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PUBLIC HEALTH ASSESSMENT
VOLUNTEER ARMY AMMUNITION PLANT
CHATTANOOGA, HAMILTON COUNTY, TENNESSEE


FACILITY NO. TN6210020933
September 7, 2004



Summary

The Volunteer Army Ammunition Plant (VAAP) is an inactive ammunition plant located approximately 4 miles northeast of Chattanooga's city center in Hamilton County, Tennessee (IT Corp 1994; ATSDR 2001). VAAP is surrounded by primarily residential areas. Originally VAAP occupied approximately 7,000 acres. However, portions of the installation were transferred to the city, county or private developers for use as soccer fields, commercial or industrial facilities and residential homes. Currently VAAP occupies about 2,070 acres (Army 2003b; ATSDR 2001; CFTP 2000; CDM 2002). The remaining property is planned for reuse as industrial or recreational areas.

The western portion of the installation consists of the remaining explosives manufacturing buildings, which are no longer used. The central and eastern areas were used to store explosives in bunkers. There are two perennial streams that run through VAAP, several intermittent streams, and a series of man-made ditches and ponds that drain the installation. The Army Corps of Engineers built VAAP to manufacture trinitrotoluene (TNT) for the U.S. Army (Army) in 1942; TNT production occurred intermittently to support WWII, the Korean War, and the Vietnam War. VAAP produced sellite, nitric and sulfuric acids, TNT, and certain chemical byproducts related to TNT production. The Army also leased an area along the western VAAP boundary to a fertilizer manufacturing company for the production of ammonium nitrate, urea, and related products from the early 1960s until 1982 (Army 2003a).

ATSDR evaluated available environmental data, documents describing planned environmental investigations and remedial actions, and information describing the planned reuse of the VAAP. ATSDR evaluated potential past and current exposures to the community from past VAAP operations. ATSDR also evaluated the potential exposure for future users of VAAP-associated property to the remaining contaminants. ATSDR considered all of the future uses described in the VAAP re-use plan. Based on these evaluations, ATSDR concluded that, in general, off-site residents, and industrial and recreational users are not exposed to contaminants released from VAAP operations (i.e., producing TNT or fertilizer) at levels likely to cause health impacts. Conclusions regarding pathways-specific exposures are as follows:

Exposure to Contaminants in Air. During TNT production, air releases, described by the community as 'acid clouds,' occurred. Information gathered for this evaluation indicates the clouds probably consisted of nitrogen and sulfur oxides, including nitric and sulfuric acid. People exposed to the clouds likely experienced concentrations of these compounds that are known to cause short-term health effects. However, there is not enough data to identify the actual concentration of the compounds, the duration of the exposure, or the frequency of the exposure. Therefore it is not possible to assess if long-term health effects could result from that exposure. Currently there are no air emissions from manufacturing processes at VAAP.

Exposure to Contaminants in Groundwater. Historically, some people near VAAP used groundwater from private wells as their drinking water source. These residents are now connected to the municipal water supply and no private wells are known to be used as drinking water sources. Monitoring data indicate that contaminants have migrated offsite and have been detected in some residential wells. However, the data are insufficient to determine if residential wells contained site-related contaminants in the past and if past concentrations were greater or less than those recently measured. Therefore it is not possible to evaluate the past potential exposure to contaminants in private wells.

Some residents reportedly use their private wells to water their lawns and gardens, or fill their swimming pools. ATSDR's evaluation indicates residents will not be exposed to contaminants that could cause health concern due to use of private wells to water lawns or gardens. A few residential wells had lead concentrations above EPA's action level for drinking water. However sampling results showing the corresponding concentration in the pool water were not identified. In addition, information describing the effectiveness of pool filtration systems for removing lead from pool water was also not identified. Frequent incidental ingestion of water with lead concentrations above the EPA action level could increase the lead exposure for children and adults. ATSDR suggests as a prudent public health action that residents, who wish to use groundwater to fill their pools, and have young children who use the pool daily, to periodically have the pool water tested for lead.

Exposure to Contaminants in Surface Soil. ATSDR's soil evaluation concluded that past, current, and future exposure to contaminants in surface soil throughout VAAP, except VAAP-32, would not be expected to result in adverse health effects. At VAAP-32, the main TNT production area, soil contamination was found at relatively high concentrations. However, it is not possible to identify the TNT concentration in the surface soil from the available sampling information; ATSDR concluded that data were insufficient to accurately assess past exposures to soil contaminants at VAAP-32. ATSDR expects that the planned future investigations and remedial actions will eliminate the potential exposure concerns.

Exposure to Contaminants in Surface Water and Sediment. VAAP hosts a variety of streams, and man-made drainage ditches and ponds. ATSDR reviewed available environmental data, potential exposure conditions, and the toxicology literature to assess the potential for health effects from recreational use of these streams and ponds. Although contaminants are present in surface water and sediment, concentrations are below levels of health concern. Contact with surface water and sediment during recreational use of streams is not expected to cause illness.

Background

Site Description and Operational History

The Volunteer Army Ammunition Plant (VAAP) is an inactive U.S. Army (Army) trinitrotoluene (TNT) production plant located approximately 4 miles northeast of the City of Chattanooga in Hamilton County, Tennessee (IT Corp 1994; ATSDR 2001). VAAP is east of Chickamauga Lake and ½ mile south of Waconda Bay. State Route 58 runs along the northern boundary of VAAP, and State Route 317 and Interstate 75 border the installation to the south. Residential areas surround VAAP (Figures 1 and 2). VAAP originally occupied approximately 7,000 acres, anecdotal information suggests the initial acreage may have been more (Public Comment 2004b). However, several portions of the installation have been transferred to the city, county or private developers. In 1979, 75 acres were given to the city for the Redoubt soccer field to the south of VAAP. In 1986, approximately 600 acres were sold to builders for housing construction on the east side of VAAP. In 1998, 91 acres along the northern VAAP boundary were sold to the Hamilton County School District. In 2000, 940 centrally located acres were sold to Chattanooga and Hamilton County for development as Enterprise South Industrial Park. In 2003, approximately 3,400 acres located throughout VAAP were sold or given to the US Department of Education, Hamilton County, and parks and recreation groups. Currently VAAP occupies about 2,070 acres (Army 2003b; ATSDR 2001; CFTP 2000; CDM 2002). Remaining property is planned for reuse as industrial or recreational areas.

There are a number of production and support facilities on VAAP. The production facilities were generally located in the western half of the installation. At VAAP, the Army produced trinitrotoluene (TNT), TNT related products (nitric and sulfuric acids, and sellite), and byproducts related to TNT production. In 1962 the facilities in the western portion of the installation were leased to a fertilizer manufacturing company for the production of ammonium nitrate, urea, and related products (Army 2003a, Public Comment 2004b). The completed TNT product was stored at VAAP in magazines located throughout the eastern half of the installation. Although most of VAAP was government owned and operated, a contractor operated the CF Industries, Incorporated (CFI) lease area in the western part of the installation.

History

VAAP, originally known as the Volunteer Ordnance Works (VOW) was only used to manufacture TNT. It employed two production methods: the batch process and the Canadian Industries Limited (CIL) continuous process. Approximately 2.9 billion pounds (lbs) of TNT was produced; sellite, nitric and sulfuric acids, and chemical byproducts of TNT were also produced at VAAP (IT Corp 1994). A detailed review of VAAP's history and a description of the TNT manufacturing processes are provided in Appendices A and B, respectively.

TNT manufacturing activities occurred intermittently during periods of war with long periods of inactivity during peace time. Active periods spanned from 1942 to 1946 (World War II), 1952 to 1957 (Korean War), and 1965 to 1977 (Vietnam War). In 1977, TNT production activities ceased and VAAP was placed on inactive status. VAAP is currently undergoing environmental investigations, remediation, and redevelopment under the oversight of a number of organizations, including the Tennessee Department of Environment and Conservation (TDEC), U.S. Environmental Protection Agency (EPA), the Regional Planning Agency, Hamilton County Real Property Office, and the U.S. General Services Administration (GSA) (IT Corp 1994; Army 2003a).

In 1962, the western portion of VAAP (referred to as the CFI Lease Area) was leased to a fertilizer manufacturing company for the production of ammonium nitrate, urea, and related products (Army 2003a). This area had previously been used to produce nitric and sulfuric acid for TNT manufacturing. During the Vietnam War, the Army reclaimed some of the lease area to increase acid production as TNT manufacturing restarted for the war effort; however fertilizer production continued as well (Bonds 1985; Army 2003a). Commercial production of ammonium nitrate continued until 1982 (Army 2003a). The CFI Lease Area is undergoing environmental investigation, remediation, and redevelopment along with VAAP as a whole.

Remedial and Regulatory History

After the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) legislation was passed in 1980, VAAP personnel suggested 26 sites as potential locations for contamination. Because the Army was in the process of conducting environmental investigations, TDEC and EPA accepted this list of 26 sites without additional investigations. The Army is conducting investigations on the installation's environmental impact under the Installation Restoration Program (IRP) (IT Corp 1994). The Army plans to complete the IRP in April 2020 (Army 2003a). Over time, the number of sites has been reduced from 26 to 18 based on records and archive reviews conducted for the Installation Assessment (IT Corp 2004). As described in Table 2, VAAP is currently divided into 18 sites, designated VAAP-1 to 6, 15, 16, 18, 20, 21, 23, and 30 to 35.

On November 1, 1991, VAAP received notification of EPA's intention to issue an Order and Agreement pursuant to section 106 of CERCLA. The order prompted a discussion between EPA Region 4 and VAAP. On February 20, 1996, EPA Region 4 decided that TDEC would oversee VAAP's remediation since it was not a National Priorities List (NPL) site; and in March 1997 the TDEC Division of Superfund became the lead remediation agency (Army 2003a).

In 2000, TDEC and EPA Region 4 decided that EPA should order enforcement vehicle (3008(h)) of the Resource Conservation and Recovery Act (RCRA). The final order was delivered and became effect on December 4, 2001 (Army 2003a). As portions of VAAP have been remediated and released for reuse, these portions have been removed from the Tennessee list of State Superfund sites. VAAP-6-Eastern Magazine Area/New Storage Area is slated to be removed from the State Superfund list shortly. Only VAAP-2-CFI Lease Area and VAAP-32-TNT Manufacturing Valley remain on the State Superfund list (TDEC 2003a).

ATSDR Involvement

In March 2001, the Agency for Toxic Substances and Disease Registry (ATSDR) received a request from EPA for a public health evaluation at VAAP. ATSDR conducted an initial site scoping visit April 18-19, 2001. ATSDR staff met base representatives and representatives of EPA and TDEC, toured the installation and surrounding areas, and collected community health concerns. ATSDR identified past, current, and future exposure pathways and determined that no immediate or long-term public health hazards existed. On June 14, 2001, ATSDR held a public availability session at VAAP. During the meeting ATSDR met with community members to gather more information on the community's health concerns (which are addressed in the Community Health Concerns section of this PHA). In September 2001, ATSDR released a health consultation outlining exposure issues that were gathered during the site visit conducted April 18-19, 2001. At that time ATSDR did not identify issues that pose an imminent public health threat, but did identify issues to be further investigated (ATSDR 2002a)

Climatology and Geology

VAAP is located in Hamilton County, which generally has cool winters (with temperatures frequently dropping to 32 degrees Fahrenheit [ºF] or less) and warm summers (temperatures usually ranging from 86-94ºF with high humidity and thunderstorms). The average annual temperature is 60.4ºF, and the average annual precipitation is 51.8 inches. Precipitation is fairly well distributed throughout the year, with peaks in the winter (from storms deriving from the Gulf of Mexico) and in July (when thunderstorms arrive from the south and southwest). The region has a growing season of about 228 days, with the first frost arriving between the end of October and the beginning of November, and the last frost occurring between the end of March and the beginning of April.

The geology of an area describes the history of the earth by examining its underlying composition (DOG 2003). Understanding the underlying composition of an area is useful, because it often provides information about groundwater flow and surface features which dictate surface water drainage.

VAAP is located within the Appalachian Valley and Ridge. More resistant sandstone, sandy shales, limestones and dolomites sustain the Appalachian Ridges. Shale is a fissile (capable of splitting) rock that is formed by consolidation of clay, mud, or silt. It is a finely stratified or laminated structure and is composed of minerals essentially unaltered since deposition. Siltstone is a rock composed chiefly of hardened silt. The Appalachian Valleys develop in more soluble limestones and dolomites. Limestone is a rock that is formed chiefly by the accumulation of organic remains (such as shells or corals) and consists mainly of calcium carbonate. Dolomite is a mineral consisting of calcium magnesium carbonate found in crystals and in extensive beds as a compact limestone. The term dolomite is sometimes used to describe a limestone or marble bed rich in magnesium carbonate (IT Corp 1994).

Different layers or strata of the earth were formed at different times in the past. The layers of rock and earth underlying VAAP are derived from the Conasauga Group and the Knox Group. The Conasauga Group is approximately 1,800 feet (ft) thick (549 meters [m]), was formed during the Cambrian Period (approximately 544 to 505 million years ago), and is composed of two units: the Conasauga Shale and the Maynardsville Limestone. The Knox Group is approximately 2,670 to 2,800 ft thick (813.8 to 853.4 m), was formed during the Upper Cambrian and the Lower Ordovician Period (approximately 500 to 440 million years ago), and is composed of four units (USGS 2003; IT Corp 1994). Two of the units that make up the Upper Cambrian/Lower Ordovician Period are present at VAAP: the Copper Ridge Dolomite and the Chepultepec Dolomite.

VAAP is characterized by diverse terrain. The elevation ranges from 700 ft above mean sea level (msl) to 1,100 ft above msl. Generally, the western half of VAAP is a wide, gently rolling valley, and in the eastern half of the installation, there are hills with moderate to steep slopes. The Maynardsville Limestone and the shale and siltstone of the Conasauga Shale form the hills to the east and west of the valley at VAAP. The more central portion of Volunteer includes a series of hills known as Summit Knobs, which provide a transition from the hills in the east and valley in the west. The Summit Knob region is underlain by Knox Group dolomite. All VAAP manufacturing areas and half of the magazine storage areas are located within the valley in the western portion of the installation.

Quality Assurance and Quality Control

In preparing this PHA, ATSDR reviewed and evaluated information provided in the referenced documents. Documents prepared for the CERCLA program must meet standards for quality assurance and control measures for chain-of-custody, laboratory procedures, and data reporting. The environmental data presented in this PHA come from site characterization, remedial investigation, and groundwater monitoring reports prepared by VAAP under CERCLA and RCRA. Based on our evaluation, ATSDR determined that the quality of environmental data available for most exposure pathways at VAAP is adequate for making public health decisions.

Evaluation of Environmental Contamination and Potential Exposure Situations

Introduction

What is meant by exposure?

ATSDR's PHAs are driven by evaluation of the potential for human exposure, or contact with environmental contaminants. Chemical contaminants released into the environment have the potential to cause adverse health effects. However, a release does not always result in human exposure, and exposure does not always result in health effects. People can only be exposed to a contaminant if they come in contact with it-if they breathe, eat, drink, or come into skin contact with a substance containing the contaminant.

How does ATSDR determine which exposure situations to evaluate?

ATSDR evaluates site conditions to determine if people could have been, are, or could be exposed (i.e., exposed in a past scenario, a current scenario, or a future scenario) to site-related contaminants. When evaluating exposure pathways, ATSDR identifies whether exposure to contaminated media (soil, sediment, water, air, or biota) has occurred, is occurring, or could occur through ingestion, dermal (skin) contact, or inhalation.

If exposure was, is, or could be possible, ATSDR evaluates whether contamination is present at levels that might affect public health. ATSDR selects contaminants for further evaluation by comparing them against health-based comparison values (CVs). These are developed by ATSDR from available scientific literature related to exposure and health effects. CVs are derived for each of the different media and reflect an estimated contaminant concentration that is not likely to cause adverse health effects for a given chemical, assuming a standard daily contact rate (e.g., an amount of water or soil consumed or an amount of air breathed) and body weight.

CVs are not thresholds for adverse health effects. ATSDR CVs establish contaminant concentrations many times lower than levels at which no effects were observed in experimental animals or human epidemiologic studies. If contaminant concentrations are above CVs, ATSDR further analyzes exposure variables (for example, duration and frequency of exposure), the toxicology of the contaminant, other epidemiology studies, and the weight of evidence for health effects.

Some of the CVs used by ATSDR include ATSDR's environmental media evaluation guides (EMEGs), reference dose media evaluation guides (RMEGs), and cancer risk evaluation guides (CREGs) and EPA's maximum contaminant levels (MCLs). MCLs are enforceable drinking water regulations developed to protect public health. CREGs, EMEGs, and RMEGs are non-enforceable, health-based CVs developed by ATSDR for screening environmental contamination for further evaluation.

You can find out more about the ATSDR evaluation process by consulting Appendix D, ATSDR'S Exposure Evaluation Process, reading ATSDR's Public Health Assessment Guidance Manual at http://www.atsdr.cdc.gov/HAC/HAGM/, or contacting ATSDR at 1-888-42ATSDR.

If someone is exposed, will they get sick?

Exposure does not always result in harmful health effects. The type and severity of health effects a person can experience because of contact with a contaminant depends on the exposure concentration (how much), the frequency and/or duration of exposure (how long), the route or pathway of exposure (breathing, eating, drinking, or skin contact), and the toxicity of the chemical. Once exposure occurs, characteristics such as age, sex, nutritional status, genetics, lifestyle, and health status of the exposed individual influence how the individual absorbs, distributes, metabolizes, and excretes the contaminant. Together, these factors and characteristics determine the health effects that may occur.

In almost any situation, there is considerable uncertainty about the true level of exposure to environmental contamination. To account for this uncertainty and to be protective of public health, ATSDR typically uses worst-case exposure level estimates for the initial screening to identify if adverse health effects are possible. These estimated exposure levels usually are much higher than the levels that people are really exposed to. If the exposure levels indicate that adverse health effects are possible, ATSDR performs a more detailed review of exposure, also consulting the toxicological and epidemiological literature for scientific information about the potential health effects from exposure to hazardous substances.

Figure 3 and Appendix D provide an overview of ATSDR's exposure evaluation process. Appendix E defines some of the terms used in this report.

What potential exposure situations were evaluated for VAAP?

ATSDR identified four potential exposure situations at and near VAAP for further evaluation:
  • Past exposures to airborne contaminants
  • Past exposure to groundwater contaminants in off-site private wells
  • Past, current, and future exposures to contaminants in surface soil during industrial or recreational use
  • Past, current and future exposures to contaminants in surface water and sediment during recreational use.
Table 1 provides a summary of potential exposure situations evaluated in this PHA. Appendix D describes the evaluation process ATSDR used to identify and evaluate potential exposure situations at VAAP.

Potential Exposure to Contaminants in Air

Currently, there is no public health hazard associated with exposure to air from VAAP. TNT production ceased in 1977 and ammonia nitrate production ceased in 1982. Past public health hazards from potential air emissions during TNT production cannot be fully evaluated because too little is known about the actual air concentrations in the surrounding community.

TNT manufacturing is not currently occurring and is not proposed at VAAP, as a result there are no air exposures to TNT, the chemicals used to make TNT or the production by-products. Anecdotal evidence indicates that past releases from TNT manufacturing occurred and potentially affected people in communities surrounding VAAP. However, past air monitoring data are not available; therefore potential exposures resulting from these releases cannot be fully evaluated. It is important to remember that nitric and sulfuric oxides that were released by VAAP during TNT production are also released by a variety of other processes including car and truck emissions and other industrial activities that burn fossil fuels. The following analysis only considers the potential exposure of VAAP-area residents to emissions related to TNT production. It is possible that for some VAAP-area residents their greatest exposure to nitric and sulfur oxides would be from a source unrelated to TNT production.

TNT Production Process

TNT was produced at VAAP from 1942 to 1945, 1952 to 1957, and 1965 to 1977. The major emissions of TNT production were nitrogen and sulfur oxides (NOx and SOx); toluene and trinitromethane (TNM) were released as well, but in very small amounts. Emissions were generated during different parts of the TNT production process. Nitrogen and sulfur oxides were generated and emitted during the nitration of toluene into crude TNT, as were small amounts of toluene and TNM. Nitrogen and sulfur oxides were also generated and emitted during the production of nitric and sulfuric acids and the Spent Acid Recovery process. Negligible amounts were also generated and emitted when crude TNT was purified. Emissions may have also occurred during the production of sellite, a chemical used to purify TNT, and the incineration of red water (a liquid waste generated during TNT production). Red water incineration results in atmospheric emissions of nitrogen oxides and sulfur dioxide and ash (primarily as sodium sulfate [Na2SO4]).

Another possible source of air contamination derives from a safety procedure called "drowning the charge." TNT production is a sensitive process. If temperatures get too high, nitrated organics can detonate. When the chemical reactions involved in TNT production begin to cause temperatures to rise faster than the cooling systems can accommodate, an automated safety procedure called "drowning the charge" is activated, and the contents of the reactor (where the chemical reactions are occurring) are dumped into a large tank of water. Although this process prevents explosions, it also generates fumes of nitrogen oxides. The most common forms of the nitrogen oxides generated have reddish hues (USAEHA 1985). Anecdotal information indicates that this safety feature was periodically exercised to assure that the system would function properly in case of emergency. It is possible that periodic testing was more frequent than the actual use of the system (Public Comment 2004b). More information on TNT production is provided in Appendix B.

Nature and Extent of Contamination

ATSDR reviewed information about many of the processes associated with TNT production to provide a description of the compounds potentially released during past operations and potential exposures. During TNT production, emissions from VAAP likely migrated across installation boundaries. Anecdotal reports indicate that "acid clouds" originating from VAAP traveled into and affected the surrounding areas (ATSDR 2001).

Air emissions rapidly mix and disperse within the atmosphere; the concentrations of the emitted compounds decrease substantially with distance as the emissions travel downwind from the source. Exposure from a particular source at VAAP depends on a variety of factors including the concentration of the source emissions, and the speed and direction of the wind. These would affect both the concentration of the compound in the air and the length of time that a person would be exposed to the compound. Anecdotal information from several sources indicates that air sampling was conducted at various locations around VAAP - at least during the last few years of TNT production. Unfortunately ATSDR was not able to obtain the data. Apparently there was no legal requirement for the air monitoring, but sampling was conducted by the company that operated the TNT manufacturing plant. It appears that while the Army and other local agencies reviewed the data, it was not stored by those agencies. The original TNT manufacturing company was sold twice since the early 1970's, ATSDR was not able to contact anyone at the current company who had any knowledge of the VAAP-area sampling. Therefore due to the lack of available air monitoring data, it is not possible to estimate the concentration of the potential contaminants in the air or the length of time that a particular concentration would be present, and not possible to fully evaluate the potential exposure.

Previous 'Health Studies'

During the PHA process several VAAP-area residents mentioned that previous studies had been accomplished during the late 1960's and early 1970's that measured the pulmonary function (the 'breathing' tests) and respiratory illness rates of VAAP-area school children compared to other Chattanooga-area children who did not live near VAAP. Based on information provided by community members (Public Comment 2004a) ATSDR was able to identify several studies that were used by EPA to identify and evaluate health effects related to air pollutants. Those studies are reviewed in Appendix F (comment #6).

Although a small decrease in pulmonary function and increase in respiratory illness rate was reported for the VAAP area during the late 1960's to early 1970's, the actual increase was small and a specific cause was not well identified. It is possible that these health effects were influenced by the emissions from VAAP, the health effects considered in the Chattanooga studies are consistent with the health effects the could be possible following exposure to compounds believed to be present in the VAAP acid clouds (see Appendix C for details). However it is not possible to identify if VAAP emissions were the sole cause of the reported health effects. Other potential confounding factors include exposure to environmental tobacco smoke, parental occupational exposures, potential exposures to dust and chemicals from hobbies, family size, and nutritional status. The researchers believe they were able to account for the majority of these factors during their analyses, however these factors illustrate the difficulty of trying to identify a specific cause for a small increase in respiratory illness.

The reduction in the respiratory illness rate reported from September 1972 through April 1973, corresponding with the reduction in emissions, suggests that the health effects may be influenced by the ambient pollutant levels and that improvement in the air quality would likely lead to improvements in the measured levels of pulmonary function and respiratory illness rates. In addition, this reduction suggests that the small measured increase in respiratory illness for the VAAP-area family segments is not a chronic condition.

Public Health Implications

Potential health effects caused by emissions from TNT production at VAAP depend on the chemical concentration within the plume (or cloud), the amount of time a person was exposed to the plume, and how frequently the person was exposed to the plume. Emissions from VAAP that traveled into the surrounding residential areas are likely to have consisted primarily of nitrogen and sulfur oxides; including nitric and sulfuric acid. Information regarding the potential health effects of these chemicals is listed below. It is unlikely that toluene or TNM traveled into the surrounding residential areas at detectable levels because only small amounts of these chemicals were produced.

Off-base concentrations of chemicals in the plume would vary significantly based primarily on how much of the compound was released at VAAP, the height of the release, the location of the release, and the meteorological conditions at the time of the release; predominantly wind speed. While no measured data exists to describe the concentration of nitrogen or sulfur oxides, ATSDR was provided some useful information by people who resided near the base during the time TNT was produced. ATSDR combined that information with basic information about the likely composition of the emissions and the chemical properties of those compounds in air. The results indicate that the clothing and vegetation damage, and short-term health effects reported by residents are consistent with short-term exposures to nitrogen dioxide, nitric acid, sulfur dioxide, and sulfuric acid at concentrations above current regulatory standards (Appendix C).

The symptoms described are consistent with the acute symptoms associated with short-term exposure to nitrogen and sulfur oxides. These symptoms are generally alleviated within a short time after the exposure stops. Little information is available to identify if long-term health effects would be likely for this type of exposure. The information below describes the acute effects common to short-term exposure to nitrogen and sulfur oxides.
  • Nitrogen Oxides
    The red/orange/brown color of the clouds was likely a result of nitrogen oxides. Nitrogen oxides are gases composed of nitrogen and oxygen. Two of the most toxicologically significant nitrogen oxides are nitric oxide (NO) and nitrogen dioxide (NO2). Nitrogen dioxide has a strong, harsh odor and can react with water or sunlight to produce nitric acid or ozone. Exposure to moderate levels of gaseous nitrogen oxides can irritate the eyes, nose, throat, and lungs of a person, as well as cause coughing, shortness of breath, tiredness, and nausea. Exposure to high levels of nitrogen oxides can cause more severe immediate effects such as rapid burning, spasms, and swelling of tissues in the throat and upper respiratory tract (ATSDR 2002b).

    While various health effects have been reported for exposures to nitrogen oxides, the reviewed literature suggests that health effects, from acute or chronic exposure, would likely begin immediately, or within a few days of the exposure (Meditext 2000, 2002). ATSDR did not identify any literature that described health effects occurring years after the exposure ended. Research also does not indicate that nitrogen oxides have reproductive effects in humans or effects on human development; nor does research indicate that children are more susceptible or affected differently than adults. The Department of Health and Human Services (DHHS), the International Agency for Research on Cancer (IARC), and EPA have not determined whether nitrogen oxides are carcinogenic (ATSDR 2002b).

  • Sulfur Oxides
    Sulfur oxides emitted during TNT production include sulfur dioxide, sulfur trioxide, and sulfuric acid. Similar to nitrogen oxide exposure, most information suggests health effects are most likely to develop during, or shortly after, exposure. The potential health effects from exposure to sulfur oxides are described below.

    • Sulfur Dioxide
      Sulfur dioxide is omnipresent, and atmospheric concentrations range from 0 to 1 parts per million (ppm). It is a colorless gas with an irritating odor. Short-term exposure to extremely high levels of sulfur dioxide (100 ppm or more) is considered immediately dangerous to life and health. Extremely high concentrations are not typically found in the environment due to routine production operations, but could occur in the immediate vicinity of some type of occupational accident.

      The more common effects of sulfur dioxide include difficulty breathing and burning of the nose and throat (ATSDR 1998a). Sensitive populations, such as asthmatics, are more likely to be affected by sulfur dioxide exposures. There is no evidence, however, confirming that children are more vulnerable to exposure. Some evidence suggests long-term exposure to persistent levels can effect lung changes; however there are confounding factors in these studies (ATSDR 1998a), and the results are inconclusive.

    • Sulfur Trioxide and Sulfuric Acid
      Sulfur trioxide is present in the environment for short periods of time as a gas, and quickly reacts with water to form sulfuric acid. Subsequently, sulfuric acid is more likely to be found in the environment. Similarly, when sulfur trioxide contacts the moist surfaces of the respiratory tract or skin, it forms sulfuric acid. Therefore, the health effects of sulfuric acid are more representative than sulfur trioxide. Sulfuric acid irritates the nose and has a pungent odor, and as with sulfur dioxide, people with asthma are more sensitive. Studies have shown that people exposed to sulfuric acid experience decreased lung function and increased risk of respiratory symptoms (Lipsett 2001). When people are exposed to both sulfuric acid and sulfur dioxide, more sulfuric acid penetrates the alveolar regions of the lung, thereby increasing its toxicity (ATSDR 2002c). Evidence indicates that occupational exposure to strong inorganic acid mists containing sulfuric acid is carcinogenic to humans (ATSDR 1998b). Occupational exposures have also been linked to etching, or erosion of tooth enamel on the central and lateral incisors (front four teeth on the upper and lower jaw) (Meditext 1988b).

Currently there are no industrial sources of air emissions at VAAP, and therefore no air exposures to TNT production by-products or other industrial chemicals. After reviewing qualitative data, anecdotal evidence, and potential exposure sources, ATSDR concluded that past potential exposure likely occurred, however it is not possible to quantify the exposure or estimate if long-term health effects would be likely due to the exposure. Past exposures could have caused short-term health effects in people who were in the immediate vicinity of the plume. Sensitive individuals may have experienced the effects sooner and the health effects may have been more pronounced. It is not possible to evaluate the potential for long-term health effects because so little is known about the actual concentrations of the nitrogen and sulfur oxides in the air, and the frequency and duration of the exposure. In addition, the potential for long-term health effects would also be influenced by the nitrogen and sulfur oxide emissions from other local industries and vehicle traffic.

Potential Exposure to Contaminants in Groundwater

Residential well sampling results indicate some private wells currently have detectable levels of site-related contaminants. Residents, however, obtain drinking water from the municipal water supply, so there are no current exposures to the site-related contaminants in the residential drinking water supply. Historically, some residents used groundwater from private wells as their primary source of drinking water, however identifying if those residents were exposed to higher or lower concentrations of site-related chemicals is not possible because sampling data are not available for that time. Some residents are currently reported to use groundwater from private wells to water lawns and gardens or fill swimming pools. ATSDR's evaluation indicates that use of private wells to water lawns and gardens is not a health concern. However, due to insufficient information about the actual concentration of lead in swimming pools filled from private wells with lead concentrations above EPA's action level, ATSDR recommends that residents who use groundwater to fill their pool periodically have the pool water tested for lead.

Site investigations indicate that groundwater contamination originating at VAAP migrated beyond installation boundaries into areas where some homes historically obtained drinking water from private wells. Past off-site sampling data detected explosives in private wells, but these data are insufficient to identify the possible contaminant concentrations or potential exposures. The Army provided bottled water to homes with detectable levels of explosives in their wells and connected these homes to municipal water supplies. Three different municipal water systems supply water to the VAAP and the surrounding community, each company complies with state and federal regulations, such as the Safe Drinking Water Act. Existing private wells are used for non-potable purposes only.

Hydrogeology

Groundwater movement at VAAP is affected by the underlying karstic geologic features. VAAP rests on a subsurface composed of soluble rocks (limestone, dolomite, and calcareous shale); minerals have dissolved and leached from the rock forming a diverse and complex aquifer system that includes springs and seeps (IT Corp 1994; PCG 2003). The aquifer system is composed of folded and faulted rocks of the Knox Group, the Conasauga Group, and the overlying residuum (subsurface soil derived from these underlying strata) (IT Corp 1994; EPA 2002). More information is provided in the Geology Section of this PHA.

VAAP can be divided into three hydrogeologic regions or domains (IT Corp 1994; GSA N.D.). Groundwater flow directions vary between the regions primarily due to variations in the prevalence and orientation of the fractures within the rock in each region. Splays (sections) of the Kingston Fault, a fault that extends throughout the region, form the boundaries of these domains (IT Corp 1994). A fault is a fracture in the crust of the earth, where one side of the fracture has been displaced (up, down or sideways) relative to the other. The Kingston Fault is a thrust fault, which means the earth fractures in such a way that the older layers of earth are placed over the younger layers. The hydrological regions include:
  1. In the western domain, which underlies most of VAAP-2-CFI Lease Area, groundwater appears to flow in an easterly direction, towards the base, and then diverts to the north or south to exit the base (IT Corp 1994; GSA N.D.).

  2. The central domain, which underlies VAAP-32-TNT Manufacturing Valley (TNTMV), is characterized by a northeasterly-plunging syncline (a large fold or trough of stratified rock) bounded on the east and west by the Kingston Fault (IT Corp 1994; GSA N.D.). Groundwater tends to flow in a northerly direction, along the syncline.

  3. The eastern domain, located in the eastern portion of VAAP, has not been characterized, except for VAAP-15-the New Landfill/Burning Ground and VAAP-23-the Redwater Ash Landfill. From the available data, perched zones appear to be in the subsurface soil and groundwater flow follows surface topography-flowing westward and possibly north-northwest as it exits VAAP (GSA N.D.).

Groundwater flow is influenced by the characteristics and structure of the bedrock, the amount of precipitation, and the water levels in the Chickamauga Reservoir (IT Corp 1994). Hydraulic conductivity, the aquifer's ability to transmit water, is highly variable at VAAP. Both the variable hydraulic conductivity (which affects the potential for and rate of groundwater flow and therefore, contaminant migration) and the unpredictable karst geology make it difficult to predict if, and how, onsite contaminated groundwater will migrate and affect offsite groundwater resources (GSA N.D.).

Groundwater Use and Drinking Water Supplies

Groundwater at VAAP was not used as a water source. In the past, VAAP pumped surface water from the Tennessee River (approximately 1 mile west of the installation) to two filtration water treatment facilities onsite. There was no permanent on-site residential population, but water was needed for employee and facility operations. In 1984, both of the installation filtration facilities were deactivated, and VAAP began using public water via the Tennessee American Water Company (TAW) (IT Corp 1994). Currently, one of the treatment facilities (Filter Plant No. 1) is being leased by the Eastside Utility District, which now supplies water to VAAP, and other areas within Hamilton County (GSA N.D., Public Comment 2004b). Filter Plant No. 2, however, is no longer used, and its repair is not an economical option.

Currently, TAW, the Eastside Utility District, and the Savannah Valley Utility District supply water to the communities and industries surrounding VAAP. TAW draws water from the Tennessee River west and south of VAAP, and the Eastside Utility District draws water from the Tennessee River (using the VAAP filtration plant) (IT Corp 1994). The Savannah Valley Utility District obtains water from a series of well fields, including Carson Spring (northeast of VAAP), which is leased from the Eastside Utility District (SVUD 2003). There is a possibility that Carson Spring draws water from an area at least partially recharged by surface and groundwater from the northeastern portion of VAAP (GSA N.D.).

Residential areas surround VAAP, and in the past, some residents have used private wells for their water supply. Sampling of these wells between 1994 and 2001 identified explosives in some of these wells. As a result, the Army supplied homes served by private wells with bottled water and, between 1995 and 1997, connected these homes to municipal water supplies (Shaw 2003). Currently, private wells are being used as a non-potable water source, such as for gardening, irrigation, heat pumps, and swimming pools (TDEC 2003a).

Nature and Extent of Contamination

Monitoring wells at VAAP have been installed at different points in time for different environmental surveys and analyses. VAAP became inactive in 1977, and environmental investigation began shortly after in 1978. The first investigations mainly sought to describe the installation, study the surface and subsurface geology, and locate potential areas of contamination (IT Corp 1994). Tables 3, 4, and 5 summarize maximum contaminant levels above CVs in on- and off-site wells and residential wells.

In the 1980s, additional surveys were conducted that further defined subsurface geology and hydrology, as well as confirmed groundwater contamination in the TNTMV and the CFI Lease Area. In 1987, a Remedial Investigation/Feasibility Study (RI/FS) was conducted following RCRA guidelines. Monitoring well installation and groundwater sampling took place throughout VAAP. The RI found that TNT-related contaminants were primarily located in the groundwater underlying the TNTMV, as well as near VAAP-15-the New Landfill/Burning Grounds. The groundwater underlying the CFI Lease Area was also found to contain detectable levels of explosives, as well as nitrate/nitrite levels above current drinking water standards (IT Corp 1994).

In December 1990, RI/FS Addendums reported detectable levels of explosives in residential wells (used for consumption, heat pumps, and gardening) near the Waconda Bay, thereby confirming off-site groundwater contaminant migration (Table 5). Surface water from Waconda Bay was sampled and found to contain quantifiable levels of nitroaromatic explosives and nitrate/nitrite (especially when Chickamauga Lake levels were low). In 1992, a Preliminary Site Inspection identified areas to be included in the upcoming Site Investigation (SI). For the 1994 SI, additional monitoring wells were installed in the VAAP-1-East Acid Area, VAAP-20-Industrial Landfill Area, VAAP-21-WW II Landfill Area, VAAP-18-Vanadium Pentoxide and Asbestos Burial Area, VAAP-16-WW II Burning Ground Area, VAAP-23-Redwater Ash Landfill, and VAAP-33-the New Acid Area; the sampling and analysis that followed further delineated groundwater contamination at VAAP.

Monitoring results indicate that groundwater contamination has been decreasing over space and time. Within the base boundary; groundwater concentrations in the eastern portion of VAAP are generally below levels of concern. Groundwater contamination is localized around the TNTMV in the western portion of the installation. Most of this contamination seems to migrate north towards Waconda Bay; though some migrates south (TDEC 2003a).

As of October 2003, approximately 200 groundwater monitoring wells had been installed across VAAP. Because VAAP is under ongoing investigation, the number of monitoring wells changes as some wells are added and others closed (Army 2003b). ATSDR's evaluation of VAAP groundwater was based on monitoring results available in June 2003, which included data from 145 on-site wells, 95 off-site wells, and 14 wells of unknown location. The Army has investigated measures to control off-site migration; none have been identified (Army 2003a). Groundwater monitoring continues at VAAP, and a RCRA Facility Investigation (RFI) for groundwater will be completed in 2005 after further collection of time-series and other relevant groundwater data (Army 2003a).

ATSDR reviewed results of groundwater sampling performed by the Army, TDEC and EPA for selected residential wells. Sampling was conducted in 1990, 1991, 1994, 2000, 2001, and 2002. Each sampling event included a unique combination of wells, both in number and location. The greatest number of wells was sampled in 1994 and 2001. Results indicate that explosive related compounds were detected in some of the residential wells as recently as 2001/2002. However the wells that were sampled in 1990 and again in 1994 or 2000 indicate that the concentrations of base-related compounds are decreasing over time. The vast majority of chemicals detected in the groundwater were below CVs. Table 5 shows the maximum concentrations for each compound with a least one sampling event where the concentration detected was above ATSDR CVs and for detected compounds without a CV.

Evaluation of Potential Public Health Hazards

As previously mentioned, due to the nature of the aquifer system underlying VAAP and the surrounding area, it is difficult to measure and almost impossible to model contaminant flow paths in this area. The potential for a residential well to be affected by VAAP-related compounds will depend more on the orientation of the fracture system that the well intersects rather than the distance of the well from VAAP. Little is known about the size, density, and orientation of the fractures that deliver water to the monitoring wells and especially the off-site residential wells. Little is known about the actual flow paths contaminants follow as they migrate off-site. Therefore it is not possible to estimate the concentration of a compound in a residential well prior to the actual sampling of that well. In addition, although the presence of explosive-related compounds in a well would likely be the result of migration from VAAP, other compounds (i.e., solvents, pesticides, metals, or nitrate) could be present in a well due to other commercial, industrial, or residential uses or waste disposal practices that are unrelated to VAAP activities.

ATSDR reviewed the residential well sampling data to evaluate if contaminants have been detected at levels that would be of concern for the current non-potable uses that have been identified. Only one of the wells that was sampled during three of the sampling events (1990, 1994, and 2001) did not have any compounds detected at concentrations above ATSDR CVs. Five of the wells that were sampled twice (1994 and 2001) and 11 of the wells that were sampled once (1994 or 2001) did not have any compounds detected at concentrations above CVs. Approximately 43% (18 of 42) of the residential wells that have been sampled at least once did not have any compounds detected at concentrations above CVs.

While these results indicate that some residential wells could safely be used for all types of domestic uses; ATSDR recommends that property owners who wish to use groundwater from their private well as a source of drinking water have the well water periodically sampled to ensure that the water quality does not degrade over time. Private well operation and sampling should only be conducted in accordance with regulations established by state and local health departments. Contact your state/local health department to identify the appropriate sampling strategy prior to using your private well as a domestic potable water source. EPA is a good source of additional background information; look for the publication Drinking Water From Household Wells (available at http://www.epa.gov/safewater/pwells1.html).

Lead was detected in 14 of the residential wells sampled; in four of the wells the measured concentration was above the EPA Action Level of 15 ppb. Approximately 14 different explosive-related compounds were detected in nine of the residential wells. The vast majority of these compounds were detected at concentrations well below levels of health concern. While some compounds were occasionally detected above CVs, they were only present at slightly elevated concentrations and were not consistently identified in the same well. None of these compounds represent a health concern. Five of the explosive-related compounds do not have specific CVs. They were detected only at very low concentrations, but were consistently identified in four of the wells. Four pesticide or pesticide by-products were also detected in some of the residential wells. Chlordane, dieldrin, and heptachlor epoxide were the only compounds detected above CVs. These compounds were only found in five of the wells sampled in 1994; two of these wells were included in subsequent sampling events, no pesticides were detected in the second sampling events. Lead and the explosive related compounds without CVs were identified for further evaluation. While VAAP is the likely source of the explosive related compounds, the source of lead has not been defined.

ATSDR evaluated the potential exposure of residents to lead and the explosive-related compounds that did not have CVs. ATSDR assumed that residents could come into contact with these chemicals most frequently by using groundwater to fill their swimming pool or by irrigating their lawns or gardens. The greatest exposure in the garden was expected to occur while working with the soil after irrigation.

ATSDR used very conservative assumptions to evaluate these potential exposures. Potential exposure to compounds while swimming was estimated by assuming that an individual would swim daily for six months and ingest 300 milliliters (ml) (over 10 ounces) of pool water during each event. These assumptions are expected to significantly over estimate the number of times children would swim in the pool and the amount of water they would ingest.

Potential for exposure to compounds in the soil was evaluated by estimating the potential increase in soil concentration assuming that over the course of the year, 2 ft of groundwater was added to the surface soil. Compounds present in the groundwater were assumed to remain solely in the top 10 centimeters (cm) (about 4 inches) of the soil. These assumptions are expected to significantly over estimate the amount of groundwater used to irrigate the soil and the concentration of the compounds in the upper soil layer.

The following table shows the estimated exposure of residents to lead and the explosive-related compounds from incidental ingestion while swimming. Typically the estimated doses would be compared with chemical specific minimal risk levels (MRLs). There are no chemical specific MRLs for any of these compounds. However, there is some limited toxicological data available for the explosive-related compounds that suggest comparisons could be made with established MRLs for related chemicals. There is also no established MRL for lead exposure for adults or children. ATSDR compared the potential lead exposure for children with the potential for an increase in blood lead levels predicted by EPA's Integrated Exposure Uptake Biokinetic Model for Lead in Children (IEUBK). This model predicts the probable blood lead concentrations for children between 6 months and 7 years due to exposure to lead in environmental media. Those estimated doses that are above the comparison values are shown in bold print.

Estimated Exposures from Incidental Ingestion of Groundwater during Swimming
Compound Receptor Maximum Concentration (ppb) a Estimated Dose (mg/kg/d) b, c Comparison Value (mg/kg/d)
2-Amino-4,6-dinitrotoluene Adult 2.8 0.003 0.005 d
Child 2.8 0.007 0.005 d
3,5-Dinitroaniline Adult 2.4 0.002 0.002 e
Child 2.4 0.006 0.002 e
4-Amino-2,6-dinitrotoluene Adult 1.5 0.002 0.005 d
Child 1.5 0.004 0.005 d
4-Amino-2-nitrotoluene Adult 1.1 0.001 0.005 d
Child 1.1 0.003 0.005 d
Lead Adult 110 0.11 No MRL
Child 110 0.275 Possible Blood Lead Increase f
a. Represents the maximum concentration measured in the residential wells.
b. Estimated Dose = (Max Concentration)*(300 ml pool water consumption/swimming event)*(183 swim days/365 days)*(100% absorption)/(Body Weight)
c. Body weight was 60 kg for a child and 150 kg for an adult
d. Specific MRLs are not available for these compounds; some limited toxicological studies though suggest they may be similar to TNT.
e. Specific MRLs are not available for this compound; limited information suggests this value is 10,000 times less than doses used for LOAEL animal studies.
f. EPA's IEUBK Model predicts a potential for increased blood lead levels with this type of exposure.
ppb = parts per billion
mg/kg/day = milligrams compound/kilogram bodyweight/day


The estimated doses for children are higher than those for adults because, pound for pound, children were assumed to ingest more pool water than adults while 'swimming'. These analyses are based on using the maximum concentration measured in the groundwater from residential wells. It is not known what effects water evaporation, which could concentrate some chemicals and possibly remove others, or filtration, which could remove certain compounds from the water, would have on the pool water quality. ATSDR did not identify any pool water sampling results that could be used to correlate expected concentrations of chemical in pool water compared to groundwater.

Frequent incidental ingestion of water with lead concentrations above the EPA action level could increase the lead exposure for children and adults. Results of the IEUBK model suggest that children may experience an increase in their blood lead levels using the conservative exposure assumptions described above. In reality, the actual exposure is expected to be much lower. The actual concentration of lead in the swimming pool water could be much lower than the maximum concentration reported in the groundwater sampling data. Children will probably not swim every day, for six months, in the same pool. Children will probably not ingest 300 ml (over 10 ounces) of pool water each time they swim. Because of the uncertainties in the actual concentration of lead in pools filled from private groundwater wells and the actual exposure of children who use these pools, ATSDR can not conclusively identify if children would be expected to experience an increased blood lead level due to almost daily ingestion of pool water while swimming. Therefore, ATSDR suggests as a prudent public health action, pool owners who wish to use groundwater to fill their pool and have young children who frequently use the pool, similar to the levels considered in the exposure analysis, periodically have the pool water tested for lead.

The following table shows the estimated increase in surface soil concentration of each of the compounds considered and the estimated number of years necessary to increase the surface soil concentration by 1 milligram/kilogram (mg/kg). This analysis suggests that the only compound in the groundwater that has any potential to affect soil concentrations, and there by potential exposures, is lead. Even the highest concentrations of the explosive-related compounds are too low to accumulate in the surface soil to levels that could affect the health of gardeners.

Estimated Increase in Surface Soil Concentration due to Groundwater Use for Gardening
Compound Maximum Concentration in Groundwater (ppb) Change in Concentration in Surface Soil (mg/kg) Years to Increase Soil Concentration by 1 mg/kg
2-Amino-4,6-dinitrotoluene 2.8 0.009 110
3,5-Dinitroaniline 2.42 0.008 128
4-Amino-2,6-dinitrotoluene 1.5 0.005 206
4-Amino-2-nitrotoluene 1.1 0.004 281
Lead 110 0.356 3
ppb parts per billion
mg/kg milligrams compound/kilogram soil


While lead does have the greatest potential to accumulate in the surface soil, it is not likely to accumulate to levels that could affect the health of gardeners. The measured lead concentrations in the groundwater are generally lower that the maximum value reported in this table; the second highest concentration in all of the residential wells was approximately 29 parts per billion (ppb). The lead concentration in the well where the maximum value of 110 ppb was reported had previously been measured at approximately 27 ppb. By this evaluation, using groundwater with a lead concentration of 30 ppb would require 10 years to increase the lead concentration in the top 10 cm of the soil by 1 mg/kg. The EPA standard for lead concentrations in residential soil is 400 mg/kg. This indicates that long-term accumulation of lead or other compounds measured in the groundwater is not likely to result from using groundwater for irrigation and that it is unlikely for potential health effects to develop from direct contact with this soil following irrigation.

Nitrate has been detected in a number of the off-base monitoring wells, and potential exposure of residents using private drinking wells has been a concern in the past. High concentrations of nitrate can cause health effects in infants and small children. ATSDR reviewed the groundwater sampling data for the residential wells to identify if nitrate concentrations were elevated during the sampling period. Nitrate was detected in 27 residential wells in the 1994, 2001 and 2002 sampling events. Only two of the samples had concentrations slightly above the CV. Those two occurrences were in two different wells during two different sampling events. One of the wells was sampled at two different times; nitrate was detected during both events, but was only above CVs for one of the sampling events. Based on the information from the residential sampling results, nitrate is not consistently detected at elevated levels in any of the residential wells. In addition these wells are no longer used as a primary source of drinking water. The nitrate concentrations detected in these wells will not cause health effects for people who use the groundwater for non-potable purposes.

In conclusion, it appears that a number of the residential wells currently have detectable levels of VAAP explosive-related compounds. Due to a lack of past residential well sampling data, it is not possible to identify if any of the residential wells were impacted by these or related compounds while, or immediately after, the TNT manufacturing process was operational. Due to the presence of lead and some explosive related compounds in some of the residential wells; ATSDR recommends that residents who wish to use groundwater from private wells for domestic purposes have their wells periodically sampled to ensure the concentrations of lead and other contaminants are within acceptable levels for the use of the water. In addition, ATSDR suggests as a prudent public health action that residents who wish to fill their swimming pools with groundwater and have young children who use the pool frequently, periodically have the pool water tested for lead.



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