ATSDR - PHA - Indian Refinery - Texaco Lawrenceville, Lawrenceville, Lawrence County, Illinois

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PUBLIC HEALTH ASSESSMENT

INDIAN REFINERY - TEXACO LAWRENCEVILLE
(a/k/a. TEXACO INCORPORATED LAWRENCEVILLE REFINERY)
LAWRENCEVILLE, LAWRENCE COUNTY, ILLINOIS

TABLES

Table 1. Completed Exposure Pathways

Pathway Name Source Medium Exposure Point Exposure Route Receptor Population Time of Exposure Exposure Activities Estimated Number Exposed Chemicals

Waste material off the site Acidic site-related waste
Soil Waste
Soil Yards Dermal
Ingestion
Inhalation Nearby residents Past
Present
Future Outdoor recreation;
Gardening 100 PAHs

On-site waste material Waste;
Soil/dust;
Petroleum products Waste
Surface soil Soil,
Waste,
Debris on the site Dermal
Ingestion
Inhalation On-site workers;
Trespassers Past
Present
Future Working or trespassing on the site 50 PAHs

Contaminated Air Refinery operations Air Emissions from refinery operations Inhalation
Dermal On-site workers;
Nearby residents Past Working,
breathing outdoors 1,500 VOCs
PAHs
Asbestos

Table 2. Potential Exposure Pathways

Pathway Name Source Medium Exposure Point Exposure Route Receptor Population Time of Exposure Exposure Activities Estimated Number Exposed Chemicals

Groundwater Refinery Ground-water Private wells Dermal Ingestion
Inhalation Nearby residents Past?
Future Drinking, Bathing, & Other Uses 100 Refinery solvents

Fish Embarrass River Fish Eating fish Ingestion Fishers Past
Present
Future Eating contaminated fish 50 PAHs

FIGURES

Figure 1. Approximate Location of former Indian Refining Co. Site

Figure 2. Approximate Location of former Refinery, Indian Acres, Land Farm, and Tank Farms

ATTACHMENTS

ATTACHMENT 1

Comparison Values Used In Screening Contaminants For Further Evaluation

Environmental Media Evaluation Guides (EMEGs) are developed for chemicals based on their toxicity, frequency of occurrence at National Priority List (NPL) sites, and potential for human exposure. They are derived to protect the most sensitive populations and are not cut-off levels, but rather comparison values. They do not consider carcinogenic effects, chemical interactions, multiple route exposure, or other media-specific routes of exposure, and are very conservative concentration values designed to protect sensitive members of the populations.

Reference Dose Media Evaluation Guides (RMEGs) are another type of comparison value derived to protect the most sensitive populations. They do not consider carcinogenic effects, chemical interactions, multiple route exposure, or other media-specific routes of exposure, and are very conservative concentration values designed to protect sensitive members of the population.

Cancer Risk Evaluation Guides (CREGs) are estimated contaminant concentrations based on one excess cancer in a million persons exposed to a chemical over a lifetime. These are also very conservative values designed to protect sensitive members of the population.

ATTACHMENT 2

IDPH Responses to Comments Received During the Public Comment Period

MEMORANDUM

To: Ken Runkle, Illinois Department of Public Health

From: Carol Fuller, Community Relations Coordinator

Date: October 28, 1999

Subject: Comments about the Public Health Assessment for the Former Indian Refining- Texaco Lawrenceville Superfund Site

Thank you for the opportunity to comment on the updated health assessment for the Indian Refining Company site. Below are comments in order of pages/paragraphs.

P. 1, Summary In the second paragraph, it says that sampling of off-site groundwater (residential wells) has not identified the presence of site-related contaminants. While this is true for the most part, remember that we did find levels of arsenic in two off-site wells during the July 1996 samples. One was at 58.2 ug/L and the other was at 60.ug/L. Arsenic has also been found in site soils at various levels, We don't know yet whether the arsenic in the off-site wells came from the site or is naturally-occurring.

Response #1: Although the arsenic in the two wells may be related to the site, IDPH believes that the arsenic is more likely naturally occurring. The arsenic levels detected in these two wells are consistent with levels of naturally occurring arsenic found in similar wells elsewhere in the state.

P.1, third paragraph It states that the RI "will not be completed until all aboveground structures are removed." Both U.S. EPA and Illinois EPA have made the point with Texaco that the RI/FS work should begin in some areas right away and will not be dependent upon the demolition work being complete. The RI work may not be final until after the removal of both above ground and below ground structures. However, some operable (remediation) units may have been completed by then.

Response #2: IDPH changed the document accordingly.

P.1, fourth paragraph Direction of groundwater flow: We can say that the flow "generally" appears to be south-southeast at the near surface, but there may be local variations."

Response #3: IDPH changed the document accordingly.

P.2, second paragraph Re: logistics of the refinery. Language- here refers to the refinery as being in a "light industrial and residential area." Is this statement referring to county zoning? If so, it would be better to state that the "site sits in an area zoned to be"... It is otherwise misleading to call a refinery site "light industrial" and may elicit negative responses from residents who live near the site.

Response #4: IDPH changed the document accordingly.

P. 2, third paragraph Instead of saying "the Refinery wraps around several residential neighborhoods," perhaps it would be more accurate to say that "the Refinery borders..." Figure 2 is referred for reference of the neighborhoods. Could you add some street names to the map in Figure 2? It would provide clarity and orientation to the reader. The last sentence of that paragraph, add after "Lawrence Addition," Indian Creek and Meadow Lake Heights, other residential areas, are approximately..."

Response #5: IDPH made appropriate changes to the text. We feel street names would clutter Figure 2 and distract from the purpose of showing the different areas of the site.

P.2. Under "Site History," you may want to add that American Western Refining Acquisitions, L.C. is a company created by and is a joint venture between Clark Oil Trading Company and Blastco Services Co. AWR Acquisitions purchased all aboveground structures and equipment during the bankruptcy auction in 1998. American Western, L.P. owns the land upon which the aboveground structures rest.

Response #6: IDPH does not believe the addition of this information is necessary for the purposes of a public health assessment.

P.3, third paragraph after "Illinois EPA issues a seal order," you may want to add "in June 1996."

Response #7: IDPH changed the document accordingly.

P.3, fourth paragraph Suggest you begin the third sentence with "Acidic tar-like waste was excavated ..." In the fourth sentence, add after "subsequently purchased" all but one, and after "Hickory Streets," add as well as some properties on the south side of Hickory Street between Third and Fifth Streets.

Response #8: IDPH changed the document accordingly.

P. 3, last paragraph In the second line it states "contained elevated levels of naturally-occurring arsenic." We haven't actually established whether the arsenic is naturally-occurring or may be site-related.

Response #9: See response #1.

P. 4 - under "Demographics" Where did you get the figure of 7,900 people? We have been told by the mayor and others in Lawrenceville that the population is less than 5,000. Do census data disagree with that? In the second sentence, if you state 300 homes, that would be within � mile of the site. Within one mile from the site would be more like 800 homes or apartments. When we mailed the residential survey for soil sampling, we used streets from Hickory north to Maple and from Third west to 14th Street. The mailing list was 797 residences.

Response #10: IDPH changed the document to reflect more current demographic data.

P. 4 The last sentence under "Demographics" says that many residents near the site have spent most of their lives in that area. That is not really correct. While we have some residents within four or five blocks to the north of the site that have lived there 30 or 40 years, most of the population close to the site (in the trailer community) is more transient in nature. Many people have lived where they presently reside less than a year or from one to three years. You could say, "The Refinery was a major source of employment for many local citizens. Some residents who live within one-half mile of the site have spent most of their lives in that general area."

Response #11: IDPH changed the document accordingly.

P. 4 Under "Discussion," in the second paragraph, you talk about "thresholds of toxicity." That is a tough concept for most citizens. Could you say instead - "The comparison values are used only to screen for contaminants that should be evaluated further. Contaminants found at levels greater than these values do not mean that adverse health effects will result."

Response #12:
IDPH changed the document accordingly.

P. 4 - Last paragraph After "environmental medium," add (e.g, soil, water or air). After "3) a point of exposure," add (contact).

Response #13: IDPH does not believe these changes are necessary to convey the message.

P.5 - Fourth sentence, second paragraph After "on-site demolition activity," add current owner hired "licensed asbestos abatement contractors." Delete "have been on the site," and leave "to remove the ACM."

Response #14: IDPH changed the document accordingly.

P. 5 - Groundwater section, first paragraph You are saying that no sediment samples have been taken at the river. Illinois EPA took a few sediment samples during December 1996. Also, a few samples of the river (surface water) have been taken at the City's storm sewer outfall. Instead of saying "biota samples," could you say fish or other wildlife?

Response #15: IDPH changed the document accordingly.

P. 5 - 2nd paragraph under Groundwater You may want to add "four" in front of "private wells." After "Many wells are shallow, sand-point wells ranging in depth from 10 to 18 feet," add (new sentence) "Others ranged from 60 to 120 feet deep." At the end of the paragraph add (new sentence) "Most residents in the Indian Creek and Meadow Lake Heights subdivisions also have private drinking water wells."

Response #16:
IDPH changed the document accordingly.

P. 6 - First paragraph under "Soil" The statement is not correct about "Most sampling activities were conducted off the site to identify any impacts to soils in nearby residential areas." Off-site samples were taken at the City-owned property find the sediments along the river as well as in residential yards. Additionally, the statement may lead readers to assume that no on-site sampling has been performed. Most of the samples taken for HRS Scoring purposes for the National Priorities List were taken on the site.

Response #17: IDPH changed the document accordingly.

P. 6 - Last paragraph, fourth sentence After "Exposure was," add also. Toward the bottom of the last paragraph, you are saying that "trespassing would probably be rare." It is actually easy to access the site from the river side, which is unfenced. One may also walk across the river on the railroad trestle onto the site. Additionally, the gates to the City property are open during the day. Children or others may walk onto that property and around the treatment plant to access contaminated areas.

Response #18:
No change was made. IDPH believes accessing the site from the river or the railroad trestle would not be a common activity. When the city property is open during the day, employees should be present, so access to this area by the general public should be controlled.

P. 7, second paragraph After "Individuals stated that the ash etched the paint on houses and cars and caused skin irritation," suggest add (new sentence) "The ash emissions also led to respiratory irritation including asthma events."

Response #19: IDPH changed the document accordingly.

P. 7, third paragraph "Material containing elevated levels of PAHs has been identified in four yards..." End of third sentence - replace "area" with "properties."

Response #20: IDPH changed the document accordingly.

P. 7, fourth paragraph Second sentence: Instead of "Shallow," you may want to say, "Some shallow (sandpoint wells, 10 - 1 8 feet deep) and some deeper wells (50 to 120 feet deep) are near the south side of the Refinery and near the tank and land farms west of Highway 1." In the third sentence, change "released" to "releasing," since the release is ongoing, and it is being actively captured or intercepted. Last sentence - once again, we are saying private wells do not contain site-related contaminants. However, the arsenic could be site- related. (U.S. EPA CERCLA document on acceptable data for risk assessment, quality assurance, sampling methods, etc. Appendix II, "Common Pollutants Generated by Seven Industries." Under Industry 7: Petroleum Refining, we find arsenic listed as compound ranked 86 and found in air, water, and soil.

Response #21: IDPH changed the document accordingly.

P. 8, second paragraph, fourth sentence When you say "IDPH assumes..." do you mean that IDPH performed risk assessment screening calculations for the contaminants found to date and took children into account for the exposure scenario?

Response #22: Yes.

P. 8, third paragraph suggest replace "pH" with "nature."

Response #23: IDPH changed the document accordingly.

P. 8, last paragraph, third sentence After "PAHs can accumulate in," suggest add "human and animal" before "fat tissue..." Near the bottom of that paragraph, after "No good human data are available about," suggest delete "how and." The sentence continues, "how much PAH exposure causes disease in humans," suggest add "or in precisely what way."

Response #24: IDPH does not believe these changes are necessary to the convey the message.

P. 9, Under Health Outcome Data, last sentence

Suggest add at the end, "for the population size."

Response #25:
IDPH does not believe this change is necessary.

P. 9, Under Community Health Concerns, first sentence

Suggest replace "several times" with "numerous times." Under #2, Middle of the paragraph - After "Contact with," suggest add "some of" before "the material."

Response #26: IDPH changed the document accordingly.

P. 10 #4 - Middle of first paragraph After "and in the workplace may contribute to cancer," suggest add "in a very small way -or- "to a small extent."

Response #27: IDPH does not believe this change is necessary.

P. 10 #6 - First sentence After "biochemical changes in the brain," suggest replace "because" with "due to." Third from last sentence - "Odors associated with current demolition activities at the Refinery should be minimal." In light of the recent problems with release of caustic odors/gases, perhaps it would be best to leave this sentence out. Since Labor Day, we have had another rash of complaints about odors. On 10/26/99, the Bureau of Air received a letter and petition signed by citizens of Lawrenceville complaining about the odors/fumes emanating from the City's storm water storage lagoon.

Response #28: The IDPH response to concern #6 refers to current odors at the Refinery. We are not referring to the city sewage treatment plant. No changes were made.

P. 11, first full paragraph under #7

Suggest replace "Outside of the workplace" with "Except for workplace-related exposures."

Response #29: IDPH believes the sentence as written is clear. No change was made.

P. 11, #9, third sentence Replace "could be taken" with "were Permitted to be taken." Next sentence, replace "When odor complaints began" with "After numerous citizen complaints and at two fish kills."

Response #30: IDPH changed the document accordingly.

P. 11, last paragraph, first sentence Replace "dilution rate should be crated" with "dilution rate should occur in the storm water storage lagoon (20 million gallons)." (Perhaps there should be something about the permit having been issued based on the sampling data for the caustic water that was submitted with the permit application?) At the end of the same sentence, replace "allowable limits" with "the City's permitted limits." In the last sentence add "in May 1999" after air sampling screening instrument.

Response #31: IDPH changed the document accordingly.

P. 12, "Conclusions" last sentence

Add "sampling" between environmental and data.

Response #32: IDPH changed the document accordingly.

P. 12, "Recommendations" - First bullet

Add "or the responsible party(ies)" after USEPA and Illinois EPA.

Response #33: IDPH did not change this recommendation. Although the responsible parties may actually be tasked to perform the sampling activities, it is the responsibility of USEPA and Illinois EPA to provide oversight to ensure the activities are done properly.

P. 14, first bullet Delete the "d" in "included."

Response #34: IDPH changed the document accordingly.

Table of Contents

Agency for Toxic Substances and Disease Registry, 1825 Century Blvd, Atlanta, GA 30345
Contact CDC: 800-232-4636 / TTY: 888-232-6348

Department of Health and Human Services

Pathway Name	Source	Medium	Exposure Point	Exposure Route	Receptor Population	Time of Exposure	Exposure Activities	Estimated Number Exposed	Chemicals
Waste material off the site	Acidic site-related waste Soil	Waste Soil	Yards	Dermal Ingestion Inhalation	Nearby residents	Past Present Future	Outdoor recreation; Gardening	100	PAHs
On-site waste material	Waste; Soil/dust; Petroleum products	Waste Surface soil	Soil, Waste, Debris on the site	Dermal Ingestion Inhalation	On-site workers; Trespassers	Past Present Future	Working or trespassing on the site	50	PAHs
Contaminated Air	Refinery operations	Air	Emissions from refinery operations	Inhalation Dermal	On-site workers; Nearby residents	Past	Working, breathing outdoors	1,500	VOCs PAHs Asbestos

P. 1, Summary	In the second paragraph, it says that sampling of off-site groundwater (residential wells) has not identified the presence of site-related contaminants. While this is true for the most part, remember that we did find levels of arsenic in two off-site wells during the July 1996 samples. One was at 58.2 ug/L and the other was at 60.ug/L. Arsenic has also been found in site soils at various levels, We don't know yet whether the arsenic in the off-site wells came from the site or is naturally-occurring.
Response #1:	Although the arsenic in the two wells may be related to the site, IDPH believes that the arsenic is more likely naturally occurring. The arsenic levels detected in these two wells are consistent with levels of naturally occurring arsenic found in similar wells elsewhere in the state.
P.1, third paragraph	It states that the RI "will not be completed until all aboveground structures are removed." Both U.S. EPA and Illinois EPA have made the point with Texaco that the RI/FS work should begin in some areas right away and will not be dependent upon the demolition work being complete. The RI work may not be final until after the removal of both above ground and below ground structures. However, some operable (remediation) units may have been completed by then.
Response #2:	IDPH changed the document accordingly.
P.1, fourth paragraph	Direction of groundwater flow: We can say that the flow "generally" appears to be south-southeast at the near surface, but there may be local variations."
Response #3:	IDPH changed the document accordingly.
P.2, second paragraph	Re: logistics of the refinery. Language- here refers to the refinery as being in a "light industrial and residential area." Is this statement referring to county zoning? If so, it would be better to state that the "site sits in an area zoned to be"... It is otherwise misleading to call a refinery site "light industrial" and may elicit negative responses from residents who live near the site.
Response #4:	IDPH changed the document accordingly.
P. 2, third paragraph	Instead of saying "the Refinery wraps around several residential neighborhoods," perhaps it would be more accurate to say that "the Refinery borders..." Figure 2 is referred for reference of the neighborhoods. Could you add some street names to the map in Figure 2? It would provide clarity and orientation to the reader. The last sentence of that paragraph, add after "Lawrence Addition," Indian Creek and Meadow Lake Heights, other residential areas, are approximately..."
Response #5:	IDPH made appropriate changes to the text. We feel street names would clutter Figure 2 and distract from the purpose of showing the different areas of the site.
P.2.	Under "Site History," you may want to add that American Western Refining Acquisitions, L.C. is a company created by and is a joint venture between Clark Oil Trading Company and Blastco Services Co. AWR Acquisitions purchased all aboveground structures and equipment during the bankruptcy auction in 1998. American Western, L.P. owns the land upon which the aboveground structures rest.
Response #6:	IDPH does not believe the addition of this information is necessary for the purposes of a public health assessment.
P.3, third paragraph	after "Illinois EPA issues a seal order," you may want to add "in June 1996."
Response #7:	IDPH changed the document accordingly.
P.3, fourth paragraph	Suggest you begin the third sentence with "Acidic tar-like waste was excavated ..." In the fourth sentence, add after "subsequently purchased" all but one, and after "Hickory Streets," add as well as some properties on the south side of Hickory Street between Third and Fifth Streets.
Response #8:	IDPH changed the document accordingly.
P. 3, last paragraph	In the second line it states "contained elevated levels of naturally-occurring arsenic." We haven't actually established whether the arsenic is naturally-occurring or may be site-related.
Response #9:	See response #1.
P. 4 - under "Demographics"	Where did you get the figure of 7,900 people? We have been told by the mayor and others in Lawrenceville that the population is less than 5,000. Do census data disagree with that? In the second sentence, if you state 300 homes, that would be within � mile of the site. Within one mile from the site would be more like 800 homes or apartments. When we mailed the residential survey for soil sampling, we used streets from Hickory north to Maple and from Third west to 14th Street. The mailing list was 797 residences.
Response #10:	IDPH changed the document to reflect more current demographic data.
P. 4	The last sentence under "Demographics" says that many residents near the site have spent most of their lives in that area. That is not really correct. While we have some residents within four or five blocks to the north of the site that have lived there 30 or 40 years, most of the population close to the site (in the trailer community) is more transient in nature. Many people have lived where they presently reside less than a year or from one to three years. You could say, "The Refinery was a major source of employment for many local citizens. Some residents who live within one-half mile of the site have spent most of their lives in that general area."
Response #11:	IDPH changed the document accordingly.
P. 4	Under "Discussion," in the second paragraph, you talk about "thresholds of toxicity." That is a tough concept for most citizens. Could you say instead - "The comparison values are used only to screen for contaminants that should be evaluated further. Contaminants found at levels greater than these values do not mean that adverse health effects will result."
Response #12:	IDPH changed the document accordingly.
P. 4 - Last paragraph	After "environmental medium," add (e.g, soil, water or air). After "3) a point of exposure," add (contact).
Response #13:	IDPH does not believe these changes are necessary to convey the message.
P.5 - Fourth sentence, second paragraph	After "on-site demolition activity," add current owner hired "licensed asbestos abatement contractors." Delete "have been on the site," and leave "to remove the ACM."
Response #14:	IDPH changed the document accordingly.
P. 5 - Groundwater section, first paragraph	You are saying that no sediment samples have been taken at the river. Illinois EPA took a few sediment samples during December 1996. Also, a few samples of the river (surface water) have been taken at the City's storm sewer outfall. Instead of saying "biota samples," could you say fish or other wildlife?
Response #15:	IDPH changed the document accordingly.
P. 5 - 2nd paragraph under Groundwater	You may want to add "four" in front of "private wells." After "Many wells are shallow, sand-point wells ranging in depth from 10 to 18 feet," add (new sentence) "Others ranged from 60 to 120 feet deep." At the end of the paragraph add (new sentence) "Most residents in the Indian Creek and Meadow Lake Heights subdivisions also have private drinking water wells."
Response #16:	IDPH changed the document accordingly.
P. 6 - First paragraph under "Soil"	The statement is not correct about "Most sampling activities were conducted off the site to identify any impacts to soils in nearby residential areas." Off-site samples were taken at the City-owned property find the sediments along the river as well as in residential yards. Additionally, the statement may lead readers to assume that no on-site sampling has been performed. Most of the samples taken for HRS Scoring purposes for the National Priorities List were taken on the site.
Response #17:	IDPH changed the document accordingly.
P. 6 - Last paragraph, fourth sentence	After "Exposure was," add also. Toward the bottom of the last paragraph, you are saying that "trespassing would probably be rare." It is actually easy to access the site from the river side, which is unfenced. One may also walk across the river on the railroad trestle onto the site. Additionally, the gates to the City property are open during the day. Children or others may walk onto that property and around the treatment plant to access contaminated areas.
Response #18:	No change was made. IDPH believes accessing the site from the river or the railroad trestle would not be a common activity. When the city property is open during the day, employees should be present, so access to this area by the general public should be controlled.
P. 7, second paragraph	After "Individuals stated that the ash etched the paint on houses and cars and caused skin irritation," suggest add (new sentence) "The ash emissions also led to respiratory irritation including asthma events."
Response #19:	IDPH changed the document accordingly.
P. 7, third paragraph	"Material containing elevated levels of PAHs has been identified in four yards..." End of third sentence - replace "area" with "properties."
Response #20:	IDPH changed the document accordingly.
P. 7, fourth paragraph	Second sentence: Instead of "Shallow," you may want to say, "Some shallow (sandpoint wells, 10 - 1 8 feet deep) and some deeper wells (50 to 120 feet deep) are near the south side of the Refinery and near the tank and land farms west of Highway 1." In the third sentence, change "released" to "releasing," since the release is ongoing, and it is being actively captured or intercepted. Last sentence - once again, we are saying private wells do not contain site-related contaminants. However, the arsenic could be site- related. (U.S. EPA CERCLA document on acceptable data for risk assessment, quality assurance, sampling methods, etc. Appendix II, "Common Pollutants Generated by Seven Industries." Under Industry 7: Petroleum Refining, we find arsenic listed as compound ranked 86 and found in air, water, and soil.
Response #21:	IDPH changed the document accordingly.
P. 8, second paragraph, fourth sentence	When you say "IDPH assumes..." do you mean that IDPH performed risk assessment screening calculations for the contaminants found to date and took children into account for the exposure scenario?
Response #22:	Yes.
P. 8, third paragraph	suggest replace "pH" with "nature."
Response #23:	IDPH changed the document accordingly.
P. 8, last paragraph, third sentence	After "PAHs can accumulate in," suggest add "human and animal" before "fat tissue..." Near the bottom of that paragraph, after "No good human data are available about," suggest delete "how and." The sentence continues, "how much PAH exposure causes disease in humans," suggest add "or in precisely what way."
Response #24:	IDPH does not believe these changes are necessary to the convey the message.
P. 9, Under Health Outcome Data, last sentence	Suggest add at the end, "for the population size."
Response #25:	IDPH does not believe this change is necessary.
P. 9, Under Community Health Concerns, first sentence	Suggest replace "several times" with "numerous times." Under #2, Middle of the paragraph - After "Contact with," suggest add "some of" before "the material."
Response #26:	IDPH changed the document accordingly.
P. 10 #4 - Middle of first paragraph	After "and in the workplace may contribute to cancer," suggest add "in a very small way -or- "to a small extent."
Response #27:	IDPH does not believe this change is necessary.
P. 10 #6 - First sentence	After "biochemical changes in the brain," suggest replace "because" with "due to." Third from last sentence - "Odors associated with current demolition activities at the Refinery should be minimal." In light of the recent problems with release of caustic odors/gases, perhaps it would be best to leave this sentence out. Since Labor Day, we have had another rash of complaints about odors. On 10/26/99, the Bureau of Air received a letter and petition signed by citizens of Lawrenceville complaining about the odors/fumes emanating from the City's storm water storage lagoon.
Response #28:	*The IDPH response to concern #6 refers to current odors at the Refinery. We are not referring to the city sewage treatment plant. No changes were made.*
P. 11, first full paragraph under #7	Suggest replace "Outside of the workplace" with "Except for workplace-related exposures."
Response #29:	IDPH believes the sentence as written is clear. No change was made.
P. 11, #9, third sentence	Replace "could be taken" with "were Permitted to be taken." Next sentence, replace "When odor complaints began" with "After numerous citizen complaints and at two fish kills."
Response #30:	IDPH changed the document accordingly.
P. 11, last paragraph, first sentence	Replace "dilution rate should be crated" with "dilution rate should occur in the storm water storage lagoon (20 million gallons)." (Perhaps there should be something about the permit having been issued based on the sampling data for the caustic water that was submitted with the permit application?) At the end of the same sentence, replace "allowable limits" with "the City's permitted limits." In the last sentence add "in May 1999" after air sampling screening instrument.
Response #31:	IDPH changed the document accordingly.
P. 12, "Conclusions" last sentence	Add "sampling" between environmental and data.
Response #32:	IDPH changed the document accordingly.
P. 12, "Recommendations" - First bullet	Add "or the responsible party(ies)" after USEPA and Illinois EPA.
Response #33:	IDPH did not change this recommendation. Although the responsible parties may actually be tasked to perform the sampling activities, it is the responsibility of USEPA and Illinois EPA to provide oversight to ensure the activities are done properly.
P. 14, first bullet	Delete the "d" in "included."
Response #34:	IDPH changed the document accordingly.