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Analysis of ATSDR's Public Health Assessment
West Pullman Iron and Metal, Chicago, IL
(November 9, 1998)
OVERVIEW
In response to a request from the Maple Park and Victory Heights Advisory Council, the TOSC Program has prepared a review of the Public Health Assessment (PHA) of the International Harvester and Dutch Boy Sites, Chicago, IL. The PHA was conducted by the Agency for Toxic Substances and Disease Registry (ATSDR) at the request of a Petitioner in the community. In summary, we believe that the PHA should be significantly modified to more accurately reflect what is known about the sites and to address community concerns over the site as a cause of health problems.
In the PHA ATSDR does not reflect the limitations in the site characterization. While ENVIRON sampled the DB site for lead, volatile organic chemicals and petroleum hydrocarbons, (Extent of Contamination (EOC) Report, July 1997), this sampling is incomplete. ENVIRON was not able to determine the extent of VOC contamination due to analytical error. The site was not sufficiently characterized for lead or petroleum hydrocarbons and no residential sampling was carried out. Previous studies do provide some additional information on the site characterization; however, this data is also incomplete. As such, there is little information on either past or present levels of contamination at either of these sites or near the sites. There was no useful data collected during the demolition activities because the sampling plan was not properly implemented.
ATSDR has neglected to adequately consider the past exposure of community residents to both on-site and off-site toxicants. Children have been reported to have dug in the soils on the site, rode their bikes on the site and “cut through the site on the way to the school bus stop” (p. 31, ATSDR report). As the site was unfenced for more than 20 years, from the time of plant closure in the mid-'70s until the summer of 1997, it is conceivable that these children were exposed to these chemicals for numerous years. Additionally, adults were known to have frequently crossed the site as the property separates the Victory Heights and West Pullman neighborhoods from the Metroline stop and the Victory Heights community from the Maple Park neighborhood.
Past exposure, including past off-site exposure, is a major concern of the community. Although the past sampling effort was limited, high levels of lead were found in some off-site soils near the site. It is then reasonable to assume that this population may have been exposed to lead over a long period. As such, TOSC recommends that ATSDR provide a clearer justification for the conclusion that off-site exposures have not led to health problems.
Despite the acknowledgement that the levels of environmental contamination at the site either during plant operation or during the time post-closure and pre-1996 are unknown, ATSDR concludes that the levels of contamination were not such to have caused any health problems. However, we do know that the present levels of contamination are very high (see attached report from TOSC, dated May 1998). Given that and the fact that the organic pollutants could only have degraded, volatilized, migrated or remained on the site and that the inorganic pollutants could only have remained on or migrated from the site, previous contamination levels must have greatly exceeded that observed in recent sampling events. TOSC recommends that ATSDR rewrite its conclusions, stating that, while information on past levels of contamination and exposure is lacking, there is reasonable scientific evidence to suggest that past levels of the organic chemicals would have been greater than that observed now. ATSDR should also mention that, for those situations, no definitive conclusions between past health concerns and potential exposure can be made (without conducting a large-scale epidemiological study).
SPECIFIC COMMENTS
TOSC has also provided a detailed set of comments pertaining to the PHA. These comments follow
Page 4, Paragraph 2 (DB)
It appears that only a very limited amount of sampling of residential properties has been accomplished, and ATSDR's summary should reflect that lack of data. However, based upon the Environ Draft EOC Report, it appears that significant lead contamination of soils near residential properties has occurred. This could have had a major impact on exposure of residents to lead
Page 4, Paragraph 3, Sentence 2 (DB)
Insufficient data is available to state that the concentrations of “polycyclic aromatic hydrocarbons (PAHs) and polychlorinated biphenyls (PCBs) in on-site soil do not constitute a current public health hazard.” It is known that there is extensive gasoline and diesel fuel contamination in the northwestern area of the site. Even if it could be concluded (which it cannot be) that this posed no risk to residents, it is not known if these levels are sufficiently high to pose a risk to workers during site remediation.
Page 4, Paragraph 4 (IH)
As we stated above, to our knowledge no comprehensive (or even basic) residential sampling has been accomplished. The data for PAHs and zinc are not presented in the document. (Those data should be included in Table 5.) The location where the samples were taken is not noted; this is important information on which to draw conclusions. Without this information, the conclusion that “exposure to the levels present at the site are not likely to cause adverse health effects” is unsubstantiated.
Page 4, Paragraphs 5 and 6 (IH)
The levels of contamination are not known for the extended period of time during which the site was unfenced. As stated in the PHA, “site security was not established until the summer of 1997, making it was possible for pedestrians to enter the site.” The community members have documented that the site was frequented until it was fenced. Even after the site was fenced, maintaining a secured property has been difficult. Photographs showing children playing on the site are available; photographs were taken both before and after the site were fenced. Given the high level of contamination on the site and the frequent access during the period when the site was unfenced, the conclusion that “adverse health effects are unlikely to occur” is unsubstantiated. If the concentrations of contaminants are high now, they must have been greater in the past, before site security. Additionally, ATSDR presents no justification on which to base the assumption that the duration of exposure was insufficient to result in any adverse health effects.
Page 5, Paragraph 1, Sentence 1 (IH)
The report states that “currently, for people trespassing on-site, both the Dutch Boy and International Harvester site represents (sic) a potential health hazard.” This statement directly contradicts the repeated dismissals (by ATSDR) of the potential for historic exposures to PAHs and lead (see, for example, page 4, paragraphs 5 and 6 of the PHA). If the sites represent a current potential health hazard, and given the extreme lack of data for historic concentrations, how did ATSDR determine that historic exposures did not cause health problems?
Page 5, Paragraph 3, Sentences 3, 5 and 6 (DB)
The PHA states that demolition and salvaging activities occurred from 1983 to 1986 and that “demolition activities were stopped after they were found to pose an imminent danger.” However, if the lead poisonings occurred in 1985 and demolition activities occurred in 1986, it appears that demolition continued for a significant period after the threat to human health was known.
Page 5, Paragraph 4 (DB)
If some of the basements and open chambers on-site are now only “partitioned off with yellow tape,” those locations must have been accessible to people entering the site before site security. No mention is made as to when the basements or open chambers were filled with soil. Is it not possible that, before site security, those areas were also accessible? What better location for children to explore? Those locations are likely places for “forts” and the like, and would therefore represent a significant potential for exposure. In the past, as the debris was uncovered, the materials present in the pile could have been distributed both on- and off-site by the wind. The PHA reports that presently the debris pile is only covered with torn plastic sheeting. As such, the materials in the pile continue to present a risk to human health as area residents may be exposed to these chemicals because of air deposition.
Page 6, Paragraph 3
The Maple Park/Victory Heights Advisory Council is misidentified in the paragraph.
Page 7, Paragraph 1
ATSDR seems to imply that the only adverse health effects with apparent clinical signs were the elevated blood lead levels noted in 1985 and 1986. However, ATSDR overlooks pertinent questions. How complete were those sampling events? Was it possible that those individuals who were frequenting the site did not have their blood lead levels tested? How many individuals were tested during the 1985 and 1986 sampling events? Are those numbers sufficient to make any statistically valid conclusions? Since the relationship between contact with the site and blood lead level cannot be made, no conclusions can be drawn from any of the sampling events.
Page 8, Paragraph 2, line 10
To better assist the community in understanding the risk to their health, it would be useful for ATSDR to be more specific when describing health problems. Rather than referring to pica as an “uncommon behavior,” TOSC suggests that ATSDR define the rate at which pica occurs in the general population and in this population, which is at risk. This would assist the community in understanding whether they need to be concerned with the additional risks associated with pica children.
Page 8, Paragraph 3, line 4
ATSDR introduces another criterion for lead, one that is higher than that set for this site, without any clear explanation. TOSC recommends that the 1,400 ppm lead level, as set by the U.S. EPA (UAO, March 1996) be used, for on-site soils.
Page 8, Paragraph 4
The UAO should be listed as the reference document for the actions “recommended” by U.S. EPA (a better term being “ordered” as they are found in an Administrative Order). In addition, the word “elevated” should be substituted for “increased” on the fifth line of paragraph 4.
Page 8, Paragraph 5
TOSC questions the argument that this “condition…does not apply to this site.” In analyses conducted in 1993 it was found then that some of the PAH concentrations in on-site samples exceeded ATSDR’s comparison levels. The concentrations of PAHs that would have occurred during and after the termination of the demolition operation are predictably higher than that in the 1993 samples. It is highly possible that, in the past, workers and the residents were exposed to much higher concentrations of PAHs, and as discussed previously, for extended periods of time.
Page 9, Paragraph 1
ATSDR needs to acknowledge the presence of petroleum-type compounds on the DB site (EOC Report, ENVIRON, July 1997). Although specific compounds were not identified, the concentrations of gasoline-related organics (GROs) and diesel-related organics (DROs) exceeded 25,000 ppm in the northwestern corner of the site. It should also be stated by ATSDR that all VOC analyses conducted in 1997 by ENVIRON were inconclusive because the minimum detection limits were excessively high (25,000 ppb) in many cases.
Page 9, Table 1
ASTDR needs to discuss more completely the possible presence of PCBs on the site, especially given the likelihood that transformers were located on the site. Where were the transformers located? Were they located near the sample with a PCB level of 0.52 ppm? How many samples were tested for PCBs? Has the site been sufficiently characterized for the presence of PCBs?
In using the 500-ppm action lead level for residential soils, the ATSDR risk assessors use comparison values that may be too high to protect the health of the residents (Tables 1 and 3, page 12). In fact, if the lead concentrations in the soil and dust are 500 ppm, EPA’s IEUBK model predicts that 18% of the children would likely have elevated blood lead levels. This value (18%) is three times the national average of children (6%) that have elevated blood lead. To provide an environment that would allow children in this community to have a blood lead level at the national average, as predicted by the IEUBK model, a soil (and dust) lead level of 200 ppm or less should be used for comparative purposes. It is important to recognize that the action lead level of 10 mg/L for children was not accepted as a no-effect level; instead, it was accepted as an action level at which public health concerns can be managed. Many researchers do not consider this an acceptable level due to possible effects on children’s mental development.
Page 9, Paragraph 2
ATSDR mentions only the results of sampling that was conducted in 1994. Sampling in 1997 by ENVIRON revealed lead concentrations exceeding 40,000 ppm near the loading dock (northwest sector) in soils up to 2’ below grade. In soils and sediments at 2’ to 4’ below grade, the lead concentrations exceeded 40,000 ppm in some locations. Even at depths of greater than 4’ below grade, lead was found at concentrations greater than 40,000 ppm. In some locations, the concentration of lead was approximately 30% (by weight). It is imperative that ATSDR note these levels as they reflect the very high levels of contamination on the DB site.
Page 9, Paragraph 3
ATSDR notes that elevated VOC levels were detected on the DB site in 1987. Since those levels “were due to a surface spills” (according to ATSDR), the level of contamination must have been much higher at the time of the spills. Therefore, VOCs in surface soil may have been a health hazard in the past for the workers and the trespassers. This possibility needs to be identified in the risk assessment.
Page 10, Paragraph 1
ATSDR states that “standing water no long occurs on-site.” How was that statement tested? What data are available to substantiate it?
Page 10, Paragraph 3
One should not dismiss the significance of air lead of 26.1 mg/m3 (value measured during 1996 demolition activities) at a site so close to a school and a residential area. Based on EPA's IEUBK model, at a 26.1 mg/m3 air lead concentration, it is likely that more than 50% of the children exposed will have elevated blood lead levels. This figure is certainly not acceptable when nationally 6% of the children have elevated blood lead. Additionally, what is the “residual release” of lead? That is, what happened to the lead that left the site? Is information about wind direction available?
ATSDR compares the air quality data collected during the demolition activities conducted in 1996 to the OSHA permissible exposure limits. This comparison is invalid since the residents of this community are likely to be exposed for longer than an 8-hour period (used in promulgating the OSHA standard). As such, the National Ambient Air Quality Standard (NAAQS) of 1.5 mg/m3 should be used for comparative purposes. While this level is more appropriate than the OSHA PEL, even at this level, neighborhood children would be expected to have elevated blood lead levels. The IEUBK model predicts that 18% of children will have elevated blood lead levels if the air lead concentration is 0.1 mg/m3 and the soil and dust lead concentrations are 500 ppm.
Finally, ATDSR reports that one air sample had a lead concentration greater than 25 mg/m3 (26.1 mg/m3). This single value alone does not indicate whether the “true value” is either below or above the action level (25 mg/m3). Therefore, the statement that “ATSDR does not consider this exceedence significant” is unjustified. On the contrary, one could argue that since lead toxicity occurred in workers during the 1986 demolition (as noted in the PHA on page 17), it is plausible that the elevated air lead concentration in combination with elevated soil lead levels posed a health problem to individuals residing in the proximity of the demolition site in 1996.
In addition, any examination of lead exposures associated with demolition activities needs to note that no monitoring or sampling occurred during the demolition activities from 1983-1986. Residents may have had exposures that lasted for years, not the shorter period during the 1996 demolition.
Page 12, Paragraph 2
ATSDR implies that since PCBs were detected in the soil in 1987, but were below detection limits in 1995, PCBs do not represent a threat to the community. This finding begs the question: Where did the PCBs go? Since PCBs are not reactive, the PCBs either were distributed in wind-blown dust or were transported mechanically (movement of soil on feet, by children, etc.). These questions are important in terms of the impact of the PCBs on community health.
Page 13, Paragraph 3
It is inappropriate to use one half of the OSHA PEL (25 mg/m3) as the comparison value for air lead concentrations when children have access to the area (through the breaks in the fence). Instead, the national average of 0.1 mg/m3 air lead concentration should be used. With lead concentrations of 25 mg/m3 in the air and 500 ppm in the soil (resulting in dust lead concentrations of the same level), the IEUBK model predicts that more than 50% of the children will have elevated blood lead levels. This is unacceptable when the national profile indicates that 6% of children have elevated blood lead.
It is also in appropriate to use one-half of the OSHA PEL (2.5 mg/m3) for respirable dust. Instead, either the NAAQS PM-10 value of 50 mg/m3 (annual value) or the PM-2.5 value of 15 mg/m3 should be used.
Page 14, Paragraph 1
ATSDR reports that a black oily sludge sample was taken from the bottom of an on-site (IH) manhole. This sludge is reported (by ATSDR) to be similar to that found in the basements of area residences after rainfall events. (A video documenting the presence of this sludge is available from the Council.) As the concentrations of the contaminants in the on-site sludge exceed ATSDR comparison levels, this material may represent a long-term exposure of many residents to the contaminants in the sludge. The black sludge needs to be removed immediately. The exposure and the potential health effects on residents should be assessed as soon as possible.
Page 14, Paragraph 3
ATSDR states that metals were detected in off-site surface soils taken at the Edward White Elementary School, a residence and along the western and northern borders of the IH site. The sampling locations and the concentrations of metals need to be provided to allow for a proper evaluation of the risk associated with these contaminants. ATSDR should consider that the presence of these contaminants might pose a long-term risk to the community.
Page 15, Table 5
The alphabetic notations (B, J, etc.) used in this table and others (see Table 4 and Tables A, B and C in Appendix C) should be defined or eliminated.
Page 15, Paragraph 2, line 4-6
The second sentence should be deleted. The last sentence should be reworded to read: “The analyses, conclusions and recommendations in this health assessment are only as valid as the data presented in the supporting documents. Where the quality control/quality assurance (QA/QC) measures used in preparing those supporting documents cannot be validated, any statements relating to those data are inconclusive.”
Page 17, Paragraph 2
ATSDR states, “These elevated levels (in two adults and three children) were attributed to the demolition activities at the Dutch Boy site.” To our knowledge, this claim is made without any factual data. Based on the existing data, a significant percentage of the children living in this community are likely to have had elevated body burdens of lead before the 1983-1985 demolition activities. It is conceivable that the additional exposure to air and dust lead during the demolition brought the body burden of a small number of children above the apparent toxicity level. It is reasonable to predict that other children also had elevated levels of lead in their bodies, but that no apparent signs of toxicity were reported. Such a highly plausible scenario must not be dismissed. The blood lead concentrations from a “mass screening” in 1986 are not a good indicator of total lead body burden, because it was at least a year after the demolition activity and several years after the closing of the plant operations. Blood lead concentration is an acceptable indicator of lead exposure only when the exposure is consistent (i.e., the environmental levels are maintained) and concurrent with the blood sampling.
ATSDR states that “there are no supporting data” on which to base the assumption that “workers were also likely to be exposed via inhalation or ingestion of contaminated soil during the operation of this site.” On the contrary, there is sufficient information pertaining to on-site contamination to assume that on-site workers were exposed previously to several contaminants. The likelihood of past exposure should not be dismissed. In the absence of information on past exposure and given the blood lead concentrations measured at the time of exposure, one must consider the past exposure.
Page 18, Paragraphs 2-4
Extensive trespassing through the contaminated sites before the area was fenced off has been reported. ATSDR states that the fence around the IH site has been difficult to maintain. We do know that children frequented the sites and, as reported by the Council, children dug tunnels, made forts, entered the basements, and created dust as they rode their bikes and made trails. As such, the potential for exposure to the contaminants is great. The on-site lead and PAH levels observed in 1995 indicate potential health hazards at the Dutch Boy site for on-site workers and trespassers in the past. The soil lead concentrations detected in 1997, both on-site and off-site, indicate that lead is a past and a current potential hazard to the community through multiple routes of exposures.
Page 19, Table 7
Why was the off-site soil exposure not considered as a possible source of past lead exposure? If its presence is evident now, its presence in the past is reasonably predictable.
Why was dermal contact omitted as a possible exposure pathway for surface soils and air? In the PHA (under “Surface Soil”) it should be stated that workers and trespassers might have been exposed to the contaminants via ingestion, inhalation (of contaminated dust) and dermal contact (with contaminated dust).
Potential off-site air lead exposure is possible when children play on the contaminated soil, even on vegetation-covered soil. Additionally, it is conceivable that children dug in these soils or played on the ground on grassy locations. This source of exposure must be considered.
Page 20, Paragraph 2, line 3
Since ASTDR is considering the effects of off-site contamination, the data generated from all of the DB and IH reports should be pooled. Due to the proximity of the sites, it is impossible to ascertain if off-site exposure was the result of contamination from one or the other of the sites. Given this, ASTDR must consider the findings obtained in the ENVIRON EOC report (1997) which revealed off-site soil lead concentrations ranging from 46 to 16,200 mg/kg, with 43 of 66 samples exceeding 500 mg/kg.
Page 20, Paragraph 2, line 5
ATSDR states, “The presence of vegetation decreases the likelihood of exposure to contaminated soils and dust.” That point should be re-assessed, because it provides no information indicating that the exposure is decreased to a level that no longer presents a health concern. A quantitative analysis of the exposure is required to make this statement meaningful.
Page 20, Table 8
Both present and future exposures to citizens may occur from access gained through gaps in the fence. Keeping the fence intact has been a long-term problem.
Page 20, Paragraph 4
ATSDR states, “However, not enough information is available to conclude whether PAHs are migrating off-site.” On the contrary, elevated concentrations of PAHs were found in the off-site soil samples collected in 1995 (Table D), 12 years after the cessation of the operation. The black oily sludge, which may contain PAHs, continues to back up to the basements of residences even now! There is not only the possible past off-site PAH exposure, but also possible present “indoor” exposures.
Page 21, Table 9
Table 9 should state that potential exposures may have occurred in the past, may be occurring in the present and may occur in the future. This is because off-site soils are still contaminated (Table D) and because of the presence of the black oily sludge, which may be contaminated, in area residences.
Page 23-24, Paragraph 4
We agree that a conservative approach must be taken in order to protect human health. However, we do not agree that these chemicals should be viewed as “harmless contaminants.” If these chemicals were harmless, then why would EPA mandate and enforce drinking water maximum contaminant levels (MCLs) for many of the same chemicals? Many of the MCLs are very low; in fact, the maximum contaminant level goal (MCLG) for lead is zero.
Page 24, Paragraph 4
The argument presented here begs the question: Should U.S. EPA not enforce drinking water MCLs for communities having a population of 10,000 or less, since
“there is no such thing as one tenth of an excess case of cancer”? A risk of one in 100,000 does not preclude the possibility that at that concentration, the chemical of concern will cause multiple cases of cancer in the community (of 10,000). Conversely, it does not mean that in another community (population 700,000) seven additional cases of cancer will result because of exposure of the population to this contaminant. This entire paragraph needs to be rewritten to better explain to the community the relevance of risk-based criteria.
Page 25, Paragraph 4
“ATSDR considers that those on-site contaminants that exceeded CREGs only (i.e., PAHs and PCBs in soil, and asbestos and arsenic in air) represent little or no hazard to public health off-site, due to the limited duration of potential on-site exposures.” That statement may be accurate for PCBs and asbestos, if fences eliminate access to the site. However, the statement is not true for past exposure, during operation and before the areas were fenced off. In addition, the statement may not true for current exposures as black oily sludge is still backing up into houses.
Page 25, Paragraph 5 (continued on P26)
Concerning the Dutch Boy site, ATSDR states that “based on the data that was available for review, off-site [lead] exposures do not appear to have been associated with any readily identifiable public health hazard in the past.” ATSDR provides little scientific basis for this statement, and for good reason: critical information is lacking to evaluate historic contamination levels and historic exposures. Nobody knows the extent to which, over 43 years of operation of the Dutch Boy facility, people were exposed to on-site or off-site contaminants. TOSC suggests that, because so little is known about past “exposure conditions,” the conservative assumption, one that is protective of human health, would be:
· The Dutch Boy site has been repeatedly accessed by children during periods when lead was present in surface soils at high concentrations.
· The type of activities that were carried out on the site is unknown, but the community members indicated that such activities as riding bikes, playing ball games, digging in soils and other activities that actively disturb soils occurred on the Dutch Boy site.
· Because of the uncertainties associated with historic contamination levels and historic exposures, no definitive conclusions can be made on those issues. However, the present high on-site and off-site lead concentrations indicate a strong likelihood for historic exposures to lead.
Page 26, Paragraph 1
Firstly, no sufficient effort was ever made to identify the public heath hazards associated with lead exposure. Secondly, it is more than likely that women of reproductive age have been exposed to elevated concentrations of lead in the soil, dust and air. For the lead exposure in children, one should also consider the maternal body burden during pregnancy when lead can be transmitted from mother to fetus. Consistently throughout the PHA, ATSDR has failed to acknowledge the past exposure. The risk assessor could not, and shouldn’t even try to, explain the problem away by stating , “However, based on the data that was available for review, off-site exposures do not appear to have been associated with any readily identifiable public health hazard in the past; nor is any such public health hazard likely to exist now or in the future.”
Related health problems were not systematically and scientifically investigated. Some of the known effects of lead effects on children’s behavior and mental development are unlikely to be recognized by parents, teachers, or physicians unless specific tests are administered. Based on the concentrations of soil lead, on- and off-sit e, the likelihood of elevated lead concentrations in the air during past operations and demolition is high. Because of the accumulative nature of lead in the body and the activity of children on the site before the fences were erected, it is likely that a significant percentage of children in this community had elevated blood lead concentrations during high exposure time periods. They are likely to have elevated body lead burden even today. Tests should be conducted to examine the body burdens of lead in children and in women of reproductive age. The assay for blood lead concentration, which mostly reflects current exposure, is not recommended to assess total body lead burden due to past exposures.
Page 26, Paragraph 2
Again, we wish to emphasize that, to our knowledge, there was not a sufficient extent of blood lead sampling conducted in 1986. While we might be able to state that those individuals with elevated blood lead levels were exposed on-site, we cannot state that these were the only individuals exposed or that those were the only individuals with elevated blood lead levels. Additionally, the PHA needs to clarify the number of people with lead toxicity (previously stated on page 5, paragraph 3 of the PHA, as five, here the PHA states 5 adults and four children).
Using 1986 standards for risk evaluation for lead is unacceptable. An action level of 10 mg/dl should be used to evaluate the children’s blood lead, rather than 25 mg/dl. Unfortunately, using blood lead as an indicator of past exposure is not acceptable. Blood lead levels only reflect body burden when exposure has been at constant environmental levels and is still ongoing.
In the past two decades, the percentage of U.S. children with elevated blood lead levels has dropped from 88% to 6%. Blood lead levels in children of this community should have followed a similar trend of decline if the environmental impact from the site contamination was negligible. Site-specific children’s blood lead levels, which reflect only current exposure, should be compared with recent national data reported in, for example, “America’s children: Key National Indictors of Well-being, July, 1998.” The most that one can conclude based upon the existing information is that there is insufficient data to predict the blood lead levels of children in this community, and no test was performed to determine the total lead body burden to indicate past exposures. As for current lead exposure, the known soil lead levels, on-site and off-site, and the likelihood of elevated maternal burden due to long-term exposure to lead provide sufficient evidence for one to be concerned over the current children’s blood lead levels. A community-wide blood lead screening of children should be recommended by ATSDR.
The lack of apparent signs of toxicity does not negate the possibility, however small, that the blood lead levels were sufficiently high as to cause low scores on cognitive ability and decreased nerve conduction in children, high blood pressure in middle-aged men, and increased likelihood of pre-term deliveries in women. The reported five cases of apparent lead toxicity do not eliminate the possibility of developmental and nervous system toxic effects in the rest of the community.
Page 26, Paragraph 3
It is inappropriate to compare the blood lead levels for 1986 with the national data for 1976-1980. In the U.S., there has been a consistent decline in blood lead levels from late 1970s up to now. Significant decreases in blood lead levels took place in the majority of the U.S. population, especially in urban populations.
Page 26, Paragraph 4
The potential for off-site exposure still exists with lead concentrations as high as 16,200 mg/kg. The PHA should call for remediation activities to be conducted in a way that is, truly, protective of human health.
Page 27, Paragraph 1
The PHA should call for remediation activities to be conducted in a way that is, truly, protective of human health.
Page 27, Paragraph 2
ATSDR again concludes that “PAHs in soil at the Dutch Boy site did not constitute a probable past hazard to public health because neither the levels nor the exposure conditions were sufficient to produce any known adverse health effects in humans.” TOSC requests that ATSDR provide the scientific basis on which to make such an argument (e.g., sampling and analysis from the period of potential historic exposure). To our knowledge, this data does not exist. PAH data taken 15 years after the plant operations ceased can not be used to assess either the past concentrations or the past exposure. Because of the degradation of PAHs (albeit slow for many) and the irreversible sorption onto soil particles, it is expected that PAH concentrations would have been much higher when the plants were in operation than what were detected at the time of sampling.
The comparison to “eating grilled steak” trivializes the concerns of the community and should be removed from the report. To our knowledge, there is no scientific basis on which to make this comparison.
Page 28, Paragraph 1
ATSDR concludes, “there is no evidence that any of these PAHs individually are carcinogenic to humans, especially by the ingestion route.” This statement is irrelevant since the PAHs would not have been ingested as a single compound but as the complex mixture present on the soils or in the dust. Furthermore, there is evidence that chewing tobacco causes a variety of cancers, and any PAHs to which a tobacco-chewer would be exposed, would be ingested. There have been thousands of hours dedicated by toxicologists, health officials and other scientists to set the risk-based criteria for PAHs. Why does ATSDR present a very limited data set (two studies) to try to dispute all of the previous efforts by EPA and others? This entire paragraph should be eliminated.
The reasoning in this paragraph also ignores the fact that the black, oily sludge continuously backs up in residential houses, and the possibility that this sludge contains significant concentrations of PAHs.
Page 28, Paragraph 2
Again, there have been many hours dedicated by toxicologists, health officials and other scientists to set the risk-based criteria for asbestos. ATSDR presents a very limited data set (“several epidemiological studies” presented in a secondary reference) to dispute all the previous efforts by EPA and others. This entire paragraph should be rewritten to reflect the scientific evidence: that the maximum level of asbestos measured in air in 1996 exceeded ATSDR’s CREG for asbestos, but that the health effects due to this exposure cannot be determined, since the length of exposure is unknown.
Page 28, Paragraph 3
The paragraph should end with the third sentence (“…did or did not exceed the CREG”). There is insufficient scientific evidence to make the additional conclusions made in this paragraph. In particular, because the detection limit was so high, ATSDR does not know whether hazardous exposures occurred. In addition, ATSDR ignores past arsenic exposures, which may have occurred during the 1983-1986 demolition work.
Page 28, Paragraph 4
How does ATSDR know the frequency of trespassing (“occasional”)? Could it not be possible that residents from the West Pullman and Victory Heights neighborhoods cross through the site twice each day, five days per week, on their way to and from the Metroline stop?
Page 29, Paragraph 1
In a discussion of hazards associated with PAHs, ATSDR states, “The maximum concentrations of PAHs in on-site soils at IH were actually higher than the maximum concentrations detected in ‘black, oily-sludge’ from the bottom of on-site manholes, suggesting that these heavily contaminated 'soil' samples would probably not qualify as the type of soil that might be incidentally (and especially not intentionally) ingested by workers or trespassers.” ATSDR appears to be stating that, because the concentration of soil PAHs were higher than in the sludge, people will not tend to ingest the soil. As written, this statement appears to be an attempt to justify an unsubstantiated conclusion that the soil PAHs do not present a health hazard. This paragraph should be rewritten.
Page 29, Paragraph 2
ATSDR again concludes, “…PAHs in soil at the IH site are not likely to have caused adverse health effects in workers.” TOSC requests that ATSDR provide the scientific basis on which to make such an argument (e.g., sampling and analysis from the period of potential historic exposure). To our knowledge, those data do not exist. PAH data taken 15 years after the plant operations ceased cannot be used to assess either the past concentrations or past exposure. Because of the degradation of PAHs (albeit slow for many) and the irreversible sorption onto soil particles, it is expected that PAH concentrations would have been much higher when the plants were in operation than what were detected at the time of sampling.
Page 29, Paragraph 3
The risk assessors write that there was “limited potential for exposure (i.e., ingestion of on-site soil).” As we have stated previously, ATSDR should recognize the potential for children playing on the site, digging in soils and then putting their fingers in their mouths, riding bikes and breathing contaminated dust. Does ATSDR have data to suggest that the presence of “asbestos in the soil at this site is not likely to pose a public health hazard?”
Page 29, Paragraph 4
What is the relevance of blood lead screening on ten children by the city of Chicago? Were these children from this community? Where are their homes located? Do they attend Edward White Elementary School? Do they play on the site? More information is needed in order to make any sense of those data.
Page 30, Paragraph 1
ATSDR states that “none of the chemicals of concern identified at the Dutch Boy and International Harvester sites are known to have cause (sic) any of the above-indicated human health effects.” However, this does not negate the possibility that health problems occurred, but were not identified. It is known that nine cases of lead toxicity occurred. Is it not plausible that other, more subtle, health problems occurred, but were not identified?
If the sludge that seeps into homes is similar in chemical composition to that in the on-site manholes, then there is sufficient cause for concern. ATSDR should address the possibility that the “in-home” sludges contain PAHs.
Page 30, Paragraph 2
ATSDR correctly states that “sustained dermal contact with complex mixtures of PAHs (e.g., coal tar) can cause skin irritation.” Children are known to have played on the IH site. Photographs have been taken of the children surrounded by a cloud of dust. Is it possible that those children sustained dermal contact if they were playing regularly on the site? In addition, allergic skin rashes are not necessarily caused by dermal exposure alone; all possible routes of exposure, including inhalation and oral exposures, can result in systemic allergic responses, including skin rashes.
Page 30, Paragraph 3
There is a consensus amongst toxicologists that elevated lead levels may be associated with aggressive behavior. The statement that any “amount of aggressive behavior is normal” is suspect. ATSDR presents no evidence for the assertion that aggression among children in this neighborhood is the result of child abuse, low self-esteem, drugs, alcohol or mental illness. Community members viewed this statement as insulting and insensitive. We challenge ATSDR to tell a citizen in a public meeting that his/her concern about his/her child’s aggressive behavior may be linked, not to lead exposure, but instead to mental illness or child abuse! This paragraph must be eliminated.
Page 30, Paragraph 5
Terms like sarcoidosis and granulomatous should be defined.
Page 30-32, Child Health Initiative
We commend ATSDR for this entire section as it portrays a much more accurate picture of the risks associated with the DB and IH sites. The author of this section should be commissioned to edit/rewrite the rest of the document. However, we have several suggestions to improve this section.
Page 31, Paragraph 2, Line 5
“Metals” should be added to the list of contaminants to which children playing on the IH site may have been exposed.
Page 31, Paragraph 4 (Current Exposure, DB)
The presence of lead in off-site (roadway) soils needs to be mentioned.
Page 32, Paragraph 2
Children may be exposed to any chemicals in the black oily sludge until that material is removed.
Page 32, Conclusions
Page 32, Bullet Item 1, #1
There is no evidence to suggest that significantly elevated blood lead levels were limited to those individuals exposed while on-site.
Page 32, Bullet Item 1, #2
PAHs were not sufficiently high as to cause any adverse health effects—because of the uncertainty over historic levels of contamination and historic exposures.
Page 32, Bulleted Item 2, #2
The lack of vegetation during the winter months creates the potential for contaminated dust to be blown from the site into residential areas. Additionally, the lack of vegetation during the winter months creates the potential for contaminated dust to be blown from the site into residential areas.
Page 32, Bulleted Item 2, #3
Proper air monitoring will not reduce exposure, proper safety precautions will.
Page 33, Bullet Item 1
On what basis is the statement made that “past exposures to these on-site contaminants are not likely to have caused any health effects?” The problem is that those data do not exist. Additionally, the lack of air quality data needs to be addressed.
Page 33, Bullet Item 4
On what basis is the statement made that “off-site exposures to site related contaminants do not appear to have been associated with any identifiable public health hazard in the past?” While the effects may not have been identified, the hazards clearly have been documented. There is no basis on which to make the statement that there is not “any health hazard likely to exist now or in the future.” In fact, the data suggest otherwise.
Page 34, Item 2
Details on the topics to be presented during any community education efforts are warranted.
Page 35, Item 1
Maintaining the fence around the site should be mentioned.
Additional recommendations:
· There is an urgent need to determine the concentrations of lead in the air around the fences, in the residential and school areas, and on the sites. The concentration of lead in the dust in the classrooms of the Edward White Elementary School and in area houses should also be determined as soon as possible. Air samples should also be obtained for other contaminants, including the PAHs, asbestos and various volatile organic chemicals that might be present at the GRO- and DRO-contaminated soils. Air samples should be take in houses when black oily sludge backs up in the sewer, especially since one Advisory Council member stated that his house reeks of a petroleum-like odor for several days after the sludge backs up in his basement.
· The infiltration of the black oily sludge in residential houses should be stopped.
· An effective community wide program to test children’s blood lead and to examine the relationship between aggressive behavior, and other possible causative factors ATSDR has suggested on page 30, needs to be implemented.
· Currently children and other residents having free access to the lead-contaminated soils along the railroad could be exposed to undesirable amounts of lead. The lead-contaminated dust and soils can be carried to their homes. This area should be should be identified as hazardous, public access to the area should be stopped, and a public health advisory warning should be issued.
· A plan to determine the body burdens of lead in women of reproductive age and in children needs to be developed as soon as possible.
· Additional analysis for PCBs on the IH site is warranted to determine the fate of the PCBs that were found in 1987, but not in 1995.
· Residents in the homes that have had black oily sludge back up in their basements should be examined for health effects potentially related to the chemicals that may be found in the sludge.
The Midwest Hazardous Substance Research Center, Michigan
State University.
Please contact us if you have any
comments or questions.