TRINITY AMERICAN CORP.
GLENOLA INDUSTRIAL DRIVE
RANDOLPH COUNTY, NORTH CAROLINA
October 20, 1997
U.S. Department of Health and Human Services
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Atlanta, Georgia 30333
BASIS FOR THE ADVISORY
RECOMMENDATIONS AND PROPOSED ACTIONS
The Agency for Toxic Substances and Disease Registry (ATSDR) is issuing this public health advisory to notify the U.S. Environmental Protection Agency; the National Institute for Occupational Safety and Health; the State of North Carolina Department of Environment and Natural Resources; the Randolph County Health Department; and the public of the Glenola community in Randolph County of ATSDR's concerns regarding potential adverse impacts on the health of residents living near the Trinity American Corp. (TAC) facility on Glenola Industrial Drive in Randolph County, North Carolina. TAC is the parent company of Trinity Foam of Carolina, Inc. and Trinity Fibers of Carolina, Inc. Data and information obtained and reviewed by ATSDR strongly suggest that hazardous substances are being released into the air and possibly into other environmental media as a result of operations at the TAC facility, and that these hazardous substances are impacting residential areas at levels that may pose a significant risk to human health. Furthermore, ATSDR believes that substantial releases of hazardous substances into the environment have occurred in the past and that environmental media other than air may have been contaminated.
ATSDR is concerned that residents are being exposed to toxic substances such as 2,4- and 2,6-toluene diisocyanate (TDI) and other isocyanates known to exacerbate or cause obstructive airway disorders and sensitization reactions. ATSDR is also concerned that residents are being exposed to other air contaminants that have been measured at levels of health and safety concern but have not been identified. During plant operations, the local residents report intermittently experiencing headaches, dizziness, rashes, throat irritation, and chest tightness that are temporally correlated with the detection of odors and elevated levels of unidentified substances measured in off-site air. ATSDR and other agencies are concerned about chemical exposures of workers within the TAC facility as well as exposures of local residents.
ATSDR issues a public health advisory for sites where a release or threatened release of hazardous substances may pose a serious threat to human health. The agency uses the following criteria to determine the need for an advisory:
This public health advisory is to notify the U.S. Environmental Protection Agency (EPA); the National Institute for Occupational Safety and Health (NIOSH); the State of North Carolina Department of Environment and Natural Resources (DENR); the Randolph County Health Department; and the public of the Glenola community within Randolph County of an ongoing public health hazard. The public health hazard is associated with the past, current, and potential future exposures to hazardous air pollutants emitted from the Trinity American Corp. (TAC) foam and fiber facility on Glenola Industrial Drive in Randolph County. The Agency for Toxic Substances and Disease Registry (ATSDR) is issuing this public health advisory in response to requests for assistance from the DENR, the Randolph County Health Department, and the Glenola community.
ATSDR has concluded that the presence of hazardous substances in the community's ambient air warrants this public health advisory [1, 2, 3]. Unidentified volatile organic compounds (VOCs) and semi-VOCs have been detected in the air and are assumed to be at levels of public health and safety concern . Compounds such as isocyanates; methylene chloride; 1,1,1-trichloroethane; acetone; benzene; ethylene oxide; formaldehyde; and other VOCs have been identified in the ambient air at levels that may pose a serious threat to public health [3, 5].
The National Contingency Plan (40 CFR Part 300.400-420) describes the types of activities required and authorized in response to a hazardous substance release at a potentially hazardous site. Activities include notification of a release (Section 300.405(f)(1)); evaluation of the site (Section 300.410); and factors to be considered related to a removal action (Section 300.415). These factors include the migration of contaminants, the threat of fire or explosion, and other events that could threaten public health.
Based on the review of the available information, ATSDR recommends the use of statutory, regulatory, or administrative authorities as appropriate to protect the public's health and to characterize these exposures further. Specifically, ATSDR recommends that appropriate agencies take the following actions:
In 1981, the TAC facility began operations at 5275 Glenola Industrial Drive in the unincorporated community of Glenola, Randolph County, North Carolina . The site consists of 15.7 acres used for the production of fiber padding and the production and fabrication of foam for the bedding and furniture industries. Four primary operations occupy the site: a fiber production facility, a polyurethane foam production facility, a warehouse, and a tenant's business (Guilford Fabricators). Thomasville Products (foam manufacturer) owned the property from 1973 to 1981. The site was undeveloped before that time .
Polyurethane foam is manufactured by reacting a resin, typically a polyether such as polyoxypropylenetriol, with TDI and water. Small quantities of an emulsifying agent, a polymerization catalyst, and a silicone lubricant are also added . For certain higher quality grades of foam, methylene chloride (MeCl) is used as a blowing agent . For fire retardant foam, a tin catalyst is added. The ingredients are mixed and deposited onto a moving conveyor, and the polyoxypropylenetriol resin and the TDI polymerize and cross-link to form the urethane resin in the shape of a continuous foam-like structure called a loaf .
The loaf dries in a cooling chamber, where exhaust fans draw off chemical emissions for 20 to 30 minutes. These emissions peak during the first 2 minutes of the blow-off, when pressure inside the foam bubbles exceeds the pressure outside . The foam continues to off-gas rapidly for the next 5 to 10 minutes . After this period, off-gassing becomes diffusion controlled. Emissions are directed to stacks, which direct them to the ambient air; no emission controls are in place. The manufacturing processes at the foam facility occur in batches which result in episodic releases of emissions.
The TAC fiber facility processes scrap fibers in the manufacturing of Spansadeck fiber insulator pads for the bedding and furniture industries . ATSDR is gathering data on the specific processes and engineering controls used in this operation.
Glenola is an unincorporated community in Randolph County, North Carolina. The 1990 U.S. Census listed the county population as 115,548 people ; approximately 500 of these people live in Glenola. Approximately 1,650 people live within a 1-mile radius of the TAC facility. This population includes 162 children less than 6 years old and 120 adults more than 65 years old .
Since June 1997, ATSDR has received more than 200 telephone calls from residents near the TAC facility. The residents have reported a number of symptoms, including dizziness, breathlessness, headaches, nausea, loss of memory, flushing of the face and neck, fatigue, lethargy, sleeping difficulties, and difficulty breathing. They report a significant reduction of symptoms after leaving the area near the facility. The health effects described during these telephone calls are similar to those described by residents in one-on-one sessions with ATSDR staff during a public availability session in May 1997 .
Personnel from the State of North Carolina Air Toxics Analytical Support Team have been conducting air sampling near the TAC facility since January 1995. While conducting sampling activities near the TAC facility, these personnel have at times reported symptoms similar to those described by the residents . Furthermore, ATSDR employees have been conducting air sampling near the TAC facility since May 1997 and have at times reported similar symptoms and observations of a visible plume during episodic events .
Environmental monitoring to date has detected TDI, hexamethylene diisocyanate (HDI), MeCl, and total hydrocarbons in the community's air. ATSDR has identified a completed exposure pathway for TDI and other volatile and semi-volatile organic compounds at levels that may pose a serious threat to public health in areas around the TAC facility.
During an ATSDR/EPA environmental sampling event, residents contacted sampling personnel at approximately 10 pm on August 11 to indicate that strong odors were present and that they were experiencing adverse health effects similar to those previously reported. EPA and ATSDR personnel confirmed the presence of the strong odors and a visible plume of material in the ambient air.
EPA personnel had two flame ionization detector monitors (FoxboroTM organic vapor analyzers, or OVAs) to monitor the ambient air for volatile organic vapors. EPA personnel had calibrated those screening instruments when they arrived in the site area on the morning of August 11. At approximately 10:00 pm , August 11, the OVAs detected total volatile organic compounds in the ambient air at the residential location at levels from 2 to 6.2 units, or parts per million (ppm). The 2 OVAs were then recalibrated (with methane) at an upwind location. After recalibration, OVA instrument readings were as high as 2.5 units (ppm). OVA readings remained elevated (greater than 1.0 unit [ppm]) for several hours. EPA and ATSDR personnel continued to monitor using the OVAs until approximately 1 am on August 12 .
A few weeks later (approximately 10 pm on September 3), an environmental scientist and an environmental engineer from the North Carolina Department of Environment and Natural Resources (DENR) observed the following OVA readings:
Based on these concentrations of unidentified contaminants, ATSDR recommended implementation of the Glenola Community Contingency Plan. The local fire department initiated voluntary evacuation of individuals living in 107 homes within a 1/4-mile radius of the facility and of facility employees.
On September 3, 1997, the State Health Director issued a public nuisance order directing the TAC facility to cease all manufacturing (foam and fiber) operations. State health officials indicated that the facility will remain closed until TAC can demonstrate that the operations are no longer a public nuisance .
ATSDR has conducted air monitoring and confirmation sampling in residential areas near the TAC facility to quantitate ambient air TDI concentrations resulting from foam production. ATSDR used tapemeters with diisocyanate-specific chemcassettes and the TDI calibration program to monitor for TDI on a continuous realtime basis during these short release periods . Results from a confirmation sampling methodology that speciates and specifically identifies each of the isocyanates have confirmed the presence of TDI and HDI in the community's air [14, 15, 16]. Analysis of air samples collected using the confirmation methodology have confirmed the presence of TDI and HDI in short-term air samples (2-45 minutes) . Because the efficiency of isocyanate capture on the sampling device used in the confirmation methodology is low, measured concentrations may underestimate the actual air concentrations [14, 15, 16]. Thirty confirmation air samples were collected and analyzed for TDI; TDI was detected in 6 samples at concentrations ranging from 0.0026 to 0.18 µg/m3. Twenty of the 30 confirmation air samples were also analyzed for HDI; HDI was detected in 9 samples at concentrations ranging from 0.05 to 0.45 µg/m3.
DENR has entered into an agreement with Duke University's Department of Occupational and Environmental Medicine to provide high quality standard clinical evaluations of residents reporting health symptoms thought to be associated with exposure to environmental contaminants. Duke University has begun clinical evaluations of certain residents within the air-shed of the TAC facility who have reported adverse health effects consistent with exposure to these substances.
These clinical evaluations being conducted by Duke University include analysis of blood samples for the presence of antibodies that are produced by the body as a result of exposure to TDI. These TDI antibodies (Immunoglobulin G (IgG) and Immunoglobulin E (IgE)) are produced as a specific response to TDI exposure. Exposure to other chemicals will not result in production of TDI-specific antibodies. The analysis of the blood samples uses an enzyme-linked immunosorbent assay (ELISA) . The ELISA tests are both very sensitive (most individuals with TDI-specific antibodies test positive) and very specific (most individuals without the TDI-specific antibodies test negative) . However, the ELISA test cannot be considered a sensitive biomarker for exposure to TDI, because many individuals exposed to TDI do not develop these antibodies. Only 14% of TDI-exposed individuals in occupational settings exhibit the presence of TDI antibodies . In nonoccupational settings, exposure to significant levels of TDI (i.e., TDI levels that would cause health effects or production of TDI antibodies) is very rare, because the compound is very volatile (dissipates rapidly into the air) and very reactive (reacts readily and breaks down with other substances). The presence of TDI-specific antibodies found in individuals with no known occupational exposures to TDI is a strong indication that significant exposures to TDI are occurring in individuals living near the TAC facility.
To date, one resident has tested positive for both the TDI antibodies (IgG and IgE); three separate evaluations of the resident's blood serum have confirmed the results. In addition, one of the two ATSDR employees who reported TDI-like health effects while in the community has tested positive and has been confirmed for one of the two TDI antibodies.
To further characterize the residential exposure to TDI and other isocyanates, ATSDR is working to augment Duke University medical evaluations by gathering additional biological samples to be analyzed for antibodies to isocyanates (TDI, HDI, and Diphenylmethylene Diisocyanate [MDI]). ATSDR worked with the Randolph County Health Department to conduct this exposure investigation September 21 - 22; 112 blood samples were collected.
The exact amount of TDI required to cause adverse health effects is unknown. People have become sensitized after being exposed to as little as 20 parts per billion (ppb) . After sensitization there is no amount of TDI that one may be exposed to safely . Studies have shown that in sensitized individuals, asthmatic attacks can occur after exposure to TDI air concentrations as low as 0.l ppb .
Individuals who live near the TAC facility or are otherwise near the TAC facility for significant periods of time have reported a number of adverse health effects, including but not limited to dizziness, breathlessness, headaches, nausea, loss of memory, flushing of the face and neck, fatigue, lethargy, sleeping difficulties, and asthma. These adverse health effects are consistent with effects resulting from inhalation exposure to hazardous substances such as TDI/isocyanates and methylene chloride. These individuals include residents as well as personnel from DENR and ATSDR.
Analytical data of HDI/TDI in off-site air, along with the health complaints of residents in the community near the foam plant which are consistent with TDI exposure, indicate that the Trinity Foam Plant may pose a serious threat to public health for people in the surrounding community and possibly for workers at the facility.
The OVAs do not indicate which specific organic compound the instrument is detecting and measuring. However, the unknown nature of the organic compound or compounds being measured at levels above 1.0 unit (ppm) by the OVA requires that ATSDR assume they are of potential health and safety concern and thus implement certain employee health and safety policies and procedures. Until the specific organic contaminants in the ambient air are identified and characterized, any agency personnel present during elevated OVA readings (1 - 5 ppm) must wear EPA Level C respiratory protection. Use of EPA Level C respiratory protection requires proper training and medical clearance; agency personnel who are not properly trained and medically cleared are required to leave the area immediately when OVA readings indicate volatile organic compounds at levels of 1 - 5 ppm . This ATSDR policy is consistent with
the EPA's guidelines: "A range of background to 5 ppm above ambient background concentrations of vapors/gases in the atmosphere has been established as guidance for selecting Level C protection. Concentrations in the air of unidentified vapors/gases approaching or exceeding 5 ppm would warrant upgrading respiratory protection to a self-contained breathing apparatus" .
Because the OVA readings that exceed 1.0 unit (ppm) were taken near residences, the potential for exposure of community members is also of public health concern. The episodic nature of these "contaminant release" events makes it difficult to characterize the potential for human exposure fully and to implement appropriate protective public health responses consistently.
ATSDR issues this public health advisory based on the following:
Based on the available information, ATSDR concludes that hazardous substances are being emitted from the Trinity American Corp. facility on Glenola Industrial Drive in Randolph County, North Carolina. These emissions are resulting in off-site air concentrations of contaminants at levels that may pose a serious threat to public health.
ATSDR recommends that appropriate agencies take the following actions:
For additional information, please contact ATSDR at the following address:
Robert C. Williams, P.E., DEE
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