PETITIONED PUBLIC HEALTH ASSESSMENT
FIELDS BROOK NPL SITE
(SPECIFICALLY CONCERNING RADIOLOGICAL CONTAMINANTS AT RMI TITANIUM COMPANY)
ASHTABULA, ASHTABULA COUNTY, OHIO
The RMI Extrusion Plant, a subsidiary of Reactive Metals, Inc., a subcontractor to the Department of Energy (DOE), is in the northeastern corner of Ashtabula County, Ohio, about three miles east of the center of the city of Ashtabula.
The subcontracted work performed for DOE included extrusion of depleted uranium (< 0.2% U-235), and of slightly enriched uranium (> 0.72% U-235) ingots into rods or tubes. RMI holds a Nuclear Regulatory Commission (NRC) license and a Resource Conservation Recovery Act of 1976 (RCRA) permit to store mixed wastes, granted by the Environmental Protection Agency (EPA). The plant is at the geometric center of the Fields Brook National Priorities List (NPL) Site, CERCLIS NO. OHD980614572.
The Agency for Toxic Substances and Disease Registry (ATSDR) prepared a public health assessment for the Fields Brook NPL site in 1986. ATSDR has conducted a review of the currently available environmental data and has prepared this addendum to that public health assessment to deal mainly with the possible radioactive contamination of the Fields Brook Site from RMI operations.
Sampling of environmental media on site (air, soil, sediments, surface water, and groundwater), has shown contamination with uranium, technetium-99, and trichloroethylene (TCE). Off-site samples have shown only a small area of uranium-contaminated soil, just outside the northeastern fence. The plant is fenced and has a manned security system, which precludes public access and prevents public exposure.
Analysis of the environmental data show that there is no apparent public health hazard associated with the RMI facility. To reduce levels of uranium-contaminated soils outside the plant to the published standard maximum levels, ATSDR recommends that the soils be cleaned up when RMI cleans up the site.
The RMI Extrusion Plant (RMI) is a privately-owned 26-acre site, at East 21st Street in the city of Ashtabula, Ohio. RMI is the geographic center of the Fields Brook National Priorities List(NPL) Site, for which ATSDR released a completed public health assessment on November 7, 1986 . In the original public health assessment, ATSDR concluded that portions of Fields Brook and its tributaries were contaminated with toxic chemicals, and that exposure to contaminants by way of absorption through skin or through ingestion may present an unnecessary health risk to young children. ATSDR further recommended:
- prevention of community access to contaminated portions of Fields Brook and its sediments;
- maintenance of the Ohio Department of Health Advisory and the state EPA health advisory for fishing in Fields Brook and in portions of the Ashtabula River;
- evaluation of soil for site contaminants, both on site and off, including soil surrounding private residences;
- evaluation of groundwater for site contaminants, and
- consideration of an air monitoring study to define the sources of contamination and the risk for area residents and workers to be exposed to airborne contaminants.
The Sierra Club of Northeast Ohio petitioned ATSDR on August 20, 1989, to consider the possibility of contamination from the RMI Extrusion Plant because the original health assessment did not discuss releases of radioactive contamination from RMI, or releases of radionuclides into Fields Brook.
The RMI plant has performed uranium extrusion operations for the U.S. Department of Energy (DOE) under a subcontract with Westinghouse Materials Company of Ohio since 1962. The principal activity of the Extrusion Plant has been the conversion of depleted and slightly enriched uranium ingots into rods or tube shapes by extrusion. The extrusion is by means of a 3,850 ton hydropress. The products are cut, straightened, pickled in an acid bath, and machined. The principal contaminants are insoluble oxides of uranium that were released into the air and water from 1962 until 1989. The plant has Nuclear Regulatory Commission (NRC) license SMB-602, and has produced depleted uranium projectiles for the Department of Defense (DOD) under DOE Contract Number DE-AC05-760R01405 .
In the past, RMI has emitted uranium metal and oxide dusts through six stacks, and has disposed of uranium process water in Fields Brook. Fields Brook, which flows through the NPL Site that bears its name, is a 3.5-mile tributary of the Ashtabula River that discharges into Lake Erie, the source of drinking water for the city of Ashtabula. Fields Brook flows through an industrial area that is one of the largest and most diversified concentrations of chemical plants in the state of Ohio, and is the principal receiving stream for many industrial discharges. The brook flows past a high school and through a residential area of Ashtabula downstream from the industrial area .
Dr. Paul Charp of ATSDR's Division of Health Assessment and Consultation, and Ms. Louise Fabinski, ATSDR's Regional Representative, visited the site on November 6 - 7, 1989. On the first day, they met with representatives of Reactive Metals, Inc., (RMI), and proceeded with a tour of the facility, observing that
- the site was fully fenced, and a guard system was manned at all times, making regular patrols of the site;
- no unauthorized persons were seen on or near the site;
- the ground surfaces were well-vegetated;
- a surface stream flows near the site (Fields Brook), and that
- active remediation work was underway on-site to remove TCE contamination.
The team visiting the site was accompanied by a representative of the US Environmental Protection Agency (EPA), Ohio EPA, and two employees of RMI. ATSDR representatives did not notice any obvious physical hazards or visible sign of contamination.
The second day of the site visit consisted of meeting with the petitioner, with a representative of the Sierra Club, and with personnel from the Ohio Health Department. Also, during a tour of the surrounding community the visitors noted that
- there was an elder care facility within a mile of the site;
- there were several hospitals within a few miles of the site;
- the neighborhoods nearest the site were lower to middle income neighborhoods, and that
- Fields Brook was still accessible and not fenced as recommended in the public health assessment.
The Fields Brook site is partially located within the City of Ashtabula and partially east of the City of Ashtabula Township, Ashtabula County, Ohio. Ashtabula is on Lake Erie in northeastern Ohio, approximately 20 miles from the Pennsylvania state line and 50 miles northeast of Cleveland. The National Priorities List (NPL) site is on the northeastern side of the city, about three miles from the city center.
Ashtabula has experienced a slow rate of population decline since 1960, including a drop of 5.4 percent from 1980 to 1986 (see Table 1). This trend is typical of many industrial cities in this region, and is due to out-migration. The county population declined by approximately three percent from 1980 to 1986.
The population of the city is predominantly white. The percentage of the population under age ten fell substantially from 1960 to 1980, because birth rates were declining and because young families with children were moving out of the area. Conversely, the percentage of elderly persons rose from 10 to 14 percent, because the elderly in their retirement years are less likely to move away.
The percentage of persons below poverty level was 11.5 percent in 1980, compared to the state average of 10.3. Median household income was $14,881 at that time, while the state median was $17,754.
The RMI Extrusion Plant (RMI) is a privately owned company consisting of eight buildings on a 26-acre site, located at East 21st Street in the city of Ashtabula, Ashtabula County, Ohio. RMI is at the geographic center of the Fields Brook National Priorities List (NPL) Site. Facility access is restricted by a fence and guard system. Fields Brook, which flows through the NPL Site that bears its name, is a 3.5-mile tributary of the Ashtabula River which discharges into Lake Erie, the source of drinking water for the city of Ashtabula. Fields Brook flows through an industrial area that is one of the largest and most diversified concentrations of chemical plants in the state of Ohio. Fields Brook is the principal receiving stream for many industrial discharges. The brook flows past a school and through a residential area of Ashtabula that is downstream from the industrial area. There were no physical hazards evident during the site visit.
Residential areas are situated clockwise from the southeast to the west of the RMI plant. North of the facility are warehouses, and docks on Lake Erie. To the east of RMI is all heavy industry and chemical plants. The population density is lowest to the east and northeast, which is also the direction of the prevailing winds. There was a high school about a quarter-mile to the west of RMI, on Fields Brook, but during the mid-1980s, it was converted into a retirement home. The nearest residence is located about a quarter-mile southeast of the plant.
The RMI Site is built on an area of unconsolidated clay till. The groundwater flows north-northwest, towards the Lake Erie confluence with the Ashtabula River, with a hydraulic conductivity of 60 cm/year. Due to the low groundwater flow characteristic of the clay till, there is insufficient water to supply drinking wells, and there are no known drinking water wells within a mile and a half of RMI. Lake Erie, three miles north of the plant, is the primary source of drinking water for the region and is also used for fishing, boating, and general recreation.
|Percent Under Age 10 Years||23||20||16||12|
|Percent Over Age 65 Years||10||11||14||16|
|Median Age||30.3||27.9||29.5||Not Available|
|Persons per Household||3.29||3.17||2.66||2.51|
(All data taken from: CENSUS OF POPULATION AND HOUSING for 1990, 1980, 1970, 1960, and Summary Tape File 1 [Ohio]: U.S. Bureau of the Census, Washington, D.C., U.S. Government Printing Office) .
The Ohio Department of Public Health, Division of Epidemiology, in 1988 completed an epidemiological study of cancers associated with the Fields Brook NPL Site . This study found no evidence of abnormally high cancer mortalities associated with the Fields Brook site. The state of Ohio does not at present have any health registry in place to keep records of specific adverse health outcomes.
ATSDR has received a petition from the Sierra Club, Northeast Ohio Group, to supplement the original health assessment and to consider radioactive contamination from RMI. The Sierra Club, in their petition, state that they are concerned with the possibility that radioactive contamination from the RMI Extrusion Plant has been accessible to residents of Ashtabula, especially to children and the elderly, and has resulted in further pollution of Fields Brook. They have asked ATSDR to "consider requiring the posting of signs along Fields Brook to the west of State Route 11" (that is where Fields Brook runs very close to homes, schools, etc.), stating "there is danger from hazardous and radioactive materials." The Sierra Club also voiced concerns about dredging and incineration of sediments from Fields Brook on November 28, 1990. They also expressed the concern of at least one RMI employee who believes his health was compromised by working at the RMI facility .