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HEALTH CONSULTATION

RUMMEL FIBRE COMPANY
ROME, FLOYD COUNTY, GEORGIA


SUMMARY

In 2002, the Georgia Environmental Protection Division (GEPD) asked the Georgia Division of Public Health (GDPH) to conduct a public health investigation at the Rummel Fibre Company. At this site, GEPD is concerned about possible adverse health effects caused by past, present, and future exposure to environmental contamination by groundwater stemming from the Rummel site.

Past disposal practices of manufacturing operations conducted at the Rummel Fibre Company (Rummel) site in the 1970's and 1980's resulted in subsurface contamination. An environmental investigation conducted in 1991 confirmed the presence of volatile organic compounds (VOCs) in groundwater above regulatory levels. Off-site migration of the VOC plume and subsequent discovery of contaminated private wells north of the facility were discovered in 1998. To ensure that exposure to contaminated drinking water would no longer occur, households located north of Rummel previously using well water were connected to the Floyd County water supply in 1999.

Families living just north of the Rummel site that used well water as a potable water supply were exposed to contaminated groundwater at levels above health-based comparison values. Based on estimated exposure doses, it is unlikely that the residents who consumed or bathed with the contaminated water experienced adverse health effects because of the low levels of VOCs found. Past employees of the previous manufacturer's at the site were not likely exposed to contaminated groundwater because Rummel has always been connected to the county water supply, which has been unaffected. GDPH recommends:

  1. Continue remediation efforts and on-site/off-site groundwater monitoring as required by GEPD;

  2. Properly abandon and cap private wells used for potable water when remediation is complete;

  3. Private well drilling should not be permitted in the contaminated area;

STATEMENT OF ISSUES

The Georgia Division of Public Health (GDPH) received a request from the Georgia Environmental Protection Division (GEPD) to conduct a health consultation for the Rummel Fibre Company in Rome, Floyd County, Georgia [1]. According to GEPD, questions have been received from nearby residents concerning groundwater contamination from the Rummel Fibre site, and the potential for health effects from exposure to groundwater contamination.

In response, GDPH reviewed residents' concerns and environmental sampling data provided to GEPD. The purpose of this health consultation is to evaluate whether contaminant levels in groundwater could represent a potential health hazard to the public.


SITE DESCRIPTION AND HISTORY

The 12-acre Rummel Fibre Company (Rummel) site, located at 607 Turner Chapel Road, Rome, Floyd County, Georgia was undeveloped prior to 1967 when Kay-Townes, Inc. (KTI) developed the property for the manufacture of television antennas and electronic equipment. The site is situated in a semi-rural area of east Rome, approximately two miles from the center of town. It is bounded by Turner Chapel Road to the west and south, woodlands to the east, and by approximately 60 acres of residential land to the north (see Figure 2). The site contains a solid waste disposal pit (SWDP) northeast of the facility, and two known surface locations where organic solvents were dumped in the past.

Site History

Alco Industries, Inc. (ALCO) purchased KTI in 1971 and continued operations under the name KTI. ALCO sold the facility to American Property Investors X (APIX) in 1980, then leased the facility from APIX to continue manufacturing television antennas and electronic equipment until 1990 when ALCO shut down operations. In the late 1970's or early 1980's, Synthane-Taylor sublet a portion of the facility from ALCO to manufacture plastic laminates for electrical panels and wire cloth filters. In 1986, Rummel purchased the Synthane-Taylor operations and continued manufacturing plastic laminates and wire filters at the facility [2]. In July 1994, Rummel purchased the facility from APIX and took over the entire facility for operations [3]. The ownership history of the property is as follows:

Date Owner Activity
1967 to 1971 Kay-Townes, Inc. (KTI) Antenna, electronic equipment manufacturing
1971 to 1980 Alco Industries, Inc. (ALCO) Antenna, electronic equipment manufacturing
1980 to 1994 American Property Investors X (APIX) Property Owners
1994 to present Rummel Fibre Company (Rummel) Plastic laminate manufacturing

Historically, the manufacturing operations at the site used trichloroethene (TCE) for degreasing components, and chemicals for electroplating and anodizing [2]. KTI reportedly discharged electroplating wastewater to an unlined pit located approximately 425 feet northeast of the manufacturing facility from 1975-1976. In addition, small quantities of solvents were reportedly discharged on the ground at both the North Central Parking Area (Parking Area) and the Northeast Loading Dock Area (NLDA) over a period of several years [5] (Figure 2).

Environmental investigations have been conducted at the site since 1991. On July 1, 1994, the site was listed on Georgia Environmental Protection Division's (GEPD) Hazardous Site Inventory (HSI) as a Class II Site (HSI# 10068). ALCO, being the responsible party, purchased back two parcels from APIX in 1994, including the Parking Area and the former SWDP, to facilitate environmental investigation and cleanup of these areas [2]. Groundwater remediation began in 1995.

In a letter dated March 8, 1998, ALCO notified GEPD that three private wells located north of the facility had been affected by a release of TCE above the maximum contaminant level (MCL) of 5 ug/l (micrograms/liter) and 1,1-dichloroethene (1,1-DCE) above the MCL level of 7 ug/l [3] (see Appendix C for definition of MCL and other comparison values). However, the contaminant plume underlies and affects several residential properties north of the facility, which are considered part of the Site [2] (Figure 2). In June 1999, the site was reclassified as a Class I Site (requiring corrective action) based on ongoing investigations conducted at the site.

Five monitoring wells have been installed off-site, immediately north of the facility. The groundwater in three of the five wells contains facility-related volatile organic compounds (VOCs) above MCLs (MW-13, MW-14, and MW-15). Three monitoring wells on this property contain TCE concentrations above the MCL. Groundwater sampling analysis indicates that the concentration of this contaminant has been declining since 1997, most likely due to natural attenuation and groundwater remediation, which began in 1995 [4].

Three private wells are located north of the Rummel site. One unused private well (Well-03), previously used for irrigation only, is located approximately 800 feet northwest of the Rummel building. This well is impacted by TCE concentrations above the MCL. However, the residence on this property has been served by county water supply since the residence was built. Sampling data for private wells (Well-01 and Well-02), located approximately 1200-1500 feet north of the Rummel building, obtained in 1999 showed peak concentrations of TCE at 100 ug/l and 270 ug/l; respectively. Well-02 showed a peak concentration of 1,1-DCE at 19 ug/l in June 1999 [2].

Three bedrock and two overburden monitoring wells were installed on the northern boundary of the 60-acre residential property located north of the Rummel site in August-October 1999, to aid in plume delineation. To date, Rummel site-derived contaminants have not been detected. In addition, three bedrock-monitoring wells have been placed in a newly developed residential subdivision just north of the 60-acre residential property. County water supply has served this subdivision from the onset of development. The horizontal extent of contamination has been delineated to non-detect levels at approximately 1600-1800 feet north of the Rummel property. The vertical extent of site contamination has been delineated to 20 ug/l, which occurs at approximately 250 feet below grade [2].

Soon after off-site VOC migration was detected, an interim groundwater recovery and treatment system was installed. This system began operation in 1995 to remove VOCs from the groundwater and to control migration from the Parking Area. The remediation system extracts groundwater from the saturated overburden at monitoring wells MW-7 and MW-10, at an average rate of approximately 1500 gallons per day. The pumped groundwater is treated by air stripping and discharged to the City of Rome Publicly Owned Treatment Works [2]. In late 2001 or in early 2002, this system was taken off-line to study the effectiveness of newly selected treatment technologies, designed to treat both the saturated soil and groundwater. The estimated time period for active remediation is expected to be less than two years, but additional time may be warranted pending actual results at the site [4].


DISCUSSION

Consultation Methodology

For each environmental medium (e.g. air, soil, or groundwater) at a site, GDPH examines the type and concentrations of regulated contaminants. In preparing this document, GDPH used comparison values to screen contaminant levels and select chemicals of concern- chemicals that exceeding one or more comparison values that warrant further evaluation. Comparison values are concentrations of chemicals that can reasonably (and conservatively) be regarded as harmless, assuming default conditions of exposure. The comparison values generally include ample safety factors to ensure protection of sensitive populations. Because comparison values do not represent thresholds of toxicity, exposure to contaminant concentrations above comparison values will not necessarily lead to adverse health effects. Comparison values used in this document are discussed in Appendix C. GDPH then considers how people may come into contact with the contaminants. Because the level of exposure depends on the route of exposure and the concentrations of contaminants, this exposure information is essential to determine if a public health hazard exists.

The potential exposure medium pathway for Rummel is groundwater. The evaluation of the groundwater pathway is included in this consultation. Information gathered and remedial activities conducted since 1995 are considered. Contaminants found from on-site groundwater sampling include: trichloroethene, 1,1-dichlororethene, cis1, 2-dichloroethene, trans1, 2-dichlorothene, chloroform, and toluene. Contaminants found from off-site groundwater sampling include: trichloroethene, and 1,1-dichlororethene.

Groundwater Exposure Pathway

Groundwater refers to aquifers, or water that lie under the Earth's surface. Groundwater can become contaminated when chemicals migrate or leach from soils or contaminated areas (e.g. lagoons, surface and buried impoundments) into an underlying aquifer. Water typically flows at a slow rate through the aquifer lessening the chance of contaminant migration. Wells and springs are supplied by groundwater, and it is only through drinking or other domestic uses of well and spring water (such as bathing or irrigating) that people are directly exposed to potentially contaminated groundwater. GDPH assessed available site data in its evaluation of groundwater contamination at the site. A summary of the site's hydrogeology, groundwater use and groundwater quality data are presented in the following discussion.

Hydrogeology

Two aquifers systems have been identified at the site: overburden and bedrock. Overburden simply refers to material overlying a useful geological marker, such as bedrock. Bedrock refers to solid rock underlying an unconsolidated surface material, such as soil. Overburden groundwater flows northwest and discharges into a spring located approximately 1400 feet northwest of the Rummel property, and to an unnamed tributary to the Etowah River near this spring. Bedrock groundwater flows northeast leaving the site where it encounters a set of southeast-northwest trending tear faults. Groundwater entering these faults flows northwesterly until a major thrust fault feature is encountered. Once groundwater enters this highly transmissive fault zone, flow becomes southwesterly, and eventually discharges into the Etowah River [2]. The tributary and fault zone are approximately 1500 feet north of the facility.

Groundwater Use

Rome relies on surface water and groundwater for its potable water supply. The Floyd County Water Department provides water to approximately 16,000 water meters within the county. Water is provided through two wells, one spring, and two city water departments. Residents in the vicinity of Rummel Fibre are all serviced by the Floyd County Water Department. Drinking water supplied by groundwater sources is described below.

  • Two deep aquifer county wells are located within a two-mile radius of Rummel [7]. The Floyd County well (Fulton Road well) and Floyd County well No. 1 (Kingston Road well) are located within a 1-2-mile radius northeast of the facility. The Floyd County well (Fulton Road) is currently dry and not being used (Figure 3).

  • Floyd County well No. 1 (Kingston Road well) is currently active and located approximately 1.25 miles from Rummel. The well services about 4,000 water meters.

  • Ten known private wells are located within the immediate (0.5 mile radius) vicinity of the facility (Figure 2). Of these wells, five have been used in the past. The status of the remaining five is unknown, however, they are located upgradient from the contaminant plume.

None of the residences within the plume area currently use private well groundwater for a potable supply. Wells 01 and 02, once used for drinking water supply, have been disconnected and the homes are now supplied with county water [2].

Groundwater Quality data

On-Site Evaluation

On-going investigations at Rummel since the early 1990s have resulted in vertical and horizontal plume delineation. A total of 27 groundwater monitoring wells have been installed downgradient, upgradient, and on both the Rummel property and off-site to characterize overburden and bedrock groundwater aquifers. Thirteen groundwater monitoring wells are located on the facility property.

Photo 2: Partial photograph of the Solid Waste Disposal Pit formerly used to dispose electroplating and anodizingTwo overburden monitoring wells are located northwest of the SWDP (in the direction of overburden groundwater flow). June 2002 sampling results showed that no contaminants exceed any comparison values [6].

Eleven groundwater monitoring wells have been installed onsite to characterize overburden and bedrock groundwater contamination as a result of past surface disposal of VOCs at the Parking Area and the NLDA (Figure 2).

The highest concentrations of trichloroethene, dichloroethene, cis/trans-dichloroethene, and toluene have been found in the overburden groundwater flowing northwest. By comparison, contaminant concentrations found in bedrock groundwater monitoring wells are lower by approximately 6-fold [2].

Since Rummel and predecessor companies have always utilized the county water supply, it is unlikely that past facility employees ingested contaminated groundwater. Potential future exposure to ingestion and inhalation of contaminated groundwater may occur for environmental contractors conducting monitoring well sampling, and while operating the groundwater remediation system. However, exposure is unlikely if standard personal protective equipment is used.

Photo 3: North-Central Parking Area (Parking Area) Photo 4: Northeast Loading Dock Area (NLDA)

Vapor intrusion from overburden groundwater into the Rummel building is another potential pathway. Past and future potential for this pathway is low considering that the building lies south of past VOC disposal areas, and overburden groundwater flow is northwest. However, given that past VOC disposal occurred just outside the building near the northwest loading dock, the northwest corner of the building may have been/or may now be subjected to VOC vapor intrusion. However, air sampling in the building has never been conducted. Additionally, MW-16 (Figure 2) directly south and adjacent to the building has been sampled many times and VOCs have never been detected [2].

Off-Site Evaluation

Sampling of private wells affected by bedrock groundwater contamination was conducted from January 1999 to August 1999. Well 01 and Well 02 were sampled six times from January 21, 1999 to August 12, 2002. The highest concentration of TCE found in Well 01 was 100 ug/l. The highest concentration of TCE found in Well 02 was 270 ug/l, while the highest level of 1,1-DCE found in this well was 16 ug/l. Well 03, Well 04, and Well 05 were sampled on January 21, 1999. The one-time sampling of Well 03 indicated a trichloroethene concentration of 23 ug/l, while VOC levels in Well 04 and Well 05 were not detected [2]. Well 04 is located south of the Rummel Fibre facility. Well 05 is located southwest of the Rummel Fibre facility (Figure 2). Both Wells 04 and 05 are upgradient from localized overburden and bedrock groundwater flows and have never been affected by groundwater contamination stemming from Rummel. Sampling results for Wells 01, 02 and 03 are provided in Appendix A.

Residents living on the properties where Wells 01 and 02 are located used well water for potable water supply until September 1999. The potable water supply from Well 02 was shared with one other residence as well. The shallow, overburden aquifer water from Well 03 had historically been used for irrigation only [8]. The residence that used Well 03 for irrigation has always been connected to the county water supply. Once groundwater contamination was detected in Well 01 and Well 02, carbon treatment units were installed on both wells to remove the VOCs. A monthly sampling program was implemented to monitor the performance of the treatment systems. No exceedances of comparison values for TCE or 1,1-DCE were detected in the treated water [2].

In September 1999, contaminated Wells 01 and 02 were replaced by connecting the affected homes to the county water supply. The wells were disconnected from all three homes but are still accessible for monitoring purposes. Agreements have been signed by the property owners to prevent the installation of a groundwater supply well on their property in the future [2].

Approximately fifteen people were likely exposed to contaminated groundwater north of Rummel. The receptor population shares a common familial lineage due to land being divided up among heirs decades ago, so it is likely that the relatives visited each other often and consumed contaminated water. Three children were raised in two of theses residences. The first child was born in 1985, and the other two children were born in approximately 1989 and 1992.

GDPH evaluated exposure, or contact with the contaminants, on the assumption that the highest levels found were representative of daily exposures, that contaminants were present in the private well water for at least 20 years, and that the contaminated water was used for drinking, cooking, bathing, and all household purposes. GDPH also assumed that adults would drink 2 liters of water a day and weigh an average of 70 kilograms (kg), and that a child would drink 1 liter of water day and weigh an average of 10 kg. GDPH does not know if:

  • the contaminant levels were higher or lower over time;
  • contaminants were present in the private well water over the entire 20-year period (1979-1999) under the assumption.

Table 1 shows the completed pathways for the site:

Table 1. Completed Exposure Pathways

Pathway Exposure Pathway Elements Time
  Source Medium Point of Exposure Route of Exposure Exposed Population  
Off-site Groundwater Well water Groundwater Drinking, Cooking, bathing, irrigation Ingestion, Inhalation, Dermal absorption Residents
(@15)
Past

Tables 2, 3, and 4 show a comparison of the highest concentration of screened constituents found in the private wells to applicable comparison values for ingestion and estimated doses potentially obtained by groundwater ingestion:

TABLE 2. COMPARISON OF RESIDENTIAL WELL SAMPLE RESULTS FROM WELL 01 TO APPLICABLE EXPOSURE COMPARISON VALUES FOR INGESTION BEFORE CARBON FILTRATION AND CONNECTION TO FLOYD COUNTY WATER SUPPLY*

Contaminant Maximum Level
(µg/L)
Drinking Water Comparison Value* Estimated Dose
(mg/kg/day)
and MRL**
Concentration
(µg/L)
Reference
Trichloroethene 1001 5.0 MCL Child: 0.01
Adult: 0.003
MRL=0.22


TABLE 3. COMPARISON OF RESIDENTIAL WELL SAMPLE RESULTS FROM WELL 02 TO APPLICABLE EXPOSURE COMPARISON VALUES FOR INGESTION BEFORE CARBON FILTRATION AND CONNECTION TO FLOYD COUNTY WATER SUPPLY*

Contaminant

Maximum Level
(µg/L)

Drinking Water Comparison Value*

Estimated Dose
(mg/kg/day)
and MRL**

Concentration
(µg/L)

Reference

Trichloroethene 2701 5.0 MCL

Child: 0.03
Adult: 0.008
MRL=0.22

1,1-dichloroethene 161 90
300
7.0
EMEG(child)
EMEG(adult)
MCL

Child: 0.002
Adult: 0.0005
MRL=0.009


TABLE 4. COMPARISON OF RESIDENTIAL WELL SAMPLE RESULTS FROM WELL 03 TO APPLICABLE EXPOSURE COMPARISON VALUES FOR INGESTION.

Contaminant Maximum Level
(µg/L)
Drinking Water Comparison Value* Estimated Dose
(mg/kg/day)
and MRL**
Concentration
(µg/L)
Reference
Trichloroethene 231 5.0 MCL Child: 0.002
Adult: 0.0006
MRL=0.22

µg/L: micrograms per liter
mg/kg: milligrams per kilogram
ppm: parts per million (approximately equal to mg/kg)
MCL: Maximum Contaminant Level
MRL: Minimal Risk Level.
1 Results are based on highest concentration level of seventeen sampling events in 1999.
2 MRL based on acute oral exposure. No intermediate or chronic oral exposure MRL's have been derived for trichloroethene because the available intermediate and chronic duration data are limited by lack of applicable information.
* Source: ATSDR, Drinking water comparison values (Spring 2003)
** Source: ATSDR, Health guidelines comparison values (Spring 2003)

The highest level of TCE was found in well 02 at 270 ug/l. People who used the contaminated water came in contact with TCE through ingestion of, inhalation of, and skin (dermal) contact with the contaminated water. Limited studies suggest that the exposure dose from evaporation of a volatile compound into air is roughly the same as the ingestion dose(1). Studies also show that TCE is readily absorbed into the body by direct dermal contact(2) [9]. Therefore, TCE can enter the body by ingestion, inhalation, and dermal absorption. Because of additional routes of exposure, GDPH estimated the total ingestion, inhalation, and dermal absorption exposure.

For a 70 kg adult: 2 liters/day ingestion dose = 0.008 milligrams/kilogram/day (mg/kg/day)
Assuming an equal inhalation dose = 0.008 mg/kg/day
Assuming dermal absorption dose equal from daily bathing(2) = 0.004 mg/kg/day
Total adult exposure to TCE = 0.02 mg/kg/day
 
For a 10 kg child: 1 liter/day ingestion dose = 0.03 mg/kg/day
Assuming an equal inhalation dose = 0.03 mg/kg/day
Assuming dermal absorption dose from daily bathing = 0.03 mg/kg/day
Total child exposure to TCE = 0.09 mg/kg/day

Table 5 shows a comparison of the highest concentration of TCE found in the private wells and the estimated doses potentially obtained by all three routes of exposure

TABLE 5. COMPARISON OF RESIDENTIAL WELL SAMPLE RESULTS FROM WELL 02 TO APPLICABLE EXPOSURE COMPARISON VALUES FOR INHALATION, INGESTION, AND DERMAL ABSORPTION COMBINED BEFORE CARBON FILTRATION AND CONNECTION TO FLOYD COUNTY WATER SUPPLY*

Contaminant

Maximum Level
(µg/L)

MRL** and Estimated Dose
(mg/kg/day)

Trichloroethene 2701

MRL=0.22
Child: 0.09
Adult: 0.02

MRL: Minimal Risk Level.
1 Results are based on highest concentration level of seventeen sampling events in 1999.
2 MRL based on acute oral exposure. No intermediate or chronic oral exposure MRL's have been derived for trichloroethene because the available intermediate and chronic duration data are limited by lack of applicable information.
** Source: ATSDR, Health guidelines comparison values (Spring 2003)

Using the most conservative estimates of TCE exposure doses (three routes of exposure), the estimated adult exposure is 10 times lower than the ATSDR non-cancer screening MRL of 0.2 mg/kg/day. The estimated child exposure is 2 times lower than the MRL. Ingestion is the most direct route of exposure. The estimated ingestion exposure dose for an adult is 25 times lower than the MRL, while the estimated ingestion exposure dose for a child is 6 times lower than the MRL. For this reason, GDPH concludes that exposure to TCE, at the highest level detected in private well groundwater, is not likely to pose an appreciable risk of harmful effects (noncarcinogenic) over the specified duration of exposure.

Vapor intrusion into the residences located north of Rummel and above the plume is a potential pathway of exposure. Because indoor air sampling has never been conducted at these residences, nor is it known whether the contaminant concentrations have been higher or lower than what has been analyzed over time, uncertainty regarding this pathway exists. However, based on the depths and screening levels of the overburden monitoring wells constructed to date, with minimum screen intervals ranging from 6 to 60 feet [4], the likelihood of vapor intrusion decreases. The U.S. Environmental Protection Agency empirically uses an attenuation factor of 1/100 to 1/1000 for soil gas migration when groundwater depths are greater than 5 feet [12]. If vapor intrusion is an exposure patway, it is unlikely to contribute to adverse health effects based on known, past groundwater concentrations.

ATSDR maintains a TCE exposure subregistry, which compiles health-related information from the nearly 5000 participants who were exposed to TCE from contaminated drinking water [13]. The participants were exposed to TCE concentrations ranging from 2.0 ug/l to 24,000 ug/l (or 0.002 mg/l to 24 mg/l) for up to 18 years. Studies of this population indicate that individuals exposed to TCE may have an increased incidence of health effects, particularly stroke. Other health effects reported among participants of the TCE Subregistry include anemia, urinary tract disorders, liver and kidney effects, diabetes, and skin conditions. Based on the available information, ATSDR has not found a cause-effect relationship between TCE exposure and the reported health effects [14].

The link between oral exposure to TCE and the incidence of cancer in humans is controversial. As part of the National Exposure Subregistry, ATSDR compiled data on 4,280 residents of three states (Michigan, Illinois, and Indiana) who had environmental exposure to TCE. It found no definitive evidence for an excess of cancers from TCE exposure [9]. However, a subsequent study in New Jersey expanded the study size to 1.5 million residents in 75 towns monitored between 1979 and 1987, and the results indicated a significant elevation of total leukemias, child leukemias, acute lymphatic leukemias, and non-Hodgkin's lymphoma in females exposed to greater than 5.0 parts per billion (ppb) TCE [9]. It should be noted that drinking water in both cases also contained other volatile organic hydrocarbons.

Another long-term study conducted in Finland showed different results. A survey of total cancer, liver cancer, non-Hodgkin's lymphoma, Hodgkin's lymphoma, Hodgkin's disease, multiple myeloma, and leukemia incidences from 1953 to 1991 in two Finnish villages contaminated with up to 220 ppb TCE and/or up to 180 ppb tetrachloroethene found no significant increase in standardized incidence ratios for these diseases [9]. On the other hand, a recent assessment of worker exposure to TCE at the View-Master Toy Factory in Beaverton, Oregon showed contrasting results. Well water at the facility supplied drinking water to 25,000+ employees between 1951 and 1998. In 1998, TCE contamination was discovered in the drinking water supply well at a concentration of 1600 ppb. It is estimated that the well has been contaminated for at least 20 years. A health outcome study (mortality) conducted on former workers indicated proportional excesses of kidney cancer and pancreatic cancer. Mortality due to kidney cancer was approximately 3 times higher for men and approximately 4 times higher for women who worked at the View-Master factory versus mortality due to same cancers based on all deaths in Oregon. Also, mortality due to pancreatic cancer was approximately 2 times higher for men and approximately 2.5 times higher for women who worked at the View-Master factory versus mortality due to same cancers based on all deaths in Oregon [11].

Although the evidence for the potential of TCE to cause cancer is inconclusive, the U.S. Environmental Protection Agency (EPA) considers TCE to be a probable carcinogen and the International Agency for Research on Cancer considers TCE to be possibly carcinogenic to humans. Finally, the U.S. National Toxicology Program considers TCE to be reasonably anticipated to be a carcinogen.

Based on our review of the relevant studies and the low levels of TCE exposure via groundwater at this site, GDPH does not believe that there is an elevated risk for cancer from past TCE exposure at the Rummel site.

The highest level of 1,1-DCE found in well 02 was 16 ug/l. People who used the contaminated water came in contact with 1,1-DCE through ingestion of, inhalation of, and skin (dermal) contact with the contaminated water. No studies were located regarding distribution in humans after inhalation exposure to 1,1-DCE; however, studies of rats have found that after inhalation exposure, 1,1-DCE accumulates in the kidneys and liver. No studies were located regarding absorption in humans or animals after dermal exposure to 1,1-DCE. Nonetheless, the physical/chemical properties of 1,1-DCE indicate that dermal absorption is probable because the molecule is small with properties similar to the lipid-soluble anesthetics. Thus, liquid 1,1-DCE is expected to readily penetrate the skin, which is a lipid rich tissue. [10].

For 1,1-DCE, ingestion is the most direct route of exposure. Using the highest concentration of 1,1-DCE detected to estimate exposure dose, the estimated adult oral exposure is 18 times lower than the ATSDR non-cancer screening chronic MRL of 0.009 mg/kg/day. The estimated child oral exposure is 4.5 times lower than the chronic MRL. For this reason, GDPH concludes that exposure to 1,1-DCE, at the highest level detected in private well groundwater, is not likely to pose an appreciable risk of harmful non-cancer effects over the specified duration of exposure.

The EPA classifies 1,1-DCE as a possible human carcinogen. Studies of oral 1,1-DCE exposure and human cancer are not found in the scientific literature. Animal studies on rats, mice, and beagles have shown slight increases in malignant and non-malignant tumors. The oral doses given to the animals were at least 800 to 14,000 times higher (at a minimum) than the oral exposure to children (0.009 mg/kg/day) and adults (0.0005 mg/kg/day) from groundwater contamination associated with Rummel. However, compared to controls, the studies' findings were statistically insignificant [10] and thus, are not conclusive. Therefore, GDPH does not believe that people's risk for cancer from past 1,1-DCE exposure at the Rummel site is elevated.

Surface Water Quality data

The VOC plume ultimately discharges into the spring located approximately 1400 feet northwest of Rummel, and to a regional thrust fault zone beneath the stream [4]. The spring has historically contained TCE and 1,1-DCE at slight concentrations. Based on available analytical data, TCE has not been present in the spring at a concentration exceeding its Georgia Surface Water Quality Standard (GSWQS) of 80.7 ug/l since November 1995 (101 ug/l). The most recent analytical results showed the spring containing 1,1-DCE at a concentration of 5.3 ug/l and TCE at a concentration of 56 ug/l. The spring is not used as a potable water supply [4].

The spring is very shallow (less than six inches) and flows approximately 100 feet into an unnamed tributary to the Etowah River. In May 1999, surface water samples were collected from two locations in the tributary, one sample was collected 150 feet downstream from the spring discharge location, and the other sample was collected 750 feet downstream from the discharge location. The resuts indicated that TCE and 1,1-DCE were detected at the location closest to the spring discharge point, but were not detected further downstream [4]. However, none of the results exceeded the GSWQS, which for 1,1-DCE is 3.2 ug/l, and for TCE is 80.7 ug/l.

The potential for human exposure does exist for persons who may come in contact with his surface water. However, adverse health effects would be unlikely because the water is not used as potable water, and the concentrations of TCE and 1,1-DCE are such that ingestion over a lifetime of drinking this water daily would not exceed the MRL.


CHILDREN'S HEALTH CONSIDERATIONS

ATSDR recognizes that the unique vulnerabilities of infants and children demand special emphasis in communities faced with contamination of their water, soil, air or food. Children are more likely to be exposed because they play outdoors and they often bring food into contaminated areas. They are more likely to come into contact with dust, soil, and heavy vapors close to the ground. Also, they receive higher doses of chemical exposure due to lower body weights. The developing body systems of children can sustain permanent damage if toxic exposure occurs during critical growth stages.

Based on past sampling results, and conservative exposure assumptions, the calculated exposure dose estimates do not exceed the MRL for children. Contaminants present in groundwater were not likely to pose adverse health effects to children by exposure to contaminated well water in the past. Moreover, contaminants are not likely to pose future adverse health effects because all residences north of Rummel are now connected to the Floyd county water supply.


CONCLUSIONS

Based on a review of available data, discussions with local and state environmental and health officials, and review of scientific literature, GDPH developed the following conclusions and assigned public health hazard categories to human exposure pathways at the site. A description of Public Health categories is provided in Appendix B.

  1. Water from private wells on the site, and near the site, pose no apparent public health hazard. Past and current exposures do not exceed an ATSDR MRL. Because the horizontal and vertical extent of groundwater contamination is known, groundwater data substantiates this conclusion.

  2. Residents who were exposed in the past to groundwater are not currently exposed, because their homes are now connected to the Floyd county water supply.

  3. Future exposure to contaminated groundwater is not likely because residents who were exposed in the past are now on the county water supply, the Rummel facility is on county water supply, and the contaminated water is being remediated.

RECOMMENDATIONS

These recommendations identify actions that GDPH has determined necessary to reduce potential health hazards and to characterize further potential public health hazards associated with the Rummel Fibre Company site.

  1. Private wells 01, 02, and 03 should be properly abandoned and capped when remediation is complete after their usefulness as groundwater monitoring wells during site remediation ceases.

  2. Private well drilling should not be permitted in areas with contaminated groundwater so that future exposure is eliminated.

  3. As required by GEPD, continue remediation efforts as well as on-site/off-site monitoring of groundwater at Rummel.

PUBLIC HEALTH ACTION PLAN

Actions Completed

  • Private wells 01, 02, and 03 have been disconnected and are no longer being used by residents.

  • The Floyd County Water Department connected all homes that were using Wells 01 and 02 to the county water supply system.

  • Subsurface remediation of the north-central parking source area at the facility began in 1995 to control and abate migration of the contaminant plume.

Actions planned

  • Continued subsurface remediation of the north-central parking source area at the Rummel Fibre facility to abate contaminant plume until no further action is necessary.

  • GEPD will continue oversight of the Rummel Fibre remediation and will continue to review periodic groundwater sampling results.

  • GDPH will review additional data as it becomes available. Actions will be taken to protect public health if necessary.

  • Establish a public information repository at the Floyd County Public Library for residents to review public health reports pertaining to the site.

  • Provide health education regarding trichloroethene and 1,1-dichloroethene exposure to the community as requested.

PREPARERS AND REVIEWERS OF REPORT

Author

Franklin Sanchez
Program Consultant
Chemical Hazards Program
Georgia Division of Public Health


Reviewers

Brad Wiggins
Environmental Health Specialist
Northwest Georgia Public Health District 1
Georgia Division of Public Health

Larry Kloet
Environmental Engineer
Hazardous Site Response Program
Georgia Environmental Protection Division


ATSDR Regional Representative

Bob Safay

ATSDR Technical Project Officer

John Steward, R.E.H.S, M.P.H.


REFERENCES

  1. Georgia Environmental Protection Division. Hazardous Site Inventory. July 1, 2002.

  2. Environmental Resources Management. Updated Compliance Status Report. December 2001.

  3. State of Georgia Department of Natural Resources. Environmental Protection Division. Consent Order No. EPD-HSR-269. October 30, 2001.

  4. Environmental Resources Management. Corrective Action Plan. December 2001.

  5. Atlanta Environmental Management, Inc. Summary of Additional Phase II Assessment at the American Real Estate Holding Site in Rome. Georgia, March 24, 1992.

  6. Environmental Resources Management. Revised Compliance Status Report Addendum. August 2002.

  7. Georgia Public Water Inventory, 1994.

  8. Wiggins, B., phone conversation with resident located north of the Rummel Fibre facility, RE: Past receptor population and residential history of properties located north of the Rummel Fibre facility. December 2002.

  9. Agency for Toxic Substance and Disease Registry. Toxicological Profile for Trichloroethylene. Atlanta: US Department of Health Human Services, September 1997.

  10. Agency for Toxic Substance and Disease Registry, Toxicological Profile for 1,1-dichloroethene (Update). Atlanta: US Department of Health Human Services, September 1994.

  11. Oregon Department of Human Services. Worker Exposure to TCE in Drinking Water: Proposed Follow-Up Activities at the View-Master Toy Factory in Beaverton, Oregon. Seminar presented at ATSDR, Atlanta, Georgia. January 21, 2003.

  12. U.S. Environmental Protection Agency. Evaluating Vapor Intrusion from Groundwater and Soil to Indoor Air, EPA OSWER Draft Guidance. Presented at the 2003 ATSDR Partners in Public Health Meeting, March 5&6, 2003, Atlanta, GA.

  13. Agency for Toxic Substances and Disease Registry. National Exposure Registry, Trichloroethylene (TCE) Subregistry, Baseline through Follow-up 3, Technical Report. U.S. Department of Health and Human Services. Public Health Service. Atlanta, Georgia. October 1999.

  14. Agency for Toxic Substances and Disease Registry. Public Health Assessment for the North Railroad Avenue Plume Site, Española, Rio Arriba County, New Mexico. U.S. Department of Health and Human Services. Public Health Service. Atlanta, Georgia. March 7, 2003.

CERTIFICATION

The Georgia Department of Human Resources prepared this Rummel Fibre Company, Rome, Floyd County, Georgia health consultation under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the health consultation was begun.

John Steward
Technical Project Officer, SPS, RPB, DHAC


The Division of Health Assessment and Consultation, ATSDR, has reviewed this public health consultation and concurs with the findings.

Roberta Erlwein
Chief, SSAB, DHAC, ATSDR


FIGURES

Demographic Statistics
Figure 1. Demographic Statisitics

Site Map Showing Surrounding Properties
Figure 2. Site Map Showing Surrounding Properties

County Well Locations
Figure 3. County Well Locations


APPENDICES

APPENDIX A: ANALYTICAL RESULTS FROM THREE INDIVIDUAL WATER WELLS

Contaminant Sample Date

Comparison Value

Reference

IW-1

IW-2

IW-3

Volatile Organic Compounds (µg/L)
1,1-Dichloroethene 1/21/99
3/30/99
4/23/99
6/3/99
7/1/99
8/12/99
2/15/99 PF
3/30/99 PF
4/23/99 PF
6/3/99 PF
7/1/99 PF
8/12/99 PF

90.0
(Child)

7.0

Chronic
EMEG

MCL

5.8
6.0
5.6
<1.0
6.0
6.1
<1.0
<1.0
<1.0
<1.0
<1.0
<5.0
<5.0
5.7
7.7
16
11
10
<1.0
<1.0
<1.0
<1.0
<1.0
<5.0
<5.0
Trichloroethene 1/21/99
3/30/99
4/23/99
6/3/99
7/1/99
8/12/99
2/15/99 PF
3/30/99 PF
4/23/99 PF
6/3/99 PF
7/1/99 PF
8/12/99

5.0

MCL

59.0
100.0
60.0
51.0
81.0
90.0
<1.0
<1.0
<1.0
<1.0
<1.0
<5.0
30.0
55.0
120.0
190.0
270.0
210.0
<1.0
<1.0
<1.0
<1.0
<1.0
<5.0
23.0

EMEG: Environmental Media Evaluation Guide
MCL: maximum contaminant level for public drinking water systems
IW: Individual water well
PF: " Post-Filter" indicates a sample after carbon treatment filter
µg/L: micrograms per liter


APPENDIX B: ATSDR PUBLIC HEALTH HAZARD CONCLUSION CATEGORIES

No Public Health Hazard

A category used in ATSDR's public health assessment documents for sites where people have never and will never come into contact with harmful amounts of site-related substances

No Apparent Public Health Hazard

A category used in ATSDR's public health assessments for sites where human exposure to contaminated media might be occurring, might have occurred in the past, or might occur in the future, but where the exposure is not expected to cause any harmful health effects

Indeterminate Public Health Hazard

The category used in ATSDR's public health assessment documents when a professional judgment about the level of health hazard cannot be made because information critical to such a decision is lacking.

Public Health Hazard

A category used in ATSDR's public health assessments for sites that pose a public health hazard because of long-term exposures (greater than 1 year) to sufficiently high levels of hazardous substances or radionuclides that could result in harmful health effects

Urgent Public Health Hazard

A category used in ATSDR's public health assessments for sites where short-term exposures (less than 1 year) to hazardous substances or conditions could result in harmful health effects that require rapid intervention.


APPENDIX C: COMPARISON VALUES AND MINIMAL RISK LEVELS

Comparison values are contaminant concentrations that are found in specific environmental media (air, soil, and drinking water) and are used to select these contaminants for further evaluation if people are exposed to the contamination. Comparison values used in this document are defined in the following paragraphs.

Environmental Media Evaluation Guide (EMEGs) are specific comparison values developed by ATSDR for use in selecting environmental contaminants for non-cancer health concerns. EMEG's are derived from Minimal Risk Levels (see below). Exposure to a level of contaminant below this level should not result in any noncancer, adverse health effects.

Maximum Contaminant Levels (MCLs) are the maximum permissible levels of contaminants allowed in public water supplies. The U.S. Environmental Protection Agency (EPA) deems exposure over a lifetime (70 years) to the MCL protective of Public Health at an exposure rate of drinking 2 liters of water per day for an adult and 1 liter of water per day for a child. In addition to health considerations, the available technologies to decrease levels and other engineering and economic considerations are used when establishing MCL's.

Minimal Risk Levels (MRLs) are estimates of daily humans exposure to a chemical that is likely to be without an appreciable risk of harmful effects (noncarcinogenic) over a specified duration of exposure. MRL's are based on human and animal studies and are reported for Acute (14 days or less), intermediate (15-354 days), and chronic (365 days or more).


APPENDIX D: EXPOSURE DOSE CALCULATION

Exposure Doses are derived by calculating the amount of contaminant that is taken into the body of and exposed person over a period of time. The following equation is used to estimate the exposure doses resulting from ingestion of contaminated groundwater:

ID sub w equals C times IR times EF divided by BW

where;

IDw = exposure dose water

C = contaminant concentration (highest dose found)

IR = intake rate of contaminated medium (based on average ingestion of 2 liters/day for adults; 1 liter/day for children)

EF = exposure factor (based on frequency of exposure, exposure duration, and time of exposure). The exposure factor used is 1, based on 20 years of exposure, 7days/week, 52 weeks/year, and 365 days/year.

BW = body weight (based on average rates for adults: 70 kg; children: 10 kg)


1 A study (McKone and Knezovich 1991) concluded that showering for 10 minutes in water contaminated with TCE could result in a daily exposure by inhalation comparable to that expected by drinking contaminated tap water.
2 TCE absorption studies show that if 80% of the body is immersed during a 20-minute bath, the estimated dermal uptake is equal to the amount of TCE from the inhalation dose of TCE from 1 liter of water used during bathing.



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