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PUBLIC HEALTH ASSESSMENT

VERONA WELL FIELD
BATTLE CREEK, CALHOUN COUNTY, MICHIGAN


APPENDIX A: FIGURES

Site Location
Figure 1. Site Location


APPENDIX B: TABLES

Table 1. Maximum concentrations of VOCs in municipal and residential wells, 1981-1988.

Chemical Municipal wells
(ppb)
Residential wells
(ppb)
Comparison Values
(ppb)
1,1,1-Trichloroethane

180

134

200A
1,1-Dichloroethane

43

150

NAC
1,2-Dichloroethane

17

325

5M, 0.38C
1,1-Dichloroethylene

11

82

90E, 0.058C
Cis-1,2-dichloroethylene

229

3,900

70A
Trans-1,2-dichloroethylene

9

31

100A
Trichloroethylene

67

657

5M
Tetrachloroethylene

120

290

100R

Reference: 13

Note: The municipal production wells have not contained detectable levels of the contaminants of concern since 1984.

Comparison Value Bases

E -- ATSDR Environmental Media Evaluation Guides for non-cancer endpoints.
C -- Cancer Risk Evaluation Guide, based on adult intake and body weight, at 10-6 lifetime cancer risk.
R -- U.S. EPA Reference Dose for chronic exposure of a child.
A -- U.S. EPA Drinking Water Health Advisory(Lifetime).
M -- U.S. EPA Safe Drinking Water Act Maximum Contaminant Level
NAC-- Possible Human Carcinogen (U.S. EPA Class C). Slope Factor or other Comparison Value is Not Available


Table 2. Maximum concentrations of VOCs in Verona Well Field purge wells, August 1984 and April 1989.

Chemical Maximum Concentration
(ppb)
Comparison Values
(ppb)
1984 1989
1,1,1-Trichloroethane

50

14

200A
1,1-Dichloroethane

11

12

NAC
1,2-Dichloroethane

1

ND

5M, 0.38C
1,1-Dichloroethylene

3

ND

90E, 0.058C
1,2-Dichloroethylene (total)

34

13

70A (c)
100A (t)
Trichloroethylene

3.8

11

5M
Tetrachloroethylene

35

43

100R

Reference: 1

ND -- Not Detected

Comparison Value Bases

E -- ATSDR Environmental Media Evaluation Guides for non-cancer endpoints.
C -- Cancer Risk Evaluation Guide, based on adult intake and body weight, at 10-6 lifetime cancer risk.
R -- U.S. EPA Reference Dose for chronic exposure of a child.
A -- U.S. EPA Drinking Water Health Advisory(Lifetime).
M -- U.S. EPA Safe Drinking Water Act Maximum Contaminant Level
NAC-- Possible Human Carcinogen (U.S. EPA Class C). Slope Factor or other Comparison Value is Not Available


Table 3. Maximum concentrations of VOCs, metals, and semi-volatile organic compounds in monitoring and extraction wells at and downgradient of contamination source areas, April 1989.

Chemical

Maximum Concentration
(ppb)

Comparison Value
(ppb)
Chlorinated VOCs
Dibromochloromethane

1,300

300E, 0.42C
1,1-Dichloroethane

3,800

NAC
1,2-Dichloroethane

340

5M, 0.38C
1,1-Dichloroethylene

560

90E, 0.058C
1,2-Dichloroethylene (total)

17,000

70A (cis)
100A (trans)
Tetrachloroethylene

32,000

100R
1,1,1-Trichloroethane

13,000

200A
Trichloroethylene

17,000

5M
Vinyl chloride

4,700

0.2E
Volatile Aromatic Hydrocarbons
Benzene

850

1.2C
Toluene

34,000

1,000A
Ethylbenzene

11,000

700A
Xylenes (total)

28,000

10,000A
Ketones
Acetone

2,900

1,000R
4-Methyl-2-pentanone

2,000

NA
Semi-volatile Organic Chemicals
Bis(2-ethylhexyl)phthalate

88

200R, 25C
2-Methylphenol

29

500R
4-Methylphenol

150

500R
Hexachloroethane

30

10R, 2.5C
N-Nitrosodi-n-propylamine

18

0.005C
Metals
Antimony

59.2

3A
Arsenic

150

3R
Cadmium

29.2

2E
Chromium

102

10,000R (III)
50R (VI)
Manganese

6,490

1,000R
Nickel

228

100A
Zinc

13,100

2,100A

Reference: 1

Comparison Value Bases

E -- ATSDR Environmental Media Evaluation Guides for non-cancer endpoints.
C -- Cancer Risk Evaluation Guide, based on adult intake and body weight, at 10-6 lifetime cancer risk.
R -- U.S. EPA Reference Dose for chronic exposure of a child.
A -- U.S. EPA Drinking Water Health Advisory(Lifetime).
M -- U.S. EPA Safe Drinking Water Act Maximum Contaminant Level
NAC -- Possible Human Carcinogen (U.S. EPA Class C). Slope Factor or other Comparison Value is Not Available
NA -- None Available


Table 4. Maximum concentrations of VOCs in sub-surface soil at the Thomas Solvent Annex and the Grand Trunk Western Railroad paint shop, April 1989.

Chemical Annex
(ppm)
Paint Shop
(ppm)
Comparison Value
(ppm)
1,2-Dichloroethane

2.4

ND

7.7C
1,2-Dichloroethylene (total)

2.7

ND

14A* (cis)
40R (trans)
Tetrachloroethylene

42,000

35

20R
1,1,1-Trichloroethane

1,800

0.620

40A*
Trichloroethylene

4,600

0.064

NA
Toluene

3,400

0.430

400R
Ethylbenzene

1,500

ND

200R
Xylenes (total)

12,000

ND

4,000R
Acetone

0.840

ND

200R

Reference: 1

ND -- Not Detected

Comparison Value Bases

E -- ATSDR Environmental Media Evaluation Guides for non-cancer endpoints.
C -- Cancer Risk Evaluation Guide, based on adult intake and body weight, at 10-6 lifetime cancer risk.
R -- Concentration calculated from U.S. EPA Reference Dose for chronic exposure of a child, assuming pica behavior.
A* -- Soil concentration calculated so that a child subject to pica behavior would ingest a dose equivalent to that obtained from drinking water containing the U.S. EPA Drinking Water Health Advisory (Lifetime).
NAC-- Possible Human Carcinogen (U.S. EPA Class C). Slope Factor or other Comparison Value is Not Available
NA -- None Available


Table 5. Maximum concentrations of VOCs in monitoring wells at the Raymond Road Landfill, March-June 1989.

Chemical

On-Site wells
(ppb)

Downgradient wells
(ppb)

Comparison Value
(ppb)
Dibromochloromethane

ND

ND

300E, 0.42C
1,1-Dichloroethane

29

2

NAC
1,2-Dichloroethane

ND

ND

5M, 0.38C
1,1-Dichloroethylene

ND

ND

90E, 0.058C
1,2-Dichloroethylene (total)

29

3

70A (cis)
100A (trans)
Tetrachloroethylene

0.4

2

100R
1,1,1-Trichloroethane

0.9

ND

200A
Trichloroethylene

1

2

5M
Vinyl chloride

4

2

0.2E
Benzene

11

0.3

1.2C
Toluene

4

0.2

1,000A
Ethylbenzene

2

ND

700A
Xylenes (total)

4

ND

10,000A
Acetone

750

8.6

1,000R
2-Butanone

800

ND

200A
4-Methyl-2-pentanone

75

ND

NA

Reference: 1

ND -- Not Detected

Comparison Value Bases

E -- ATSDR Environmental Media Evaluation Guides for non-cancer endpoints.
C -- Cancer Risk Evaluation Guide, based on adult intake and body weight, at 10-6 lifetime cancer risk.
R -- Concentration derived from U.S. EPA Reference Dose for chronic exposure of a child.
A -- U.S. EPA Drinking Water Health Advisory (Lifetime).
NAC-- Possible Human Carcinogen (U.S. EPA Class C). Slope Factor or other Comparison Value is Not Available
NA -- None Available


Table 6. Concentrations of chemicals found in soil samples from residential areas near the Verona Well Field, 1984.

Chemical Maximum Concentration
(ppm)
Comparison Values
(ppm)
Benzene

0.017

20C
Methylene chloride

0.646

100E, 90C
Toluene

0.009

400R
Acetone

0.183

200R
2-Hexanone

0.071

NA

Reference: 18

Comparison Value Bases

E -- ATSDR Environmental Media Evaluation Guides for non-cancer endpoints.
C -- Cancer Risk Evaluation Guide, based on adult intake and body weight, at 10-6 lifetime cancer risk.
R -- Concentration calculated from U.S. EPA Reference Dose for chronic exposure of a child, assuming pica behavior.
NA -- None Available


Table 7. Estimated air concentrations of selected VOCs in equilibrium with the maximum concentrations found in groundwater at the Verona Well Field site.

Chemical Maximum Concentration Comparison Value (air)
(ppm)
Water (1)
(ppb)
Air (est.)*
(ppm)
Dibromochloromethane

1,300

6

NA
1,1-Dichloroethane

3,800

1,613

NAC
1,2-Dichloroethane

340

155

0.025A, 0.01C
1,1-Dichloroethylene

560

1,098

0.02I, 0.02C
1,2-Dichloroethylene (total)

17,000

1,631

NA
Tetrachloroethylene

32,000

3,473

0.009I, NAC
1,1,1-Trichloroethane

13,000

1,676

NA
Trichloroethylene

17,000

1,423

NA
Vinyl chloride

4,700

90,240

0.6E
Benzene

850

60

0.031C
Toluene

34,000

2,435

1I
Ethylbenzene

11,000

902

0.3I
Xylenes (total)

28,000

2,005

NA

* -- Equilibrium concentration (by volume) calculated from Henry's Law. Coefficients from References 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 46.

Comparison Value Bases

E -- ATSDR Environmental Media Evaluation Guides for chronic exposure for non-cancer endpoints.
I -- ATSDR Environmental Media Evaluation Guides for intermediate-term exposure for non-cancer endpoints.
A -- ATSDR Environmental Media Evaluation Guides for short-term exposure for non-cancer endpoints.
C -- Cancer Risk Evaluation Guide, based on adult intake and body weight, at 10-6 lifetime cancer risk.
NAC-- Possible Human Carcinogen (U.S. EPA Class C). Slope Factor or other Comparison Value is Not Available
NA -- None Available


RESPONSIVENESS SUMMARY

The MDPH released a draft of this health assessment for public comment on May 25, 1993. The Public Comment Period lasted until June 24, 1993. The MDPH and ATSDR received comments from residents and government officials within the period. These comments and ATSDR and MDPH's response to them follow. The pagination cited in the comments is that in the reviewed draft, and may not agree with the current revision.

Comments received by the MDPH from an Occupational Health Nurse (R.N.) living and working in Battle Creek:

  1. On page 6, under Community Health Concerns, I object to the statement, "...no questions relating directly to public health were raised by the public." To me, questions concerning the potential exposure to chemicals are public health issues.

Response: The commenter is correct in that concerns with exposure to chemicals are often a response to a perceived threat to public health resulting from the exposure. However, it can be difficult to identify the underlying health concern when a citizen raises a question about potential exposure, and it is properly the responsibility of the U.S. EPA and MDNR to address these questions. The sentence has been revised to replace the term "directly" with "explicitly".

  1. On page 13 reference to "Lifetime" is used with no definition. Are you addressing a child born during the time of this episode, or an entire adult life? Statements like this cause a great deal of concern to the general public.

Response: The usage has been clarified to indicate that it refers to a 70-year exposure.

  1. Page 14, under Aromatic Compounds, the first sentence of a paragraph should introduce the rest of the paragraph. This sentence leads you to believe that these compounds are non-cancer causing. The rest of the paragraph deals with the cancer causing effects of these chemicals.

Response: The paragraph has been revised for clarity.

  1. Page 14, 3rd paragraph, last sentence states that there may be a moderate increased risk of contracting skin cancer. Why is skin cancer only addressed in this sentence, as other locations of cancer are mentioned several times in the paragraph?

Response: According to the ATSDR Toxicological Profile for Arsenic (Reference 40), the oral slope factor for arsenic is computed for the chance of contracting skin cancer. Other cancer sites have not been studied adequately for a slope factor to be developed. A sentence to this effect has been added to the paragraph.

  1. Page 17, in regards to further studies on zinc, if an advisory issued has determined levels, then why are there no MRL's?

Response: ATSDR's Division of Toxicology has not promulgated MRLs for zinc. Different agencies have different criteria for issuing standards and advisories.

  1. Page 17, paragraph 3, last sentence, states that after filtering, manganese, nickel, and zinc have elevated levels. What are the health effects for these compounds?

Response: The potential health effects from exposure to these metals are described in the paragraphs preceding the one referenced.

  1. Page 21, under Recommendations, excellent summary of recommendations. Why haven't [surface] soil samples been taken?

Response: That question is better addressed to the U.S. EPA and MDNR. Soil samples have been taken, however, the samples were from below the surface, and do not provide adequate information on the risks from contact with surface materials and fugitive dust. Surface soil samples were probably not considered necessary because the primary sources of surface soil contamination, leaks and spills during operations at the two Thomas Solvent facilities and disposal into the drum pit at the Grand Trunk Paint shop, were stopped by 1984. Volatile chemicals in the surface soils would probably have evaporated long before the Remedial Investigation began. Access to the source areas is also restricted, so public exposure should be limited. The Raymond Road Facility has long been fenced, the operations at the Grand Trunk Marshalling Yard would deter most trespassers, and the Annex was fenced in April 1993 (Reference 2).

  1. The age old question for me is, what is the combined effect of exposure to all these elements? Can that be determined?

Response: In general, there is little or no information available on the health effects of exposures to mixtures of contaminants.

  1. I am concerned about health effects over a period of time, and the discontinuing of the studies of the exposed individuals. As an Occupational Health Nurse in Battle Creek, it seems that the employees experience an unusually high level of cancer diagnosis. Have longitudinal studies been done on cancer and miscarriages for this area?

Response: The individuals included in the MDPH/CDC Health Study have also been enrolled in the ATSDR Trichloroethylene Exposure Sub-Registry, which provides for some longitudinal health studies.

  1. What about workers at the Grand Trunk Paint Yard and the Thomas Solvent Annex? Medical surveillance should have been conducted on these employees. Have their records been examined and followed for effects noted with them?

Response: The MDPH Division of Occupational Health inspected the Thomas Solvent Raymond Road facility four times between 1961 and 1981. No occupational health or safety violations were found. MDPH has no records of any inspections of the Thomas Solvent Annex or the Grand Trunk Paint Yard. The Thomas Solvent Company declared bankruptcy and closed in 1984, so their records may not be easily accessible.

  1. I completely agree that access to the Thomas Solvent Annex should be restricted, however, since it has been opened for this period of time, data on skin absorption should be included in this report. Also, I noted no air sampling for these chemicals at these different sites. Since most of these hazardous substances are reported to evaporate in the air. One should be done with low wind speed, at different heights, both over this area and down wind of the site.

Response: There is no data available on surface soil contamination at the site, and therefore it is impossible to evaluate the hazards from skin contact and absorption. We recommended that such data be collected. No air sampling was reported in the Remedial Investigation Report. Air sampling is not likely to yield any site-specific data, since any volatile chemicals in the surface soil would probably have evaporated and dispersed soon after operations ceased in the Annex area, when Thomas Solvent went out of business in 1984. Recent information indicates that the Annex area has been fenced.

  1. This list of names of Preparers of Report, are all employees of the State or Federal Government. Were any local residents included on this panel?

Response: The assessors consulted with local health department personnel and sought comments from local residents regarding their health concerns with respect to the site. The ultimate responsibility for preparing the document lies with the State and Federal Agency personnel listed.

Comments received by MDPH from a manager of the City of Battle Creek Public Works Department:

  1. Page 1 Summary Remediation of only one site has occurred, that being the Thomas Solvent [Raymond Road] location. No remediation has occurred at the other two sites. The report refers to the "site" as possessing public health hazard. By definition, this could include the public water supply system. As our monthly reports to the Department of Health indicate, there has been no detectable levels of VOC's other than chlorination by-products in drinking water supply since October 1984.

Response: The summary of the remediation has been revised to more accurately reflect the status. A sentence indicating that there has been no contamination detected in the municipal water system since 1984 has been added.

  1. Page 2 The report has implied that the contamination plume from the gas station to the northwest of the well field has affected Battle Creek's water supply. The City, with the assistance of the MDPH, has established a rigorous sampling program for those wells of concern. To date, no detectable levels of VOC have occurred.

Response: A statement describing this sampling and results has been added to this text.

  1. As of this date, the Thomas Solvent Annex area has been secured with a chain-link fence and a contractor is on the site constructing a soil vapor extraction (SVE) system.

Response: Thank you for the information. The authors received similar information from the MDNR site manager. The text has been changed to reflect the current situation.

  1. Page 3 The City of Battle Creek blended contaminated water with noncontaminated water during the months of May - October 1984. No blending has occurred since October 1984.

Response: The text has been revised to make clear that the blending was only done for a limited time.

  1. Page 4 The report's description is in contradiction to that of the USGS modeling efforts and the City's experience in regards to the Marshall Formation. Based on the City of Battle Creek's work on development of public water, there are at least two water-bearing formations in the Marshall Formation. It is our belief that there are two fractured zones in which sufficient quantity of water can be produced and can be found, typically, from 80 to 120 feet below the surface and 130-150 feet below the surface, just above the Coldwater shale. These zones are separated by an aquitard and in most locations, a lens of Coldwater shale about 2 feet in thickness.

Response: Thank you for the information. The text has been revised to reflect this information.

  1. Page 5 There is 57,000 population in the service area [of the City water system]. As the City of Battle Creek continues to develop supply to the north of the original well field, our production has shifted northward. Consequently, the ground water divide has moved northward, therefore the contamination sites may no longer be in the influence of the well field.

Response: Thank you for the updated population figure. The text has been revised to include that figure. The most recent data MDPH has on the hydrogeology of the site area, collected during the RI in 1989, indicate that all three source areas are within the zone of influence of the well field (1). These data were collected before the latest extension of the well field, the four wells that were installed in 1990. The commenter is correct that increased use of more northern wells would be likely to move the zone of influence northward. However, it is impossible to determine, in the absence of new data, whether the source areas are within the current zone of influence of the wells.

  1. Page 6 The report implies that if residents are within the service area of the municipal water supply, they are using the public supply. The City of Battle Creek does not have mandatory water connection. Therefore, private water systems do exist within our service area.

Response: The text has been revised to reflect that aspect of the situation.

  1. Page 8 The report indicates that the public water supply has been below 2 ppb [of VOCs] since 1984. Our records indicate water quality has been below detectable limits since June 26, 1984, with detection limit as low as 500 parts per trillion [0.5 ppb]. All laboratory work was performed at the Michigan Department of Public Health laboratory.

Response: The text has been revised to more accurately reflect the situation.

  1. Page 10 The report indicates that the existing well field does not have a gate at the main entrance. There is an existing automatic gate at the main entrance that was open during your visit.

Response: Thank you for the information. The text has been revised to reflect this information.

  1. Page 11 The report implies dilution [is used] as a means of providing a safe water supply to the public. The City of Battle Creek has not and will not consider dilution of contaminated well water with uncontaminated water to meet its water quality since Fall 1984. The City has taken exhaustive efforts to develop a water supply with each wellhead meeting nondetectable levels of VOCs.

Response: The reference to dilution at this point has been removed in the current revision.

  1. Page B-3, Table I The time scale used for reporting purposes of 1981-1988 is deceiving. Our records indicate that since 1984, all production wells have been below [U.S. EPA] MCLs (Maximum Contaminant Levels) or in most cases below MCLG's [Maximum Contaminant Level Goals], which are non-detectable levels.

Response: A note to this effect has been added to the Table.

  1. The City of Battle Creek requests a detailed definition of the word "site" as it is used in the report. Does it include land south of the purge line? Does it include land north of the purge line? The casual use of the word "site" in this report indicates that public water is unfit to drink. This is not the case and can be proven based on laboratory analysis of ground water quality as monitored north and south of the purge line between 1984 and present as performed by the Michigan Department of Public Health.

Response: The RI for the site says, "The Verona Well Field site, as defined by the well field's zone of influence ..." (Reference 1, p. iii). According to the U.S. EPA, "The [Verona Well Field] site includes the well field, three contaminant sources, and the groundwater between the sources and the well field." (15) The contaminant sources cited are the Thomas Solvent Raymond Road Facility, the Thomas Solvent Annex, and the Grand Trunk Western Railroad Paint Shop. This assessment uses the latter definition of the site. Yes, the site so defined includes the entire well field, and analysis of water from the municipal wells provided some of the "On-Site Contamination" data. We have attempted to make clear that the contamination no longer reaches the municipal wells.

Comments received by ATSDR from four residents of the site vicinity:

  1. The EPA, MDPH and ATSDR have done it again; the Health Assessment is misleading, opinionated, contradictory and more propaganda. The narrow "Report on the Battle Creek Health Study" becomes the "comprehensive health study." This comprehensive health study looked at only one of the three sources at this site, looked only at 7 VOC and not all 28 contaminants of concern in the Health Assessment which was down from 48 chemicals in EPA's risk assessment. Houses with other than the Health Study's 7 VOC were comprehensively not in the study. Houses whose wells weren't tested were comprehensively not in the study. Houses without phones were comprehensively not in the study.

    Local residents complained about the endless flaws of the Health Study at every meeting possible. The only good thing any local resident said about the health study was that it was a good way to waste a million dollars. This Health Assessment continues the lies of the Health Study, on page 18, "a reference or control group who were not exposed," when over half of the unexposed control group were city residents whose only water supply was from the Verona Superfund site. The Health Study in fact compares two groups who drank from the exact same contaminated aquifer.

    Again on page 18, "mortality statistics did not focus strictly on study and control areas"; in 1980-1984, 97% of the City of Battle Creek's residents drank water from the Verona Superfund site. Where in the real world would you find a better match than this? The MDPH's mortality reports showed a statistically significant increase at 99% level for cancer, diabetes, and liver disease for the city residents who drank water from this Superfund site. Why is this not in the Health Assessment?

Response: The text has been revised to more clearly indicate which rates the health study found to be increased.

    If the only soil tests for residential areas near the Verona Well Field all showed contamination, why are they not covered in the Health Assessment (EPA's H1-5)? If off-source surface soil gas testing showed high levels of contamination, why is this not in the Health Assessment? Many of these tests were within 5 feet of residential areas (EPA's Tech Memo of May 15, 1985).

    Attached are five pages of comments on the health study as that is the basis of the Health Assessment. WOULD YOU PLEASE DO A HEALTH ASSESSMENT BASED ON FACTS?

Response: The citizens' comments on the health study are beyond the scope of this assessment to address.


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