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HEALTH CONSULTATION

AK ZINN
BATTLE CREEK, CALHOUN COUNTY, MICHIGAN



DISCUSSION

During the EA/PI in July 1991, the contractor found approximately 70 storage barrels, 3 stained areas from past liquid spills, and various other containers and debris in the buildings on the property. The contractor collected samples of floor tile, ceiling tile, and insulation for analysis for asbestos content. One of 2 floor tile samples and 1 of 4 insulation samples contained asbestos. The contractor estimated that the amount of asbestos-containing material on the property exceeded the standards set under the U.S. Environmental Protection Agency (U.S. EPA)'s National Emission Standards for Hazardous Air Pollutants (NESHAP), Asbestos Revision,2 requiring removal of the asbestos-containing material before or during demolition of the building. The NESHAP regulations also specify the removal techniques to be used to minimize release of asbestos and human exposure to the materials. The contractor concluded that a further Phase II Environmental Assessment of the property, including sampling of the contents of the barrels, was necessary to determine the extent of any contamination on the property (4). As of this writing, there is no record available that the Phase II Environmental Assessment or any sampling of the barrels has been done.

During the BFRA in May 1997, the MDEQ collected 35 samples of surface soil from the property. Some of the samples contained arsenic, benzo(a)pyrene, or lead at concentrations above the MDEQ Generic Clean-up Criteria for Industrial or Commercial Use (Table 1) (6). The concentrations of those three chemicals, plus antimony, benzo(a)anthracene, benzo(b)fluoranthene, beryllium, dibenz(a,h)anthracene, or indeno(1,2,3-cd)pyrene in some samples exceeded the MDEQ Generic Clean-up Criteria for Residential Use (7). The samples in which the arsenic concentration exceeded the Industrial/Commercial Criteria were collected from the northeast corner of the property. Those with lead concentrations above the Criteria were from around the main building, and the one sample with benzo(a)pyrene above the Criteria was also collected near the building, but was not the sample with the highest lead concentration (5). The lead concentrations were within the range typically found in urban areas, or near buildings of ages similar to those on the property (8). The concentrations of benzo(a)anthracene, benzo(b)fluoranthene, and indeno(1,2,3-cd)pyrene were also within the range typically found in urban soils (Reference 9, Table 5-3). Anyone might incidentally ingest enough arsenic from the soil in the northeast corner of the property to exceed the ATSDR Minimum Risk Level (MRL) or the U.S. EPA Reference Dose (RfD), though they would not be likely to ingest enough to attain the doses or durations at which adverse non-cancer health effects have been observed. Lifetime continuous exposure to soil containing the levels of arsenic found on the property might result in a low increased risk of contracting cancer, however, that level of exposure is not likely to occur on the property (10).

During the BFRA in May 1997, the MDEQ collected 12 samples of subsurface soil from the property. One sample contained an arsenic concentration in excess of the MDEQ Industrial/Commercial Criteria (Table 2) (6). This sample was collected from the northeast corner of the property, near the two surface soil samples which contained arsenic concentrations in excess of the Industrial/Commercial Criteria (5). The arsenic or benzo(a)pyrene concentrations in several samples exceeded the MDEQ Residential Use Criteria (7).

During the BFRA in May 1997, the MDEQ collected unfiltered samples of groundwater from 5 temporary monitoring wells on the property. Some of these samples contained lead, manganese, methylene chloride, or trichloroethylene at concentrations above MDEQ/U.S. EPA drinking water standards (Table 3) (7). None of the samples contained any chemical at levels that would pose a health hazard from dermal contact (11). Evaporation of methylene chloride and trichloroethylene during household use of the groundwater might produce concentrations in the air above ATSDR Minimum Risk Levels (MRLs), though the concentrations would not likely exceed the levels at which adverse health effects have been observed (12, 13, 14). The highest concentrations of chemicals were found in samples from a well on the western portion of the property (5).

The area of the property is served by the Battle Creek Municipal Water System, with no known private wells in the area. The primary source for the Battle Creek Municipal Water System is the Verona Well Field, approximately 3 miles northeast of the AK Zinn property. The Verona Well Field and private wells in that area have had a history of contamination with volatile organic chemicals including trichloroethylene, traced to sources in that vicinity and not related to the contamination at the AK Zinn property. The Kalamazoo and Battle Creek Rivers are between the property and the Well Field, which should provide barriers to groundwater flow between the areas. The Municipal Water System, the U.S. EPA, the MDCH, and the MDEQ have been taking actions to ameliorate the contamination in the city's drinking water supply and the private wells (15).

During the preliminary reconnaissance of the property in December 1996, MDEQ staff observed the portions of the roof and first floor of the main building had collapsed. Access to the property is not restricted. Trespassers have apparently used and may continue to use the property for recreation, leaving graffiti on the walls and several ramps for stunt skateboarding in one building.

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