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PETITIONED PUBLIC HEALTH ASSESSMENT
CABOT-WROUGHT PRODUCTS - DIVISION OF CABOT CORPORATION
(a/k/a NGK METALS/CABOT BERYLCO, INCORPORATED)
MUHLENBERG, BERKS COUNTY, PENNSYLVANIA


CONCLUSIONS

1. The site has been classified as an Indeterminate Public Health Hazard, primarily due to the lack of past air (prior to 1979) and off-site groundwater (prior to 1990) data. Data needed to evaluate the significance of past air and drinking water exposure pathways can no longer be obtained.

2. Data and scientific information that are available lead ATSDR to believe that significant exposures are not likely to occur through: 1) on-site surface soil, 2) off-site surface soil (for site-related contaminants not already analyzed), 3) off-site groundwater (for site-related contaminants not already analyzed in private wells 2 & 3), 4) off-site biota, and 5) stream sediment (subsequent to unusual sediment found during September 1991). However, actual data for the above mentioned environmental media are necessary to confirm whether or not a public health threat may exist and is further basis for an Indeterminate Public Health Hazard classification.

3. Based upon the environmental and exposure data evaluated by ATSDR, concentrations of contaminants detected in air, water, soil, and sediment are not believed to represent any public health hazard.

4. A past and current completed exposure pathway exists for users of private well 2. However, based on the low level of chromium detected in the groundwater, no adverse health effects are expected. Since future exposures are likely, continual monitoring of that private well water or provision of an alternative water supply is advised.

5. Current scientific evidence indicates that some humans may have an immunological hypersensitivity to beryllium which could cause chronic beryllium disease to occur in those individuals at relatively low levels. Therefore, ATSDR advises that individuals who suspect they have been exposed to clinically significant levels of beryllium in the past through the inhalation pathway and are experiencing symptoms of shortness of breath, fatigue, weight loss, chest and joint pains, cough, and skin rashes should consider consulting an occupational/environmental medicine specialist to determine whether specialized testing for beryllium sensitivity is appropriate.

Data gaps or data inadequacies are data that are needed to adequately or more fully evaluate environmental contamination and human exposure. These data inadequacies will be listed, although some data are no longer available. Data inadequacies discovered by ATSDR during preparation of this petitioned public health assessment include the following:

  1. On-site surface soil characterization (0-3" dry weight basis) has not been conducted to determine contamination at the Disposal Area Drain Field and areas around presently covered solid waste management units where contaminants may have migrated during waste disposal.
  2. Complete off-site groundwater characterization (for site-related contaminants) has not been conducted to determine the actual extent of the contaminant plume.
  3. Some site-related contaminants were not analyzed for in groundwater samples at private wells 1, 2, and 3 (only private well 2 needs to be sampled, unless the groundwater plume is determined to extend outside of the EPA specified well inventory area; private well 1 is no longer in use and private well 3 is outside of the EPA well inventory area).
  4. Local background beryllium soil sampling has not been conducted to assist in determining site-related impacts.
  5. Dry weight samples were not conducted for the unusual sediment observed in Laurel Run on September 17, 1991. The unusual sediment may no longer be present for sampling.
  6. Off-site biota samples have not been conducted for potentially contaminated food chains.
  7. The CREG for beryllium in soil is currently well below background levels commonly found in the environment. No reliable data are available indicating that beryllium causes cancer by ingestion. However, further study is needed to determine whether some levels and forms of beryllium may pose a non-cancer health threat to humans by the ingestion route.
  8. Comparison values are not available for lead in soil.

RECOMMENDATIONS

1. Sample on-site surface soil (0-3" depth), for all site-related contaminants, at the Disposal Area Drain Field and around other Solid Waste Management Units where contaminant migration may have occurred. Representative on-site surface soil sampling should also be conducted following remediation in order to evaluate the effectiveness of remedial activities and any future potential health threat, as well as establish a post-remedial baseline.

2. Conduct a representative number of surface soil samples in residential lawns, parks, and playgrounds in areas downwind of NGK. Samples should be analyzed for arsenic, cadmium, copper, and lead, which are on-site subsurface soil contaminants of concern.

3. Conduct an expanded water well inventory to include areas west of the current EPA specified well inventory area extending to the Schuylkill River to determine whether any groundwater wells are in use in areas where the contaminant plume may exist or migrate. The depth and use of any wells identified should be recorded and those wells that are being used and which might be contaminated should be analyzed. Groundwater samples should not be field filtered.

4. Sample private well 2 for site-related contaminants that have not already been analyzed to ensure that contaminant levels in groundwater are not a current public health threat. Ensure that users of private well 2 continue to receive safe drinking water in the future. Groundwater samples should not be field filtered.

5. Restrict NGK property, properties within the EPA specified well inventory area, and properties west of the EPA specified well inventory area extending to the Schuylkill River, from groundwater use until groundwater remediation or characterization is conducted or until some alternative action is taken to ensure the protection of public health from contaminated groundwater supplies.

6. Conduct current sediment samples to identify whether sediment in Laurel Run near NGK is showing elevated levels of metals. Sediment contaminants should be analyzed on a dry weight basis.

7. Conduct a representative number of fish tissue samples from Laurel Run at locations adjacent and downstream from NGK. Fillet samples should be analyzed for metals present in NGK's wastewater discharge.

8. Actions should be taken during NGK site remediation to protect on-site workers and prevent migration of contaminants. Ambient air monitoring during excavation and transport of on-site waste is also recommended.

9. ATSDR also recommends that the Pennsylvania State Tumor Registry continue to monitor for increases in the incidence of upper respiratory and lung cancer that may develop from past exposure to beryllium in the air.

HEALTH ACTIVITIES RECOMMENDED

In accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended, the data and information developed in the NGK Metals Petitioned Public Health Assessment have been evaluated by the Health Activities Recommendations Panel (HARP).

Available air data indicate that off-site concentrations of beryllium are occurring at levels which are not normally expected to result in adverse health effects (chronic beryllium disease) in the general population. However, in rare cases, some humans have been shown to have a hypersensitivity to beryllium at low levels of exposure. Such hypersensitive responses appear to be dose-independent. The symptoms of chronic beryllium disease are similar to a relatively rare disease, sarcoidosis. Based upon five reported cases of sarcoidosis in the area and the difficulty of diagnosis of this disease, HARP recommends a case series or case studies to be considered for reported cases of sarcoidosis to be conducted through ATSDR's Division of Health Studies, and health professional and community education to be conducted through ATSDR's Division of Health Education.

Current scientific evidence suggests that beryllium is not carcinogenic by ingestion. Further study is needed to determine whether some levels and forms of beryllium may present non-cancer health effects from ingestion of beryllium and to determine accurate biomarkers of susceptibility to beryllium-related illnesses. Based on those data needs, HARP recommends further research into beryllium to be conducted through ATSDR's Division of Toxicology.

Based upon worker-related health concerns, HARP recommends that this petitioned public health assessment be referred to the National Institute for Occupational Safety and Health for investigation of those and other work related health concerns.

PUBLIC HEALTH ACTION PLAN

The purpose of the Public Health Action Plan is to ensure that this petitioned public health assessment not only identifies public health hazards, but also provides a plan of action designed to mitigate and prevent adverse human health effects resulting from exposure to hazardous substances in the environment.

Actions Undertaken

1. ATSDR responded to a petition for a public health assessment (petitioned on December 7, 1990) by conducting a scoping visit on January 26, 1991. A site screening report was drafted and presented internally on February 6, 1991. A decision was made that a public health assessment was warranted and a letter was sent to the petitioner on May 30, 1991. The petitioned public health assessment process was initiated in June 1991. ATSDR staff met with the petitioner to discuss concerns and the petitioned public health assessment on February 3, 1993. The initial release petitioned public health assessment was sent out for EPA and state technical review on April 26, 1993. Additional community health concerns were gathered during availability sessions on June 8, 1993. The petitioned public health assessment was released for over 60 days of public comment on September 1, 1993. Public comments were addressed and further revisions to the assessment were made based upon public comments, additional data and information, and further toxicological research.

Actions Planned

1. As a health follow-up action, ATSDR will forward a copy of this petitioned public health assessment to the National Institute for Occupational Safety and Health for investigation of work related health concerns and issues.

2. ATSDR will be available to provide technical assistance to local, state, or federal agencies or offices that may seek assistance in carrying out actions recommended in this petitioned public health assessment.

3. The Division of Health Assessment and Consultation will use this petitioned public health assessment as an educational tool for the community to make them aware of the possible hazards present, the likelihood of exposure, and to assist the community in assessing possible adverse health outcomes associated with exposure to hazardous substances.

4. The Division of Health Assessment and Consultation will review new data as it becomes available for ATSDR's review and evaluation.

5. If any new data presented to ATSDR are found to be of public health concern, the Division of Health Assessment and Consultation will revise this petitioned public health assessment as appropriate.

In addition, ATSDR will collaborate with appropriate federal, state, and local agencies to pursue the implementation of the recommendations outlined in this petitioned public health assessment.

ATSDR will reevaluate and expand the Public Health Actions when needed. New environmental, toxicological, or health outcome data, or the results of implementing the above proposed actions, may determine the need for additional actions at this site.

PREPARERS OF REPORT

Preparers of Report:

Jeffrey A. Church, REHS
Environmental Health Scientist
Petition Response Branch
Division of Health Assessment and Consultation

Tim Hampton, MSPH
Environmental Health Scientist
Petition Response Branch
Division of Health Assessment and Consultation

Frank Schnell, PhD, DABT
Toxicologist
Petition Response Branch
Division of Health Assessment and Consultation

Thomas Umbreit, PhD
Toxicologist
Petition Response Branch
Division of Health Assessment and Consultation

ATSDR Regional Representative:

Charles J. Walters
Region III Representative
Philadelphia, PA

REFERENCES

1. Dunn Geoscience Corporation. NGK Metals Corporation RCRA Facility Investigation. Volume 1: text and maps. Volume 2: Appendices. Harrisburg, Pennsylvania: Dunn Geosciences. November 15, 1990.

2. Dunn Corporation. Human health evaluation and ecological assessment, NGK Metals Corporation Reading facility. Mechanicsburg, Pennsylvania: February 1992.

3. U.S. Environmental Protection Agency, Region III. "Statement of Basis" and "RCRA Final Decision and Response to Comments." No date.

4. U.S. Bureau of the Census. Census of population and housing, 1990: Summary tape file 1B (Pennsylvania) [machine readable data files]/prepared by the Bureau of the Census. Washington, DC.

5. Water Well Inventory Muhlenberg Township Berks County, Pennsylvania. Dunn Geoscience for NGK and EPA. Document No. 5756-6, June 24, 1991.

6. Dunn Geoscience Corporation. NGK Metals Corporation RCRA Facility Investigation Addendum. Harrisburg, Pennsylvania: Dunn Geosciences. October 25, 1991.

7. Cabot Berylco. monitoring well reports for March 29, 1982; November 22, 1983; January 10, 1984; August 15, 1984; November 14, 1984; June 11, 1985; December 18, 1985; February 14, 1989. January 3, 1990; and a random summary of monitoring well reports from the PADER files.

8. Dunn Geoscience Corporation. Letter to Mr. Vernon Butler, EPA, regarding RCRA Ambient Air Sampling Program, with enclosures. Mechanicsburg, Pennsylvania: March 20, 1991.

9. National Climatic Data Center. Surface Weather Observations for Reading, Pennsylvania, June 25-July 30, 1991 and November 17-December 8, 1992. Asheville, North Carolina: April 20, 1995.

10. Resident. M.J. Reider Associates, Inc. Certificate of Analysis for surface soil. November 25, 1992.

11. RUST Environment and Infrastructure. Progress Report #7 August and September 12994. Mechanicsburg, Pennsylvania: October 13, 1994.

12. U.S. Environmental Protection Agency, Region III, Central Regional Laboratory, Environmental Services Division. Analytical Report Muhlenberg Township. Lab Request No. REQ95007. Annapolis, Maryland: December 1, 1994.

13. RUST Environment and Infrastructure. Soil Sampling Work Plan. Mechanicsburg, Pennsylvania: May 5, 1994.

14. Agency for Toxic Substances and Disease Registry. Record of activity for telephone communication with Ms. Helen Tuman, Lancaster Laboratories. Atlanta: May 8, 1995.

15. Dunn Geoscience Corporation. NGK Metals Corporation RCRA Facility Investigation Addendum. Document 5756-6. USEPA comments and technical responses. Lancaster Laboratories 1990 and 1991 analytical results. January 10, 1991.

16. Muhlenberg Township Authority. September 27, 1990, M.J. Reider Associates, Inc. Certificate of Analysis to Mr. Robert Walborn, Muhlenberg Township Authority. Reading, Pennsylvania.

17. Pennsylvania Department of Environmental Resources, Norristown, Pennsylvania. November 13, 1984, memo to Mr. Robert Stark, Muhlenberg Township Authority, regarding Reading Crest Well.

18. Pennsylvania Department of Environmental Resources. Aquatic Biological Investigation by Peter E. Bronner. February 10, 1982.

19. Bureau of Mining and Reclamation, Harrisburg. Biological/Chemical Stream Survey by Hobart S. Baker, Jr. and Richard A. Hazenstab. January 26, 1989.

20. Pennsylvania Department of Environmental Resources, Reading, Pennsylvania. September 10, 1991, memo to James A. Flesher, PADER, regarding surface water samples.

21. Pennsylvania Fish Commission. Laurel Run Biological Assessment by David E. Spotts. February 27, 1989.

22. Pennsylvania Department of Environmental Resources, Reading, Pennsylvania. November 12, 1991, memo to Bob Schott, PADER, regarding surface water samples.

23. Pennsylvania Department of Environmental Resources, Harrisburg, Pennsylvania. Discharge Monitoring Reports from November 1989 to October 1992.

24. Agency for Toxic Substances and Disease Registry. Site Summary for January 27, 1991, site visit.

25. NGK Metals Corporation. Monthly Air Monitoring Reports 1979-94 to Pennsylvania Department of Environmental Resources, Reading.

26. RUST Environment and Infrastructure. Letter to Ms. Lynne Woodside, NGK Metals Corporation, regarding soil sampling summary. Mechanicsburg, Pennsylvania: August 3, 1994.

27. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Beryllium. Atlanta: ATSDR, April, 1993.

28. Agency for Toxic Substances and Disease Registry. Health Assessment Guidance Manual. Lewis Publishers, Chelsea, MI: 1992.

29. Shacklette, H.T. and J.G. Boerngen, 1984, Element Concentrations in Soils and Other Surficial Materials of the Coterminous United States. USGS Prof Paper 1270. Washington, DC: U.S. Govt. Printing Office.

30. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Copper. Atlanta: ATSDR, December 1990.

31. Newman, L.S., K. Kreiss. Nonoccupational Beryllium Disease Masquerading as Sarcoidosis: Identification by Blood Lymphocyte Proliferative Response to Beryllium. American Review of Respiratory Disease. May 1992, 145:1212-1214.

32. Eisenbud, M.; and J. Lisson. Epidemiological aspects of beryllium-induced nonmalignant lung disease: A 30-year update. Journal of Occupational Medicine. March 1983, 25: 196-202.

33. L.S. Newman. To Be2+ or not to Be2+: Immunogenetics and occupational exposure. Science. October 8, 1993 262:197-198.

34. USEPA. 1987. Health Assessment Document for Beryllium. USEPA Office of Health and Environmental Assessment. Washington, DC, 1987. EPA/600/8-84/026F.

35. National Research Council. 1977. Drinking Water and Health, vol. 1. Washington, DC. National Academy Press. p. 233.

36. Browning, E. 1969. Toxicity of Industrial Metals. New York. 2nd. ed. Appleton-Century-Crofts. p. 69.

37. Schroeder, H.A. and and M. Mitchner, 1975, Life-term studies in rats: Effects of aluminum, barium, beryllium, and tungsten. J. Nutr. 105: 421-427

38. Morgareidge, K, Cox, G.E. and Bailey, D.E., 1975, Chronic feeding studies with beryllium sulfate in rats: Evaluation of carcinogenic potential. Food and Drug Research Laboratories, Inc.,Pittsburgh, PA, Final Report to the Aluminum Company of America.

39. Goyer, Robert A. (1991). Toxic effects of Metals. Chapter 19 In: Casarett and Doull's Toxicology: The Basic Science of Poisons, 4th Edition (Mary O. Amdur, John Doull, and Curtis D. Klaassen, Eds.). Pergamon Press, New York, pp. 623-680. Alkylbenzenes, pg 190-191.

40. US Environmental Protection Agency. 1993. Compendium of human exposure and body burden biomarkers for metals. Environmental Monitoring Systems Laboratory, Office of Research and Development, U.S. Environmental Protection Agency, Las Vegas, Nevada, EPA/600/X-93/002.

41. US Environmental Protection Agency. Integrated Risk Information System. Chromium VI, I.A. Reference Dose for Chromium Oral Exposure. Washington, D.C.: June 1, 1995.

42. National Research Council of Canada. Effects of Chromium in the Canadian Environment. NRCC No. 15017, pg 18. 1976.

43. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Chromium. Atlanta: ATSDR, April, 1993.

44. ATSDR. Toxicological Profile for 1,1-Dichloroethene (Update). Atlanta: ATSDR, December 1993.

45. Pennsylvania Department of Health. State Health Data Center. Pennsylvania Cancer Registry. 1989 and 1990. Cancer incidence and mortality in Pennsylvania 1984: Forty-five selected counties; Cancer incidence and mortality in Pennsylvania 1985. Cancer incidence and mortality in Pennsylvania 1986. Harrisburg, Pennsylvania.

46. Golden, RJ, NJ Karch. Assessment of a waste site contaminated with chromium. In: Paustenbach, DJ, ed. The Risk Assessment of Environmental and Human Health Hazard: A Textbook of Case Studies. New York: John Wiley and Sons. 1989:577-600.

47. Desai, S.G. and Simon, Michael R., 1985. Epidemiology of Sarcoidosis. In: Sarcoidosis (Jack Lieberman, Ed.), Grune & Stratton, Inc., 1985, pp. 25-37.

48. Pennsylvania Department of Environmental Resources. Aquatic Biological Investigation by Michael R. Boyer. March 21, 1991.

49. Muhlenberg Township Authority. A November 30, 1990 memorandum from R.L. Walborn, Muhlenberg Township Authority, to Board Members regarding water quality

50. City of Reading, Bureau of Water. Letter from Mr. Anthony Consentino with attached information and data. Reading, Pennsylvania: December 2, 1993.

51. Current Medical Diagnosis and Treatment. Michael J. Aminoff et al. Appleton and Lange, East Norwalk, Connecticut. 1993.

52. Menzer, Robert E. (1991). Water and Soil Pollutants. Chapter 26 In: Casarett and Doull's Toxicology: The basic science of poisons, 4th Edition (Mary O. Amdur, John Doull, and Curtis D. Klaassen, Eds.). Pergamon Press, New York, pp. 872-902.

53. ATSDR. Draft Toxicological Profile for Fluorides, Hydrogen Fluoride, and Fluorine. Atlanta: ATSDR, July, 1991.

SELECTED BIBLIOGRAPHY
REFERENCES REVIEWED BUT NOT CITED

American Lung Association. Sarcoidosis. Pamphlet. 1980.

Angstadt, P.J., State House of Representatives, Harrisburg, Pennsylvania. January 2, 1991. Letter to ATSDR in support of petitioner's health assessment request.

A.T. Kearney, Inc. NGK Metals Corporation Field Oversight: Residential Sampling Work Plan. Bala Cynwyd Pennsylvania: September 7, 1994.

ATSDR. Review of Clinical Information on Persons Living in or Near Oak Ridge, Tennessee, Supplied by William Reid, M.D., a Physician Practicing in Oak Ridge, Tennessee. Atlanta: ATSDR, DHS, HIB, September 3, 1992.

ATSDR. Toxicological Profile for Arsenic. Atlanta: ATSDR, March, 1989.

ATSDR. Draft Toxicological Profile for Antimony. Atlanta: ATSDR, October, 1990.

ATSDR. Toxicological Profile for Barium. Atlanta: ATSDR, July, 1992.

ATSDR. Toxicological Profile for Cadmium. Atlanta: ATSDR, March, 1989.

ATSDR. Toxicological Profile for Lead. Atlanta: ATSDR, June 1990.

ATSDR. Toxicological Profile for Manganese. Atlanta: ATSDR, July, 1992.

ATSDR. Draft Toxicological Profile for Mercury. Atlanta: ATSDR, October, 1992.

ATSDR. Toxicological Profile for Nickel. Atlanta: ATSDR, December, 1988.

ATSDR. Toxicological Profile for Selenium. Atlanta: ATSDR, December, 1989.

ATSDR. Toxicological Profile for Thallium. Atlanta: ATSDR, July, 1992.

ATSDR. Toxicological Profile for Vanadium. Atlanta: ATSDR, July, 1992.

ATSDR. Site meeting notes with petitioner, public and officials. January 28 & 30, 1991.

ATSDR. February 7, 1991, NGK Metals Facility Trip Report.

Berks Group of the Sierra Club. Letter to ATSDR. January 12, 1991. in support of petitioner's health assessment request.

Bradley, B. It's a Pain When the Well is Sick. Reading Eagle/Times, no date.

Brower, M.W., G.B. Evans, Jr, and B.D. Frontrop, eds. 1983. Hazardous Waste Land Treatment. Boston, MA. Butterworth. p. 244.

Brown CW Jr. U.S. Toxic-waste Unit Makes Site Check at NGK. Reading Eagle/Times February 8, 1991.

Cabot Berylco. Landfill modification request. October 21, 1982.

Cabot Wrought Products Division, Cabot Corp. Letter to US Environmental Protection Agency Region III. April 3, 1985. Response to Notification of Deficiency and Notice of Violation No. III-85-13VR EPA No. Pad 044540136 of March 5, 1985.

Commonwealth of Pennsylvania. Environmental Resources. Memo to Solid Waste Facilities Supervisor. Memo 8-354-1948. November 4, 1986. Discovery of leaching of chromium, fluorides, and sulfates into groundwater.

Commonwealth of Pennsylvania, Office of Attorney General. Press release. January 5, 1990. NGK illegal disposal of calcium cyanide and other wastes.

Cullen, M.R.; Kominsky, J.R.; and M.D. Rossman, et al. Chronic Beryllium Disease in a Precious Metal Refinery: Clinical Epidemiologic and Immunologic Evidence for Continuing Risk From Exposure to Low Level Beryllium Fume. American Review of Respiratory Disease. January 1987, 135:201-208.

Debiec J. Environmental Impact of the NGK Metals Facility on the Local Community. [report for English Class on Technical Writing]. Penn State University--Reading, 1990.

Dunn Geoscience Corporation. Letter to local resident. January 11, 1991. Well water analysis high on hexavalent chromium. Offer to supply bottled water, and if levels significantly increase, connection to city water. Attachment of analysis.

Dunn Geoscience Corporation. Letter to Corrective Action RCRA Enforcement Section, US Environmental Protection Agency Region III, Philadelphia, Pennsylvania. April 8, 1991. Air monitoring, outline for ecological assessment; risk assessment for selenium. Private well survey.

Dunn Geoscience Corporation. RCRA Corrective Measures Study. Summers Model and the Three Dimensional Finite-Difference Groundwater Flow Model. February 21, 1992.

Dunn Geoscience Corporation. Letter and sampling results for Pond 6 waste area. May 11, 1992.

Gannett Fleming Water Resources Engineers, Inc, Harrisburg, Pennsylvania. letter to Pennsylvania Department of Environmental Resources, Norristown, Pennsylvania. October 10, 1984. Reporting improvement of Reading Crest Well during pumping operations. Requesting preliminary permitting.

Hays, Barbara, Sierra Club letter of support. January 16, 1991.

Heinz, J. Senator for Pennsylvania. Letter to ATSDR. February 8, 1991. Enclosed letter from petitioner.

Kemron Environmental Services. Farmington Hills, Michigan. March 10, 1978. Tissue analysis for Reading Hospital, patient not identified. No beryllium in lung biopsy.

Kriebel, D.; Brain, J.D.; Sprince, N.L.; and H. Kazemi. The Pulmonary Toxicity of Beryllium. American Review of Respiratory Disease. 1988, 137:464-473.

Lancaster Laboratories, Inc. 1990. Analysis results.

NGK Berylco, NGK Metals Corporation. Material Safety Data Sheets for Beryllium Copper Casting Alloys, Beryllium Copper Wrought Alloys, and Beryllium Nickel Alloys. 1990.

NGK Metals Corporation. Letter to Field Operations Supervisor, Commonwealth of Pennsylvania, Bethlehem District Office. August 28, 1989. response to Notice of Violation, August 9, 1989.

O'Pake, Michael, Senator of Pennsylvania letter to James Mason, ATSDR. Letter of support for petition.

Pennsylvania Department of Environmental Resources. Aquatic Biology Investigation by Robert F. Frey. September 22, 1971

Pennsylvania Department of Environmental Resources, Harrisburg, Pennsylvania. February 11, 1993, letter from Robert C. Smith, II, PADER, regarding background soil sampling.

Pennsylvania Department of Environmental Resources, Norristown, Pennsylvania. Letter to Muhlenberg Authority. June 6, 1983. Reading Crest Well application denied pending cleanup.

Pennsylvania Department of Environmental Resources, Norristown, Pennsylvania. Letter to Muhlenberg Township Authority. August 1, 1983. Concerning Reading Crest Well application.

Pennsylvania Department of Environmental Resources. NPDES permit and cover letter. September 2, 1992.

Pennsylvania Department of Health. State Health Data Center. Health Profile of Berks County 1990. Harrisburg, Pennsylvania. 1990.

Petitioner. Letters to ATSDR. Oct. 16, 1990; Oct. 19, 1990; Nov. 12, 1990; Dec. 7, 1990; Jan. 1, 1991; Jan. 28, 1991; Jan. 30; 1991; Feb. 6, 1991; Feb. 7; 1991; Feb. 9; Feb. 22, 1991; Mar. 11, 1991; May 13, 1991; May 30, 1991; Aug. 9, 1991; Aug. 29, 1991; Sep. 4, 1991; Oct. 2, 1991; Oct. 17, 1991; Nov. 6, 1991; Nov. 21, 1991; Nov. 26, 1991; Nov. 30, 1991; Dec. 25, 1991; Jan. 23, 1992, Jan. 25, 1992; Feb. 23, 1992; Feb. 24, 1992; Mar. 20, 1992; Apr. 6, 1992; May 4, 1992; May 15, 1992; June 16, 1992; Sep. 21, 1992; Oct. 1, 1992; Oct. 12, 1992; Oct. 22, 1992; Nov. 10, 1992; Dec. 8, 1992; Dec. 14, 1992; Dec. 23, 1992; Jan. 7, 1993; Feb. 5, 1993; Feb. 16, 1993; June 4, 1993; June 7, 1993; July 17, 1993; Sep. 13, 1993; Sep. 15, 1993; Sep. 17, 1993; Feb. 16, 1995; and Mar. 30, 1995.

Petitioner. Letters to Governor Casey of Pennsylvania. July 21, 1990, and September 25, 1990, and reply by Regional Environmental Protection Manager, Bureau of Waste Management, Harrisburg, Pennsylvania. August 17, 1990.

Petitioner. No date. Chronology of events at site from 1930s.

Raffle PAB, Lee, WR, McCallum RI, and Murray R. Hunter's Diseases of Occupations. London: Edward Arnold. No date: 268-273.

Reeves, AL. Beryllium. In: Handbook on the Toxicology of Metals, Vol. II, 2nd edition. New York: Elsevier Science Publishing Co., 1986:95-116.

Regional Administrator, USEPA Region III, Philadelphia, Pennsylvania. Letter to Office of Senator Heinz, Philadelphia, Pennsylvania. Apr 12, 1991. Detailing EPA's response and continuing activities resolving NGK site problems.

Resident. Letter to ATSDR. March 11, 1991. Discussed family illness and expressed support for the public health assessment.

Resident. Letter to ATSDR. March 25, 1991. fisherman and 8 year area resident of Reading reports fishing in Schuylkill River at Laurel Creek and developing sarcoidosis.

Resident. Letter to ATSDR. July 8, 1992. Described unusual health conditions and requested a list of physicians.

Resident. Letter to ATSDR. August 12, 1992. Discussed concerns of environmental contamination.

Resident. Letter to ATSDR. September 3, 1992. Discussed health concerns and beryllium air monitoring.

Resident. Letter to ATSDR. February 24, 1993. Discussing a physician findings regarding health effects from beryllium at Oak Ridge, Tennessee.

Resident. Letter to Dr. Ronald G. Crystal, Cornell Medical Center, and Mr. Daryl Kimball, Physicians for Social Responsibility. May 23 and 24, 1993.

Resident. Letter to ATSDR. June 8 and 9, 1993. Discussed community health and environmental concerns.

RUST Environment and Infrastructure. NGK Metals Corporation RCRA Facility Investigation Work Plan. Mechanicsburg, Pennsylvania: April 1994.

SMC-Martin, Doylestown, Pennsylvania. letter to Environmental Engineer. Kawecki Berylco Industries. August 25, 1980. Monitoring results and site history.

US Army Heidelberg Medical Department Activity. August 20, 1980. Letter to resident on sarcoidosis and association with deodorant sprays and metals.

US Environmental Protection Agency, Region III. Memo from Mr. Jim Gouvas and Mr. Dave O'Brien to Mr. Bernie Turlinski regarding Air Compliance Inspection Report with attached photos, Multi-Media Screening Checklist (December 12, 1993), and Fiscal Year 1993 Air Monitor System Audit (April 6, 1993). Philadelphia, Pennsylvania: January 10, 1994.

US Environmental Protection Agency, Region III. Memo from Mr. Chris Pilla to Ms. Cynthia Metzger regarding NGK Metals Corporation's Sampling and Analysis Work Plan. Philadelphia, Pennsylvania: March 8, 1994.

US Environmental Protection Agency, Region III, Philadelphia Pennsylvania. letter to NGK Metals, Reading, Pennsylvania. December 8, 1989. Review of draft RCRA Facilities Investigation.

US Environmental Protection Agency, Region III. August 15, 1988. NGK Metals Corporation, Administrative Consent Order, U.S. EPA /Docket No. RCRA-III-011-CA.

US Environmental Protection Agency, Office of Health and Environmental Assessment. November 1987. Health Assessment Document for Beryllium. EPA/600/8-84/026F.

Wagnor, J.K.; Infante, P.R., and T. Mancuso. Beryllium Carcinogenicity Studies. Science. July 28, 1978, 201:298-303.


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