ML22271A837

Atsdr 2007 Public Health Assessment for Nuclear Fule Services, Inc. (Attachment to Appeal to Judge Hawkens Re Denial of Access to Sensitive Unclassified Non-Safeguards Information)

ML22271A837
Person / Time
Site:	Erwin
Issue date:	09/28/2022
From:	Nuclear Fuel Services, US Dept of Health & Human Services, Agency for Toxic Substances & Disease Registry (ATSDR)
To:	NRC/OGC
SECY RAS
References
70-143-LA, RAS 56458, TBD
Download: ML22271A837 (90)

Text

NUCLEAR FUEL SERVICES, INC.

ERWIN, UNICOI COUNTY, TENNESSEE EPA FACILITY ID: TND003095635 MAY 29, 2007 THE ATSDR PUBLIC HEALTH ASSESSMENT: A NOTE OF EXPLANATION

This Public Health Assessment was prepared by ATSDR pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) section 104 (i)(6) (42 U.S.C. 9604 (i)(6)), and in accordance with our implementing regulat ions (42 C.F.R. Part 90). In preparing this document, ATSDR has collected relevant health data, environmental data, and community h ealth concerns from the Environmental Protection Agency (EPA), state and local health and environmental agencies, the community, and potentially responsible parties, where appropriate.

In addition, this document has previously been provided to EPA and the affected states in an initial release, as required by CERCLA section 104 (i)(6)(H) for their information and review. The revised document was released for a 30-day public comment period.

Subsequent to the public comment period, ATSDR addressed all public comments and revised or appended the document as appropriat e.

The public health assessment has now been reissued. This concludes the public health assessment process for this site, unless additional information is obtained by ATSDR which, in the agencys opinion, indicates a need to revise or append the conclusions previousl y issued.

Agency for Toxic Substances & Disease Registry.................................................... Julie L. Gerberding, M.D., M.P.H., Administrator Howard Frumkin, M.D., Dr.P.H., Director

Division of Health Assessment and Consultati on...................................................................... W illiam Cibulas, Jr., Ph.D., Director Sharon Williams-Fleetwood, Ph.D., Deputy Director

Cooperative Agreement and Program Evaluation Branch.................................................................... Richard E. Gillig, M.C.P., Chief

Exposure Investigations and Site Assessment Branch.............................................................................. Susan M. Moore, M.S., Chief

Health Promotion and Community Involvement Branch........................................................................Susan J. Robinson, M.S., Chief

Site and Radiological Assessment Branch................................................................................................ Sandra G. Isaacs, B.S., Chief

Use of trade names is for identification only and does not constitute endorsement by the Public Health Service or the U.S. Department of Health and Human Services.

Additional copies of this report are available from:

National Technical Information Service, Springfield, Virginia (703) 605-6000

You May Contact ATSDR Toll Free at 1-800-CDC-INFO or Visit our Home Page at: http://www.atsdr.cdc.gov Nuclear Fuel Services, Inc. Final Release

PUBLIC HEALTH ASSESSMENT

NUCLEAR FUEL SERVICES, INC.

ERWIN, UNICOI COUNTY, TENNESSEE

EPA FACILITY ID: TND003095635

Prepared by:

Site and Radiological Assessment Branch Division of Health Assessment and Consultation Agency for Toxic Substances and Disease Registry FOREWORD

The Agency for Toxic Substances and Disease Registry, ATSDR, is an agency of the U.S. Public Health Service. It was established by Congress in 1980 under the Comprehensive Environmental Response, Compensation, and Liability Act, also known as the Superfund law. This law set up a fund to identify and clean up our country's hazardous waste sites. The Environmental Protection Agency, EPA, and the individual states regulate the investigation and clean up of the sites.

Since 1986, ATSDR has been required by law to conduct a public health assessment at each of the sites on the EPA National Priorities List. The aim of these evaluations is to find out if people are being exposed to hazardous substances and, if so, whether that exposure is harmful and should be stopped or reduced. (The legal definition of a health assessment is included on the inside front cover.) If appropriate, ATSDR also conducts public health assessments when petitioned by concerned individuals. Public health assessments are carried out by environmental and health scientists from ATSDR and from the states with which ATSDR has cooperative agreements.

Exposure: As the first step in the evaluation, ATSDR scientists review environmental data to see how much contamination is at a site, where it is, and how people might come into contact with it. Generally, ATSDR does not collect its own environmental sampling data but reviews information provided by EPA, other government agencies, businesses, and the public. When there is not enough environmental information available, the report will indicate what further sampling data is needed.

Health Effects: If the review of the environmental data shows that people have or could come into contact with hazardous substances, ATSDR scientists then evaluate whether or not there will be any harmful effects from these exposures. The report focuses on public health, or the health impact on the community as a whole, rather than on individual risks. Again, ATSDR generally makes use of existing scientific information, which can include the results of medical, toxicologic and epidemiologic studies and the data collected in disease registries. The science of environmental health is still developing, and sometimes scientific info rmation on the health effects of certain substances is not available. When this is so, the report will suggest what further research studies are needed.

==

Conclusions:==

The report presents conclusi ons about the level of health threat, if any, posed by a site and recommends ways to stop or reduce exposure in its public health action plan. ATSDR is primarily an advisory agency, so usually these reports identify what actions are appropriate to be undertaken by EPA, other responsible parties, or the research or education divisions of ATSDR.

However, if there is an urgent health threat, ATSDR can issue a public health advisory warning people of the danger. ATSDR can also authorize health education or pilot studies of health effects, full-scale epidemiology studies, disease registries, surveillance studies or research on specific hazardous substances.

Interactive Process: The health assessment is an interactive process. ATSDR solicits and evaluates information from numerous city, state and federal agencies, the companies responsible for cleaning up the site, and the community. It then shares its conclusions with them. Agencies are asked to respond to an early version of the report to make sure that the data they have provided is accurate and current. When informed of ATSDR's conclusions and recommendations, sometimes the agencies will begin to act on them before the final release of the report.

Community: ATSDR also needs to learn what people in the area know about the site and what concerns they may have about its impact on their health. Consequently, throughout the evaluation process, ATSDR actively gathers information and comments from the people who live or work near a site, including residents of the area, civic leaders, health professionals and community groups. To ensure that the report responds to the community's health concerns, an early version is also distributed to the public for their comments. All the comments received from the public are responded to in the final version of the report.

Comments: If, after reading this report, you have que stions or comments, we encourage you to send them to us.

Letters should be addressed as follows:

Attention:

Manager, ATSDR Records Center Agency for Toxic Substances and Disease Registry 1600 Clifton Road (E-60)

Atlanta, GA 30333 Table of Contents Background......................................................................................................................................1 Site Description and History........................................................................................................1 Site Visit......................................................................................................................................5 Demographics, Land Use, and Natural Resource Use.................................................................5 Health Outcome Data...................................................................................................................8 Community and Petitioner Health Concerns.................................................................................11 Table 1. Contaminant concentrations in on-site wells...................................................................15 Table 2: Contaminant concentrations in off site groundwater; 3 year average*...........................17 Table 3. Contaminant concentrations in off-site monitoring wells in 1997*................................18 Child Health Considerations..........................................................................................................24 Conclusions....................................................................................................................................24 Recommendations..........................................................................................................................25 Public Health Action Plan..............................................................................................................26 Author............................................................................................................................................26 Appendix A....................................................................................................................................29 ATSDR Response to Public Concerns.......................................................................................29 Appendix B....................................................................................................................................42 Response to Community Comments: Public Comment Release...............................................42

Table of Figures

Figure 1. NFS site location................................................................................................. 4 Figure 2. Demographic distribution around the NFS facility............................................. 6 Figure 3. Railroad Well capture zone analysis for 1000 gpm........................................... 10 Figure 4. On-site and off-site monitoring well locations.................................................. 14 Figure 5. Off site contamination, March 2000.................................................................. 19 Figure 6. Off site contamination, March 2001.................................................................. 20 Figure 7. Potential Exposure Pathways............................................................................ 22

iii Summary The Agency for Toxic Substances and Disease Registry (ATSDR) received a petition from an individual (the petitioner) to evaluate the Nuclear Fuel Services, Inc. (NFS) site for inclusion on the Superfund list. The concerns listed by the petitioner include contamination of groundwater with volatile organic compounds (VOCs) and the use of radioactive materials. Other concerns included cancer rates in the community and concern for the contamination of the Nolichucky River and releases to the air from plant operations. The petitioner also raises issues related to the NFS history of operational violations.

This public health assessment will only address th e concerns raised regarding the presence of volatile organic compounds. The concerns regardi ng radioactive materials will not be addressed as explained in the following paragraph.

ATSDR Legislative Authority ATSDR derives its authority to a ddress environmental contaminant issues at this site from the Comprehensive Environmental Response, Comp ensation, and Liability Act (CERCLA) as codified at 42 USC 9601 within the United States Code. However, CERCLA excludes any releases of specific radioactive materials that are considered sour ce, byproduct, or special nuclear material (42 USC 9601(22)). Therefore, those portions of the petition request concerning the use, releases, or potential releases of various types of nuclear materials can not be addressed by ATSDR. ATSDR is investigating other avenues by which the petitioners concerns for the nuclear and radiological issues can be addresse d. ATSDR will address the releases of volatile organic compounds to the air, surface water, and groundwater as well as the presence of uranium and other naturally occurring radioactive materials in the groundwater.

Background

Site Description and History Nuclear Fuel Services, Inc. (NFS) operational history began in 1957 in Erwin, Tennessee.

Initially, the facility was operated as the Davison Chemical Division of W.R. Grace Co. prior to being renamed as NFS (1).

Erwin is a town of about 6,000 people located in Unicoi County about 15 miles south of Johnson City and 120 miles northeast of Knoxville. Unicoi County covers about 200 square miles in northeast Tennessee and has a population of about 20,000. The area surrounding Erwin is mostly within the Cherokee National Forest.

The land area of NFS, itself, covers approximately 64 acres in the southern part of Erwin. The site is bordered by Interstate 26, the Riverview Industrial Site, and property belonging to the CSX Railroad, both to the west. Interstate 26 lies north of the facility and the Love Chapel Elementary School is about 1 mile south of the site. NFS sits about 30 feet above the Nolichucky River that runs by Interstate 26; whereas, the mountains rise to about 5,000 feet a few miles from the site.

1 The town of Erwin and surrounding areas include residential, commercial, industrial, and farming areas. The site is underlain by unconsolidated alluvium at various depths consisting of silts and clays, clayey sand, and sand with varying amounts of gravel and cobble. The alluvium coarsens with depth into cobbles and boulders. Alluvium is sediment such as a riverbed deposited by flowing water. This cobble/boulder zone overlies weathered, fractured bedrock consisting of steeply sloping beds of shale or shale interbedded with dolomite and siltstone (2).

One of the primary activities of NFSs Erwin Plan t is to prepare high-enriched uranium to be processed into fuel for the Department of Ener gy's Naval Reactor Program. The US Department of Energy supplies the uranium processed at NFS for this and other purpo ses. Other activities performed at this facility include the processing of high-enriched uranium scrap to recover the uranium, laboratory operations for manufacturing support and new development, and waste treatment and packaging for shipment. NFS also performs commercial work for the private sector and leases space to the private sector at their facility. These activities include cleaning of uranium hexafluoride cylinders and downblending of high-enriched uranium and converting it to low-enriched uranium compounds (BLEU) to be used in the commercial sector. Other site activities include, or once included, converting uranium hexafluoride to either uranium oxides, uranium tetrafluoride, and/or metallic uranium. NFS also in the past manufactured reactor fuel materials composed of either uranium or thorium, and recovery of these isotopes, production of thorium metals, and production of mixed oxide fuels containing uranium.

NFS currently is regulated for environmental corrective action and decommissioning activities by the US Nuclear Regulatory Commission (NRC), the state, and the US Environmental Protection Agency (EPA). The facility is a licensee of the NRC and a permitted EPA Resource Conservation and Recovery Act (RCRA) facility. As such, the facility must establish a system for controlling hazardous waste from its generation until its ultimate disposal. NFS is an active facility and CERCLA regulations do not necessarily apply as the law specifically excludes any releases from the nuclear fuel operations. These nuclear releases are under regulatory authority of the NRC and the hazardous waste and hazardous waste constituents are regulated by the EPA and the State of Tennessee.

Under regulatory oversight by the NRC, NFS is in the process of decommissioning on a project-by-project basis. This includes the former pond area in the unused northern portion of the site or areas and buildings in need of decontamination to protect the environment, in accordance with NRC, EPA, Tennessee Department of Environment and Conservation (TDEC), and all applicable federal and state regulations. Decommissioning is the process converting a nuclear facility to a condition that is safe to public health and safety or the environment. The decommissioning activities at NFS include removal of contaminated soils, sediments, debris, and disassembly of equipment and buildings. The wastes generated are recycled when possible or are containerized and then transported to EPA and NRC approved radioactive waste burial grounds in other states.

The site also generates low-le vel radiological waste generated from laboratory processes and trash. This waste also contains elemental mercury used during analytical testing of its products.

This results in the generation of mixed wastes which are regulated both by the NRC and the EPA as well as the state. The laboratory trash consists generally of paper, gloves, and discarded laboratory equipment. EPA documentation states that the analytical procedure is necessary to confirm that the sample of NFS product meets applicable customer quality standards. The nature of the product and specifics regarding the analysis are considered Confidential Restricted Data

2 per the United States Department of Energy as it is related to national defense and security. The mercury is recycled as much as possible during the analytical procedure to limit the amount of mixed mercury waste generated.

NFS also operates an outdoor firing range is in nearby Jonesborough, Tennessee for training and maintaining proficiency of its security forces. The range is in residentia l area and adjacent to a business.

In the early history of NFS, several processes required the use of degreasing agents containing volatile organic compounds (VOCs)1 such as tetrachloroethylene (PCE). Since the 1970s, NFS reportedly stopped the use of VOCs in their processes although during its use, a large amount of VOCs were released to the environment via either spills (such as in the maintenance areas) or venting. Per applicable laws and permits in effect at the time, NFS also released radioactive materials into the waste holding areas, th e on-site ponds which ultimately reached the Nolichucky River. In 1991, NFS began partial remediation of the site. These activities included removing the sludges from Ponds 1, 2, and 3, and removal of accessible waste in the Pond 4 area.

The wastes identified in Pond 4 groundwater inflowing prior to this remediation included VOCs, tributyl phosphate, and pthalates (3). The removal was and continues to be under authorization from the NRC, EPA, and the state. Excavation of the low-level waste burial area began in 1997.

In 1992-1993, a RCRA permit was jointly issued to NFS by EPA and the state for the operation of a mixed waste storage area. Additionally, this RCRA permit required the systematic investigation of releases of hazardous wastes constituents to the environment and the subsequent correction action and cleanup.

1 In this document the term volatile organic compound, VOC, refers only to perchloroethylene (PCE) and its breakdown products produced in the environment.

3 Figure 1. NFS site location.

4 In September 1996, pursuant to the RCRA permit investigations, the US EPA Region IV concluded that there was a plausible pathway for human exposure to the PCE plume in groundwater, but there was no current exposure. A pump and treat system was installed and operated to remediate the contaminant plume and prevent further migration.

In 2000, as part of a RCRA Corrective Measures Study, NFS developed a pilot study to enhance the anaerobic degradation of the VOCs contaminating the groundwater as this would accelerate the remediation. The field pilot study involved the injection of a molasses carbon source into the groundwater. As a carbon source, the molasses stimulates the naturally occurring bacteria in the groundwater to more efficiently degrade the VOCs. Besides reducing the concentration of VOCs, the system also immobilizes uranium migration by converting the uranium to an insoluble precipitate in the groundwater using a patented technology (4).

Current activities on the site include the proce ssing of nuclear fuel products and the chemical conversion of these materials with the potential for production of ammonia gases or other nitrogen containing compounds.

NFS has had numerous NRC violations resulting from poor documentation of chain of custody and location of special nuclear material. None of these violations was for actual loss of material, but for a lack of accounting for where quantities of material were moved within the facility.

Site Visit In February 2006, representatives from ATSDR traveled to Erwin to meet with representatives from NFS, local officials, state and federal (NRC and EPA) regulators, the Tennessee Department of Health representative, a local plastics company in the industrial park downgradient from the site, and members of the public. During this visit, ATSDR collected community concerns. These concerns include releases of radioactive materials, safety issues, and emergency response and notification of the surrounding area. ATSDR also placed public announcements in local media outlets advertising the meetings and methods whereby community concerns could be relayed to ATSDR.

Demographics, Land Use, and Natural Resource Use In the 2000 census, Unicoi Countys populati on was 17,667 of which 51.2% were female. Its racial makeup was 98% white and 1.9% Hispanic or Latino. The average household size was 2.3 individuals. The population of Erwin was 5,610 with 53.7% of the population female. The racial composition was 97.8% white with 125 individuals of other racial backgrounds as defined by the US Census Bureau. Furthermore, 97.3% of the Erwin population lived in 1559 single family households with an average family of 2.2 individuals. Those between the ages of 18 and 65 numbered 4,503 with 299 below the age of 5 and the remaining population, 1283, 65 years of age or older (5). The population within a one mile radius of NFS was estimated to be 2,638 consisting of 186 children under the age of 6 and 472 females between the ages of 15 and 44, child-bearing age (Figure 2).

5 Figure 2. Demographic distribution around the NFS facility

6 Within the vicinity of NFS lie three bodies of surface water--Banner Spring Branch, Martin Creek, and the Nolichucky River. Banner Spring Branch is completely contained within the NFS property boundary and is thought to arise from fracture flow originating in the surrounding mountains. Banner Spring flows toward the north and west ultimately flowing into Martin Branch at the northwest corner of the site. At one time Banner Spring Branch flowed through the site but NFS diverted and channelized the spring. Now it follows the site boundary prior to emptying into Martin Creek. Prior to the channelization of Banner Spring Branch, the land was marshy and NFS constructed holding ponds in this area (1). Martin Creek forms in the Unaka Mountains southeast of Erwin, flows into North Indian Creek which enters the Nolichucky River about 1.5 miles north of NFS. The flow rates of these creeks range from 300 to 5,000 gallons per minute.

The state of Tennessee Wildlife Resources Agency, Fisheries Management Division maintains a state fish hatchery specializing in both rainbow trout and brown trout within a mile northeast of NFS. It has 14 outdoor concrete raceways, a hatchery building, and a managers residence. The facilitys water supply consists of about 30 artesian wells that are hydrologically upgradient from the NFS operations. The source of the artesian well water is thought to be produced by the down gradient flow of groundwater associated with the surrounding mountains. This same flow may form the Banner Spring Branch.

The Nolichucky River is a major river draining the Blue Ridge Mountains of western North Carolina and upper East Tennessee and is considered a receiving stream for surface water runoff.

The river enters Unicoi County, Tennessee, flowing through ranges known locally as the Bald Mountains and the Unaka Mountains. The flow rate of the river averages about 14,000 gallons per minute at Embreeville about 8 miles up river from the facility. The Nolichucky River ultimately flows into the French Broad River that merges with the Holston River, forming the Tennessee River outside of Knoxville, Tennessee. The majority (64%) of the Nolichucky River watershed is in Tennessee with the remainder in North Carolina. Many of the streams in the watershed are impaired by silt accumulation and livestock grazing (6).

The City of Erwin obtains its drinking water from both springs and wells; 6 public supply wells are within 5 miles of NFS. The closest well, the Railroad Well, however, is about 3500 feet northeast of NFS and hydrological tests indicate that this well does not draw from beneath the NFS nor from areas downgradient of the facility. NFS reports that there are no private wells between their operation and the river (7). Furt hermore, Erwin Utilities informed ATSDR that they are aware of only one private well in Erwin and that well is both upgradient and uphill from NFS.

The geology underlying the area consists of bedrock formations and karst features. Karst geology has been defined as areas where chemical dissolution has enlarged joints, fractures, bedding planes, or other openings in soluble, underlying bedrock; karst is also characterized by sinkholes, caves, and disappearing streams (8).

The geology consists of 3 limestone (dolomite) formations and a formation consisting of sandstones, siltstones, shale, limestone, and othe r dolomitic species of rock. The bedrock is also covered with deep soils and alluvium which is made up of a variety of materials, including fine particles of silt and clay and larger particles of sand and gravel (12). The depth of the alluvium ranges from 6 to 15 feet with cobbles and boulders at the deeper depths. Below the alluvium lies

7 tilted beds of shale that are fractured so groundwater flow is directed downward until solid bedrock is reached. Although the groundwater is replenished mostly from rain and surface waters, there is some upward flow as a result of the surrounding groundwater flow down the mountains with their fractured geological formations (9,11).

Groundwater under NFS and immediately downgradient is not used as a supply either to NFS or other industrial activities associated with the industrial park. In general the groundwater is moving toward the river as discussed in the groundwater model report released in 1997.

Furthermore, it appears that the upward gradient from the bedrock aquifer would limit the downward migration of the contaminants.

The nearest well is to the north of the site and upgradient (Railroad Well) and hydrological tests indicate that this well is not affected by draw down from water withdrawn beneath the NFS (Figure 3) (9, 10). The groundwater typically flows toward the north-northwest (7). Other water features include ephemeral springs that rapidly appear following local rains that average about 45 inches per year. The US Geological Survey estimates that about 22% of the rain recharges the groundwater in the area. An environmental indicator assessment states that groundwater beneath NFS enters the backwater area of the river via an upflow (11).

Meteorological information for the Erwin area was obtained from documentation prepared for the Nuclear Regulatory Commission (12). The typical wind direction at the facility follows the valley topography in a southwest to northeast direction with an average wind speed of less than 8 miles per hour during daylight. Typically, the wind direction reverses directions during the evening hours. This reversal is related to unequal land heating and the presence of the mountains in the area.

Health Outcome Data Typically, health outcome data consist of information derived from databases such as morbidity/mortality data, cancer incidence, birth defects data or any site-specific community health records and/or health studies. Health outcome data can provide information on various aspects of the health of people living around site. It may reveal whether people living or working near a site are experiencing adverse health effect s at a rate higher than would be expected to occur. Health outcome data can constitute a key source of information for conducting public health assessments. However, site-specific health outcome data are rarely available or of sufficient or adequate quality to enable linking health outcomes with site-related exposures; health outcome data will not prove a cause or an effect. Discussions were held with representatives of the Tennessee Department of Health, Johnson City office, and from the East Tennessee State University in Johnson City. The state has limited reliable health data for this area of Tennessee.

The state of Tennessee is in the process of improving its cancer registry; however, the existing registry is neither certified by th e North American Association of Central Cancer Registries, Inc.

(NAACCR) nor the CDC2. Other registries, such as morbidity, mortality, birth defects, and other disease registries are not available for the state of Tenne ssee. NAACCR is a professional organization that develops and promotes unifo rm data standards for cancer registration;

2 Information from the CDC NPCR program at http://www.cdc.g ov/cancer/npcr/naaccr.htm and accessed on April 27, 2007.

8 provides education and training; certifies population-based regist ries; aggregates and publishes data from central cancer registries; and promotes the use of cancer surveillance data and systems for cancer control and epidemiologic research, public health programs, and patient care to reduce the burden of cancer in North America. NAACR fu rther states that one of the fundamental necessities of cancer surveillance is for users of cancer information to be assured that case definitions, coding practices, and conversions of medical terminology to useful categories is standardized. This enables compilation of case-specific information into useful and meaningful registers. It also enables meaningful comp arison of data across different registries. 3 The CDC has maintained a National Program of Cancer Registries since 1994. The program develops data sets for member states (including Tennessee). However, as the Tennessee Cancer Registry is not certified as discussed above, the expanded dataset for the state is not included.

The program web site can be accessed via the internet at the following address http://www.cdc.gov/cancer/npcr/datarelease.htm (accessed on April 27, 2007).

3 Information from the NAACCR web site, http://www.naaccr.org/ accessed on April 27, 2007.

9 Figure 3. Railroad Well capture zone analysis for 1000 gpm.

10 Community and Petitioner Health Concerns Based on information received from the petitioner, the major community concern is cancer with 36 cancers reported in a self-administered survey in the area bor dering the facility. The other concerns raised by the petitioner include degradation of the air and quality, and the perceived lack of environmental monitoring of these two potential pathways. ATSDR received additional public health concerns at two public meetings held in Erwin in February and August 2006. These concerns and the ATSDR response are included in Appendix A.

Concerns of the petitioner and the community related to the nuclear operations at the site were forwarded to the appropriate federal agency, the Nuclear Regulatory Commission (NRC).

ATSDR met with the NRC to discuss these concerns.

Environmental Contaminati on and Other Hazards The Comprehensive Environmental Response, Co mpensation, and Liability Act (CERCLA) as codified at 42 USC 9601 within the United States Code gives the legislative authority to ATSDR to evaluate releases from hazardous waste sites. CERCLA further defines a release in many ways such as a spill, leak, emptying, discharge, leaching, dumping, or disposing of hazardous material in an uncontrolled manner. However, CERCLA also excludes any releases of specific radioactive materials that are considered source, byproduct, or special nuclear material (42 USC 9601(22)).

By definition, source material is uranium and/or thorium in any physical or chemical form that contain by weight 1/20 of one percent (0.05 percent) or more of these elements. Source material does not include special nuclear material (SNM). SNM is material containing among other radionuclides, enriched uranium or plutonium. By-product material is any material made radioactive following exposure to SNM or the waste associated with ore processing.

ATSDR receives it authority to address hazardous releases from the CERCLA; therefore, those portions of the petition request concerning releases or potential releases of various types of nuclear materials can not be addressed by this public health assessment nor by ATSDR. ATSDR is investigating other avenues by which the petitioner concerns for the nuclear and radiological issues can be addressed. ATSDR will address the releases of volatile organic compounds to the air, surface water, and groundwater.

NFS conducted a remedial alternatives analysis (RAA) to select an appropriate technology for controlling and/or remediating groundwater. The RAA identified enhanced anaerobic bioremediation and reductive precipitation (EABRP) as the selected technology that would best remove the organic contaminants from the groundwater. This technology involves enhancing the natural biological degradation of the PCE and its degradation products. The system works by supplying an additional organic carbon source (molasses) as an energy substrate to the naturally occurring bacteria within the groundwater system. The molasses accelerates oxygen depletion in the water that is conducive to the degradation of the PCE through the removal of chlorine atoms (reductive dechlorination), replacing them with hydrogen atoms. NFS also adds ferrous sulfate that precipitates the soluble uranium as insolubl e precipitate, thus immobilizing any uranium in the water.

11 On-Site Contamination The Nuclear Fuel Services site was not required to perform environmental sampling for non radioactive materials for many years. These non-nuclear materials included organic and inorganic chemicals and metals. ATSDR, however, reviewed quarterly and annual RCRA Facility Investigation and Interim Measures Progress Reports submitted to the regulatory authorities for the years 1997 through 2004. Other documents reviewed included water sampling data for the Nolichucky River for the years 1993 through 2004 and National Pollution Discharge Elimination System (NPDES) reports coveri ng the 1999 through 2004 time frame. Not all the reports reviewed are referenced in this public health assessment; however, the data reported in this public health assessment covers the three year period 2002, 2003, and 2004.

Prior to 1984, NFS disposed of various materials on their property as allowed by the laws in effect at that time. The disposal areas included landfills, ponds, and other types of impoundments such as trenches. To enable proper site assessment and site remediation, EPA initially divided the waste operations into 23 solid waste management units (SWMUs) and 7 areas of concern (AOC).

Based on analyses of the SWMUs as required by the RCRA permit, 11 required no additional actions, 5 units are under institutional controls with the remaining SWMU requiring interim measures to alleviate waste issues. The AOC remedial activities included 4 areas under institutional control, 2 areas requiring either interim actions or remediation, and the remaining AOC, required no further action.

In 2005, planned activities for the SWMU and AOC locations included soil removal and confirmatory sampling, quarterly and annual inspections, groundwater remediation and related activities including pilot testing, installation of tanks to assist in the groundwater remediation, and additional sampling of surface water and sediments in the Nolichucky River (7).

Releases from NFS have contaminated the gr oundwater beneath the facility. An extensive monitoring program identified PCE, TCE, cis-1,2 DCE, vinyl chloride, and uranium in the water beneath the plant that flows toward the river. NFS installed a series of monitoring wells within their operational boundaries and another 21 monitoring wells off-site. Many of the well locations are depicted in Figure 4. In 1997, the NFS groundwater monitoring program consisted of sampling approximately 54 monitoring wells. The programs purpose was regulatory in design and helped to further define areas of groundwater contamination as well as its movements.

Groundwater contamination is mostly associated with the former pond areas (SWMU 1, 2),

underground storage tanks (SWMU 18), Building 130 Scale Pit (SWMU 20), and the radiological waste burial grounds (SWMU 9) (9). According to the Environmental Indicator assessments (13, 14, 15), the plume in 1996-2004 co vered an area of approximately 13 acres (600 feet by 900 feet) in the northernmost portion of the facility and extended an additional 5 to 8 acres off the NFS property toward the Nolichucky River. The contaminants in the on-site plume included PCE, TCE, cis-1,2 DCE, vinyl chloride, and uranium; whereas, the off-site plume contains PCE, TCE, cis-1,2 DCE and vinyl chloride.

From these monitoring wells, NFS reported the c oncentrations of the contaminants in the groundwater within the facility boundary. The results of the onsite sampling, shown in Table 1, indicated that the average concentration of PCE was 1.7 milligrams per liter (mg/L) with the maximum measured concentration of 8.4 mg/L. The maximum concentrations of the PCE degradation products ranged from 1.6 mg/L for dichloroethylene to 0.01 mg/L for trichloroethylene and vinyl chloride. These results are also given in Table 1.

12 Monitoring data for the groundwater plume in 2002, indicated that the maximum concentration of PCE in the alluvial aquiver exceeded 13,000 micrograms per liter (µg/L) and extended beyond the west boundary of the facility toward the industrial park. According to the EPA, the apparent source of the PCE plume is one of the maintenance shop areas within the NFS fence line.

Environmental sampling and analyses of groundwater collected during RCRA activities indicated the presence of uranium, PCE, and its degradation products in the groundwater beneath the NFS facility. The uranium plume was about 0.7 acre (250' by 120') and exceeded the EPA Maximum Contaminant Level (MCL; 30 micrograms per liter; µg/L). Uranium concentration in the groundwater plume ranged from approximate ly 30 to 1,100 pCi/L. The area of the PCE groundwater plume exceeding the National Drinking Water Maximum Contaminant Level (MCL

= 0.005 mg/L) was approximately 19 acres (1200 ft by 700 ft). PCE concentrations in this plume ranged from approximately 0.005 milligrams per liter (mg/L) to 14 mg/L. Associated PCE degradation product concentrations are also present in portions of the PCE groundwater plume (15). The EPA also has a Maximum Contaminant Level Goal (MCLG) that is not enforceable and the MCLG for the contaminants is zero.

13 Figure 4. On-site and off-site monitoring well locations

14 Table 1. Contaminant concentrations in on-site wells Well Number PCE TCE DCE Vinyl Tributyl Chloride phosphate 71 0.021 0.011 1.324 0.728 18.43 72 0.585 0.115 0.507 0.07 6.21 93 0.005 0.09 1.665 0.515 81 94 0.03 0.005 0.005 0.01 0.01 108a 4.8 0.005 0.005 0.01 0.55 109a 0.34 0.077 0.22 0.03 0.01 111a 8.4 0.005 0.6 0.01 0.01 112a 0.099 0.013 0.01 0.01 0.01 114a 0.009 0.005 0.005 0.01 0.01 114b 0.92 0.073 0.059 0.01 0.01 28 1.27 0.157 0.433 0.101 0.07 102a 0.944 0.028 0.029 0.006 0.02 103a 4.956 0.223 0.401 0.021 0.02

average 1.721 0.062 0.405 0.118 8.182 geometric 0.027 0.095 0.029 0.103 mean 0.294

MCL 0.005 0.005 0.07 0.002 --

• values expressed as milligrams per liter; data from the Groundwater risk assessment at Nuclear Fuel Services, Inc.

and adjacent industrial park site (9)

The geometric mean represents the central tendency of a distribution if the numbers do not appear to be evenly distributed.

MCL - maximum contaminant level, a legally enforceable concentration of contaminants in drinking water.

Off-Site Contamination Monitoring of organic contaminants outside the property boundary of NFS has been very limited.

RCRA reports indicate there are 9 monitoring wells outside the fence line and west of the railroad property. Of these wells, Well 120 lies inside the boundary of the Riverview Industrial Park. The other wells, 116 through 118, are either outside the industrial park or between the park and NFS (Figure 4).

The sampling results have been reported in numerous RCRA Facility Investigation reports from the EPA. In 2002, a private engineering and environmental services company was hired by a facility in the industrial park to sample the monitoring well installed by NFS outside their boundaries and within the industrial park area.

The private company's results indicated the presence of volatile organic compounds as well as the presence of radioactive materials in the groundwater obtained from the industrial park. Table 2 shows the results of the sampling in these off-site wells and the Maximum Concentration Level (MCL) for these contaminants. The MCL is the federal limit for contaminants in drinking water.

EPA has also established a goal for these contaminants in drinking water, the Maximum Contaminant Goal Level (MCGL) and that value is set at zero (0). Table 3 gives the 3 year

15 averages in these wells. During the sampling and monitoring effort in 2000, the extent of the groundwater plume was mapped with the results shown in Figure 5. At that time, the maximum concentration of PCE was 13 mg/L and the lowest concentration found was below the MCL for this contaminant and below the analytical limits of detection.

Within a year of the 2000 sampling round and following the bioremediation with molasses and iron, the plume had expanded as expected. However, the maximum contamination of PCE in the monitoring wells decreased, the maximum detected concentration was greater than 5 mg/L beneath the CSX property; the lowest concentration detected was less than 0.1 mg/L, was below the MCL for this contaminant and below the analytical limits of detection (Figure 6).

The naturally occurring radioactive elements uranium and thorium were detected in wells below the MCL for these contaminants. Other radioactive materials detected included technetium-99 and various plutonium isotopes. The technetium-99 was below the MCL for that radionuclide, as was the plutonium.

Releases to the atmosphere from NFS were not reported in any documentation supplied to ATSDR from the state or EPA. However, the EPA Toxic Release Inventory (TRI) database contains release information on over 500 chemicals or chemical categories from industrial processes. NFS reports their total chemical releases to the TRI system; however, neither uranium nor plutonium are required to be included in the TRI list of re ported chemicals. Furthermore, concentrations are not reported, only the total amounts of materials released are given. The TRI data are available from the EPA on their internet site at the following web address:

http://www.epa.gov/tri/tridata/tri04/index.htm#what (accessed on April 27, 2007).

The TRI data reported for 2004 indicates that NFS released 103 pounds of nitrates and nitrogen compounds to the air, 25,620 pounds to surface waters, and 4,050 pounds were sent to EPA approved landfills. NFS does not perform environmental air sampling for non-radiological materials as this is not require d by the EPA for their operations.

ATSDR received data from the Tennessee Department of Environment and Conservation on annual sampling of the Erwin Utilities Railroad Well located north of the site. The well was sampled for both regulated and unregulated volatile organic compounds. Chloroform was detected at 0.00114 milligrams per liter (mg/L) and 0.00151 mg/L in 2006 and 2007, respectively. There is no established MCL for this unregulated contaminant. For regulated contaminants, tetrachloroethylene (PCE) was detected at 0.000856 mg/L and 0.00158 mg/L in 2006 and 2007, respectively. The established MCL for this contaminant is 0.005 mg/L. No other volatile organic compounds were detected in the Railroad Well.

16 Table 2: Contaminant concentrations in off site groundwater; 3 year average*

Contaminant and Quarter 1 Quarter 2 Quarter 3 Quarter 4 3 year MCL average average average average Average mg/L mg/L mg/L mg/L mg/L Tetrachloroethylene 0.479 0.413 0.455 0.005 mg/L 0.442 0.484 Trichloroethylene 0.019 0.017 0.019 0.005 mg/L 0.02 0.019 Cis 1,2 dichloroethylene 0.032 0.027 0.024 0.048 0.033 0.07 mg/L Trans 1,2 dichloroethylene 0.013 0.009 0.008 0.009 0.010 0.1 mg/L Vinyl Chloride 0.017 0.015 0.018 0.017 0.002 mg/L 0.019

• data expressed in milligrams per liter of water; data derived from USEPA RCRA Facilities Investigation reports covering 2002, 2003, and 2004 for off-site monitoring wells Maximum Contaminant Level - legally enforceable concentration allowed in public drinking water

Physical and Other Hazards No physical hazards to the public were observed at the site as the site has a physical security force to limit any trespassing. Worker safety and health is addressed by the sites health and safety plan associated with regulatory oversight by both the Nuclear Regulatory Commission and the Tennessee Occupational Safety and Health Administration.

No noticeable odors were detected during the site visit and facility tour which included portions of the blending facility.

Other hazards associated with the site are the presence of hazardous chemicals and radioactive materials, heavy equipment used in the ongoing remediation work and in normal plant operations.

17 Table 3. Contaminant concentrations in off-site monitoring wells in 1997*

Tetrachloro Trichloro Cis 1,2 Trans 1,2 Vinyl Well Number ethylene ethylene dichloroethylene dichloroethylene Chloride (mg/L) (mg/L) (mg/L) (mg/L) (mg/L)

116a 0.48 ND ND ND ND

116b 2.4 0.091 0.11 ND ND

117a 0.15 ND ND ND ND

117b 0.5 ND ND ND ND

118a ND 0.005 0.003 ND ND

118b ND 0.011 0.007 ND 0.0002

119a 0.13 0.011 0.003 ND ND

120a 0.29 0.016 0.012 ND ND

120b 0.46 0.018 0.014 ND ND

121a 0.062 0.005 0.003 ND ND

121b 0.097 0.005 0.003 ND ND

Average 0.416 0.022 0.022 ND ND

MCL 0.005 0.005 0.07 0.01 0.002

• Data from Nuclear Fuel Services (1997).

18 Figure 5. Off site contamination, March 2000

19 Figure 6. Off site contamination, March 2001

Pathways Analysis An environmental exposure pathway consists of five elements:

(1) a source of contamination; (2) an environmen tal medium in which the contaminants may be present or into which it may migrate; (3) points of human exposure; (4) routes of human exposure, such as inhalation, ingestion or dermal absorption; and (5) a receptor population. A completed exposure pathway exists in the past, present, or future if all five of the elements of an exposure pathway link the contaminant source to a receptor population. A potential exposure pathway exists if there is insufficient data for one or more of the five elements linking the source of the contamination to the receptor population or if modeling replaces sampling data. A pathway can be eliminated if one or more of the five elements do not exist or the pathway is unlikely to occur. A future completed exposure pathway occurs when the contamination at a point of exposure exists and that contamination would expose a receptor population if the population were present. Future potential pathways exist if the contamination does not currently exist at a point of exposure but might migrate to some point of exposure. Figure 7 represents typical exposure pathways for a generic hazardous waste site.

20 The fact that completed exposure pathways exist at hazardous waste sites, does not necessarily suggest the potential for adverse health effects. The evaluation of the exposure pathways with respect to health effects appears in a subsequent section of this public health assessment.

This section contains discussion of the potential for contaminants to present public health hazards via environmental exposure pathways in th e past, in the present, and in the future.

Exposure Evaluation Process A release of a contaminant from a site does not always mean that the substance will have a negative impact on a member of the off-site community. For a substance to pose a potential health problem, exposure must first occur. Human exposure to a substance depends on whether a person comes in contact with the contaminant, for example by breathing, eating, drinking, or touching a substance containing it. If no one comes into contact with a contaminant, then no exposure occurs and thus no health effects can The five elements of an exposure pathway are occur. Even if the site is inaccessible to the public, (1) source of contamination, environmental (2) contaminants can move through the environment to media, (3 point of exposure, route of human ) (4) locations where people could come into contact with exposure, and (5) receptor population. The them. source of contamination is where the chemical or radioactive material was released. The ATSDR evaluates site conditions to determine if environmental media (e.g., groundwater, soil, people could have been or could be exposed to site-surface water, air) transport the contaminants.

related contaminants. When evaluating exposure The point of exposure is where people come in pathways, ATSDR identifies whether exposure to contact with the contaminated media. The route of exposure (e.g., ingestion, inhalation, dermal contaminated media (soil, water, air, waste, or biota) contact) is how the contaminant enters the body.

has occurred, is occurring, or will occur through The people actually exposed are the receptor ingestion, dermal (skin) contact, or inhalation. population.

ATSDR also identifies an exposure pathway as completed or potential, or eliminates the pathway from further evaluation. Completed exposure pathways exist if all elements of a human exposure are present. A potential pathway is one that ATSDR cannot rule out because one or more of the pathway elements cannot be definitely proved or disproved. A pathway is eliminated if one or more of the elements are definitely absent.

21 Figure 7. Potential Exposure Pathways

Assessing Health Effects Exposure does not always result in harmful health effects. The type and severity of health effects that a person can experience depend on the dose, which is based on age at exposure, the exposure rate (how much), the frequency and/or duration of exposure (how long), the route or pathway of exposure (breathing, eating, drinking, or skin contact), and the multiplicity of exposure (combination of contaminants). Once a person is exposed, characteristics such as his or her age, gender, nutritional status, genetics, lifestyle, and health status influence how he or she absorbs, distributes, metabolizes, and excretes the contaminant. The likelihood that adverse health outcomes will actually occur depends on site-specific conditions, individual lifestyle, and genetic factors that affect the route, magnitude, and duration of actual exposurean environmental concentration alone will not cause an adverse health outcome.

More information about the ATSDR evaluation process can be found in ATSDRs Public Health Assessment Guidance Manual at http://www.atsdr.cdc.gov/HAC/HAGM/ or by contacting ATSDR at 1-888-42-ATSDR. An interactive program that provides an overview of the process ATSDR uses to evaluate whether people will be harmed by hazardous materials is available at http://www.atsdr.cdc.gov/training/public-health-assessment-overview/html/index.html.

22 A. Completed Exposure Pathways This public health assessment focuses on exposures to volatile organic compound releases to the environment by way of the surface water, groundwater, and air. As stated earlier in this section, exposure pathways are complete when contaminants are traceable through the 5 elements comprising an exposure pathway.

Environmental sampling has shown the presence of volatile organic compounds in the groundwater. An evaluation of scenarios whereby an individual would consume this water indicates that groundwater is not a source of drinking water. Nor do data suggest that contaminants have migrated against the normal groundwater flow toward the Railroad Well that serves as a source of drinking water for the community. No data were identified indicating contamination of private wells by these contaminants.

NFS has sampled the Nolichucky River for the presence of volatile organic compounds. The sampling location was along the backwash areas near the mouth of Martin Creek. These data do not indicate the presence of volatile organic compounds contamination at levels of public health concern. Furthermore, this portion of the river is not used because of the nature and conditions of the marshy backwash area.

Data suggest that the groundwater beneath the NFS facility migrates toward the Nolichucky River and flows into the river. The State of Tennessee reported that the downstream quality of public water processed from the river is considered excellent.

The EPA Toxic Release Inventory data reports that NFS has rel eased nitrate and other related compounds to the atmosphere. However, air sampling for these contaminants and other non-radiological contaminants has not occurred.

B. Potential Exposure Pathways Nuclear Fuel Services, Inc. reported that they have not used PCE a nd its breakdown products since the 1970s. However, past uses resulted in spills, releasing the chemicals to the air and to the soils ultimately contaminating the groundwater. Groundwater sampling results and concentration maps for VOCs show very high levels of the contaminant suggesting that large volumes of these compounds were spilt on the gr ound around the maintenance areas prior to the 1970s on the NFS property. ATSDR did not locate any surface soil sampling or atmospheric sampling around these areas that occurred at the time of these spills. As VOCs are no longer used, there will be no current or future exposures to these contaminants via the air pathway. No current uses of groundwater occur in the downgradient areas and restrictions to the use of groundwater in this area are restricted.

Other potential exposure pathways that could result in human exposures include the release of nitrates and nitric acids as well as ammonia compounds to the surface and the air.

NFS is currently seeking a waste water permit to a llow them to divert processing water, currently stored on site, to the municipal sewage system. Until that permit is granted, the potential for exposures to waste water containing nitrogen compounds such as ammonia exists.

Not directly related to site contaminants but associated with NFS is the firing range in Washington County used by their security forces. The contaminants associated with this type of activity include residue from spent gunpowder including various heavy metals and the heavy

23 metals associated with the fired bullets. These heavy metals include, but are not limited to, copper, lead, zinc, steels, and brass. The concerns expressed to ATSDR include migration of these contaminants to local surface waters that serve as sources of public water supplies to downstream communities.

Public Health Implications The Nuclear Fuel Services, Inc. site released volatile organic compounds to the ground, contaminating both surface soils on site and th e groundwater. Although these releases occurred in the past, there are no current or future uses for the off-site groundwater as the community is on public water supplies. Furthermore, the public well closest to the facility is hydraulically upgradient and has not been impacted by these releases. Additionally, the facility-wide enhanced bioremediation and reductive dechlorination project (RCRA corrective action) has proven to be very effective at remediating the PCE contaminated groundwater.

Without a completed exposure pathway, adverse health effects related to these releases are unlikely.

C. Community Health Concerns Evaluation Members of the community in Erwin and surrounding cities and towns have expressed a variety of concerns to ATSDR. The concerns ranged from impacts on environmental quality (air, water) in Erwin, other towns in Tennessee and North Carolina, perceived increases in cancer rates and self-reported cancer including colon and multiple myeloma, thyroid disease, Alzeheimers Disease, multiple sclerosis, skin, and joint ailments. Concern also was raised regarding the firearms training facility located in Washington County.

ATSDR addresses these comments and concerns in Appendix A, entitled Public Concerns received by ATSDR following the February and August 2006 site visits.

Child Health Considerations In communities faced with air, water, or food contamination, the many physical differences between children and adults demand special emphasis. Children could be at greater risk than are adults from certain kinds of exposure to hazardous substances. Children play outdoors and sometimes engage in hand-to-mouth behaviors that increase their exposure potential. Children are shorter than are adults; this means they breathe dust, soil, and vapors close to the ground. A childs lower body weight and higher intake rate results in a greater dose of hazardous substance per unit of body weight. If toxic exposure levels are high enough during critical growth stages, the developing body systems of children can sustain permanent damage. Finally, children are dependent on adults for access to housing, for access to medical care, and for risk identification.

Thus adults need as much information as possi ble to make informed decisions regarding their childrens health.

The evaluation performed by ATSDR at the Nuclear Fuel Services, Inc. site did not find any current exposure pathways for any chemical. Moreover, there is insufficient evidence to show completed exposure pathways to organic chemicals.

Conclusions ATSDR has evaluated the releases of volatile organic compounds to the environment surrounding the Nuclear Fuel Services, Inc. facility in Erwin, Tenne ssee. The releases of these

24 materials may have occurred in the 1950s, 1960s, a nd 1970s; there was little or no monitoring of the environmental media at that time.

Current conditions related to the groundwater indicate that the groundwater is not being used as a source of drinking water nor has the contamination impacted public water sources. The levels of contaminants in the bordering Nolichucky River are not at levels of a public health hazard.

Using the protocols developed by ATSDR to evaluate pathways of exposure to populations around potentially contaminated or contaminated sites, ATSDR considers the NFS facility hazard rankings as such:

1. Past Conditions - There is no verifiable in formation that groundwater was not used prior to the 1980s. Furthermore, there is a historical lack of both on-site and off-site sampling of atmospheric releases. ATSDR considers the site an Indeterminant Public Health Hazard. This category applies to sites where critical information is lacking (missing or has not yet been gathered) to support a judgment regarding the level of public health hazard from past exposures.

2. Current and Future Conditions -ATSDR ranks this site as No Apparent Public Health Hazard. As there are no completed exposure pathways existing whereby the groundwater would be used as a source of public water. The lack of knowledge about the karst formations is of concern for there is insufficient data to determine if the contaminants associated with groundwater in this area will impact public wells in the future. Because the contaminants present in the groundwater are a mixture of many volatile organic compounds, health effects of mixtures may be an issue. However, no available studies directly characterize health hazards and dose-response relationships for exposures to whole mixtures containing 1,1,1-trichloroethane, 1,1-dichloroethane, trichloroethylene, and tetrachloroethylene. Furthermore, physiologically based pharmacokinetic (PBPK) models have not b een developed to predict dispositional and toxicological outcomes of joint action of mixtures of these four chemicals. Similarly, interactions of heavy metals with other heavy metals or organic compounds are unknown at this time.

3. Based on all available information, ATSDR concludes that although some exposure might be occurring as a result of site conditions via the atmospheric exposure pathways, exposures are not at levels likely to cause adverse health. Say something about mixtures.

4. As previously stated, CERCLA legislation directing ATSDR activities excludes the evaluation of the radioactive materials released from this site. The conclusions of this public health assessment do not apply to the issues surrounding the use of radioactive materials by the Nuclear Fuel Services, Inc

Recommendations ATSDR has evaluated the issues associated with the release of organic contaminants associated with the Nuclear Fuel Services, Inc. facility. Based on con cerns received by ATSDR, the following recommendations are made:

25 1. A community education plan should be initiated by the appropriate agency to inform the area residents as to the nature and migration of the contaminants. This should include the movement of contaminants in the groundwater 2. ATSDR should meet with the public to discuss the findings of this public health assessment 3. If ATSDR receives any requests for a basic radiation safety and information presentation from the communities, those requests will be routed to both the Nuclear Regulatory Commission and Nuclear Fuel Services.

4. Inform the EPA about the concerns about lead exposure and migration as related to the gun range in Washington County.

Public Health Action Plan ATSDR will coordinate with local officials a nd media outlets to set up public meetings to disseminate the findings of this public health assessment.

ATSDR will begin formulating an action plan to discuss the h ealth impacts of the site to present to the public.

ATSDR will forward the concerns regarding the gun range to the site and to the EPA for their evaluation.

ATSDR will contact the local emergency re sponse organizations and hospital for the purposes of their activities in event of NFS accidents.

Author

Paul A. Charp, Ph.D.

Senior Health Physicist

26 References

1 National Institute for Occupational Health and Safety (2006). Technical Basis Document An Exposure Matrix for W.R. Grace and Company in Erwin, Tennessee 2 Arcadis Geraghty & Miller, Inc. (1999). Revised groundwater flow and solute-transport modeling report. Nuclear Fuel Services, Inc., Erwin, Tennessee.

3 Nuclear Fuel Services (1996). Interim Measures (IM) Progress Report SWMUs 2, 4, and

6. Dated September 26, 1996.

4 Morie CS, Greene J, Page GB, Ilgner B (2002). Tetrachloroethylene and uranium remediation using IRZ in Gavaskar AR, Ch en ASC (eds). Remediation of chlorinated and recalcitrant compounds2002. Proceeedings of the Third International Conference on Remediation of Chlorinated and Recalcitrant Compounds. (Monterey, CA 2002).

5 http://factfinder.census.gov

6 Tennessee Department of Environment and Conservation (2006). 2006 305(b) Report:

The Status of Water Quality in Tennessee. Tennessee Department of Environment and Conservation, Nashville, Tennessee 7 Nuclear Fuel Services (2004). Facility Action Plan Revision 2 for Nuclear Fuel Services, Inc. Erwin, Tennessee. Prepared for the Tennessee Department of Environment &

Conservation. Nuclear Fuel Services, December 2004.

8 Wolfe WJ, Haugh CJ, Webbers A, Diehl TH (1997). Preliminary Conceptual Models of the Occurrence, Fate, and Transport of Chlorinated Solvents in Karst Regions of Tennessee. US Geological Survey. Water-Resources Investigations Report 97-4097.

9 Nuclear Fuel Services (1997). Groundwater risk assessment at Nuclear Fuel Services, Inc. and adjacent industrial park site. June 1997.

10 Geraghtry and Miller (1996). Railroad well capture zone analysis near the Nuclear Fuel Services Erwin, Tennessee 11 Tennessee Department of Environment and Conservation (2004). Environmental indicator evaluation memorandum (EI memo). Prepared by the Division of Solid Waste Management. September 17, 2004.

12 US Nuclear Regulatory Commission (2002). Environmental assessment for proposed license amendments to Special Nuclear Material License No. SNM-124 regarding downblending and oxide conversion of surplus high-enriched uranium. Docket 70-143.

13 EPA (1996). First Evaluation Memo of NFS status under the Environmental Indicator Codes CA725 and CA750. Prepared by EPA, September 11, 1996.

14 Tennessee Department of Environment and Conservation (2004). Environmental indicator evaluation memorandum (EI memo). Prepared by the Division of Solid Waste Management. November 19, 2004.

15 EPA (2002). RCRA Cleanup Reforms: Region 4 Success Story. Successful Pilot Test:

Enhanced In-Situ Anaerobic Dechlorination of PCE and Reductive Precipitation of Uranium. (www.epa.gov/correctiveaction/success/r4s_nucl.pdf (accessed April 27, 2007).

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