Rapid

Health Impact Assessment

Millsboro, DE
Leah Baskin Graves, MPH, Aaron Aber, Natalie Agee, Ben Grimes, and Lionel
Wilson

Maryland Institute for Applied Environmental Health
School of Public Health
University of Maryland College Park

Table of Contents
Executive Summary ................................................................................................................................................. 4
Acknowledgements ................................................................................................................................................. 4
HIA Introduction ....................................................................................................................................................... 5
HIA Screening ............................................................................................................................................................. 5
HIA Scoping ................................................................................................................................................................. 6
HIA Assessment ......................................................................................................................................................... 6
Geographic Analysis of Target Community: Millsboro, DE ............................................................... 6
Population and Sociodemographic Data ................................................................................................... 7
Poultry Processing Overview ......................................................................................................................... 7
Millsboro Health Status ..................................................................................................................................... 8

Access to Healthcare ...................................................................................................................................................... 8

Respiratory Issues ........................................................................................................................................................ 9
Cancer ................................................................................................................................................................................ 9
Mortality Rates and Birth Weight ........................................................................................................................ 10
Overburden of Industrial Facilities ........................................................................................................... 11
NRG Indian River Power Plant .............................................................................................................................. 11
Mountaire Millsboro Poultry Processing Plant .............................................................................................. 11
NCR Superfund Site .................................................................................................................................................... 12
Millsboro TCE Site ...................................................................................................................................................... 12
Thorogoods Concrete ................................................................................................................................................ 13
Occupational Health ........................................................................................................................................ 13
Air and Water Quality near Harim Millsboro ....................................................................................... 14
Water Quality Regulations ...................................................................................................................................... 14
Water Quality Profile ................................................................................................................................................. 15
Air Quality Regulations ............................................................................................................................................. 16
Toxic Substances ......................................................................................................................................................... 17
Air Quality Profile ....................................................................................................................................................... 18
Traffic Concerns ........................................................................................................................................................... 19
Odor Issues .................................................................................................................................................................... 19
Zoning Regulations ..................................................................................................................................................... 20
Millsboro Inhalation and Biomonitoring Study .............................................................................................. 20
Chemicals ............................................................................................................................................................. 21
Arsenic ............................................................................................................................................................................. 23
Chloride ........................................................................................................................................................................... 24
Chromium ...................................................................................................................................................................... 25
Cobalt ............................................................................................................................................................................... 26
Lead .................................................................................................................................................................................. 27
Nitrates ............................................................................................................................................................................ 28
Hydrogen Sulfide ......................................................................................................................................................... 29
Particulate Matter (PM)............................................................................................................................................ 30
Trichloroethylene (TCE) .......................................................................................................................................... 31
Volatile Organic Compounds (VOCs) .................................................................................................................. 32

HIA Reporting and Recommendations ........................................................................................................ 33

Reporting ............................................................................................................................................................. 33
2

Key Findings .................................................................................................................................................................. 33

Recommendations ........................................................................................................................................... 34

Appendix A Tables and Figures ................................................................................................................... 38

Figures ................................................................................................................................................................... 38
Tables ..................................................................................................................................................................... 49
Appendix B NCR Monitoring Well TCE Exceedances ......................................................................... 51
Appendix C BP Environmental Well Monitoring Exceedances from the Harim Millsboro
Site ............................................................................................................................................................................... 52
Appendix D Zoning Map .................................................................................................................................. 53

Executive Summary
In 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.

Acknowledgements
The 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
4

HIA Introduction
A 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.

HIA Screening
Sussex 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
5

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.

HIA Scoping
In 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.

HIA Assessment
Geographic Analysis of Target Community: Millsboro, DE
Millsboro, 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
6

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.
Population and Sociodemographic Data
In 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).
Poultry Processing Overview
The 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
7

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.
Millsboro Health Status

Access to Healthcare
The 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
8

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.
Respiratory Issues
An 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.
Cancer
In 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.

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.
Mortality Rates and Birth Weight
Sussex 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.

10

Overburden of Industrial Facilities

Within 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.
NRG Indian River Power Plant
The 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) MultiPollutant 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.
Mountaire Millsboro Poultry Processing Plant
The 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
11

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]
NCR Superfund Site
The 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]
Millsboro TCE Site
The 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
12

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]
Thorogoods Concrete
Thorogoods Concrete is located two miles east of the Harim Millsboro site. No release data was
included in the TRI profile for Thorogoods Concrete.
Occupational Health
The 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

13

identified in poultry processing workers due to long periods spent on their feet and in awkward
positions [105].
Air and Water Quality near Harim Millsboro
Water Quality Regulations
The 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. Nonconventional pollutants do not fall under the previous categories, and contain common poultryrelated 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,

14

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.
Water Quality Profile
It 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.
15

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.
Air Quality Regulations
The 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

16

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 PhiladelphiaWilmington-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

Toxic Substances
The 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

17

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.
Air Quality Profile
EPA 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 nonmanufacturing 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
18

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.
Traffic Concerns
The 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]
Odor Issues
Millsboro 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
19

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.
Zoning Regulations
The 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.
Millsboro Inhalation and Biomonitoring Study
A 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 2.5mile 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
20

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.
Chemicals
During 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

Arsenic*

Colorless and
odorless
chemical
found
naturally in
the earths
crust

MCL of 0.010
mg/L for drinking
water

Chloride*

Solid, clear
crystal with
little or no
odor

SMCL of 250 mg/L

for drinking water

Chromium -3 and
Chromium-6*

Odorless and
tasteless
metallic
element

MCL of 0.1 mg/L

for drinking water

Cobalt

Silver-grey
solid metallic
element

None

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.
No known health effects.
Can cause corrosion in
metal pipes, thus
increasing amount of
heavy metals in 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
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 Carcinogen
Analysis
Yes chronic
exposure associated
with an increased risk
of skin, bladder,
kidney, prostate, and
lung cancer

No

Chromium-6
carcinogenic when
inhaled and possible
carcinogen when
ingested

EPA has not classified

cobalt for
carcinogenicity

21

Chemical

Description

EPA Standards

Hydrogen Sulfide*

Colorless gas
with a rotten
egg odor

None. OSHA has

set standards for
occupational
exposure.

Lead

Bluish grey
solid metal

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

Nitrate*

Colorless,
odorless,
tasteless
compound
Solid and
liquid
particles
found in the
air

MCL of 10 mg/L
for drinking water

Gases in the
air that form
from liquids
or solids

EPA MCL for

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

Particulate Matter
(PM2.5 and PM10)*

Volatile Organic
Compounds
(VOCs)*

Trichloroethylene
(TCE)

Colorless or
blue liquid
with a sweetsmelling

See Table 5

EPA MCL for TCE

in drinking water is
0.005 mg/L

Health Effects
heart problems, asthma,
pneumonia, fibrosis.
Acute exposure -nausea,
headache, irritation of the
eyes and respiratory
tract, and death at
extremely high
concentrations (over 500
ppm). Chronic exposureimpaired vision, sense of
smell, dizziness, and
possible neurological
defects.
Central nervous system
effects impaired ability
to learn, increased
irritability, behavioral
issues, motor clumsiness.
Organ failure,
hypertension, kidney
failure, paralysis,
reproductive effects
Methemoglobemia,
dizziness, headache,
difficulty breathing,
brain damage, death
Acute exposure -Asthma,
heart attack, irritation of
airways, coughing,
decreased lung function.
Chronic exposureincreased mortality
among individuals with
chronic heart or lung
disease
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.
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

EPA Carcinogen
Analysis
EPA has not classified
hydrogen sulfide for
carcinogenicity

EPA designation for

lead is a probable
human carcinogen by
ingestion

EPA has not classified

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

Bromoform - Probable
human carcinogen
Chloroform likely to
be carcinogenic
Dibromodichlorometh
ane not classifiable
as carcinogenic
Likely to be
carcinogenic by all
routes of exposure

22

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.
23

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
24

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
25

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

[74]

mg/L.[73],
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.
Cobalt
What 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?
26

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).
27

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].
Nitrates
What 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?

28

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]
Hydrogen Sulfide
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 H2S was not available. For H2S emissions data, please see the section on
Mountaire Millsboro.
29

Particulate Matter (PM)

What is particulate matter and how can exposure occur?
Particulate matter (PM) is a mixture of solid particles and liquid droplets found in the air. Some
particles, such as dust, dirt, soot, or smoke, are large or dark enough to be seen with the naked
eye, while others are so small that they can only be detected through a microscope.[88]
PM includes inhalable coarse particles (PM10) that have diameters larger than 2.5 micrometers
and smaller than 10 micrometers. Sources of PM10 include smoke, dirt, and dust from factories,
farming, and roads. Mold, spores, and pollen are also sources of PM10. Fine particles (PM2.5)
have diameters that are 2.5 micrometers and smaller. To get an idea on the size of PM2.5, the
average human hair is about 70 micrometers in diameter, thus it is approximately 30 times larger
than PM2.5. Sources of PM2.5 include all types of combustion, including motor vehicles, power
plants, residential wood burning, forest fires, agricultural burning, and some industrial
processes.[89]
PM has many different sizes and shapes and can be made up of hundreds of different chemicals.
Primary particles are emitted directly from a source, such as construction sites, unpaved roads,
fields, smokestacks or fires. The majority of PM in the United States consists of secondary
particles, which are formed during reactions in the atmosphere of chemicals such as sulfur
dioxides and nitrogen oxides that are emitted from power plants, industries and automobiles.
PM2.5 is lighter, thus the particles can stay in the air longer and travel farther. For example,
PM2.5 particles can stay in the air for days or weeks and can travel hundreds of miles to other
states or regions.88 PM10 can stay in the air for minutes or hours and travel as anywhere from a
few hundred yards to 30 miles.
People are exposed to PM during inhalation when they directly breathe in the particulate matter
suspended in the air. As the body inhales, PM2.5 in the air can travel deep into the lungs and into
the bloodstream due to its smaller size. PM10 is more likely to stick to the sides of the airway or
get stuck in the narrow passages of the lung.
What are the NAAQS standards for particulate matter?
PM is one of the six criteria air pollutants for which NAAQS standards have been set (Table 5).
The EPA has two types of national air quality standards to protect against the adverse effects of
exposure to pollutants. Primary standards protect public health, including the health of at-risk
populations such as people with pre-existing heart or lung disease (such as asthmatics), children,
and older adults. Secondary standards protect public welfare and include protection against
visibility impairment, damage to animals, crops, vegetation, and buildings.
What are the health effects of particulate matter exposure?

30

Exposure to PM can cause respiratory symptoms such as aggravation of asthma, heart attacks,
irritation of the airways, coughing, or decreased lung function.[90] Data has shown evidence of
the effects of short-term exposure to PM10 on respiratory health, and PM2.5 data on chronic
exposure shows that it is a stronger risk factor for mortality among individuals with
cardiovascular issues or lung disease. Additionally, the EPA has linked exposure to particulate
matter with cancer.
Since PM2.5 can persist in the air longer and travel far, the adverse exposures can affect a larger
population and it can be difficult to pinpoint the source of pollution. Vulnerable populations
include individuals with pre-existing lung or heart disease, the elderly, and children. Childhood
exposure to PM can affect lung development by causing a reduced lung growth rate and deficits
in lifelong lung function. Research on sociodemographic variables and exposure to PM2.5 has
shown that non-white ethnic groups, individuals with less than a high school education, and
those living in poverty are more likely to be exposed to PM2.5.[91]
What are the particulate matter levels on and around the Harim Millsboro site?
DNREC monitors air quality data in eight sites to ensure compliance with NAAQS standards.
For Sussex County PM2.5 data, DNREC uses a stationary monitor located 23 miles west of the
Harim Millsboro site in Seaford, DE (38.6444, -75.613056). From 2003-2008, the annual PM2.5
concentration at the Seaford site was above the NAAQS standard (Figure 21).
Trichloroethylene (TCE)
What is TCE and how can exposure occur?
Trichloroethylene (TCE) is a colorless liquid with a mild sweet odor similar to that of
chloroform.[92] The odor from TCE is noticeable in the air at levels of 21.4 ppm.[93] TCE is
not produced in the environment naturally and is typically used as a solvent for metal degreasing,
in the production of refrigerants, as a dry cleaning agent, and in the textile industry. It is also the
building block for manufactured chemicals such as flame retardant chemicals, insecticides, and
polyvinyl chloride (PVC), and in consumer products such as adhesives, rug cleaners, paint
removers/strippers, spot removers, and typewriter correction fluids.[94]
Exposure to TCE occurs when it is released into the environment from the site at which it is
produced. For example, dry cleaning facilities can emit TCE into the air, where it breaks down
slowly and can be transported long distances.[93] Industrial uses of TCE might contain liquid
waste with high levels of chemical. Any dumping or leaks can cause TCE to enter the soil,
where it easily migrates to sources of groundwater. TCE evaporates quickly from water to air
and can enter homes through vapor intrusion.
Is there an EPA maximum contaminant level (MCL) for TCE in drinking water?

31

TCE is included under EPAs National Primary Drinking Water Regulations, thus regulation of
levels in drinking water in public water supplies is legally enforceable. The EPA MCL for TCE
in public water systems is 0.005 mg/L.
What are the health effects of exposure to TCE in drinking water?
Acute effects of exposure to TCE via inhalation can cause dizziness, tiredness, headaches, and a
loss of coordination. Exposure to very large amounts in the contaminated air can cause
unconsciousness or death. [93] Exposure through drinking water has been associated with liver
problems. Chronic exposure through inhalation can lead to changes in mood, memory, attention,
reaction time, or vision. The EPA has designated TCE to be carcinogenic to humans by all
routes of exposure. There is strong evidence that it can lead to an increased risk of getting
kidney cancer, and there is a strong relationship between TCE exposure and liver cancer and
malignant lymphoma (blood cancer).
What are the TCE levels on and around the Harim Millsboro site?
BP Environmental groundwater testing data from the Pinnacle site conducted during the 2013
Limited Subsurface Investigation revealed a TCE level of 1.2 g/L, exceeding the EPA MCL of
0.005 mg/L.
DNREC groundwater samples of TCE taken between 2005-2015 from Holidays Acres and
Colonial Estates do not have TCE levels listed because they state that the samples were below
the reporting level of 0.5 g/L.
Volatile Organic Compounds (VOCs)
What are VOCs and how can exposure in drinking water occur?
Volatile organic compounds (VOCs) are carbon-containing compounds that have numerous
industrial, commercial, and residential uses, such as the production of refrigerants, pesticides,
plastics, adhesives, paints, gasoline, solvents, cleaners, and degreasers.[95] VOCs can be
released into the environment from sources such as industrial air emissions, leaking storage
tanks, landfills, wastewater runoff, septic systems, and injection through wells.[99] The physical
and chemical properties of VOCs allow them to easily move between the atmosphere, soil,
surface water, and groundwater.[96] VOCs in groundwater are a cause for concern because they
are an indicator that a pathway exists for other toxic chemicals to reach drinking water wells.[99]
Is there an EPA maximum contaminant level (MCL) for VOCs in drinking water?
Total Trihalomethanes (TTHM) are included under EPAs National Primary Drinking Water
Regulations, thus regulation of TTHM levels in drinking water in public water supplies is legally
enforceable. Trihalomethanes are by-products of chlorine, a chemical commonly used to
disinfect drinking water from pathogens (organisms that cause disease).[97] Trihalomethanes
form when chlorine reacts with the naturally-occurring materials in water. TTHM includes
bromodichloromethane, bromoform, chloroform, and dibromochloromethane. EPAs MCL of
TTHM is 0.08 mg/L (80 g/L).
32

What are the health effects of exposure to VOCs in drinking water?

The potential health effects of long-term exposure to VOCs over the MCLs have been linked to
an increased risk of cancer, circulatory, reproductive, and central nervous system problems,
along with liver, kidney, central nervous system, stomach, and heart issues.[99] The health
effects associated with long term, low-level VOC exposure in drinking water are not known, and
additional research on this topic is needed.
What are the VOC levels on and around the Harim Millsboro site?
BP Environmental groundwater sampling data of the Pinnacle site revealed levels of volatile
organic compounds that exceeded DNREC SIRS groundwater cleanup standards (Appendix C).
These standards are used as guidance when determining if a hazardous site requires further
investigation or a remediation plan.[98]
A 2006 United States Geological Survey (USGS) report on VOCs in groundwater tested
approximately 3,500 public and private drinking water wells across the country between 19852002.[99] Chloroform, PCE, and TCE were included in the USGS findings as the most
frequently detected VOCs, and these contaminants were also found in groundwater at the
Pinnacle site. DNREC detected chloroform in the Colonial Estates and Holiday Acres wells at
levels that exceeded the median concentration of 0.6 g public wells in the USGS report (Figure
22).

HIA Reporting and Recommendations

Reporting
Reporting is an important step of the HIA process because it ensures that the results reach the
community. With the information gathered in the HIA, residents can leverage the assistance of
additional stakeholders who can provide further support. This HIA will be presented to
Protecting Our Indian River along with a survey template for assessing the concerns and
awareness of other residents. A one-page fact sheet listing some of the primary processing plant
pollutants will also be distributed for quick and easy reference.
Key Findings
1. Residents in the area of interest are overburdened with pollution from multiple sources:
Within a two-mile radius of the Harim Millboro plant, there are two EPA Superfund
sites, a coal-fired power plant, an animal vaccine factory, a concrete factory, and a
poultry processing plant.
There are several potential hazardous emissions and elevated levels of chemicals that
already exist on the Harim Millsboro site such as TCE, hydrogen sulfide, arsenic,
chloride, chromium, cobalt, nitrates, particulate matter, and VOCs.

33

2. The sociodemographic variables for residents in the area of interest are lower than
county, state, or nationwide levels.
The median household income is lower.
Percentage of families living below the Federal poverty level is higher than county,
state, and nationwide levels.
Unemployment rates are higher than county and state levels (equal to nationwide
unemployment rate).
Home ownership rate is lower than county, state, and nationwide levels.
Percentage of residents with an education level less than a high school diploma or
equivalent is lower than county, state, and nationwide levels.
3. The health status of the Millsboro community is lower than county, state, and Federal
levels.
Lung cancer incidence rates are significantly higher, particularly among men, and
data has shown that a cancer cluster exists in the Indian River region.
Chronic bronchitis, emphysema, and heart disease rates are higher in the zip codes of
interest.
The percentage of deaths due to cancer and heart disease are higher in the zip codes
of interest.
4. 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.
Trucks and employee vehicles will increase emissions from vehicular exhaust and
impact traffic.
Large amounts of water used in the plant could result in offal in the water, polluted
water, and a threat to groundwater resources.
5. The current odor problem will be exacerbated by the addition of the Harim Millsboro
plant.
Residents are already dealing with noxious odors from the Mountaire Millsboro plant.
Recommendations
The Harim plant should move to a more remote area with fewer existing sources of
pollution and fewer residents dealing with adverse health effects.
Concerned residents and members of Protecting Our Indian River have stated that they want the
Harim plant to move to a more remote location with proper setbacks so that the facility is not as
close to residential areas. The location should have fewer existing sources of pollution and
should not be in an area where residents are suffering from adverse health effects. The exception
to approve the land use as potentially hazardous should not be granted.
DNREC should reassess the setback distances between the site and wells/property lines.

34

Parts of the sprayfield at the Harim Millsboro plant are within 85 feet of the well head for the
Holiday Acres community, and residents feel that the sprayfield discharge will pollute the
groundwater, used as their primary source of drinking water. According to Delaware
regulations, the plant must be located in an area with at least a 150 foot buffer 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.
Limit the use of water in the processing plant.
Poultry processing plants use approximately seven gallons of water per bird, which might lead to
a depletion of groundwater resources for existing residents, particularly those who use well water
as their primary source of drinking water. In addition, Harim Millsboros plant operation would
cause the entry of significant amounts of offal and other processing by-products into the water.
Processing plants typically use water from hoses to act as a broom to clean waste out of the
processing room, but it is preferable to use a dry method for handling waste. Operators can
collect solids from the floor with shovels and place the material in separate containers before
employing water for cleanup.[100] This will prevent offal and other poultry by-products from
entering sources of water and becoming decomposed.
Change the poultry feed diet.
Poultry feed is often supplemented with additives and proteins to improve the quality of meat by
increasing the size of the bird, reducing its fat composition, and keeping it free from infectious
diseases. Additives also improve the quality of the feed by improving its digestibility by the bird
and preventing the growth of mold. During the slaughtering process, poultry manure is often
removed from the bird and becomes a major component of poultry processing wastewater. This
poultry manure often contains high levels of nitrogen, phosphorous, chlorine, hormones,
antibiotics, and pathogens.[101] Approximately 75% of the antibiotics administered to chickens
end up being excreted back into the environment. Undigested proteins in the poultry litter can be
broken down by bacteria into ammonia and ammonium that pollute the air.[102] When applied
to spray fields or discharged into surface water or groundwater, these feed components can
pollute the water.
Employing nutrient management methods can reduce the pollution load by limiting the intake of
excess nutrients the chicken cannot absorb and ends up excreting. If a bird is given an
appropriate amount of feed containing a proper ratio of amino acids, the bird can still grow
sufficiently and the utilization of feed will improve, which can result in a reduction in poultry
litter.101 This can be accomplished by formulating the feed so that it closely matches the
nutritional requirements of birds in their different stages of growth so that the amount of
nutrients excreted is reduced.
Government agencies must engage the community in the decision-making process.
Involving the community is an integral part of the decision-making process. It can also serve as
a way for residents to communicate their needs and educate both parties on the health impacts of
a decision. In regards to Harim Millsboro, the government did not actively involve the residents

35

in the political process. During a meeting with concerned residents and members of Protecting
Our Indian River, many remarked that they would not have previously purchased their homes if
they had known about the processing plant coming to their neighborhood (personal
communication, February 15, 2015).
Install air monitors within the area of interest and conduct air monitoring.
Currently, the closest air monitor that conducts partial year (April October) ozone monitoring,
year-round monitoring of PM2.5, air toxics, carbonyls, and metals is located 23 miles west in
Seaford, DE. A second monitor is located in Lewes, DE, approximately 19 miles north of the
area of interest and conducts partial year (April October) ozone monitoring and assesses wind
speed/direction. Placing a monitor within the area of interest will allow residents to assess the
quality of the air in their neighborhood and will provide an accurate understanding of the
cumulative effects of air pollution.
Water quality in private and public wells should be monitored regularly.
The SDWA does not apply to private wells, so residents must conduct their own water testing,
which can be expensive. DNREC and/or Harim Millsboro should create a contract with private
well owners to provide free water quality testing to be conducted by an independent lab to ensure
that the water is safe to drink. The test results should be given directly to residents with
instructions on how to read the report and determine the safe levels.
Establish a panel of community residents to address noxious odor issues
The panel should consist of residents within the area of interest, experts, and officials from
Delaware Public Health, DNREC, and Harim Millsboro to address odor complaints and enact a
mitigation process to reduce any noxious odors.
Assess the health care infrastructure of the area of interest
Sussex County is identified as a medically underserved area and does not have a sufficient
amount of primary care, mental health, and dental providers for low-income residents.
Government officials should ensure that access to healthcare is improved and disease prevention
strategies are in place prior to allowing a new industrial facility into the area.
Establish a traffic plan and vehicle pollution reduction strategy
The trucks and employee vehicles will bring increased traffic concerns to the area. The town
should look to install appropriate signage, stop lights, and establish regulations for when the
trucks can enter the facility. They should also place plant entrances away from residential areas,
assess speed limits, require that Harim Foods cover the cost of road improvements, and adopt the
road to ensure it is kept clean.
Ensure that OSHA safety standards are met for workers.

36

This includes ensuring that workers are not exposed to chemicals at levels above OSHA
baselines, that they have access to proper protective wear, and that their musculoskeletal health is
not threatened. This could also include air monitoring of organic dusts and other chemicals to
ensure that they do not exceed acceptable levels.

37

Appendix A Tables and Figures

Figures
Figure 1 Millsboro Communities of Interest

Figure 2 Millsboro Population by Age %

Millsboro Population % by Age Group
30
25
20
Population
%

24.6 23.6

21.7

23.9

26.2
20.9

22.6

17.7

15

10

9.7

2010
2013

5
0

Under 18

1824

2544

4564

65 and older

Age Group
Data based on 2010 Census and 2013 ACS 5Year Estimates

38

Figure 3 - % Non-White and Poultry Activities

Figure 4 Median Household Income

Median Household Income
$70,000
$59,878

$60,000

$53,046

$52,710

$50,000
$40,000

$37,434

$30,000
$20,000
$10,000
$0
Millsboro Census Block
Group (506.02 BG 3)

Sussex County

Delaware

United States

Data based on 2013 ACS 5year estimates

39

Figure 5 - % of Families Below Federal Poverty Level

Percent Families Below Poverty Level
25.0%
20.0%

19.9%

15.0%
11.3%
8.9%

10.0%

7.8%

5.0%
0.0%
Millsboro Census Block Group
(506.02 BG 3)

Sussex County

Delaware

United States

Data based on 2013 ACS 5year estimates

Figure 6: Unemployment Rates

Unemployment Rate Ages 16+
9.80%

9.70%

9.70%

9.60%
9.40%
9.20%

9.00%

9.00%

8.90%

8.80%
8.60%
8.40%
Millsboro Census Block Group
(506.02 BG 3)

Sussex County

Delaware

United States

Data based on 2013 ACS 5year estimates

40

Figure 7: Home Ownership Rates

Home Ownership Rate
90.00%
78.95%

80.00%

72.45%

70.00%
60.00%

64.94%
56.78%

50.00%
40.00%
30.00%
Millsboro Census Block Group
(506.02 BG 3)

Sussex County*

Delaware

United States

Data based on 2013 ACS 5year estimates

*Sussex County has the highest home ownership rate in the state
(New Castle County 70%, Kent County 72.33%)

Figure 8: Education Status

% Less than HS Diploma/Equivalent for Residents Over 25
17.0%
16.0%

15.9%

15.0%

14.4%

14%

14.0%
13.0%

12.3%

12.0%
11.0%
10.0%
Millsboro Census Block Group
(506.02 BG 3)

Sussex County

Delaware

United States

Data based on 2013 ACS 5year estimates

41

Figure 9 - 2014 Clean Air Task Force Estimated Adverse Health Effects due to Particulate Matter Emissions
from Power Plants [15]
2014 Estimated Adverse Health Effects due to Particulate Matter Emissions from Power
Plants
400
375 cases per year
350
300
250

Asthma ER Visits

2014
Annual 200
Incidence

Chronic Bronchitis
141 cases per year

150

Hospital Admissions
Asthma Attacks
Heart Attacks
Death

100
50
0
Indian River Region

Sussex County
Location

Figure 10: Indian River Region Zip Codes of Interest for DPH Cancer Incidence Analysis

Figure from 2007 Delaware Health and Social Services, Division of Public Health 2007 Report: Cancer Cluster
Investigation: Indian River AreaError! Bookmark not defined.

42

Figure 11 - Cancer (all-types) rates per 100,000 people

Ageadjusted cancer rate per 100,000 people,
20002004
553.9

560
540
520

Incidence
Rate

501.3

500

473.6

480
460
440
420

Indian River

Delaware

United States

Data obtained from the Delaware Health and Social Services, Division of Public Health 2007 Report: Cancer
Cluster Investigation: Indian River Area[16]
Figure 12 - Average Annual Age-Adjusted Lung Cancer Incidence Rates: 2000-2004
Average Annual AgeAdjusted Lung Cancer Incidence Rates: 20002004
120
105.6
100
80
Lung cancer
incidence rate per 60
100,000 residents

76.9

79.1

Delaware

Sussex County

63

40
20
0
United States

Indian River

Data obtained from the Delaware Health and Social Services, Division of Public Health 2007 Report: Cancer
Cluster Investigation: Indian River Area [16]

43

Figure 13 - 2013 Geographic Research, Inc. Mortality Statistics

2013 Percent of Population Mortality Rates
1.20%
1.00%
0.80%

19966, Millsboro, DE
19939, Dagsboro, DE

% of
0.60%
Deaths

Sussex County, DE
Delaware

0.40%

USA
0.20%
0.00%
% Malignant neoplasms
(cancerous tumors)

% Chronic lower
respiratory diseases

% Diseases of heart

% All causes

Healthcare data retrieved April 10, 2015, from SimplyMap database, Geographic Research Inc.[14]
Figure 14 Industrial Facilities Map

44

Figure 15: EPA TRI Explorer Data on NRG Indian River Historical On-Site Releases
TRI Explorer OnSite Emissions for Zip Code 19939
6
5
4
Tons of emissions
(millions)

Land
Air

2
1
0

Data obtained from EPA Toxics Release Inventory Summary on zip code 19939.
http://iaspub.epa.gov/triexplorer/tri_factsheet.factsheet?pDataSet=TRIQ1&pyear=2013&pzip=19939

Figure 16 Mountaire Millsboro 2013 Air Releases

2013 Mountaire Millsboro Releases
3,167 pounds

Hydrogen Sulfide

8%
8%

Zinc

8%

76%

Manganese
Compounds
Copper
Compounds
Source: 2013 EPA
TRI data via

Data obtained from EPA Toxics Release Inventory Summary

45

Figure 17 - Mountaire Millsboro comparison with all other TRI facilities in 20131

Figure 18 TRI Air Emissions Data for Zip Codes of Interest

TRI Air Emissions Data
4,500,000
4,000,000
3,500,000
3,000,000
Pounds per
year

2,500,000
Zip Code 19966

2,000,000

Zip Code 19939

1,500,000
1,000,000
500,000
0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
Year

46

Figure 19 - Chloride Monitoring Well Exceedances

Chloride Monitoring Well Exceedances for Harim Millsboro 20012013
2000
1800
1600
1400
1200
mg/L 1000
800
600
400
200
0
5/9/01

5/9/01

7/23/03

1/21/04

4/27/04

7/13/04

4/16/10

10/7/13

MW04

MW03

MW04

MW04

MW04

MW04

MW03

MW04

Figure 20 - Chloride Levels in Public Wells

40
Chloride Levels in Public Wells
34.9

35
30

28.1

28.3

29.3
27.6

27.3

26.9

25.8

29.7

25.9

25
mg/L

20
15.8

15.4

16.2
14.1

15

13.1

14.2

13.4

14.2
12

10

Holiday Acres
Colonial Estates

5
0

3/22/05,
7/5/2005

4/17/06

4/24/07

1/9/2008, 3/11/2009, 4/13/2010,

1/24/08
3/30/09 4/14/2010

6/5/11

2/21/12

1/16/14

2/9/15

DNREC Sampling Data

0 mg/L reporting limit

47

Figure 21 Sussex County Mean PM2.5 Concentrations

Sussex Co. PM2.5 Weighted Mean Per Year
(NAAQS12 g/m3 primary average mean over three years)
15
14
13
PM 2.5
Concentration 12
g/m3
11

EPA Air Quality Standard

(12 g/m3, 3 Year Average)

10
9
8

Source: EPA Air Quality Statistics Report

Air Monitor located in Seaford, DE

Figure 22 Chloroform concentrations in Millsboro public wells

ChloroformConcentrationinPublicWells
EPAMCL 80ug/L
18
16
14
12
10
ug/L
8
6
4
2
0

Holiday Acres
Colonial Estates

DNREC Sampling Date

.5 ug/L reporting limit until 6/25/08 sampling,
0 ug/L reporting limit thereafter

48

Figure 23 2013 Traffic proximity in Millsboro, DE

Tables
Table 1: Geographic Research, Inc. Health Status at Zip Code, County, State, and Country Levels
Variable
19966,
19939,
Sussex
Delaware
Millsboro,
Dagsboro,
County,
DE
DE
DE
% Migraines or severe headaches, 2013
15.40
15.42
15.50
15.85

USA
15.88

% Any Cancer, 2013

9.34

9.21

9.05

8.23

8.15

% Chronic bronchitis, 2013

4.59

4.56

4.53

4.38

4.34

% Ever had Asthma, 2013

13.00

13.01

13.02

13.07

13.04

% Emphysema, 2013

2.44

2.41

2.37

2.16

2.12

% All Types Heart Disease, 2013

13.02

12.88

12.75

11.92

11.73

Healthcare Data retrieved April 10, 2015, from SimplyMap database [14]

49

Table 2- Indian River Community-Level Survey (IRCLS) Risk Factors

1. Ever smoker
2. Current smoker
3. Heavy Smoker
4. Smoked > 25 Years
5. Secondhand Smoke Exposure
6. Family History of Lung Cancer
7. Chronic Bronchitis / Emphysema
8. Worked in High-Risk Industry
9. Workplace Exposure to Carcinogens
10. Private Well Water at Residence
11. Wood Burning to Heat Residence
12. Sussex County Resident > 15 Years
Data obtained from Lung Cancer in Sussex County, Delaware: Findings from the Indian River Community-Level
Survey (IRCLS)[17]

Table 3 Groundwater Exceedances at NRG site

Chemical
Maximum Groundwater Concentration from
EPA Primary MCL
NRG samples
Arsenic
1,450 g/L
10 g/L
Chromium
211 g/L
100 g/L
Thallium
8.4 g/L
2 g/L
Data obtained from Environmental Integrity Project and Earthjustice report - Out of Control: Mounting Damages
From Coal Ash Waste Sites [20]

Table 4 Particulate Matter Concentrations from Millsboro Inhalation and Biomonitoring Exposure Study
Season 1 PM2.5 concentration
Season 2 PM2.5 concentration
Average
(g/m3)
(g/m3)
g/m3
NRG plant not operational
NRG plant not operating at 100%
20.3
Personal PM2.
19.6 SD 3.4
23.2 SD 5.7
11.8
Indoor Residential PM2.5
12.6 SD 3.8
10.9 SD 3.3
11.3
Outdoor Residential PM2.5 16.2 SD 1.5
6.5 SD 2.0
9.3
Millsboro Ambient PM2.5
12.1 SD 2.0
6.5 SD 1.7
8.9
Seaford Ambient PM2.5
11.1 SD 1.5
6.7 SD 1.6
(23 mi west of Millsboro)
Data obtained from RTI International - Millsboro Inhalation Exposure and Biomonitoring Study [58]Error!
Bookmark not defined.
2

Table 5 - NAAQS Particulate Matter Standards

Pollutant

PM2.5

PM10

Primary/Secondary

Averaging
Time

Level

Form

Primary

Annual

12 g/m3

Annual mean, averaged over 3 years

Secondary

Annual

15 g/m3

Annual mean, averaged over 3 years

Primary and
secondary

24-hour

35 g/m3

98th percentile, averaged over 3 years

Primary and
secondary

24-hour

150 g/m3

Not to be exceeded more than once per year on

average over 3 years

50

Appendix B NCR Monitoring Well TCE Exceedances

&
51

Appendix C BP Environmental Well Monitoring & Exceedances from the Harim Millsboro Site

SYMBOL LEGEND
ENCE
TREE LINE
SHRUBBERY
SPRAY FIELD
QUADRANTS
WATER SUPPLY
WELL
PERAMEMT
MONITORING
WELL
NESTED
MONITORING
WELL
BUILDING
FOOTPRINT
EXISTING
MONITORING
WELL
UNITS- MG/ KG
Al - ALUMINUM
As - ARSENIC
Ba - BARIUM
Cd- CADMIUM
Cr - CHROMIUM
Co - COBALT
Fe - IRON
Pb- LEAD
Mn - MANGANESE
Ni - NICKEL
V - VANADIUM
Hg - MERCURY

1,1,2-TCA-1,1,2-TRICHLOROETHANE
CHBr2Cl- CHLORODIBROMOMETHANE
CHCl3 - CHLOROFORM
CHBrCl2- DICHLOROBROMOMETHANE
PCE- TETRACHLOROETHENE
TCE- TRICHLOROETHENE
Cl- CHLORIDE
NO2- NITRITE
NO3- NITRATE

(d)= DISSOLVED METAL CONCENTRATE

GRAPHIC SCALE IN FEET

Prepared For:
ALLEN HARIM FOODS, LLC
126 N. SHIPLEY STREET
SEAFORD DE 19973

Site:
PINNACLE FOODS GROUP, LLC
29984 PINNACLE WAY
DAGSBORO, DE

Date:01/11/12
Revision Date:11/25/13
Project: AL-190-04
Drafted by:JP

FIGURE 13- SITE MAP SHOWING

GROUNDWATER QUALITY
EXCEEDANCES

SCALE 1" =227 FT

Environmental, Inc.
8615 Commerce Drive, Unit One
Easton, Maryland 21601

52

Appendix D Zoning Map

53

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