PETITIONED PUBLIC HEALTH ASSESSMENT
CABOT-WROUGHT PRODUCTS - DIVISION OF CABOT CORPORATION
(a/k/a NGK METALS/CABOT BERYLCO, INCORPORATED)
MUHLENBERG, BERKS COUNTY, PENNSYLVANIA
The NGK Metals Corporation is a beryllium processing plant located approximately four miles north of Reading, Pennsylvania. The beryllium processing plant has released hazardous substances into the environment through on-site disposal of process wastes, wastewater discharge, and air emissions. The Agency for Toxic Substances and Disease Registry (ATSDR) has evaluated data for on- and off-site contamination and its possible impact on human health.
Based upon environmental and exposure data evaluated by ATSDR, concentrations of contaminants detected in air, water(1), soil(2), and sediment are not believed to represent any public health hazard. However, ATSDR has classified the NGK site as an Indeterminate Public Health Hazard. This classification is primarily due to the fact that no data exist for air (prior to 1979) and groundwater (prior to 1990). Therefore, ATSDR is not able to determine whether exposures, through air and groundwater, that may have occurred prior to those dates represent a public health hazard. In addition, ATSDR does not consider other media and exposure pathways likely to present a public health threat; however, additional data and information are needed before such a conclusion can be reached. Additional data needed include on-site soil, off-site surface soil, off-site groundwater, off-site biota, and stream sediment, which is further basis for an indeterminate classification.
Although adverse health effects are not expected based upon concentrations of contaminants detected, ATSDR established completed exposure pathways for on- and off-site ambient air, off-site groundwater (private wells 1 and 2), and off-site surface soil. Potential exposure pathways exist for on-site surface soil, off-site groundwater (private well 3), off-site sediment, off-site surface water, off-site biota, and beryllium worker's clothing.
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 testing for beryllium sensitivity is appropriate.
Citizens expressed concerns about environmental contamination; pathways of exposure; the potential for adverse health effects, such as brain tumors and cancer; and data quality and regulatory issues. ATSDR has addressed those concerns individually in the Public Health Implications section of this petitioned public health assessment. In an effort to gather additional community concerns ATSDR held availability sessions on June 8, 1993. As a result of the availability sessions, a number of community members discussed health concerns with ATSDR staff, and those concerns have been incorporated into the Community Health Concerns section of this petitioned public health assessment.
The petitioned public health assessment was released for public comment September 1, 1993, through November 12, 1993. Comments received have been listed and addressed in Appendix D of this document. Some comments necessitated revisions to this assessment. Likewise, revisions were made during finalization of this petitioned public health assessment due to additional data and information, and further toxicological research.
ATSDR has made recommendations to eliminate or reduce the potential for future exposures. Recommendations have also been made for additional on- and off-site characterization of environmental media where potentially completed exposure pathways exist, and further information is needed to determine the relevance of these pathways.
ATSDR's Health Activities Recommendation Panel recommended health follow-up actions to conduct a case series or case studies to investigate reported cases of sarcoidosis, health professional and community health education, further toxicological research on beryllium, and referral of this petitioned public health assessment to the National Institute for Occupational Safety and Health for further investigation of work related health concerns. In addition, ATSDR has developed a Public Health Action Plan which outlines the actions to be taken, by ATSDR and involved agencies, at the site subsequent to the petitioned public health assessment.
Through its petitioned public health assessment process, the Agency for Toxic Substances and Disease Registry (ATSDR) has evaluated the public health significance of the NGK Metals Corporation site. More specifically, ATSDR has determined whether health effects are possible and has recommended actions to eliminate or reduce the potential for future exposures at this site. ATSDR, which is in Atlanta, Georgia, is a federal agency within the U.S. Department of Health and Human Services and is authorized by the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) to conduct public health assessments of hazardous waste sites. ATSDR was petitioned by a private citizen on December 7, 1990, to evaluate the NGK site.
A. Site Description and History
The NGK (Reading) facility, a 65-acre complex, is located along Tuckerton Road between Highways 61 and 222 in Muhlenberg Township, Berks County, Pennsylvania, approximately four miles north of downtown Reading. The site is bounded by Tuckerton Road, Water Street, the Penn Central Railroad (Conrail) and PA Route 61 (Figure 1, all figures are in Appendix A).
Industrial activities began prior to November 1935, when the site was owned and operated by the Pennsylvania Malleable Iron Company. In November 1935, the site was bought by the Beryllium Corporation. Their operations began in March 1936. As a result of consolidations and mergers, the Beryllium Corporation became part of Kawecki Chemical Berylco Industries Inc., and Cabot Corporation. On September 30, 1986, Cabot sold assets of the Reading beryllium alloy plant to NGK Metals Corporation, a subsidiary of NGK Insulators Ltd. of Nagoya, Japan. The plant operates today as the NGK Metals Corporation (1).
No information is available about manufacturing activities at the site prior to 1935. From 1936 to 1965, manufacturing activities at the site included extraction of beryllium hydroxide from beryl ore, and production of beryllium salts and various types of beryllium metal and alloys.
The extraction of beryllium hydroxide from beryl ore was discontinued in 1965. From 1965 to 1992, operations included: production of beryllium copper, beryllium nickel, and beryllium aluminum alloys; casting, heat treatment, and rolling of beryllium alloys; and chemical and mechanical cleaning of beryllium alloys. However, in November 1992, the plant shut down the melting furnaces and hot rolling operations.
Little information is available about waste management activities at the site prior to the early 1950s. During the 1940s, there was a retention basin near the eastern boundary of the plant property adjacent to Tuckerton Road. It is not known what materials were discharged into the basin (1).
During the 1950s and 1960s, the plant used several ponds to treat waste. A series of unlined ponds were used for sludge settling and wastewater treatment. Fluoride waste, spent acids, and acidic rinse waters were neutralized by a lime treatment process and allowed to settle. As the facility grew, wastewater treatment needs changed and the use of settling ponds at the site was discontinued. Before closure, waste treatment ponds were covered with gravel and soil, or with mushroom soil, a highly organic soil composed mainly of manure and top soil. The organic nature of the soil used to cover the settling ponds encouraged grass to grow, and the grass cover served to minimize dust and erosion. Currently, a wastewater treatment facility is in operation.
A separate pond were used for disposal of lime sludge. This area is marked as Pond 6 in the Solid Waste Management Unit map (Figure 2). This pond was excavated and cleaned in the late 1970s and became the site of the existing landfill which is currently permitted for non-hazardous residual waste. The excavated material consisted of soil mixed with wastewater treatment sludge resulting from lime treatment of fluoride wastes, spent acids, and acid rinses. This material was placed in a pile adjacent to the western edge of former Pond 6 and designated Pond 6 waste pile (Figure 2). The Pond 6 waste pile has since been relocated to the southeast quadrant of the facility and covered. The site mapping does not reflect the new location of Pond 6 waste pile.
The Disposal Area Drain Field located in the southeastern corner of the site is believed to have been used in the past as a catchment basin for overflow from the various Solid Waste Management Units. That drain field is the only contaminated waste area that is not currently covered with mushroom soil, pavement, or gravel (2, 3).
Other waste disposal areas (Figure 2) include the Southeast Red Mud and Filter Cake Disposal area and the Southwest Red Mud and Lime Disposal area, which stored solid waste in unlined surface impoundments. "Red mud" was the material remaining after extraction of beryllium from the ore (typical chemical composition for red mud: silicon 24-27.5%, fluoride 6.5-10.5%, iron 6.5-9.5%, sodium 1-3%, beryllium 0.3-7.5%, aluminum 6.5-7.5%, potassium 0.5-1%, magnesium, calcium, copper, phosphorous 0-0.5%). By the early to mid-1960s, both of those areas were covered with soil (1).
B. Site Visit
A petition was submitted to ATSDR by a citizen of Reading, Pennsylvania, on December 7, 1990, to investigate allegations of environmental pollution at NGK Metals Corporation in Reading, Pennsylvania. ATSDR agreed to evaluate the petition and visited the site. Mr. Charles Walters [Agency for Toxic Substances and Disease Registry (ATSDR) Region III Representative], Mr. Joseph Carpenter, and Mr. Timothy Hampton (from ATSDR Headquarters), and a representative of the Pennsylvania Department of Health (PADOH) met with the petitioner on January 29, 1991, to gather information and discuss the petitioner's concerns about the NGK site.
On January 30, 1991, NGK conducted a site visit/meeting and tour of the NGK facilities for ATSDR and other involved agencies. This meeting also included representatives from the Pennsylvania Department of Environmental Resources, Pennsylvania Department of Health, United States Environmental Protection Agency (EPA), the project manager for Dunn Geosciences (NGK's remediation and site evaluation contractor), and other NGK plant representatives. During the site visit, the locations of previous waste management ponds were identified. Also identified were the landfill (operated under a Pennsylvania Department of Environmental Resources residual waste regulation permit), the drum storage area, the raw materials storage area, the discharge pipe from the current wastewater treatment system (operated under a National Pollutant Discharge Elimination System permit), and the acid neutralization tank. In addition, areas contaminated during past operations were observed. Access to the site is limited by an eight foot chain-link fence surrounding the site and a 24-hour security guard service.
ATSDR solicited health concerns from interested parties. Besides interviewing the petitioner, interviews were conducted with other concerned citizens, Commonwealth agencies, and a representative from the Muhlenberg Township Water Authority. Those interviews provided valuable information about state environmental monitoring data, community health concerns, reports of unusual illnesses, and water quality of the Muhlenberg Township water supply.
NGK and Muhlenberg Township are located in Berks County, Pennsylvania. ATSDR obtained 1990 demographic information for a one and two-mile radius around NGK and for Berks County to help characterize the area population (see Table 1 and Figure 3).
Population estimates within a 1- and 2- mile radius of the facility are 4,927 and 14,686 respectively. The population characteristics within a 1- and 2- mile radius are very similar. The site area population is predominantly white (98%) and, compared to Berks County, there is a noticeably larger percentage of persons in the older age categories (i.e., 45 to 64 and 65 and over). There is also a smaller percentage of females near the site in the age group 15-44, which is considered the primary child-bearing age. The fact that the majority of the housing units are owner occupied suggests a relatively stable area population. The median housing value around the site area is lower than for Berks County and the difference is more pronounced within 1-mile of the site (4).
The NGK Metals site is surrounded by commercial and residential land uses. Several light industries are located across the street from the site on NGK's southern boundary. An active railroad line (Conrail) is adjacent to its eastern border. Residences are located within 50-100 yards south of NGK. A cemetery, church, and small businesses also surround the property.
Muhlenberg Township Water Authority and Reading Bureau of Water supply the public water for domestic and industrial use within a 3-mile radius of the site. Muhlenberg Township began public water service in the late 1940s to 1950s. Within a 3-mile radius of the site, the Muhlenberg Township Water Authority has a total of 11 production wells; one of the eleven wells, the Reading Crest Well (approximately 500 feet deep), is not in service. The City of Reading draws water from Lake Ontelaunee located approximately 2.5 miles north of the site.
Water from private wells in the area has been used for drinking purposes. EPA required NGK to conduct a water well inventory in Muhlenberg Township during the spring of 1991. The well inventory concentrated on areas immediately surrounding the site and hydraulically downgradient of the site (approximately 2-3 miles southwest). Two private wells (with depths of 125 and 150 feet) were identified in the EPA specified well inventory area. In addition, private wells outside of the EPA designated well inventory area were observed (5). Further information regarding the well inventory and the water quality analyses of these wells will be discussed in the Off-site Contamination and the Off-site Groundwater Pathway subsections.
A local stream next to the southern boundary of the site (Laurel Run) flows approximately 2 miles southwest until it converges with the Schuylkill River. Laurel Run is a small stream, but flows the entire year.
The Schuylkill River discharges to the south, joining the Delaware River at Philadelphia, and acts as the primary drainage pathway for the region. The river supports a wide range of activities, such as sport fishing from boats and river banks. Local fishermen report that many people fish and swim just below the Laurel Run and Schuylkill River confluence. The Schuylkill is also used as a water source by downstream towns.
The groundwater system in the vicinity of the NGK site consists of a discontinuous unconfined aquifer made of unconsolidated clay, sand, and gravel overlying fractured bedrock. Two aquifer zones have been defined: the first 100 feet (shallow zone) and between 100 to 200 feet below ground surface (deep zone). There are no on-site wells extending greater than 200 feet below the ground surface (1). There is no confining layer between the different aquifer materials. Groundwater flow beneath the NGK site is generally to the west within the shallow aquifer zone, with groundwater flow to the northeast in the northern portion of the site (1, 2, 3). Groundwater in the deep aquifer zone follows regional groundwater flow which trends west-southwest toward the Schuylkill River (3, 6). A downward vertical groundwater flow exists beneath the site with the exception of the area closest to Laurel Run. Here the vertical gradient is reversed and groundwater flows from the deep zone to the shallow zone. Laurel Run is believed to be hydraulically connected to groundwater zones below the site. Laurel Run appears to be recharging the aquifer near the site, but further downstream (approximately 1 mile) the groundwater zone appears to be discharging to Laurel run (1, 6).
The Pennsylvania Department of Health (PADOH), Eastern District, was contacted by ATSDR for health outcome data. The State of Pennsylvania has a cancer registry, containing data collected during the last nine years; however, lag time in establishing the registry statewide and a high background cancer incidence in the state limit the usefulness of this registry to ATSDR at this time. Cancer is a disease that can develop years after the exposure to the causative agent. Although the database may reflect the consequences of chronic exposures beginning 20-30 years earlier, the relatively few years of information recorded by the database cannot reveal any trends in cancer incidence in the area over the 60 year life of the NGK facility.
Concerns about NGK from nearby residents in Reading or Muhlenberg Township were received by the PADOH, Eastern District. A majority of the concerns centered around requests for a health study. Several citizens who met with ATSDR also suggested that a health study should be conducted. ATSDR staff has met with the petitioner on several occasions to discuss concerns regarding NGK. Community members expressed concerns, as well as asked questions of ATSDR staff, during the site visit and the availability sessions that were open to the public. In addition, some community health concerns were gathered during telephone conversations with local residents and through letters written to ATSDR. Based on those letters, interviews, and information gathered during the site visit and availability sessions, the following community health concerns were identified:
1. The chemicals (chromium and fluoride) found in a local private drinking water well might cause cancer.
2. Contaminated on-site groundwater could contaminate local drinking water supplies.
3. Airborne dust from NGK's old wastewater treatment lagoons might cause health problems.
4. Residents living in the Reading area may develop sarcoidosis from exposure to beryllium oxide.
5. Untreated storm water runoff and treated wastewater from NGK that are discharged into Laurel Run could be having a detrimental effect on aquatic wildlife. Furthermore, the treated waste and untreated storm water that are discharged into Laurel Run may eventually reach Schuylkill River (via Laurel Run) and contaminate local water supplies down river.
6. Some people may have contaminated private wells and may be unaware of contaminated groundwater. This may affect people who have summer homes and were not interviewed during the well survey.
7. The Reading Crest Well water is contaminated, and attempts have been made in the past to bring the well into service. There is concern that the well may be brought on-line in the future.
8. Laurel Run is impacted by contaminants in surface water from wastewater discharged from NGK. There is concern for the health of children who play in Laurel Run and persons who may have eaten or may currently be eating fish from Laurel Run or at the confluence of the Schuylkill River and Laurel Run.
9. The present parameters for the NGK National Pollutant Discharge Elimination System (NPDES) permit are too high, and compliance for the new, more stringent, standards is not required until August 1993. The Pennsylvania Department of Environmental Resources (PADER) and EPA have delayed compliance deadlines several times already.
10. Deposition from air emissions from the metal facility over its entire history has accumulated in homes and on lawns throughout the community. Such contamination is believed to have impacted the health of persons in the community in the past and could be a current and future health threat.
11. The analytical procedure used to analyze the concentration of beryllium from air monitoring conducted since 1979 not measuring all forms of beryllium present in the sample and therefore, is not revealing the actual concentration of beryllium present in the air.
12. There are no air monitors due south of the NGK plant to detect the levels of beryllium in which the nearest residents (along Water Street) might be exposed.
13. People have developed brain tumors and lung cancers due to exposure from site-related contaminants.
14. The community could be exposed to contaminants during remediation when the solid waste management units are consolidated.
15. What is beryllium poisoning and its symptoms? Once absorbed, where does it go?
16. Health conditions that were reported by citizens as having occurred or occurring in the community include: children with liver problems, heart problems, asthma, and allergies; cancers of various types; emphysema and general respiratory illnesses; berylliosis; Parkinson's disease; Hodgkin's disease; brain tumors; myopathy; mottling of teeth; brittle bones; hair loss; rashes; irritation at night; lots of colds; and a degenerative condition resulting from the side effects of treatment for beryllium poisoning.
17. Could a child with asthma be more susceptible to beryllium?
18. Dust carried home, from the beryllium plant, on worker's clothing may have resulted in illnesses.
19. Exposures may result from residential gardens, community parks, and playing fields.
20. Could contaminants in groundwater cause respiratory infections from showering or cause mottled teeth, stress fractures, and colic in children?
21. Work practices at the plant were very poor and dusty in the past.
22. Exposures may have occurred from going on site before the site was fenced or from fields or caverns where contamination was dumped.
23. There are a lot of illnesses around the site, particularly in the Cherokee Ranch area.
24. Possible health hazards such as digging at or around the site, contaminated off-site groundwater, and air violations have not been communicated to the public.
25. Lake Ontalaunee, from which the City of Reading gets its water supply, is being contaminated with beryllium.
26. Further contamination may have resulted from floods on Laurel Run in the past and dredging conducted by the Army Corp of Engineers.
27. Orange and green colored smoke that caused a burning sensation was emitted from plant stacks in the past. Ash from the plant would deposit on automobiles and seemed to deteriorate paint.
28. Water in Laurel Run turns strange colors when it rains. Could water from Laurel Run that was used on gardens in the past be a health concern?
29. There is a concern that the RCRA Facility Investigation conducted by Dunn Geoscience Corporation and air monitoring data collected by NGK are not reliable sources of information.
30. Do elevated levels of CD4+ T cells in the lung or blood make people more susceptible to chronic beryllium disease? What is a normal CD4+ T cell count and what would be abnormally high? Should OSHA or ATSDR check the CD4+ T cell count of people who work at and live around beryllium alloy manufacturing facilities? Is beryllium the antigen in chronic beryllium disease? Is it possible that sarcoidosis has been analyzed in cases that may actually be chronic beryllium disease? If beryllium shows up in a biopsy of lung tissue (dried) from a person diagnosed with sarcoidosis, at what concentration (ppm) would it be a questionable case of chronic beryllium disease?
31. Is anyone doing research on a connection between beryllium and brain tumors or arthritic conditions resulting from absorption and or ingestion of beryllium?
Some of those questions and concerns are addressed in various discussions and evaluations throughout the document; however, at the end of the Public Health Implications section, specific responses are given to each individual concern listed here.