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This public health assessment evaluates if a public health hazard exists to residents living near thePGA North site. To assess the potential adverse health effects of environmental contamination to thesurrounding community near the PGA North site, the concentration of the contaminant in a specificmedium (soil, air, or water) is compared to a screening value for that contaminant in that particularmedium. The screening value is used to identify the chemicals that need to be evaluated in site-specific detail in the public health assessment.

There are several types of screening values which are dependent on the type of exposure pathway(dermal, ingestion, and inhalation) and the medium in which the contaminant is found (soil, air, orwater). The screening levels are calculated using conservative health protective assumptions. Theseprovide guidance in determining if the level of a chemical could present a public health hazard tonearby populations. If the concentration of the chemical is below the screening value, adverse healtheffects would not be expected. If the chemical concentration is above the screening value, then it iscalled a contaminant of concern (COC) and is further evaluated to determine if adverse healtheffects are likely to occur. The different screening levels used in this PHA are described below.

Soil Screening Levels

Site-specific soil contaminant concentrations are compared to Soil Remediation Levels (SRLs) todetermine which soil contaminants will be evaluated further in the Public Health Assessment. SRLsfor soil ingestion are calculated by ADHS, Office of Environmental Health using a human health-based approach that is generally consistent with risk assessment methodologies. SRLs protectagainst toxic doses of systemic toxicants, and limit excess lifetime cancer risk to one-in-one million(10-6) for known human carcinogens and to one-in-one hundred thousand (10-5) for possible andprobable human carcinogens. ATSDR accepts the Arizona SRLs as an appropriate screening levelthat can be used for site purposes. Chemical concentrations in soils that exceed SRLs may notnecessarily represent a health risk. Rather, when contaminant concentrations in soil exceed thesestandards, further evaluation may be necessary to determine whether the site poses an unacceptablerisk to human health (ADHS 1997a).

Groundwater Screening Levels

Groundwater contaminants found in private wells were compared to the USEPA maximumcontaminant levels (MCLs). The MCLs are enforceable drinking water regulations that areprotective of public health to the extent feasible in public water supplies. If levels of contaminationin a well were found above the MCL, then exposure intakes were calculated and compared to theATSDR minimal risk levels (MRLs).

The selected list of contaminants of concern (COCs) indicates which contaminants will be evaluatedfurther in the public health assessment. It does not mean that the listed contaminant will causeadverse health effects from exposures. The following sections present the levels of contaminantsfound in soil and groundwater and compare them to the appropriate comparison values. This willidentify the COCs that need to be evaluated further to determine if they present a public health threat to the residents who live near the PGA North site.

3.1 On-Site Contamination

3.1.1 On-site Soil Contamination

The Unidynamics facility is completely fenced off to prevent public access. Prior to 1978, wastesolvents were disposed of in four dry wells on the Unidynamics property. In 1989, during theremedial investigation at Unidynamics facility, 51 volatile organic compounds (VOCs) were foundin the on-site soil, including trichloroethylene (TCE), methyl ethyl ketone (MEK), isopropanol,trichloroacetic acid (TCA), toluene, and acetone. Table 1 lists the 1989 soil contaminants and their comparisons to nonresidential SRLs (Crane 1989).

Table 1.

On-site Soil VOC* Contaminants Concentrations and Comparison to SRLs.


Range (ppm ) Occupational SRL (ppm) Above SRL?
TCE § <1.0 - 5,586 70 YES
MEK <1.0 - 179 27,000 NO
Isopropanol <1.0 - 962 10,000 NO
TCA ** <1.0 - 42 4,500 NO
Toluene <0.5 - 6 70 NO
Methanol <1.0- 48 340,000 NO
Acetone <1.0 - 232 8,800 NO
* VOC = volatile organic compound; † SRLs = soil remediation levels; ‡ ppm = parts per million; § TCE = trichloroethylene; ¶ MEK =methly ethyl ketone; ** TCA = trichloroacetic acid;

TCE concentrations were below the respective nonresidential SRL until depths of approximately 34feet deep with the highest TCE soil concentrations found at 39 - 50 foot depths. The highest TCEconcentration in surface soil (0-2ft.) was 0.2 ppm. Concentrations of acetone, MEK, toluene,isopropanol, TCA, and methanol were below their respective SRLs. ADHS was unable to obtainmore recent soil data. According to Malcolm Pirnie (consultant for Crane Co.), the levels of thesechemicals have been reduced since remediation activities (air stripping, well injection) began in1994. If surface runoff has occurred, it would not be a problem since the surface levels of TCE arebelow the SRL.

Chemical analyses for metals in samples from the dry wells and sedimentation tanks indicate thatseven of the 11 metals that were analyzed were found above background concentrations. Theseincluded aluminum, barium, arsenic, mercury, lead, chromium and zinc (Dames & Moore 1988). These levels have also been reduced since the remediation activities began. The 1989 metals concentrations are provided below in Table 2.

Table 2.

Highest 1989 On-site Soil Metals Concentrations and Comparison to SRLs*.


Highest Concentrations (mg/kg) SRL (mg/kg) Above SRL?
Aluminum 80,000 1,000,000 NO
Barium 3,240 110,000 NO
Arsenic 110 10 YES
Mercury 4.0 180 NO
Lead 3,100 2,000 YES
Chromium 290 4,500 NO
Zinc 4,200 510,000 NO
* SRLs = soil remediation levels; † mg/kg = milligrams per kilogram.

As shown on Table.2, the 1989 concentrations of arsenic and lead were above the respective SRLs. Pesticides were found in concentrations that were representative of background concentrations inagricultural areas. ADHS does not have available data to determine the type or amount ofradioactive materials that were used at the facility.

3.1.2 On-site Groundwater Contamination

As of February 1999, Subunit A had levels of TCE that range from less than 1.0 micrograms per liter (µg/L) to 4,500 µg/L with the highest concentrations on-site (Crane 1989). Perchlorate was found in Subunit A in an on-site monitoring well at 81 µg/L. The Subunit B/C has levels of TCE ranging from non-detect to 4 µg/L with the highest concentrations being on-site. Table 3 below shows the concentrations of TCE and perchlorate in the two subunits compared to MCLs (ADEQ 1999; Malcolm Pirnie 1999a).

Table 3.

Current On-site TCE* and Perchlorate Concentrations in the Two Groundwater Subunits Compared to MCLs.


Range of TCE Concentrations (µg/L) Above TCE MCL?
(5 µg/L)
Range of Perchlorate Concentrations(µg/L) Above Perchlorate HBGL§ (31.5 µg/L)
A ND - 4500 YES NDe - 81 YES
*TCE = trichloroethylene; MCL = maximum contaminant level; µg/L = micrograms per liter; ND= not detected; §HBGL = health-based guidance level.

The drinking water for the Goodyear municipal wells comes from Subunit C. The Goodyear Well#10 is the only municipal well in the groundwater plume area. TCE has never been detected in thiswell. As can be seen from Table 3, perchlorate has not been detected in Subunit B/C.

3.1.3 Past On-site Thermal Oxidizer Emissions

The thermal oxidizer was in operation intermittently from 1994 to 1998 during which time it wasperiodically tested for removal efficiency of the on-site soil contamination. The thermal oxidationsystem was turned off in October 1998 to evaluate the need for continued soil remediation at theUnidynamics facility.

According to the data provided by Malcolm Pirnie and CH2MHILL, the only chemical that was analyzed in the emissions since January 1996 was TCE. The levels of TCE detected in the emissions ranged from 0.25 µg/L to 59 µg/L during the years 1996 to 1998 (CH2MHILL 1999b). Although pilot testing was conducted in 1993, emissions data from June 1994 to December 1995 were not available. Tests for dioxin were not normally included in the monitoring tests that were conducted on the thermal oxidizer at the Unidynamics facility.

According to the National Research Council (NRC), the release of dioxins from a thermal oxidizerunit is dependent on several factors. These include the type of chemicals and chemical mixtures, theinternal temperature of the unit while in operation, and whether the unit is equipped with aquencher. According to Therm Tech, the manufacturer for the thermal oxidizer at the Unidynamicsfacility, when their units are operated properly and have the correct pollution equipment, there is norelease of dioxins (Therm Tech.1999). ADHS was unable to get data to verify this statement.

As stated in the NRC report on Waste Incineration and Public Health, all types of organic chemicals, including polychlorinated dioxin/furans, can be destroyed under high-temperature oxidizing conditions. Destruction can occur at around 1800 o Fahrenheit (ºF) or higher if oxygen and organic molecules are well mixed as in practical combustion devices. Destruction of polychlorinated dioxins/furans present in the waste feed stream can take place at temperatures as low as 1350 o F if oxygen and organic molecules are perfectly mixed. However, dioxins and furans are also produced within the incineration process from precursors that are not destroyed below 1,800 o F. Although dioxins/furans may be present in the incoming mixture, most of the dioxins/furans in the exhaust gases are the products of formation within the incinerator and not persistence of the compounds present in the waste stream (NRC1999, p.3-19). According to Malcolm Pirnie, the internal temperature of the thermal oxidizer when in operation was around 1,600 ºF (Malcolm Pirnie 1999b).

Without proper emissions data, the ADHS cannot determine if, or how much, dioxin was present inthe emissions from the thermal oxidizer on the Unidynamics facility and whether the emissionspresented a public health hazard to community residents in the past.

There is also an air stripper at the facility which is used to remediate the contaminated groundwater.The TCE is routed through granular activated carbon and adsorbs to the carbon. The carbon mustbe changed out periodically in order for the system to effectively remove the TCE before it isreleased into the outside air. Thus, proper operation of the air stripper and carbon vessels is veryimportant. If improperly operated, it could result in a release of TCE to the air. ADHS does nothave available data to evaluate whether this unit has been or is currently being correctly operated.

3.2 Off-Site Contamination

The off-site contamination consists of a groundwater plume that extends from the Unidynamics facility northward for approximately 2 miles.

3.2.1 Off-Site Groundwater Contamination

Globe and SunCor Private Wells

There are seven private irrigation wells and one private domestic well located on the northernportion of the groundwater plume. Three of these wells are known as the Globe Wells #1, #2, and#4 and are located west of Bullard Road. The other 4 wells, known as the SunCor wells, are locatedeast of Bullard Road.

Globe Well #1, which is located behind the house on Bullard Road, and Globe Well #2, locatedfurther west from Globe Well #1, provide irrigation water to the small irrigation canals that parallelthe RID on the south side to the west of Bullard Road. Globe Well #4 is located in the middle ofthe fields. SunCor irrigation wells #33A, #33B, and #33C located on the northern end of thegroundwater plume. SunCor Well #33A has a permanent activated carbon treatment system and isbeing incorporated in the final groundwater remedy. Water from this well is being used to irrigatethe golf courses and decorative lakes in Pebble Creek and will be similarly used for the new SunCorhousing development which is being built east of Bullard Road. SunCor Well #33B is used only foremergency purposes. SunCor Well #33C has been abandoned.

The MCL for TCE is 5 µg/L. Since perchlorate does not yet have an MCL, it is compared to ADHS's interim screening level known as the health-based guidance level (HBGL) for perchlorate of 14 µg/L. The Globe Well #1 and #2 have levels of TCE above the MCL. SunCor Well #33A has elevated levels of TCE but this is corrected with the use of a carbon filter system. All the wells that were tested for perchlorate had levels below the HBGL. Tables A1 - A10 in the Appendix summarize the sampling data of these wells from 1997 to 1999 (Malcolm Pirnie 1999a).

The irrigation water from the Globe wells flows into a holding pond located nearby between the RIDand the small canals. According to the ADEQ, the holding pond which is owned by the GlobeCorporation, has never been tested for contaminants. The irrigation water is cycled through thefields and held in the holding pond until further need arises. It is safe to assume that the water in theholding pond has traces of TCE and perchlorate as does the irrigation water in the small canals sincethey are connected. Table 4 provides a summary of the TCE and perchlorate levels found in theGlobe and SunCor wells and comparisons to the appropriate screening levels (Malcolm Pirnie1999a; ADEQ 1999).

Table 4.

TCE* and Perchlorate Concentrations in Private Irrigation/Domestic Wells (February 1997 - February 1999).
Well TCE Perchlorate Comments
  Range µg/L (before filter) Filter system? Above MCL§ of 5 µg/L? Range (µg/L) Above HBGL
of 31.5 µg/L?
Globe #1 39 NO YES ND** NO Used for irrigation 20 days/month.
Globe #2 ND - 25 NO YES 5 NO Used to irrigate fields west of Bullard Road.
Globe #4 ND - 1 NO NO NS†† NS Is minimally used for irrigation.
Globe Domestic 19 - 250 YES < 1.0
(after filter)
ND NO Used as drinking water.
ND-<1 NO NO NS NS ---
ND-< 1 NO NO NS NS ---
ND-< 1 NO NO NS NS Rarely used.
340 - 490 YES ND
(after filter)
NS NS Used for golf course and decorative lakes in Pebble Creek and the new SunCor developments.


ND- 270 NA‡‡ NA 6 NO Abandoned.
*TCE = trichloroethylene; PGA = Phoenix Goodyear Airport; µg/L = micrograms per liter; § MCL = maximum contaminant level; ¶ HBGL = health-based guidance level; ** ND = not detected; ††NS = not sampled; ‡‡ NA = not applicable.

Results shown in Table 4 indicate that the treatment system on the Globe Domestic private well and the SunCor Well #33A continues to be effective in decreasing the TCE concentrations to <1 µg/L which is below the MCL of 5 µg/L. Photographs of the Globe and SunCor wells, the connecting canals, and holding pond are located in the Appendix.

Park Shadows Apartments Private Wells

Park Shadows Apartments are located on Litchfield Road approximately one-half mile south of the Unidynamics plant encompasses 44 square acres. There is a drinking well and an irrigation well located on the grounds. The drinking well, which draws water from the Subunit B/C aquifer which is clean, has been regularly sampled over the past several years and has never had any detection of TCE. The irrigation well is screened at a higher level and pulls water from Subunit A. According to the ADEQ, TCE concentrations in the irrigation well have been detected at 2.2 µg/L twice over the past 10 years. However, in March 2000, TCE was detected at a level of 23 µg/L in the irrigation well. ADEQ has strongly advised the Park Shadows Apartments management not to change the irrigation well into a drinking water well. Table 5 provides the concentrations of TCE in the wells at the Park Shadows Apartments.

Table 5.

TCE* Concentrations in Private Wells at Park Shadows Apartments
Wells TCE (µg/L) Above MCL? Perchlorate
Irrigation Well ND§ - 23 YES NS
Drinking Water Well ND NO NS
*TCE = trichloroethylene; µg/L = micrograms per liter; MCL = maximum contaminant level;§ND = not detected; NS = not sampled.

As can be seen from Table 5, TCE has been detected in the irrigation well at the Park ShadowsApartments at levels above the federal MCL. The private wells at Park Shadows have not beentested for perchlorate.

In this section, TCE was identified as a COC in on-site soil. Both TCE and perchlorate wereidentified as COCs in on-site groundwater. TCE was identified as COC in off-site groundwater. These COCs will be further evaluated based upon a toxicological evaluation in order to determine if they present a public health threat.


In order to determine if residents are being exposed to the chemicals at levels of public healthconcern at the site, pathways are identified to determine if and how residents are being exposed tothe contaminants. A resident can only be exposed if a pathway is completed at levels of publichealth concern. Pathway analysis considers the source of contamination, the transport of thecontaminant through environmental media, an exposure point, a potential route of exposure, and the existence of a receptor population. Both current and future potential pathways are evaluated.

4.1 Incomplete Exposure Pathways

Incomplete current exposure pathways indicate that the contamination is present but is not able to reach the surrounding population for a variety of reasons.

On-site Soil and Groundwater Contamination

The Unidynamics property is fenced off preventing any public access to the site and exposures to thesoil and groundwater contamination. Unidynamics used to dump some of their waste in an areanear the mountains just west of the facility known as White Tanks. The investigation of the contamination at White Tanks is still being conducted.

Thermal Oxidizer Emissions

The thermal oxidation system was turned off in October 1998 to evaluate the need for continued soilremediation at the Unidynamics facility. Currently, no one in the Goodyear area is being exposed to the emissions from the thermal oxidizer.

Future exposures to thermal oxidizer emissions will not occur unless the thermal oxidizer is put backinto operation. USEPA is in the process of deciding if the thermal oxidizer is needed for further on-site soil remediation. If the thermal oxidizer is put back into operation, ADHS will request toreview and evaluate the proposed sampling plan for testing air emissions to ensure it is protective ofpublic health. In addition if the thermal oxidizer is used again, ADHS will request the air emissions data to evaluate and determine if a public health threat exists.

Off-site Groundwater

SunCor Well # 33A, which has a carbon filter treatment system, is currently being used to providewater for the ornamental lakes and golf course in the Pebble Creek housing development. Use of thetreated water does not represent a health hazard if the carbon treatment system is functioning properly.

4.2 Complete Past, Current, and Future Exposure Pathways

Past Occupational Exposure Pathways

It is known from our preliminary overview that many former Unidynamics workers were exposed toTCE and other chemicals in their jobs on a daily basis. These would have included inhalation,ingestion, and dermal exposures to the various chemicals used at the plant. Their reports indicatedthat they were exposed to many different chemicals including nitric acid, tear gas, MEK,hydrochloric acid, explosive chemicals, radioactive materials such as tritium and cobalt, and TCE while performing different types of jobs.

Past Air Emissions Exposure Pathways

Past thermal oxidizer emissions could have led to inhalation exposures for residents living nearbythe unit. Because many community residents are concerned about their past inhalation exposures tothe thermal oxidizer emissions, ADHS has calculated past inhalation exposure doses from the available emissions data. These are presented in Section

Current and Future Exposure Pathways

It is possible that dermal, inhalation, and ingestion exposures have occurred and will continue whenfarmworkers irrigate the fields, and when children play in the irrigation water in the small canals orat the Park Shadows Apartments. Additional exposures may also occur if the abandoned wells inthe area are fixed and used for drinking or irrigation purposes, or if an irrigation well is convertedinto a drinking water well. Photographs of the Globe wells, small irrigation canals, and nearbyirrigation water holding pond are provided in the Appendix.

Approximately 2,000 homes have been built in the Pebble Creek housing development, of which1,500 are currently sold. It is anticipated that approximately 6,000 residents will soon be living inthis area assuming three residents per house. The new SunCor housing development that is currentlyunder construction will have approximately 3,500 homes and 10,500 residents. Construction for thenew Globe housing development, which will be located just west of Bullard Road and south of theRoosevelt Irrigation District (RID) canal, has not yet begun but approximately 2,000 homes areplanned bringing in approximately 6,000 new residents into the area. The Globe Corporation, whoowns the land west of Bullard Road, stated that the Globe wells may be shut down when housingconstruction begins since they won't be needed for irrigation purposes.

Table 6 provides a description of the past, current and potential future exposure pathways that havebeen identified and the estimated surrounding population at risk. These estimates assume three persons per residence.

Table 6.

Summary of Exposure Pathways.


Media Point of Exposure Route of Exposure Estimated Population COC
Unidy-namics air
air emissions
300 TCE§ past
Thermal Oxidizer air air emissions inhalation 400 TCE past
Park Shadows Apts. groundwater water used for irrigation purposes ingestion
600 TCE past
Globe #2 Well groundwater water in irrigation canals ingestion


10 farmworkers TCE

Globe #2 Well
SunCor #33A
groundwater irrigation water for canals, golf courses, & ornamental lakes




Pebble Creek
4,500 res.
(2,000 homes)
Globe #2 Well
SunCor #33A
groundwater irrigation water for canals, golf courses, & ornamental lakes ingestion


Pebble Creek
4,500 res.
(2,000 homes)
10,500 res.
(3,500 homes)
6,000 res.
* PGA= Phoenix Goodyear Airport; † Assumes three residents per household; ‡ COC = contaminants of concern; § TCE =trichloroethylene; res.= residents


5.1 Toxicologic Evaluation

The potential for adverse health effects in persons exposed to site-specific contaminants throughcurrent or future exposure pathways has been analyzed by ADHS. Some children could be exposedto TCE and perchlorate if they play or drink the water in the small irrigation canals or in the holdingpond located next to the larger RID canal. Two of the Globe irrigation wells have concentrations ofTCE at levels which are above USEPA's MCL. TCE was also recently detected in the irrigationwell at the Park Shadows Apartments at a level which is above the federal MCL. Concentrations ofperchlorate were found in Globe Well #2 irrigation well but the level was not above the health-based guideline value. Based on these facts, TCE is the only contaminant of concern which merits detailed evaluation.

5.1.1 Health-Based Guidance Levels (HBGLs)

Health-Based Guidance Levels (HBGLs) are tools used to assist in evaluating the public health riskposed by each specific contaminant of potential concern. They are calculated by ADHS using ahuman health-based approach that is generally consistent with risk assessment methodologiesrecommended by ATSDR and USEPA. ADHS has used standard exposure assumptions, and, wherenecessary, has made conservative assumptions based upon research of the particular exposurescenario and professional judgement. Equations used to quantify exposures were based upongenerally accepted methods, models, toxicity values, and assumptions developed by USEPA. Thestandard exposure assumptions were obtained primarily from Risk Assessment Guidance forSuperfund (RAGS), Supplemental Guidance Standard Default Exposure Factors (USEPA 1991). The risk management values used to calculate the HBGLs are consistent with the methodology usedto calculate the Arizona residential Soil Remediation Levels (SRLs). HBGLs protect againstnoncancer health effects, and limit excess lifetime cancer risk to one-in-one million (10-6) for knownhuman carcinogens and to one-in-one-hundred-thousand (10-5) for possible and probable humancarcinogens.

Health-Based Guidance Levels (HBGLs) are individually protective of human health, includingsensitive groups, over a lifetime. Chemical concentrations that exceed the applicable HBGL maynot necessarily represent a health threat. Rather, when contaminant concentrations exceed theHBGL, further evaluation may be necessary to determine the potential public health risk. TheHBGLs calculated in this public health assessment consider the human health threat from thecumulative inhalation, ingestion and dermal contact with TCE in the small irrigation canals. Theywere also calculated for inhalation contact with TCE in the emissions that came from the thermal oxidizer. Health-Based Guidance Levels (HBGLs) for Past On-site Thermal Oxidizer Emissions

The ADHS calculated an annual ambient air HBGL for TCE levels that were detected in theemissions of the thermal oxidizer during the time it was in operation to determine if residents wereexposed to levels of TCE that could affect their health. The highest TCE level detected was used inthe calculations, which assumed that people were consistently exposed to that level for 30 years, 350days per year. The exposure duration for carcinogens was assumed to be 30 years, with six of thoseyears as a child and 24 years as an adult. Since exposure to contaminants in air may be different forchildren and adults, carcinogenic risks during the first 30 years of life were calculated using age-adjusted exposure factors. These factors integrate exposure from birth until age 30, combiningcontact rates, body weights, and exposure durations for small children and adults. Exposure doseswere averaged over a lifetime (70 years) for carcinogens.

Annual HBGLs are also specifically protective of noncancer health effects for childhood exposure. Exposure assumptions reflect childhood inhalation rates and body weight. The focus on children isprotective of the higher daily intake rates by children relative to their body weight. For noncancerhealth effects, the exposure duration was assumed to be 350 days per year for six years. Exposuredoses are averaged over the period of exposure (six years) for noncancer health effects. Air HBGLsuse the default childhood inhalation rate of 10 cubic meters per day (m3/day) and default bodyweight of 15 kilograms (kg) (USEPA 1989,1991).

The ADHS used a "box model" to calculate the movement of the emissions from the stack of the on-site thermal oxidizer into the residential areas of Goodyear (ADHS 1997). It assumes the air iswell-mixed within the box and the dimensions of the box are equal to the human breathing zoneheight and the length of the emission source in the predominant wind direction. Given theseassumptions, ADHS estimated outdoor ambient air TCE concentrations of 0.0016 mg/m3 due to thepast vapor emissions from the thermal oxidizer on the Unidynamics facility.

Table 7 displays the estimated outdoor TCE air concentration using the highest TCE concentrationdetected in the available thermal oxidizer emissions data. This outdoor air concentration was thencompared to the HBGL to determine if the TCE in the emissions presented a health threat when thethermal oxidizer was in operation.

Table 7.

Estimated Outdoor Air Concentrations of TCE* in the Thermal Oxidizer Emissions and Comparison to the HBGL (1996 through 1998).
Range of Emission TCE Concentrations Estimated Outdoor Air TCE Concentration in Emissions Ambient Air HBGL for TCE Above HBGL?
0.25 - 59.0 µg/L 0.0016 mg/m3 § 0.009 mg/m3 NO
* TCE=Trichloroethylene; HBGL=Health-based Guidance Level;µg/L = micrograms per liter; §mg/m3 = milligrams per cubic meter.

As can be seen in this table, the concentrations of TCE in the past emissions from the on-site thermaloxidizer did not exceed the HBGL. This indicates that the level of TCE in the emissions would notbe considered a health threat to the community even if the thermal oxidizer operated for 30 years.But this is not applicable to dioxin emissions since it they were not tested for during the time the thermal oxidizer was in operation. Health-Based Guidance Levels (HBGLs) for the Contaminated Water in the Small Irrigation Canals

This section analyzes all the various exposure pathways that children, adults, and farmworkers maybe exposed to the contaminated water in the small irrigation canals. ATSDR and ADHS standardexposure assumptions for intake rates, body weights, exposed dermal surface area, averaging times,and exposure duration were used. Equations and exposure factors are provided in Table A11-A29in the Appendix. ADHS calculated both residential and occupational HBGLs as comparison valuesthat would incorporate all the various exposure pathways to the contaminated water via incidentalingestion and dermal contact, and inhalation pathways.

The residential exposure scenario conservatively assumes that adults and children are exposed to thecontaminated irrigation water via inhalation, ingestion, and dermal contact during periodic floodirrigation times or play activities such as playing in the canal water. A child is assumed to play inthe irrigation water for 4 hours per day, 350 days per year (City of Phoenix 1998) for six years. Thechild is exposed via incidental ingestion and dermal contact with the contaminants in the water for a4-hour period during each irrigation event (ADHS 1997a). An adult is assumed to have incidentalcontact with the irrigation water that has flooded the fields while walking next to the irrigated fields. It is assumed that the amount of time for this activity would account for one hour per day, 350 daysper year for 30 years. The adult is exposed via inhalation of contaminants escaping from the floodirrigation waters for the 4 hours that the water is assumed to be standing in the property.

The occupational exposure scenario for flood irrigation quantifies exposures to workers involved inmaintenance of the irrigated properties. This exposure scenario conservatively assumes that workersare exposed to contaminants in the flood irrigation water via incidental inhalation, ingestion anddermal contact during regular farming activities. A farmworker involved in flood irrigation duties isassumed to have incidental inhalation, ingestion, and dermal contact with the flood irrigation waterfor eight hours per day, 250 days per year for 25 years (ADHS 1997).

ADHS's HBGLs for flood irrigation indicated the highest concentration of TCE in the contaminated groundwater that would not be considered to cause adverse health effects when used for irrigation purposes in the fields. The residential HBGL for TCE is 397 µg/L for adults and 87 µg/L for children. The occupational HBGL is 100 µg/L for adults. As seen in Table 8 below, estimated exposure doses from ingestion of contaminated water from the Globe #2 well and the Park Shadows irrigation well are below the respective HBGL.

Table 8.

Comparison of TCE* Concentrations in the Globe Irrigations Wells to the HBGLs.
Chemical Found in Private Well Exposure Pathway Usage of Private Well Comparison of Exposure Intake to HBGL
TCE Levels in Wells HBGL Exceeds HBGL?
TCE Globe #1
Globe #2
Irrigation Wells
irrigation of fields 39 µg/L
22 µg/L
adult: 397 µg/L

child: 87 µg/L

occupational: 100 µg/L


TCE Park Shadows Irrigation Wells irrigation of apartment grounds 23 µg/L NO
a TCE=Trichloroethylene; † HBGL=Health-based Guidance Level. These HBGLs assume that adults and children are exposed to the contaminated irrigation water 350 days per year; µg/L = micrograms per liter.

ADHS concludes that the TCE levels detected in irrigations wells Globe #1, #2, and Park Shadows do not represent a current public health threat. Ingestion Exposures to Eating Edible Plants Irrigated with Contaminated Groundwater

In response to community concern, the ADHS conducted research to determine if a public healththreat exists from the consumption of vegetables that could be grown in the fields that have beenirrigated with the TCE contaminated groundwater. A literature search was conducted to identifyhow volatile organic compounds (VOCs) are taken up by edible plants and what the accessability ofthe VOCs are to humans who might eat the plants. ADHS has concluded that there are insufficientdata to identify the possible health threat related to the ingestion of edible plants grown with the useof contaminated groundwater.

While much of the present research has focused on the uptake of pesticides into plants, the researchon the uptake of industrial pollutants by plants and food crops is rudimentary. Studies have focusedon the uptake of individual organic chemicals by crops such as corn, radishes, barley, beets, wheat,and soy. However, experimental results have been inconsistent, and have been dependent on thevarious factors within the study.

Trapp and McFarlane (1995) have developed mathematical models to account for some of thesevariables in order to predict the uptake of organic chemicals into plants and the fate of differentchemicals. However, the authors suggest that more data are needed for a variety of chemicals andtissues to strengthen the correlations. Consistent correlations would enable investigators to predicthow much of a chemical is absorbed into the plant and its accessability to humans.

Available data suggest that the uptake of organic contaminants by plants is dependent on the variousproperties of the chemical, the plant, and its environment. Until these variables can be determined and identified, any health threat to humans due to the consumption of food grown with TCE contaminated groundwater cannot be determined.

5.1.2 Limitations of Toxicological Data

More detailed toxicological information on TCE and perhclorate are summarized in the Appendixfor reference. Each chemical is summarized with regard to use, interaction with other chemicals,exposure routes, toxicokinetics, toxic (health) effects, carcinogenicity and regulatory status. Much ofthis information is provided by the Toxicological Profiles published by the ATSDR. ADHSrecognizes that the scientific literature includes limitations, such as the extrapolation of high-doseanimal studies to low-dose human exposures and studies done on single chemicals while manyexposures may be to complex mixtures of chemicals. ADHS has considered these factors in the evaluation of the PGA- North site.

5.2 Health Outcome Data Evaluation

5.2.1 Evaluation of Arizona Department of Health Services (ADHS) Health Studies

The ADHS studies reviewed in the Health Outcome Data Section 1.5, analyzed cancer andchildhood leukemia mortality and incidence rates in Maricopa County, including the Goodyear area,since 1965. These studies measured the mortality of five disease categories and the incidence ofchildhood cancers and leukemia. These studies did not measure morbidity (illness) or any adversehealth effects that do not result in death or cancer. There was no indication of elevated mortality orincidence rates of total cancers or childhood leukemia in the Goodyear area found in these studies.

If higher cancer rates had been found in the Goodyear area, no causal relationship could be drawnfrom these findings. Since the development of cancer has multiple risk factors and potential causes(e.g., lifestyle, genetics, socioeconomic status, and environmental), it is not possible to assume that agiven disease condition is or is not caused by a specific environmental contaminant. In addition, pastexposures cannot be quantified or verified eliminating the possibility of determining causation in anyhealth study that would be conducted. Therefore, if an additional study were conducted, it would notbe able to determine if any cancers in residents in the Goodyear area are due to past exposures to TCE or any other contaminants from the PGA North site.

5.2.2 SunCor Housing Development Risk Assessment (1998)

In 1998, a risk assessment was conducted by Papadopulos & Associates, for the new SunCor housing development. It evaluated the human risk that residents might have from exposure to potential volatilization of TCE from contaminated groundwater beneath the SunCor housing development in Goodyear, Arizona. The ADHS reviewed the risk evaluation to determine if the assumptions and calculations used in the report were correct.

The potential migration of TCE from the groundwater through the overlying soil area and into theair was evaluated to determine the potential TCE concentrations in air that residents might breathe.The risk assessment concluded that TCE in the groundwater does not represent a significant riskfrom volatilization through soil to residents who live in the SunCorp development. There arelimitations to modeling indoor air concentrations. ADHS cannot determine the accuracy of the modeling results without having access to the necessary data.

5.3 Health Concerns Evaluation

This section reviews the results of the ADHS survey, and addresses the concerns that were voiced bythe community residents and former Unidynamics workers.

This survey process has been extremely successful in helping the ADHS identify and address manyof the concerns of the community residents and former Unidynamics workers. Residents had manymisunderstandings, worries, and concerns related to living near the PGA North site. ADHS helped toclarify many of these misunderstandings, alleviate some of the community fears, and address majorconcerns on a one-to-one basis with community members. In addition, ADHS sent environmentalhealth educational materials to survey participants and doctors in the area.

The community survey is meant only to be used as guidance in identifying and addressing publichealth and community concerns. It is not designed to be a scientific epidemiological study. Since theresults are not medically confirmed (with a few exceptions), the survey data cannot and should notbe used to make conclusive statements concerning the health of the residents who live near PGANorth site or who worked at the Unidynamics plant.

They are deeply concerned that many of their health problems are due to living near the PGA North site and being exposed to the contamination. Since some of the health conditions that were reported,such as eye and respiratory problems, are not legally required to be reported to a registry, there is noavailable health outcome database to use for comparison. This makes it extremely difficult todetermine if any amount of a specific illness in an area is unusual. Therefore, no conclusions can bemade as to whether the community residents are experiencing unusual adverse health effects (otherthan those that result in death) that would be related to exposure to the chemical contamination atthe PGA North site.

Former Unidynamics workers have voiced major concerns about their health problems that havedeveloped subsequently to their employment at the plant. Some of the health problems expressed byformer workers (respiratory, heart, nerve, and eye problems) are consistent with long term exposureto working with high levels of TCE. However, ADHS is unable to link the cause for these healthproblems directly to past exposures to chemicals at the plant since there are many confoundingfactors. Because the development of cancer and other diseases have multiple risk factors andpotential causes (e.g., lifestyle, genetics, socioeconomic status, and environmental), it is usually notpossible to assume that a given disease condition is or is not caused by exposures to specificenvironmental contaminants. Past exposures of former workers at the Unidynamics plant cannot bequantified or verified. This eliminates the possibility of determining causation of subsequent diseases that former workers developed.


5.3.1 Community Residents Concerns

This section identifies and addresses the concerns of the community residents who were not former Unidynamics workers.

  • What is Trichloroethylene (TCE)?

TCE is a clear, odorless, nonflammable liquid used for vapor degreasing of fabricated metal parts.Consumer products that contain TCE include typewriter correction fluid, paint removers andstrippers, cosmetics, rug cleaners and spot removers, and adhesives. Before 1977, TCE was used asa general anesthetic, analgesic, grain fumigant, disinfectant, pet food additive, and extractant of spices and caffeine in coffee (ATSDR 1997). Community Drinking Water Concerns

  • Are the municipal drinking water sources in Goodyear, Litchfield, and Pebble Creeksafe to use as drinking water? Is the water being monitored for harmful contaminants?

Yes. The drinking water in Goodyear, Litchfield, and Pebble Creek is safe to drink. The quality ofdrinking water supplied in these areas meets drinking water standards established by USEPA in theSafe Drinking Water Act amended in 1991. The municipal wells in the City of Goodyear, LitchfieldPark Service Company, and Pebble Creek are monitored on a quarterly basis and there have been nodetections of contaminants above drinking water standards. These standards are protective of publichealth. More specifically, the City of Goodyear routinely monitors wells in proximity to the TCEplume at least quarterly to ensure that the water is safe for consumption. The ADHS reviewed thepast data from the samples taken from Goodyear wells #2, #3, and #10. The results show that thesewells have no VOCs, including TCE at levels of public health concern. Since Goodyear well #10 isthe only Goodyear municipal well that is located over the plume, it is being watched carefully toensure that it is not contaminated.

The Crane Co. maintains 24 groundwater monitoring wells throughout the contaminatedgroundwater area under the direction of ADEQ. The purposes of the monitoring program are todefine the horizontal and vertical extent of contamination, and to provide data on the effectiveness ofthe groundwater containment and cleanup program. This also helps to identify any municipal wells that may be in the path of migrating contaminated groundwater (USEPA 1999).

  • How can the drinking water from the municipal wells be safe if the groundwater is contaminated?

Groundwater is water found in large amounts under the ground surface. There are three main bodies of groundwater underneath the PGA North site that are called aquifers. Located at different depths, they are known as the upper Subunit A, middle Subunit B, and the lower Subunit C aquifers. The upper aquifer (Subunit A) contains groundwater that became contaminated from waste solvents that were disposed of in dry wells on the Unidynamics facility and is not used as a source for drinking water by the City of Goodyear. The middle aquifer (Subunit B) produces very little water and restricts groundwater from moving from the upper Subunit A to the lower Subunit C aquifer. The lower aquifer (Subunit C) is used for drinking water, agricultural and industrial purposes in the Goodyear area (USEPA 1999). The middle and lower Subunits B and C are often called the lower B/C Subunit aquifer.

TCE has been detected in a small area in the lower B/C Subunit aquifer. This contamination has notmigrated to the Goodyear municipal wells. The Goodyear municipal well #10 is the only well that islocated in the plume area. TCE has never been detected in this well. This situation is beingmonitored carefully by various agencies to prevent the municipal wells from becomingcontaminated. Remediation activities are pulling the contamination away from the municipal wellsso they will not become contaminated. Community residents are encouraged to call the ADHS and ADEQ for updates on this situation if they are concerned.

  • Are the private wells at Park Shadows Apartments safe?

There are two private wells at Park Shadows Apartments. One is used for irrigation purposes and the other for drinking and domestic purposes. These wells are sampled on a regular basis as determined by ADEQ. Results from past samples have found that the drinking well had no detected VOCs, including TCE. Water samples from the irrigation well have detected levels of TCE at 2.2 micrograms per liter (µg/L) consistently for the past several years. Recent samples from this irrigation well have shown levels of TCE at 23 µg/L. This is above the USEPA's MCL of 5 µg/L but below the HBGL for irrigation water. This is not considered a health hazard. The drinking water well pulls water from Aquifer C which remains free of TCE. These wells have not been tested for perchlorate. It is recommended in this report that perchlorate be tested in these wells.

  • There are signs posted along the small irrigation canals that warn people not to touchthe water because it is contaminated. Will my child get sick if he or she plays in thatwater?

The water from the Globe wells, where the signs are posted, is contaminated with low detections ofTCE and perchlorate. The water from these wells flows into the small irrigation canals that are usedto irrigate the agricultural fields and is stored in the nearby holding pond. Because a new SunCorhousing development is being built nearby which will bring more children into the area, the ADHSconducted an exposure assessment to determine if the water presents a health hazard to children. The analysis showed that the levels of TCE and perchlorate are not high enough to cause healthproblems even if children play in the canals every day of the year. The well water is being routinelymonitored by ADEQ. Even though TCE and perchlorate are present in the small canals, it won'thurt anybody who comes in contact with the water or drinks it.

However, there are several physical hazards apparent around the canal area. There are rusty brokenpipes around the various pumps in the area that are accessible to children. There are large opencement drains that children can crawl into and an open well that a child could fall into. This is also aconcern since new residential areas are being built nearby. Photographs of these areas are included in the Appendix.

  • Are farm workers being exposed to TCE contaminated water in the small irrigationcanals?

It is likely that farm workers could be exposed to the contaminated water in the small irrigationcanals when working in the fields. This would happen if they drank the water, used the water tocool themselves, or used it to wash their hands and face. The ADHS conducted an exposureassessment to determine if the water presents a health hazard to farm workers. Although the water iscontaminated, the levels of TCE and perchlorate are not high enough to cause health problems, evenif the farm workers come in contact with it eight hours a day for 250 days per year. The water isbeing monitored by ADEQ. The remediation activities that are taking place will eventually clean thegroundwater and the water in the canals. Even though TCE and perchlorate are present in the smallirrigation canal water, the levels will not cause adverse health effects to anyone who comes in contact with or drinks the water.

  • Has there been any remediation of the groundwater in Goodyear? Will the remediationof the groundwater improve the safety and quality of the water?

Yes. Full scale remediation (cleanup) of the groundwater contamination began on the PGA Northsite in September 1990. The Crane Co. established groundwater monitoring, groundwater cleanup,and soil cleanup programs to implement the required cleanup. Groundwater cleanup is beingaccomplished through a network of groundwater extraction and groundwater injection wells. Sixgroundwater extraction wells pump approximately 1,300 gallons per minute to contain and restorethe contaminated aquifer.

The extracted groundwater is treated to remove the VOCs. Then it is either re-injected back into theaquifer or used for irrigation. The groundwater treatment unit removes the VOCs using air strippingtechnology and then treats the contaminated air coming from the unit with granular activatedcarbon. There has been a drastic reduction of TCE concentrations since treatment began. Theextraction wells have removed approximately 26,000 pounds of VOCs from the groundwater sinceoperation of the system began. It is estimated that the system at the Unidynamics plant will operatefor at least 25 years.

  • Has the presence of TCE in the groundwater resulted in higher rates of cancer in the community residents who live in the Goodyear area?

ADHS has routinely conducted several studies to analyze the amount and types of cancer during the past three decades throughout Maricopa County. These studies also include the Goodyear area. Results from these studies show that the Goodyear area did not experience elevated mortality or incidence rates of cancer, or childhood leukemia during the years from 1965 to1990.

According to the American Cancer Society (ACS), there are many causes of cancer. These includegenetic factors, viruses such as the Epstein Barr virus which can cause various lymphomas, and thehuman papillomavirus (HPV) that can cause non-melanoma skin cancer, and environmental factors(ACS 1999). The ACS has available information on the different types of cancer, their causes, andtreatment. Currently, no evidence suggests that the TCE in the groundwater has resulted in higherrates of cancer in the Goodyear area residents.

  • Can people in the community collect chemicals in their bodies (bioaccumulation) fromdrinking contaminated water?

VOCs do not significantly collect in the human body. This class of chemicals is easily processed bythe body and eliminated. Therefore, exposure in Goodyear to water contaminated with TCE or otherVOCs should not result in collection of VOCs in people.

How much is collected in the body depends on the chemical properties of the contaminants. One of the main factors responsible for chemicals collecting in the body is when a chemical does not break down easily in the body. Because TCE is easily broken down by the body and excreted, it is unlikely that TCE would accumulate in the body tissues of people living in the Goodyear area.

  • Many residents are concerned about the presence of perchlorate in the drinking waterafter attending the February 1999 public meeting held by the USEPA. This concernwas voiced by several people who called in during the following months after themeeting.

The drinking water in Goodyear, Litchfield, and Pebble Creek is safe to drink and clean ofperchlorate. However, there are small amounts of perchlorate in the Globe well #2 which provideswater to the irrigation canals west of Bullard Road. It is not possible for the residents of Goodyearto come in contact with the perchlorate in the groundwater unless they drink, swim or rinse off in theirrigation water in the canals or holding pond. The perchlorate concentration in the irrigation canalsis below the ADHS health guideline of 14 parts per billion (ppb). Nonetheless, the ADHS sent outhealth education information packages to doctors throughout the Goodyear area, to inform them ofthe perchlorate in the water, and the likelihood of any health effects from being exposed to theperchlorate.

Perchlorate originates as a contaminant in the environment from the solid salts of ammonium,potassium, or sodium perchlorate. The perchlorate part of the salts is quite soluble in water and canpersist for many decades under typical groundwater and surface water conditions, because of itsresistance to react with other available elements. Perchlorates dissolve easily in water and are quitecapable of migrating to groundwater.

Perchlorates are used in pyrotechnics, explosives and jet or rocket fuels. They are also used ascatalysts or as digesting agents in analytical chemistry laboratories, as etching and engraving agents,as an ingredient in electrolytic baths in depositing lead and electro-polishing and in the manufactureof various chemical compounds. Perchlorates can be used in oxygen-generating devices for life-support systems in submarines, space ships, bomb shelters and breathing apparatuses. Perchloratescan be used in paper and wooden matches and automobile air bags.

Potassium perchlorate is used to treat Grave's disease, an autoimmune disorder that affects thethyroid function leading to a hyperthyroid state. Perchlorate can interfere with the function of thethyroid. When this happens, the pituitary gland responds to the low level of hormones by producingthyroid-stimulating hormone (TSH) causing the thyroid gland to become enlarged. This can causehypothyroidism where people can feel sluggish, depressed, cold, or tired. There are many causes forhypothyroidism. Thyroid disorders are very common, and are more frequent in females than inmales.

USEPA is in the process of developing a federal standard for perchlorate that will be based on theresearch currently being conducted around the country. ADHS uses the health-based guidance levelin the interim. As stated earlier, it is not possible for the residents of Goodyear to come in contactwith the perchlorate in the groundwater unless they drink, swim or rinse off in the irrigation water in the canals or the holding pond. Community Concerns Related to Air Pollution

  • Thermal Oxidizer: Several Goodyear residents expressed concerns about the thermaloxidizer, which was set up to remediate the soil at the Unidynamics facility. Theseresidents wondered if, while the thermal oxidizer was still in operation, they had beenexposed to cancer-causing compounds, such as dioxins and furans that could havebeen present in the emissions.

The thermal oxidizer was in operation intermittently from 1994 to 1998. It was periodically testedfor TCE removal efficiency of the on-site soil contamination. It was turned off in October 1998 toassess whether further soil remediation was needed. Presently, no one is being exposed to theemissions from the thermal oxidizer.

The dioxin emissions from a thermal oxidizer are dependent on the type of air pollution controlequipment being used, the chemicals that are being burned, internal temperatures, and otheroperating conditions. Therm Tech, the manufacturer of the thermal oxidizer at the PGA North site,stated that this unit has all the necessary components to prevent dioxins from being formed. The unithas a quencher; it provides good mixing of the combustion gases enough to prevent dioxins frombeing created in the oxidizing chamber. ADHS was not able to get testing data on dioxin levels inemissions from other thermal oxidizers.

Chemicals in the emissions, including dioxins, from the thermal oxidizer will become diluted whenthey are released into ambient air. However without proper data, ADHS cannot determine if or howmuch dioxin was present in the past emissions from the thermal oxidizer at the PGA North site. Theemissions data for the thermal oxidizer at the PGA North site includes only TCE since that is whatwas being removed from the soil. Past emission data and exposure dose analysis for TCE isprovided in Section 5.1.1.

ATSDR reports that the average American adult has a circulating level of dioxin of seven picogramsper gram (seven parts per trillion) of body fat (ATSDR 1998).It is estimated that the daily intake ofdioxins and furans by a maximally exposed individual living near a modern thermal oxidizer is only0.9%of the total daily intake and 99.1% is from other various sources, primarily meat and dairyproducts (ATSDR 1998, p.467).

  • Since the thermal oxidizer is not operating, could the respiratory problems be causedby any other contamination on the PGA North site?

Many Goodyear residents in the survey complained of respiratory problems. This includedproblems with asthma, hayfever, and other bronchial irritations. Many residents believe that theirrespiratory problems are due to the contamination on the PGA North site. However, due to the typeand nature of the contaminants present at the PGA North site, it is extremely unlikely that theywould cause these types of respiratory complaints reported by the community. There are severalother environmental problems present in the Goodyear area that could cause these types ofrespiratory complaints. In fact, respiratory problems are found throughout the Phoenix Valley.

Residents also reported that a strange smell occurs in the area at night periodically. When thisoccurs, they and their children develop breathing difficulties which prevents them from goingoutside in the evenings. The nearby aluminum smelter, IMSAMET, was often identified as the source of the odors.

IMSAMET Aluminum Smelter

Many community residents are concerned about the emissions form the IMSAMET facility(formerly known as Imsalco). The aluminum recycling plant is located at 3829 South EstrellaParkway, near the southwest corner of Goodyear Airport. This facility is not part of the PGASuperfund Site, however, ADHS investigated these concerns.

IMSAMET of Arizona was first built to burn old airplane parts after WW II. It is now an aluminumsmelter facility that recycles aluminum. Aluminum dross (impure aluminum) is brought to the sitefrom both primary and secondary aluminum industries, and then crushed and milled to producepurified aluminum ingots. The ingots are then shipped out to industries such as auto makers,aluminum siding makers and roofing companies that use the recycled aluminum in their products. Four tons of recycled aluminum is shipped out every month to such industries.

The IMSAMET facility was investigated in 1989 in response to a series of complaints by localcitizens about excessive emissions (white smoke and odors). As a result, the facility was issued 29citations in 1989 by Maricopa County for operating in violation of County Visible EmissionsStandards at night. During this investigation, "the white horizontal smoke plume appeared wellover 1/4 mile from the source with no end in sight." Odors from the emissions produced weresimilar to a strong ammonia smell combined with a pungent onion odor (Maricopa County Memos1990). IMSAMET installed a new baghouse to control the particulate emissions from the furnaces,and continued to educate their employees on proper operating procedures for the furnaces.

The type of industrial process conducted at IMSAMET will release smoke, odor, and particulates(small particles) into the air. According to Maricopa County, Level II source testing is conductedperiodically by IMSAMET for criteria pollutants which include carbon monoxide (CO), nitrogenoxides (NOx), and particulate matter (small particles in the air). Since 1995, Level II source testingfor criteria pollutants conducted by IMSAMET has indicated that the facility is in complianceaccording to the permit conditions listed by Maricopa County, with the exception of a test conductedin 1999. This test showed elevated levels of CO and the results are being verified. Maricopa Countystaff also visited the facility in response to the ADHS inquiry but stated that nothing could beidentified as the cause of the odors. ADHS encouraged Maricopa County to continue itsinvestigation especially at night.

Community residents continue to complain of intermittent white smoke at night which they believecauses their respiratory problems. Even though the levels of particulates in the emissions are withinacceptable limits, the inhalation of particulates may cause respiratory irritation, aggravate mucousmembranes, and create discomfort in those people already prone to respiratory disease (MaricopaCounty memos, 1990). Testing for specific substances such as lead, beryllium, cadmium, or dioxinshave not been conducted. Community residents are encouraged to call the Maricopa CountyEnvironmental Response and Complaint line at 602/506-6616 if they would like to find out moreabout the IMSAMET facility, discuss their concerns, or find out more about its compliance history. IMSAMET will also offer tours of their facility for interested residents.

Dust and Particulate Matter

Additional air quality issues exist in the Goodyear area that could explain some of the respiratoryproblems that are affecting so many community residents. There are high levels of dust andparticulate matter in the air that come from farming activities and pesticide spraying. These types ofactivities are known to cause respiratory problems but are oftentimes overlooked since much of thecommunity focus is on the contamination at the PGA North site. The contamination at the PGANorth site does not have the necessary environmental characteristics that normally cause such healthproblems throughout a surrounding community. This is described below in more detail.

Maricopa County has been in violation of the standards for small air particles (particulate matterless than 10 microns in size, called "PM-10") for most of the past decade. Particulate matterconsists of airborne particles made of solid and liquid droplets of materials that vary in size andorigin. The small particles can be inhaled into the respiratory tract causing respiratory problems.The smallest of these particles (less than 2.5 microns in size) are thought to be the most damagingsince they can be breathed deeply into the lungs causing severe irritation.

The causal link between exposure to small particulate matter and adverse health effects is wellestablished. While some people are not affected by this type of air pollution, others will be verysensitive and develop certain types of bronchial irritations including asthma, and hayfever. Theestimated number of premature deaths due to PM-10 in Arizona is 963 per year. Those affected areprimarily the elderly and those already suffering from a cardiopulmonary or respiratory disorders(ADHS, 1995). Particulate matter, including the smaller dust particles, can also carry certainallergens, or even viruses that may cause respiratory irritation.

According to the American Lung Association of Arizona (ALAA), respiratory problems are now extremely prevalent throughout Maricopa County. The growth of Phoenix has led to a tremendousamount of construction and farming activities which have increased particulates and dust in the air,pollens and molds, and other respiratory irritants throughout the Valley and the outlying areas(AALA 1999). Also, new pollens and molds have been introduced into the area as people havemoved into the Phoenix Valley and planted different types of trees and shrubs.

Pesticides in the Goodyear Area

The Goodyear area is a large agricultural area with a climate that allows farmers to grow crops allyear round which includes aerial spraying of pesticides throughout the year. There have been severalreports by community residents that pesticide spraying occurs on the fields and also over cars drivingon the roads. While many residents may not be reactive to this type of spraying, others may be verysensitive and develop certain health problems from being exposed to the aerial drift of pesticides.Residents who believe that they have experienced this type of exposure should contact medicaldoctors who are familiar with pesticide poisoning and discuss their individual situations.

  • Is it safe to live in Goodyear since there is contamination on the PGA North site?

Currently, community residents are not being exposed to chemicals on the PGA North site at levelsthat would be considered a public health hazard. The only possible exposures that residents mayhave to any chemicals related to the PGA North site is to the water in the small irrigation canalslocated on the north end of the groundwater plume, and typical exposure scenarios indicate this does not pose a public health hazard.

5.3.2 Former Unidynamics Workers Concerns

This section identifies and addresses the concerns that were expressed by many of the former Unidynamics workers.

  • One of the main concerns of the former Unidynamics workers is whether their currenthealth problems are caused by past exposure to TCE and various other chemicals whileworking at Unidynamics. This question addresses only noncancerous health effects. The next question addresses TCE and cancer.

As a defense contractor, Unidynamics was responsible for the design, development, production,testing, and support of tactical and strategic weapon and defense systems. A variety of chemicalssuch as nitric acid, hydrochloric acid, tear gas, explosive powders, paints, glue, oils, acetone, andother chemicals were used in this industry.

It is known from our preliminary overview that many former Unidynamics workers were exposed toTCE and other chemicals in their jobs on a daily basis. Their reports indicate that they were exposed to many different chemicals including nitric acid, tear gas, MEK, hydrochloric acid,explosive chemicals, radioactive materials such as tritium and cobalt, and TCE while performingdifferent types of jobs. Many former Unidynamics workers reported that they were not adequatelytold of the dangers of the chemicals with which they were working and safety precautions were notalways enforced.

During the survey, former employees described the type of work they did, and how they workedwith the various chemicals. The workers responsible for cleaning metal parts did so by dipping themin large open vats of TCE with their bare hands up to their elbows on a daily basis. This would bean indication of direct dermal and inhalation exposures to TCE. Other employees packed handgrenades with powder, or tested tear gas components. The smoke from these tests would fill thebuilding and everyone in the building would breathe the fumes. Reports indicated that employeescontinuously smelled fumes throughout the work day. Ventilation was not effective in getting rid ofthe chemical fumes from the daily chemical processes in the buildings. Employees stated thatoftentimes these activities were conducted without proper protective equipment. While shoes, shopcoats, and safety glasses were sometimes used, gloves or masks were not used regularly whenworking directly with the chemicals. These reports indicate that inhalation and dermal exposuresoccurred on a daily basis.

A separate building was used for making radioactive components for defense purposes. It is possiblethat employees were exposed to the radioactive materials. Without proper data, ADHS cannotdetermine the type of materials that were used or how they were handled.

Employees were responsible for the waste disposal of chemicals, including the radioactive waste, into dry wells located in the back of the facility. In 1980 and 1984, radioactive waste in thedumping area outside was cleaned up and taken to a proper radioactive waste facility. Chemicalwastes were also taken to an area many miles west of Goodyear known as White Tanks where theywere dumped, burned, and exploded. This aspect of the dumping is not covered in this report andcan be addressed when additional data becomes available.

The employees that worked with the explosive powders described that they would go home coveredin a pink chemical powder from the plant. This powder would then be spread in the carpet, clothes,towels, and curtains in their homes where their children would play with it. The powder would notwash out of their clothes, hair or skin. It would even get in the food in the kitchen. Although therewas some concern about this voiced by the former workers, they stated that no one really understoodthe danger of children playing with the powder at that time and it was considered a normaloccurrence. This situation would indicate direct dermal, inhalation, and possibly ingestionexposures to the pink powder, however ADHS does not know the chemical makeup of the powder.

A majority of the workers who called ADHS believed that their current health problems were causedfrom their past exposure to the chemicals used at Unidynamics. The major complaints reported byformer workers included skin cancer, respiratory, heart, nerve, and eye problems. There werereports of various cancers such as male breast cancer, skin cancer and multiple melanoma, lung,throat and rectal cancers, leukemia, non-hodgkin's disease. Other health problems included vertigo,memory loss, facial swelling, skin problems, throat and esophagus problems, and headaches. It isvery difficult to determine if these conditions are caused by previous exposures to the chemicals usedat the Unidynamics plant since the exposures happened in the past and direct causation cannot beproven. While some of the symptoms that have been described by former employees are consistentwith chemical exposures, there are many confounding factors that interfere with the determination ofcause and effect in such a situation.

The use of radioactive materials at the former Unidynamics facility has been documented. However, ADHS was unable to obtain data to determine types of materials, and how they were used.This would help to determine what exposures to the radioactive materials may have occurred to theformer workers. ADHS will conduct an investigation if future information becomes available on thetype and amount of radioactive materials that were used at the facility.

It is beyond the scope of this general health assessment to conduct an epidemiological study of thehealth effects from past occupational exposures in this situation. However, since TCE is thechemical of concern that has been the focus of the remediation activities, the following paragraphsprovide some description of health effects from occupational exposures to TCE. This will providean indication of the types of health effects that have been suggested in studies conducted on chemicalexposures to TCE in occupational settings.

A summary of animal and human studies that have been conducted on TCE can be found in theATSDR Toxicological Profile for TCE (ATSDR 1997). The toxicological profiles are prepared inaccordance with guidelines developed by the ATSDR and USEPA. They succinctly characterize thetoxicologic and adverse health effects information for hazardous substances. Each peer-reviewedprofile identifies and reviews the key literature that describes a hazardous substance's toxicologicproperties.

Respiratory problems were the most noted Unidynamics worker health symptom. Although this typeof health problem has many causes, it is possible that past exposures to chemicals used atUnidynamics may have caused respiratory problems for some of the former workers. In fact, oneformer worker stated that their doctor had requested that they change their job because the chemicalexposures at work had compromised their esophagus and respiratory system. Morphology of lungcells has been studied in rats and mice exposed to TCE. A 30-minute inhalation exposure to 500parts per million (ppm) resulted in changes in the nonciliated epithelial cess of the bronchial tree.Similar Clara cell-specific damage was observed in mice after a 6-hour exposure to 100 ppm TCE.A reduction in pulmonary enzyme activity was also observed. In an occupational study, a workerdeveloped labored breathing and respiratory edema after welding stainless steel that had beenwashed in TCE. This was attributed to inhalation of the decomposition products of TCE. However,he also had a history of smoking which may have predisposed the subject to these respiratory effects(ATSDR 1997, p. 12).

Another common health complaint described by former workers were heart problems. Cardiaceffects including tachycardia, ECG abnormalities, and arrhythmias have been reported in humansfollowing acute inhalation exposures to TCE. A number of deaths following acute inhalationexposure to TCE have been attributed to cardiac effects (ATSDR 1997, p. 167). A few case studiesof persons who died following acute occupational exposure to TCE have revealed cardiacarrhythmias to be the apparent cause of death. In animals, TCE is apparently responsible for thecardiac sensitization because chemicals that inhibit the metabolism of TCE increase its potency. Inone study, hypertension, enlarged, heart, and arrhythmia were seen in some workers accidentallyexposed to TCE at a level that was unspecified but at least 15 ppm. Sufficient human and animalinformation is available to identify the nervous system as the most sensitive target for the acuteeffects of TCE from inhalation.

Information from occupational studies on humans indicated that, while the nervous system may bethe most sensitive target of TCE exposure, other targets include the liver and kidneys. Short termexposures showed that working with TCE and its breakdown products have led to residualneuropathy, characterized by nerve damage particularly characterized by facial numbness, jawweakness, and facial discomfort (ATSDR 1997, p. 27). Other reported neurological effects ofchronic occupational exposure to unquantified TCE levels include memory loss, mood swings,trigeminal neuropathy, cranial nerve VII damage and decreased psychomotor function, impairedacoustic-motor function, and psychotic behavior with impaired cognitive function. A case study of aretired metal degreaser who had been exposed to between 1.5 and 32 ppm for 1-2 hours per day overa period of 20 years reported symptoms of headache, forgetfulness, vertigo, nausea, and loss offeeling in hands and feet persisting for 4 years after retirement(ATSDR 1997, p. 38). Othersymptoms of workers exposed to chronic long term exposures to TCE (between eight and 170milligrams per cubic meter (mg/m3)) for one to two hours per day over a period of 20 years reportedsymptoms of headaches, forgetfulness, vertigo, nausea, and loss of feeling in hands and feet(ATSDR 1997, p. 171). Human experimental studies revealed mild effects on motor coordination,visual perception, and cognition (ATSDR 1997, p. 138). The symptoms noted above were reportedby some of the former Unidynamics workers in the community survey.

A TCE registry has been established by ATSDR to monitor people in communities where exposurecould be verified and doses could be adequately estimated. The participants are interviewedregularly to collect important health data over their lifetimes to provide more understanding of theeffects of exposure to TCE. Thus far, data indicate excess numbers of heart disease and respiratorycancer deaths, as well as stroke, anemia, liver and kidney disease, and hearing and speechimpairment. The greatest limitation to these studies is the difficulty in estimating dose, and possibleexposure to multiple chemicals (ATSDR 1997, p.170).

The development of adverse health effects from exposure to TCE is "dose" and "situation"dependent. According to the ATSDR Toxicological Profile for TCE, a susceptible population willexhibit a different or enhanced response to TCE than will most persons exposed to the same level ofTCE in the environment. Reasons may include genetic makeup, age, health and nutritional status,and exposure to other toxic substances such as cigarette smoke. These factors may result in areduced detoxification or excretion of TCE, compromising the function of organs affected byTCE. In addition, people who consume alcohol or are treated with disulfiram may be at greater risk ofTCE poisoning because ethanol can inhibit the metabolism of TCE and cause it to accumulate in thebloodstream, increasing its potential effects on the nervous system. Compromised hepatic and renalfunction may place one at higher risk upon exposures to TCE or its metabolites since the liver servesas the primary site of TCE metabolism and the kidney as the major excretory organ for TCEmetabolites. Metabolism of TCE differs significantly between men and women (ATSDR 1997, p.161).

Although many of the self-reported symptoms reported by workers appear to be consistent with TCEexposures, the cause for such symptoms cannot be fully determined by this health survey. An in-depth study would be required to determine if an association between past exposures to TCE andpresent health problems could be identified. Since the exposures occurred in the past, and since thereare many factors that would interfere with the analysis, such a study would have many limitationspreventing a solid conclusion. In other words, based on the available data, there is no way todetermine if a worker's past exposure to the chemicals used at Unidynamics is the definite cause oftheir current health problems. Former workers, who are concerned about their exposures to thechemicals at the plant, are encouraged to speak with a doctor who is trained in occupationalexposures and to discuss their health status and previous exposures to chemicals for a more specific individual exposure assessment.

A summary that provides a description of additional studies conducted on occupational exposures toTCE and their results is provided in the Appendix, and also in the 1997ATSDR Toxicological Profile for TCE.

  • Does exposure to TCE cause cancer?

According to the ATSDR Toxicological Profile for TCE, tumors in the lungs, liver, and testes werefound in studies using high doses of TCE in rats and mice, providing evidence that high doses ofTCE can cause cancer in experimental animals. Based on the limited data in humans regardingTCE exposure and cancer, and evidence that high doses of TCE can cause cancer in animals, theInternational Agency for Research on Cancer (IARC) has determined that TCE is probablycarcinogenic to humans. In general, the associations drawn from the limited epidemiological data inhumans, as well as cancer studies in animals, are suggestive yet inconclusive. Based on theavailable data, cancer should be an effect of concern for people exposed to TCE in the environmentand at hazardous waste sites (ATSDR 1997, p.5, 153). In general, people with the greatest potentialfor exposure to TCE are those exposed in the workplace. Health effects from these exposuresdepend on many factors including sex, age, type and length of exposures to TCE, and concentrationsof TCE.

Three European studies have found slight but statistically significant increases in cancer in workersexposed to TCE. One such study showed that the combined incidence of stomach, liver, prostate,and lymphohematopoeitic cancers was increased among 2,050 male and 1,924 female Finnishworkers who were occupationally exposed primarily to TCE and other solvents. The workers wereexposed principally through inhalation, although there was some dermal contact. In a study ofSwedish workers who worked with TCE, a statistically significant increase in non-hodgkin'slymphoma was observed. However, these studies are limited by uncertainties in the exposure data,small sample sizes, and likely exposure to other chemicals (ATSDR 1997, p. 46, 96).

The ADHS survey showed that among the workers, skin cancer including melanoma was the mostprevalent cancer. This was followed with cases of lung cancer, non-hodgkin's lymphoma, malebreast cancer, and throat cancer. Other epidemiologic studies have examined the effect on workersfrom inhalation exposure to TCE. A significant increase in bladder cancer and lymphomas wasdetected in a cohort of 1,424 men with unspecified exposure to TCE. In another study, a significantrise was also discovered in the incidence of lung/bronchus/trachea, cervix, and skin cancers in morethan 330 deceased cleaning and/or laundry workers who worked with TCE.

  • Does exposure to TCE cause Lupus?

It is not known whether exposure to TCE can cause lupus. Systemic lupus erythematosus (SLE), commonly called lupus, is a chronic multisystem inflammatory disorder. The exact cause of lupus is unknown. In lupus, the body produces abnormal antibodies that react against the person's own tissues. Lupus can affect many organs of the body including the heart, lungs, kidneys, and central nervous system. The disease can look like many different illnesses; it may cause some rashes, arthritis, anemia, seizures, or psychiatric illness (American College 1992).

SLE is four times more common in African Americans compared with Caucasians in the UnitedStates. Hispanics and Asians have been reported to have higher rates than Caucasians. An elevatedprevalence of SLE has been found in North American Indians. However, this increased prevalencewas isolated to three of 75 American Indian tribes. A prevalence rate of 119 per 100,000 personswas reported in Sioux women (Fessel 1988).

  • Are learning disabilities and mental retardation caused by exposure to TCE?

According to the ATSDR Toxicological Profile for TCE, learning disabilities and mental retardation have not been associated with chronic exposure to TCE in the drinking water.

  • Several former workers stated that they had contacted the Occupational Safety andHealth Administration (OSHA) on several occasions and wanted to know if thoseinvestigations were on file.

Several former workers told stories of workers getting injured or killed in explosions, having severebreathing and eye problems from the chemical fumes in the plant, and dipping their arms in largeTCE vats to wash metal parts without the use of gloves or eye protection. According to somereports, safety precautions were not enforced or encouraged. There were descriptions of workerswho, after working with a toxic pink powder all day at work, would go home covered in the powderwhich would then get into the carpets, drapes, towels, clothes, and hair of their children and wouldnot wash out.

Some former workers stated that they contacted the Occupational Safety and Health administration(OSHA) on several occasions about the poor working conditions at the plant but for politicalreasons, they were not allowed to speak with OSHA representatives alone without their supervisors.They felt that this prevented OSHA from knowing about the poor safety conditions at the plantallowing for the continuation of more injuries on the job. Other workers stated they were afraid tosay anything because they would lose their jobs.

OSHA has one investigation on record that was conducted in 1989. They found poor electrical setups in the plant that were subsequently fixed. By law, OSHA is only able to address current existingproblems at work sites. The OSHA is unable to currently address past occupational complaints offormer Unidynamics workers particularly since the Unidynamics plant is now closed. According tothe OSHA, a complaint can be filed with them anonymously and it will be followed up especially ifmore than two people call in. The OSHA tries to provide anonymity for employees who file acomplaint by keeping their names, positions, and other employee identifying information unknownto the employer in question (OSHA 1999). The federal OSHA has a web site that reports theinvestigations that have been conducted at occupational facilities around the country.

5.4 ATSDR's Child Health Initiative

ATSDR's Child Health Initiative recognizes that the unique vulnerabilities of infants and childrendemand special emphasis in communities faced with contamination of their water, soil, air, or food.Children are at greater risk than adults from certain kinds of exposures to hazardous substancesemitted from waste sites and emergency events. They are more likely to be exposed because theyplay outdoors, they often bring food into contaminated areas, and the developing body systems ofchildren can sustain permanent damage if toxic exposures occur during critical growth stages.HBGLs used in this report are specifically protective of childhood exposure for adverse health effects.

There are four major issues that relate to children living near the PGA North site. They are as follows:

  • The level of the TCE and perchlorate in the water in the small irrigation canals is low enough that even if children play in it during the day, adverse health effects would not be expected.

  • The water in the holding pond has not been tested for TCE and perchlorate. Since it appears that the water from the small canals flow into the holding pond, it would be prudent to have the water tested. Trash around the holding pond and a chair indicates that children play around this area.

  • There are many physical hazards at the PGA North site along the smaller irrigation canals and the holding pond area. These include rusty broken metal pipes, large broken ragged cement pipes that children can crawl into, a large unprotected open well which a child could fall into, rusty piping around the Globe wells, rusted metal laying on the ground, and other physical hazards that could hurt children playing in the area. In addition, the underlying canal tunnels are completely open when the canals are dry. These tunnels leave areas where children could fall into and get hurt. Photographs that show some of the physical hazards in the area are included in the Appendix.

  • There were several reports of children having respiratory problems in the Goodyear area. As stated previously, the nature of the contamination on the PGA North site is such that it does not explain all the respiratory complaints. Various causes for these have been explained in this document. Residents are encouraged to contact the Air Quality Division at the Maricopa County Environmental Services Department or the Arizona Department of Environmental Quality (ADEQ) to find out detailed specific information regarding air quality in the West Valley, or to file complaints. Health questions related to air pollution in the area can be addressed at the ADHS, Office of Environmental Health.

In summary, there are many physical hazards in and around the irrigation canals that could pose ahealth threat to children who might play in the area. Since new housing developments are beingbuilt near these irrigation canal areas, it is important to secure these areas in such a way to prevent children from gaining access and getting hurt.

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