in high concentration at the Harim Millsboro site.

Chemical Description EPA Standards Health Effects EPA Carcinogen Analysis

Arsenic* Colorless and odorless chemical found naturally in the earths crust

MCL of 0.010 mg/L for drinking water

Acute exposure - nausea, vomiting, numbness or burning sensations in the hands and feet, cardiovascular effects, and fatigue. Chronic exposure- skin discoloration and thickening of soles of feet and palms of hands.

Yes chronic exposure associated with an increased risk of skin, bladder, kidney, prostate, and lung cancer

Chloride* Solid, clear crystal with little or no odor

SMCL of 250 mg/L for drinking water

No known health effects. Can cause corrosion in metal pipes, thus increasing amount of heavy metals in water.

No

Chromium -3 and Chromium-6*

Odorless and tasteless metallic element

MCL of 0.1 mg/L for drinking water

Skin irritation from ingestion. Shortness of breath, coughing, and wheezing from acute exposure via inhalation. Bronchitis, pneumonia, decreased lung function, and destruction of nasal septum from chronic exposure via inhalation

Chromium-6 carcinogenic when inhaled and possible carcinogen when ingested

Cobalt Silver-grey solid metallic element

None Nausea, vomiting, vision problems, skin irritation, thyroid damage, heart problems, death from oral exposure. Decreased lung function, congestion, edema, and hemorrhage from acute inhalation. Chronic inhalation respiratory irritation, wheezing,

EPA has not classified cobalt for carcinogenicity

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Chemical Description EPA Standards Health Effects EPA Carcinogen Analysis

heart problems, asthma, pneumonia, fibrosis.

Hydrogen Sulfide* Colorless gas with a rotten egg odor

None. OSHA has set standards for occupational exposure.

Acute exposure -nausea, headache, irritation of the eyes and respiratory tract, and death at extremely high concentrations (over 500 ppm). Chronic exposure- impaired vision, sense of smell, dizziness, and possible neurological defects.

EPA has not classified hydrogen sulfide for carcinogenicity

Lead Bluish grey solid metal

None. EPA maximum action level for lead in drinking water is 0.015 mg/L2

Central nervous system effects impaired ability to learn, increased irritability, behavioral issues, motor clumsiness. Organ failure, hypertension, kidney failure, paralysis, reproductive effects

EPA designation for lead is a probable human carcinogen by ingestion

Nitrate* Colorless, odorless, tasteless compound

MCL of 10 mg/L for drinking water

Methemoglobemia, dizziness, headache, difficulty breathing, brain damage, death

EPA has not classified nitrate for carcinogenicity

Particulate Matter (PM2.5 and PM10)*

Solid and liquid particles found in the air

See Table 5 Acute exposure -Asthma, heart attack, irritation of airways, coughing, decreased lung function. Chronic exposure-increased mortality among individuals with chronic heart or lung disease

EPA designation for diesel particulate matter - likely to be carcinogenic to humans by inhalation

Volatile Organic Compounds (VOCs)*

Gases in the air that form from liquids or solids

EPA MCL for Total Trihalomethanes (TTHM) in drinking water is 0.08 mg/L

Acute exposure - eye, nose and throat irritation, headache, nausea, vomiting, dizziness, worsening of asthma symptoms. Chronic exposure to high levels- damage to liver, kidneys, and central nervous system.

Bromoform - Probable human carcinogen Chloroform likely to be carcinogenic Dibromodichloromethane not classifiable as carcinogenic

Trichloroethylene (TCE)

Colorless or blue liquid with a sweet-smelling

EPA MCL for TCE in drinking water is 0.005 mg/L

Acute effects of exposure to TCE via inhalation can cause dizziness, tiredness, headaches, and a loss of coordination. Acute exposure to large quantities in air can

Likely to be carcinogenic by all routes of exposure

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Chemical Description EPA Standards Health Effects EPA Carcinogen Analysis

cause unconsciousness or death. Chronic exposure - changes in mood, memory, attention, reaction time, or vision when inhaled.

MCL maximum contaminant level under the Safe Drinking Water Act Primary Standards SMCL secondary maximum contaminant level under the Safe Drinking Water Act Secondary

Standards NAAQS National Ambient Air Quality Standards

*Common poultry processing plant pollutant

Arsenic What is arsenic and how can exposure in drinking water occur? Arsenic is a colorless and odorless chemical found naturally in the earths crust.[59] Arsenic usually found in the environment combined with other elements such as oxygen, chlorine, and sulfur is called inorganic arsenic.[60] Arsenic combined with carbon and hydrogen is referred to as organic arsenic. Organic forms of arsenic are usually less harmful than inorganic forms. Arsenic also has industrial uses in pigments and dyes, in preservatives of animal hides, glass manufacturing, agricultural pesticides, fertilizers, and various pharmaceutical substances. When arsenic is released into the air from industrial waste, it can remain in the environment for a long time before it is removed from the air by rain, snow, and gradual settling.[61] Once on the ground or in surface water, arsenic can enter groundwater sources and affect drinking water. Arsenic can also enter groundwater due to the erosion of natural deposits of the earths crust.[62] People living near factories, waste sites or farms where arsenic or pesticides were once used may be susceptible to arsenic exposure.[63] What are the health effects of arsenic exposure? The acute (short term) health effects of arsenic exposure include nausea, vomiting, numbness or burning sensations in the hands and feet, cardiovascular effects, and fatigue from decreased production of red and white blood cells.[64] Chronic (long term) exposure to arsenic can result in skin discoloration, skin thickening, and small corn-like growths on the palms of the hand and soles of the feet. Chronic exposure to arsenic is also associated with an increased risk of skin, bladder, kidney, prostate, and lung cancer. Is there an EPA maximum contaminant level (MCL) for arsenic in drinking water? Arsenic is included under EPAs National Primary Drinking Water Regulations, thus regulation of arsenic levels in drinking water in public water supplies is legally enforceable. The EPA MCL for arsenic in drinking water is 0.010 mg/L.

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What are the arsenic levels on and around the Harim Millsboro site? Elevated arsenic levels of 18.2 mg/L and 5.7 mg/L were found in samples taken during the BP Environmental Limited Subsurface Investigation in 2013. Between 2004-2015, Delawares Office of Drinking Water tested arsenic levels in eight water samples from Colonial Estates and Holiday Acres. Seven of the samples tested below the reporting level of 0.0005 mg/L. When the reporting limit decreased to 0 mg/L for the 12/16/2011 sample from Colonial Estates, the results showed an arsenic level of 0.0005 mg/L. A sample taken from a home located in the Possum Point community had a level of 0.0099 mg/L. These results are under the EPA MCL for arsenic, but data from the Inland Bays Foundation has noted that an arsenic level of 0.0005 mg/L can present an excess of 2.5 additional cancer risk per 100,000 residents.[43] Chloride What is chloride and how can exposure in drinking water occur? Chlorides are mineral compounds that are dissolved by the water as it filters through the earth.[65] They are distributed in nature as salts of sodium (NaCl), potassium (KCl), and calcium (CaCl2) and appear as a solid, clear crystal with little or no odor. Sodium chloride, calcium chloride, and magnesium chloride are commonly used in snow and ice control.[66] Potassium chloride is also used in the production of fertilizers. Chlorides can migrate into groundwater sources from landfill leachates, septic tank effluents, industrial effluents, irrigation drainage, seawater intrusion in coastal areas and animal feed. Is there an EPA maximum contaminant level (MCL) for chloride in drinking water? Chloride is included under the EPAs National Secondary Drinking Water Regulations, therefore the secondary maximum contaminant level (SMCL) of 250 mg/L is not federally enforceable for public or private water supplies, but is intended to be used as a guideline for states.[66] What are the health effects of chloride exposure? A salty taste in drinking water is typically evident when chloride levels above the SMCL of 250 mg/L.[64] Although there are no known health effects that can develop from exposure of chloride in drinking water, high levels of chloride can react with metal pipes and form soluble salts that cause corrosion, thus increasing the level of heavy metals in drinking water.[67] What are the chloride levels on and around the Harim Millsboro site? BP Environmental groundwater testing data from the Harim Millsboro site revealed a chloride level of 560 mg/L, more than twice the SMCL, in a sampling well within the vicinity of an abandoned underground storage tank (UST) used to hold brine.[45] DNREC groundwater

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samples taken between 1989 and 2013 from monitoring wells located in the Harim Millsboro spray fields show levels of chloride exceeding the EPA MCL eight times within a thirteen-year period (Figure 19). DNREC groundwater samples of chloride taken between 2005-2015 from Holidays Acres show levels between 12-16.3 mg/L; Colonial Estates samples were between 25.8-34.9 mg/L (Figure 20) Chromium What is chromium and how can exposure in drinking water occur? Chromium is an odorless and tasteless metallic element.[68] Trivalent chromium (chromium-3) is found naturally in many fruits, vegetables, and yeast. Chromium-3 is also used in poultry feed as it has been found to increase the weight and meat quality of broiler chickens while also decreasing the fat content.[69] Hexavalent chromium (chromium-6) can be found naturally in the environment from the erosion of natural chromium deposits, but it can also be produced in industrial processes. Evidence of chromium-6 entering the environment has occurred through leakage, poor storage, or inadequate industrial waste disposal practices. What are the health effects of chromium exposure? Consuming drinking water contaminated with chromium over several years can cause allergic dermatitis (skin irritation). When inhaled, chromium-6 is considered a carcinogen, and in September 2010, the EPA drafted an assessment to examine whether chromium-6 should be considered a carcinogen when ingested.[70] The final decision is pending. Is there an EPA maximum contaminant level (MCL) for chromium in drinking water? Total chromium is included under EPAs National Primary Drinking Water Regulations, thus regulation of chromium levels in drinking water in public water supplies is legally enforceable. The maximum contaminant level for chromium is 0.1 mg/L. In 2012, EPAs 3rd Unregulated Contaminant Monitoring Rule (UCMR 3) required public water systems serving over 10,000 people and some smaller systems to monitor water for 30 different contaminants, including hexavalent chromium and total chromium.[71] What are the chromium levels on and around the Harim Millsboro site? Of the 18 water wells that BP Environmental installed on the Vlasic site, three were tested for chromium, and elevated levels were found in two of the sampled wells (see Appendix C). BP Environmental noted in its Limited Subsurface Investigation that the source of the chromium was unknown and warranted further investigation (pp. 21).[45] EPAs 1991 Record of Decision assessment of the NCR Corporation Superfund site noted that elevated levels of chromium were discovered in groundwater samples.[72] NCR manufactured

26

cash registers, and a chrome finish was applied to the cash register parts. The assessment noted that contaminated groundwater continued to migrate and posed threats to human health and drinking water sources if site remediation did not occur. The contamination migration route occurred in areas to the north and northeast of the site. Delawares Office of Drinking Water tested the public wells in Holiday Acres and Colonial Estates. In an analysis of 2005-2014 data, chromium was detected in the drinking water samples from both sites at levels below the EPA maximum contaminant level (MCL) of 0.1 mg/L, but above the DNRECs Site Investigation and Remediation Section (SIRS) screening level of 0.0

mg/L.[73],[74] Four out of 15 samples taken from private wells in Possum Point in 2014 showed

chromium levels between 0.00063 mg/L 0.0511 mg/L. CobaltWhat is cobalt and how can exposure in drinking water occur? Cobalt is a naturally occurring metal that is a silvery grey solid at room temperature.[75] It can be found in rocks, soil, water, and plant roots. .[76] In addition, cobalt is a component of vitamin B12, thus is an essential element for animals and humans. Cobalt also has many industrial uses. For example, it is often mixed with other metals to form an alloy, a stronger metal that is less prone to corrosion, and used in aircraft engines, magnets, and tools used for grinding and cutting. Cobalt compounds are used as colorants in glass, paints, ceramics, and paint driers. It is also used as an additive in phosphate fertilizers to increase plant growth.[77] Furthermore, some types of cobalt give off radiation.Radioactive cobalt is used most commonly in the medical field to administer radiation therapy to cancer patients.[78] However, radioactive cobalt is also used in food irradiation, the process of applying radiation to food, to sterilize food, destroy pathogens, extend the shelf life, disinfect fruits and grains, delay ripening, and slow the growth of sprouts on foods such as potatoes and onions.[74] Cobalt particles can be released from coal-fired power plants, incinerators, vehicular exhaust, through the mining and processing of cobalt ores. Once cobalt is in the environment, it cannot be destroyed. Cobalt particles in windblown dust, seawater spray, volcanic eruptions, and forest fires and may get into surface water from runoff and leaching when rainwater washes through soil and rock containing cobalt.74 Groundwater concentrations of cobalt typically average between .001 to .01 mg/L, but can be higher in regions rich with cobalt (Minnesota, Alaska, California, Idaho, Michigan, Missouri, Montana, Oregon, and Pennsylvania) or near mining and smelting operations.[74],[79] What are the health effects of cobalt exposure? The consumption of cobalt has been associated with nausea, vomiting, vision problems, dermatitis, thyroid damage, heart problems, and even death.[80] The EPA has not classified cobalt as a cancer-causing agent in humans.[81] Is there an EPA maximum contaminant level (MCL) for cobalt in drinking water?

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The EPA has not set primary or secondary drinking water regulations for cobalt. Currently, cobalt is included in the EPAs drinking water Contaminant Candidate List 3 (CCL 3), a list of contaminants that are not subject to any current or proposed national primary drinking water regulations, but are known or anticipated to occur in public water systems. The EPA has determined that contaminants listed on the CCL may require future regulation under the Safe Drinking Water Act (SDWA). What are the cobalt levels on and around the Harim Millsboro site? The 2013 BP Environmental Brownfield Investigation (BFI) Report noted that cobalt levels in groundwater exceeded the DNREC SIRS level of 0.6 g/L (.0006 mg/L) in four monitoring wells on the Pinnacle site (see Appendix C). Currently, the Delawares Office of Drinking Water does not monitor public wells for cobalt. Nine out of the 15 private well samples taken from Possum Point homes in 2014 contained levels of chromium. Samples ranged from 0.0018 mg/L to 0.523 mg/L. Lead What is lead and how can exposure in drinking water occur? Lead is a naturally occurring metal. Small amounts of lead can be found in soil, water, and air before 1978 (EPA). Due to lead accumulation in the atmosphere and animals, traces of lead may be found in poultry manure and waste offal which may discharge into groundwater and streams. Is there an EPA maximum contaminant level (MCL) for lead in drinking water? While there is no set maximum contaminant level for lead in drinking water, EPA does monitor lead levels in water using a treatment technique (TT) that measures the corrosiveness of the water. The maximum action level discovered by a TT for lead in drinking water is 0.015 mg/L^2 (EPA). According to the Center for Disease Control, there is no safe blood level of lead in children. What are the health effects of lead exposure? Lead is a known neurotoxin that irreversibly attacks the peripheral and central nervous system which leads to an impaired ability to learn, increased irritability, behavioral issues, motor clumsiness, and organ failure primarily in children. In adults, lead at low levels causes hypertension and kidney failure. At high levels, lead is known to cause paralysis and complications with the male and female reproductive systems [111], [115]. Pregnant women and children are most sensitive to lead exposure because of lead's ability to mimic and replace calcium absorption in the human body [118]. Children who are rapidly growing and absorbing calcium, can accumulate high levels of lead in their bones and blood which cause physical and cognitive delays (Holtzman).

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What are the lead levels on and around the Harim Millsboro site? Millsboro, DE, drinking water measured lead levels of 14.4 parts per billion while one site out of 22 sites exceeded the Treatment Techniques action level as reported by the Annual Drinking Water Quality Report for 2011 for the town of Millsboro [118]. NitratesWhat are nitrates and how can exposure in drinking water occur? Nitrate is formed by a reaction between nitrogen and oxygen that forms a colorless, odorless, and tasteless compound. Nitrates are found naturally in the environment as microorganisms break down organic materials such as fertilizers, decaying plants, and manure.[82] Plants typically take up nitrates, but rainfall or irrigation can cause nitrates to leach into groundwater. At moderate levels, nitrates are harmless components of sources of food and water. High levels of nitrates are usually attributable to human activities such as the use of fertilizers and manure on spray fields, animal feedlots, municipal wastewater and sludge, septic systems, and nitrogen fixation from the atmosphere by legumes, bacteria, and lightning.[82] Due to the large pore size and high porosity of sandy soils, shallow groundwater below sandy soils such as on Delaware coast, are susceptible to relatively high nitrate contaminated Shallow groundwater below sandy soils is susceptible to nitrate contamination.[82] This presents a risk to residents who obtain their drinking water from shallow wells, as their water can be prone to nitrate contamination. Is there an EPA maximum contaminant level (MCL) for nitrates in drinking water? Nitrate is included under EPAs National Primary Drinking Water Regulations, thus regulation of nitrate levels in drinking water in public water supplies is legally enforceable. The EPA MCL for nitrates in public water systems is 10 mg/L. What are the health effects of nitrate exposure? Consumption of drinking water with high levels of nitrates can have adverse health effects, particularly on infants and pregnant women. For example, methemoglobinemia, a form of nitrate poisoning, occurs when nitrates in the body are converted to nitrite and absorbed into the blood.[83] The hemoglobin is then converted to methemoglobin, which does not carry oxygen as efficiently as hemoglobin. Infants, pregnant women, and individuals who are deficient in the enzyme that turns methemoglobin back to hemoglobin are all susceptible to methemoglobinemia. This disease results in a bluish color of the skin, especially around the eyes and mouth. Symptoms include dizziness, headache, difficulty breathing, brain damage, and death. What are the nitrate levels on and around the Harim Millsboro site?

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Groundwater nitrate levels of 2.0 mg/L and higher are typically strong indicators that land use is affecting the quality of groundwater.[84] BP Environmental found elevated nitrate levels of 4.2 mg/L and 9.9 mg/L at two of the 18 sampling wells from the Pinnacle site.[45] An analysis of 2005-2015 Holiday Acres and Colonial Estates public water system sampling data from the Delaware Division of Public Healths Drinking Water Watch found that all sample values were below the DNREC reporting limit of 0.3 mg/L.[73] HydrogenSulfide What is hydrogen sulfide and how can exposure occur? Hydrogen sulfide (H2S) is a colorless volatile gas with a strong rotten egg odor. It is found naturally in the environment and from man-made processes. It can be found in gases exerted from volcanoes, sulfur springs, swamps, natural gas, petroleum and stagnant bodies of water.[85] Industrial sources of H2S include petroleum refineries, natural gas plants, petrochemical plants, coke oven plants, and food processing plants. During poultry processing H2S is formed during the storage, handling, and decomposition of protein and other sulfur-containing components such as animal waste that often occur in underground sewers.[86] With humans, bacteria found inside the mouth and gastrointestinal tract produce hydrogen sulfide during the digestion of food containing vegetable or animal proteins. It is denser than air and can remain in the atmosphere for up to 18 hours.[87] What are the NAAQS standards for hydrogen sulfide? Currently, the EPA does not have NAAQS standards set for H2S levels in the environment. The Occupational Safety and Health Administration (OSHA) set standards for the exposure of H2S in the workplace. OSHA set an acceptable ceiling limit of 20 ppm for hydrogen sulfide in workplace air; the ceiling limit is a 15-minute time-weighted average that cannot be exceeded at any time during the working day. What are the health effects of hydrogen sulfide exposure? The odor from H2S is noticeable at low concentrations anywhere from 0.0005 to 0.3 parts per million. At high concentrations, a person can lose their ability to smell H2S, which is problematic because he or she might falsely think that hydrogen sulfide is no longer present, thus increasing their exposure risk to air levels that can cause serious health effects. In addition to the noxious smell of H2S, exposure can cause nausea, headache, and irritation of the eyes and respiratory tract. Acute exposure at extremely high concentrations (over 500 ppm) can cause death. Chronic exposures have resulted in impaired vision, sense of smell, dizziness, and possible neurological defects. The EPA has determined that data for hydrogen sulfide are inadequate to make an assessment on whether exposure causes cancer. What are the hydrogen sulfide levels on or around the Harim Millsboro site? Air monitoring data on H