GRAND TRAVERSE COMMONS/BUILDING 50 AREA
[a/k/a GRAND TRAVERSE COMMONS (GTC50)]
TRAVERSE CITY, GRAND TRAVERSE COUNTY, MICHIGAN
The federal Agency for Toxic Substances and Disease Registry and the Michigan Department of Community Health (MDCH) have a cooperative agreement for conducting assessments and consultations regarding potential health hazards at toxic chemical contamination sites within the State of Michigan. The Michigan Department of Environmental Quality (MDEQ), Superfund Section, has asked the MDCH to evaluate any health risks associated with several properties included in the Brownfield Projects throughout Michigan.
The U.S. Environmental Protection Agency defines Brownfields as "abandoned, idled, or under-used" industrial and commercial facilities where expansion or redevelopment is complicated by real or perceived environmental contamination. Local governmental entities have asked the MDEQ to conduct environmental assessments of the Brownfield properties in their jurisdiction. The MDEQ has consulted with the MDCH concerning public health aspects of these assessments.
The MDCH health consultation for a Brownfield property includes consideration of the following fundamental questions:
- Are there any imminent or urgent threats to public health associated with the property?
- Does the proposed future use of the property pose any long-term public health hazard?
- What specific actions, if any, are necessary to make the property safe for future use?
- Is there enough information available to answer these questions, and if not, what additional information is needed?
The conclusions and recommendations provided in an MDCH health consultation pertain only to human health hazards identified for the property under review given the intended future land use. An MDCH health consultation may not be used to demonstrate compliance with the requirements of the Michigan Natural Resources and Environmental Protection Act, 1994 PA 451, as amended, or the administrative rules promulgated there under.
The Grand Traverse Commons is a 500-acre tract located near the southwest side of TraverseCity, Michigan. The Grand Traverse Commons/Building 50 Area (GTC50) is a 35-acre parcelof that tract which includes the main building of the former Traverse City State Hospital. TheGrand Traverse Commons is currently owned by the non-profit Grand Traverse CommonsRedevelopment Corporation (GTCRC), which envisions redeveloping the entire 500-acre areainto a mixed residential and light commercial community.
Environmental sampling of the GTC50 property revealed concentrations of various chemicalsof concern greater than the corresponding Michigan Department of Environmental Quality(MDEQ) criteria. The only compound with the potential to cause adverse health effects at theGTC50 is lead. Currently, because there is no access restriction, children, especially thoseenrolled at the daycare and childcare centers on the property, could be exposed to unsafe levelsof lead in the surface soil. However, it is unlikely that children would regularly frequent theareas in which the exceedances were located. If residential units are built on the property,pregnant women and children residing in those homes could be at increased risk for exposure tolead. Until more complete characterization of the soil and redevelopment plans are known, thesite is classified as posing no apparent public health hazard.
It is recommended that the extent of lead contamination at the GTC50 be better characterizedand that the GTCRC have asbestos-containing materials, and lead-based paints contained orremoved. Parents of and caregivers for children at the daycare and childcare centers should beinformed of the presence of lead at the property, the hazards associated with exposure, andsteps to reduce children's exposure to lead.
The Michigan Department of Environmental Quality (MDEQ) has asked the MichiganDepartment of Community Health (MDCH) to evaluate the health risks associated with theGrand Traverse Commons/Building 50 Area (GTC50) property as part of their BrownfieldRedevelopment Assessment (BFRA) of the property.
The GTC50 is located at 1200 West 11th Street, Traverse City, Grand Traverse County,Michigan (Figure 1). The parcel is on the western city limits of Traverse City, and alsoincludes some land outside the city in Garfield Township. Adjacent properties include amedical campus to the north; city, county, and state properties to the east; a wetland to thesoutheast; the campus area of the former state hospital to the south; and woodlands to the west. Kid's Creek flows northward approximately 350 feet east of the GTC50 east boundary. There isan open drain that enters the property from the west, passes between the buildings and underBuilding 50, then exits the property at the northeast corner. It is not clear where this drainempties, though it probably reaches to Kid's Creek.
The GTC50 property is a 35-acre portion of the grounds of the former Traverse City StateHospital, formerly known as the Traverse City Regional Psychiatric Hospital. The hospital wasa state-owned mental health institution that operated from 1885 to 1989, when it was closed aspart of the nationwide trend to de-institutionalize the mentally ill. Building 50 (Figure 2),constructed in 1885, was the main building of the State Hospital. The property also includesseveral smaller outbuildings and the sites of several former structures. These service buildingsincluded a shop building, used by carpenters and other craftsmen, a laundry, a painting andglazing building, and an auto shop. According to fire insurance maps, some buildings wereenlarged or demolished over time, or the activity was moved to a different building (EDR2001).
In 1991, the governments of Traverse City and Garfield Township established the non-profitGrand Traverse Commons Redevelopment Corporation (GTCRC) to oversee the redevelopmentof the 500-acre Grand Traverse Commons, including the Building 50 Area. In 1993, the Stateof Michigan donated the land including the Building 50 Area to the GTCRC (MDEQ 2001a). The GTCRC and a community mental health organization currently occupy portions ofBuilding 50. Several community service organizations, including a women's resource center,childcare and daycare centers, and an arts center occupy a chapel on the east end of the GTC50property (Building 43; see Figure 2) (Traverse Group 2000). Outdoor children's play areas areon the northwest side of the chapel and the southwest side of Building 80 across Eleventh Streetsouth of the chapel (MDEQ 2001b). The GTCRC plans to redevelop the entire area as a mixedresidential and light commercial area, with a town square in the midst of the Building 50 Area(Spielberg 2001).
In early 2000, the GTCRC contracted for a preliminary facility assessment and environmentalsite assessment (ESA) of the GTC50 property. The contractor carried out the fieldwork on May24, 2000. This assessment included a search of available records concerning the property, aninspection of the buildings on the property, collection of samples of suspected asbestos-containing material (ACM) from Building 50, collection of samples of subsurface soil from theproperty, collection of surface water from a drain and a sump in separate rooms in Building 50,and a soil sample from a second sump in a tunnel below the building (Traverse Group 2000). Analytical results of the samples are summarized in Table 1 and discussed below.
In October 2000, the GTCRC asked the MDEQ to perform a BFRA on the Building 50 Area. The MDEQ carried out the fieldwork for the BFRA on April 10-12, 2001. They collectedsamples of surface soil, subsurface soil, groundwater, surface water, and sediments on and nearthe property (MDEQ 2001a, 2001b). The purpose of collecting samples was to characterizepotential contamination in the various media, to determine the potential for contaminantmigration from possible source areas, and to evaluate potential health and safety concernsassociated with detected contaminants to those people on or near the property now or in thefuture. Analytical results of the samples are summarized in Tables 1-5 and discussed below.
The sampling results discussed in this consultation were taken from the available investigationsof the property, and are not adjusted for limitations or bias in the sampling programs. Thetables presented in this consultation provide concentration ranges for chemicals of concerndetected in the samples collected.
Chemicals of concern for this consultation were selected from those that were found in anyenvironmental media sampled at the property at a concentration above MDEQ Generic CleanupCriteria (MDEQ 2000). The MDEQ criteria are contaminant levels in environmental media thatare developed to be protective of human exposure and the environment under specific land-usescenarios (i.e., residential, industrial and commercial). These criteria are protective of frequentlong-term exposure. Therefore, contaminants at concentrations less than these conservativelevels are not expected to pose a public health hazard. Concentrations that exceed these levelswarrant further consideration to determine if a public health hazard is likely. For thisconsultation Residential and Commercial I criteria were used, since development plans for theproperty are for residential and light commercial use.
The MDEQ criteria used in the present Health Consultation include: Ambient Water QualityValues (AWQVs), Soil Direct Contact Criteria (DCC), Drinking Water Criteria (DWC), SoilCriteria Protective of Drinking Water (DWPC), Groundwater Surface Water Interface Criteria(GSI), Soil Criteria Protective of the Groundwater Surface Water Interface (GSIPC). They aredefined below:
AWQVs are levels in surface water that are considered protective of humans not using thewater body as a drinking water source and of aquatic and terrestrial life. The AWQV for agiven chemical is the most restrictive of the value protective of human health or terrestrial oraquatic wildlife for that chemical.
DCC are levels in soil that protect people from unacceptable exposure to contaminants throughincidental (unintentional) ingestion of soil and dermal (skin) contact with soil. ResidentialDCC are protective of both adults and children who may live on the property.
DWC are levels in groundwater that are considered safe for long-term daily consumption. Adverse aesthetic impacts (taste and/or odors) are taken into account for some hazardoussubstances. Residential DWC are protective of both adults and children who may live on theproperty. These criteria are only used at a site if groundwater is currently used as a source ofdrinking water or could be used as drinking water in the future.
DWPC are levels in soil that are not expected to contaminate groundwater at levels greater thandrinking water criteria. These criteria are based on models that describe how contaminants canleach from soil into groundwater that is used as a source of drinking water. These criteria areonly used at a site if groundwater is currently used as a source of drinking water or could beused as drinking water in the future.
GSI are levels in groundwater that are protective of receiving surface waters. The GSI pathwayis relevant to all land uses if there is a hydraulic connection between the groundwater and asurface water body.
GSIPC are levels in soil that are not expected to leach and contaminate groundwater at levelsgreater than the corresponding GSI. The soil-leaching pathway is relevant to all land uses ifthere is a hydraulic connection between the groundwater and surface water body.
During Phase II of the ESA in May 2000, the contractor for GTCRC collected a total of 15samples of subsurface soil (depths between 0-4 and 18-20 feet) from seven borings on theGTC50 property, in the "vicinity of the old shop building to the west of Building 50 (MDEQ2001b)." The samples were analyzed for selected metals (1), volatile organic compounds (VOCs;13 samples only), polycyclic aromatic hydrocarbons (PAHs), and polychlorinated biphenyls(PCBs; seven samples only). These data are summarized in Table 1. Only two samplescontained any chemical of concern at a concentration above relevant MDEQ Generic CleanupCriteria (MDEQ 2000). Naphthalene was found near the main entrance to Building 50 at aconcentration greater than its GSIPC. Naphthalene and zinc were found at concentrationsgreater than their respective GSIPC east of Building "0," in the area of the former laundry.
The contractor also collected water samples from a sump in an underground electrical room andfrom a floor drain in a basement pump room of Building 50. Additionally, the contractorcollected a sample of soil from a different sump in a tunnel beneath Building 50. Thesesamples were analyzed for the full range of analytes tested for in the subsurface soil samplesdescribed above. Several metals were detected in the water samples (2), and metals and PAHswere detected in the soil sample (3). There are no MDEQ Generic Cleanup Criteria for substancesfound in drains or sumps. The chemicals of concern in drains and sumps could originate fromsweepings of metal filings, deterioration of plumbing, or rinsing of floor spills. Therefore, theorigin cannot be known with certainty. A hydraulic connection from the sumps and drain togroundwater or surface water, in this case, is doubtful.
During the facility assessment of Building 50, the contractor found floor tile that analysisshowed to contain asbestos. The contractor assumed that pipe insulation seen in the basementand that fire doors throughout the building were likely also to contain asbestos, though samplesof the insulation were not collected for analysis. From the age of the building, some of thepaint used probably contained lead, though paint samples were not collected from the buildingfor analysis. Other potentially hazardous materials found in the building include presumablyPCB-containing ballast units for fluorescent lights, a concrete transformer pad where PCB fluidhad once leaked, refrigeration units containing chlorofluorocarbon or hydrochlorofluorocarbonfluids, old batteries, pigeon droppings, mold, and mildew (Traverse Group 2000).
During the BFRA in April 2001, the MDEQ collected and analyzed 12 samples of subsurfacesoil (depths ranging from 0-28 inches to 8-12 feet) from 12 borings on the GTC50 property(Figure 2). As shown in Table 1, several semi-volatile organic compound (SVOC) detectionsexceeded relevant MDEQ Generic Cleanup Criteria (MDEQ 2000). All of these exceedancesoccurred at the same sample location, SB11, near a building currently used by security staff(Building 66), in the area of the former shop building. The SVOC analytical detection limitsreported for the subsurface soil sample from SB11 were elevated, causing the relevant criteriavalues of some chemicals to be less than the limit of detection. From the resultant data, it isunclear whether the chemical was present in the sample and at what concentration. Almost allSVOCs analyzed for in the sample were suspect. This anomaly was probably due to the likelypresence of organic contaminants, such as would be found in total petroleum hydrocarbons. The validity of the analytical results for SB11 is therefore questionable.
Metals were detected at all of the soil boring locations. Five magnesium concentrations andone manganese concentration exceeded at least one of their respective criteria (Table 1). Themaximum concentration of magnesium, just greater than twice the DWPC, was estimated fromthe designated background sample at SB01, east of the main hospital building, in an open fieldwith no apparent history of previous building or activity sites, and may be questionable. Theother four exceedances are considered to be valid data. The manganese exceedances were only2% greater than the criteria and considered minimal. Any exceedance of criteria for zinc, asseen in the ESA results, was not observed in the MDEQ samples.
The MDEQ collected 30 samples of surface soil from the GTC50 property (Figure 3; see Figure2 for building numbers). Table 2 shows that various samples contained concentrations ofSVOCs or metals above MDEQ Generic Cleanup Criteria (MDEQ 2000). The criteriaexceedances of acenaphthene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene,carbazole, dibenzo(a,h)anthracene, fluoranthene, fluorene, indeno(1,2,3-cd)pyrene,naphthalene, and phenanthrene in the surface soil were observed primarily in samples from twolocations: SS04, south of the garage for Building 88, the former residence on the eastern-mostside of the property, and SS11, at the west end of Building 62, on the west side of the property,in the former fill area. As well, the concentration of phenanthrene in the sample taken fromSS03, near the playground west of Building 80 on the east side of the property, exceeded theGSIPC for that compound.
The highest concentrations of metals in GTC50 surface soils were detected in samples collectedprimarily to the west of Building 50, most commonly in the southwest corner of the property(SS16-18 and SS20), where paint spray booths and shops were formerly located, which wouldexplain the high concentrations of metals in this area (Figure 3; see Figure 2 for buildingnumbers). Several criteria exceedances for metals were observed also at SS05, at the northeastcorner of Building 50. Lead was the chemical of concern most frequently exceeding the DCCat these sample locations, with the maximum concentration almost seven times the DCC (Table2). Other metals detected above criteria were arsenic, barium, chromium, cyanide, magnesium,and zinc. The designated background surface soil sample, SS01, taken from the open field onthe east side of the property, exceeded only the GSIPC for cyanide.
The MDEQ constructed temporary monitoring wells in seven of the borings from which thesubsurface soil samples had been taken (Figure 4) (4). Groundwater samples from each well werecollected for analysis. As seen in Table 3, the only nonmetal concentration exceeding anyrelevant MDEQ Generic Cleanup Criteria, the U.S. Environmental Protection Agency (EPA)Safe Drinking Water Act Maximum Contaminant Level (MCL), or the U.S. EPA Safe DrinkingWater Act Secondary Maximum Contaminant Level (SMCL) was bis(2-ethylhexyl)phthalate, atup to eight times the criterion. Metals were detected in all of the samples. The highestconcentrations of most of the chemicals of concern were found in one sample, collected from awell west of the main building, TMW5, in the area of the former laundry, just north of theformer paint shops (MDEQ 2000, 2001b). The designated background groundwater sample,TMW4, exceeded the DWC for aluminum, iron, and manganese.
The MDEQ also collected sediment and surface water samples from four locations on or nearthe GTC50 property (Figure 5). Three locations were on a drain that runs through the property: one sample of each matrix was collected just outside the west property boundary (upstream), atthe northeast corner of Building 53 (the current laundry), and at a former retention basin in thenortheast corner of the property (downstream). The fourth sampling location, on Kid's Creek,was approximately 350 feet east of the property boundary, where Eleventh Street crosses Kid'sCreek (MDEQ 2001b). As shown in Table 4, none of the sediment samples contained anychemical of concern at a concentration above the Residential and Commercial I DCC. Table 5shows that none of the surface water samples contained any chemical of concern at aconcentration above the AWQV (MDEQ 2000, 2001b).
During the BFRA, the MDEQ did not sample for asbestos, in accordance with an agreementwith the GTCRC.
Access to the property as a whole is not restricted. There is vehicle traffic across the property,including a bus line. The grounds are fairly well maintained, and there are no physical hazardspresent, as noted in the ESA. Some of the buildings on the property are still in use, at least inpart. The unused buildings are generally locked, though some windows in these buildings arebroken, potentially providing access (Spielberg 2001).
To determine whether nearby residents are, have been, or are likely to be exposed tocontaminants associated with a property, the Agency for Toxic Substances and Disease Registry(ATSDR) and MDCH evaluate the environmental and human components that lead to humanexposure. An exposure pathway contains five major elements: 1) a source of contamination, 2)contaminant transport through an environmental medium, 3) a point of exposure, 4) a route ofhuman exposure, and 5) an exposed population. An exposure pathway is considered a completepathway if there is evidence that all five of these elements are, have been, or will be present atthe property. Alternatively, an exposure pathway is considered complete if there is a highprobability of exposure. It is considered a potential pathway if there is no evidence that at leastone of the elements above are, have been, or will be present at the property, or that there is alower probability of exposure. The table below lists the complete and potential pathways at theGTC50 property.
|Source||Environmental Transport and Media||Chemicals of Concern||Exposure Point||Exposure Route||Exposed Population||Time Frame|| |
|Previous operations on the property||Subsurface soil||Table 1||On-site excavations||Incidental ingestion, dermal contact, inhalation||Utility and construction workers||Past||Potential|
|Previous operations on the property||Surface soil||Table 2||On-site surface soil||Incidental ingestion, dermal contact, inhalation||Workers, customers, trespassers||Past||Complete|
|Previous operations on the property||Surface soil||Table 2||Dust from on-site surface soil||Incidental ingestion, dermal contact, inhalation||Nearby residents||Past||Potential|
|Previous operations on the property||Surface soil||Table 2||On-site surface soil||Incidental ingestion, dermal contact, inhalation||Future residents||Past||Incomplete|
|Previous operations on the property||Groundwater||Table 3||Nearby private wells (none known)||Ingestion, dermal contact, inhalation||Nearby residents||Past||Potential|
|Previous operations on the property||Groundwater||Table 3||On-site private wells (if installed)||Ingestion, dermal contact, inhalation||Future residents||Past||Incomplete|
|Previous operations on the property||Surface soil to surface water||Table 2, |
|Surface water bodies on and near property||Incidental ingestion, dermal contact, inhalation||Nearby residents, trespassers||Past||Potential|
|Previous operations on the property||Surface soil to surface water||Table 2, |
|Surface water bodies on and near property||Incidental ingestion, dermal contact, inhalation||Future residents||Past||Incomplete|
|Previous operations on the property||Surface soil to surface water to sediments||Table 2, |
|Surface water bodies on and near property||Incidental ingestion, dermal contact, inhalation||Nearby residents, trespassers||Past||Potential|
|Previous operations on the property||Surface soil to surface water to sediments||Table 2, |
|Surface water bodies on and near property||Incidental ingestion, dermal contact||Future residents||Past||Incomplete|
|Previous operations on the property||Surface soil or groundwater to surface water||Table 2, |
|Municipal surface water intakes||Ingestion, dermal contact, inhalation||Traverse City residents||Past||Potential|
Access to the GTC50 property is not restricted. Several organizations, including the GTCRC, achildcare organization, and a daycare facility, occupy parts of buildings on the property. Thechildcare and daycare facilities each have an outdoor play area adjacent to their buildings(Buildings 43 and 80). There is vehicle traffic, including a bus line, across the property. Graffiti on the buildings' walls indicates there has been trespass on the property (MDEQ 2001b,Spielberg 2001, Traverse Group 2000). Therefore, individuals regularly associated with theproperty have a high probability for exposure and are considered to have complete exposurepathways. Surface soil is the only medium involved in the complete pathway scenarios.
There is no information regarding utility or construction worker exposure to contaminants inthe subsurface soil at the GTC50 property. Assuming that appropriate personal protectiveequipment was, is, or will be used, exposure to this population is considered a potentialpathway. Because the validity of the data for the one subsurface soil sampling location withcriteria exceedances is questionable (see earlier discussion), there may be no chemicals ofconcern in this medium.
Nearby residents have been, are, or may be potentially exposed to particulate contaminantsgenerated by construction activities at the GTC50 site. Migration of the contaminants also canoccur via the groundwater (water levels in the temporary monitoring wells constructed by theMDEQ indicate that the shallow groundwater at the GTC50 property flows generally to thesoutheast), however there are no known private wells down-gradient from the site. Similarly,surface soil contaminants can runoff to surface water and, further, adhere to sediments. It ispossible that contaminants from the GTC50 site may enter the open drain on the property andend up in Kid's Creek, potentially exposing future and nearby residents. Currently, as shown inTable 4 and 5, there are no chemicals of concern detected in sediment or surface water.
Traverse City residents using the municipal water supply may have potential exposurepathways. East of the GTC50 property is a largely residential area of Traverse City, which issupplied by the municipal water system. This system uses water from Grand Traverse Bay,north-northeast of the property, on Lake Michigan. The primary intake is on the East Arm ofthe bay with an emergency intake on the West Arm of the bay (MDPH 1989). The open drainon the GTC50 property is presumed to empty into Kid's Creek. The groundwater at the sitemight discharge into Kid's Creek or Boardman Lake, 1.4 miles east of the property. BoardmanLake and Kid's Creek both discharge to the Boardman River, which flows into the West Arm ofGrand Traverse Bay. The available groundwater and surface water data (Tables 3 and 5) do notindicate that the groundwater contamination has migrated off the GTC50 property to Kid'sCreek. If it should, however, dilution from other streams and the Boardman River (aboveBoardman Lake), and the circulation of water in Grand Traverse Bay, will likely reduce theconcentrations of any contaminant from with the GTC50 property to below levels of healthconcern before the water reaches the emergency intake in the West Arm of the bay, much lessthe main municipal intake in the East Arm or the Northport municipal water intake at the northend of the bay. (The Northport intake is approximately 26 miles north of the property. Thesurface water distance from the property to the main Traverse City intake is approximately 40miles, because the water must flow around the Old Mission Peninsula (16 miles long), whichseparates the East and West Arms of Grand Traverse Bay.) In addition, the MDEQ Division ofDrinking Water and Radiological Protection (DWRP) monitors all municipal water systems andcan order appropriate remedial actions when any contaminant is found at a concentration aboveState of Michigan Drinking Water Standards, which generally are the U.S. EPA drinking water standards.
The contractor carrying out the preliminary facility assessment concluded that there was enoughACM present in Building 50 that the U.S. EPA would require specified asbestos-handlingremoval techniques be used before the building is renovated or demolished, as specified in theU.S. EPA's National Emission Standards for Hazardous Air Pollutants, Asbestos Revision(NESHAP). The preliminary facility investigation did not report that any of the ACMidentified was in a friable condition and shedding asbestos fibers (Traverse Group 2000). Mostintact ACM poses no health hazard with the matrix confining the asbestos fibers and preventingthem from entering human bodies. If the matrix is broken or becomes friable, this frees theasbestos fibers to enter the lungs of people in the vicinity of the fibers. Removal of the ACM ordemolition of the underlying structure is likely to result in breakage and liberation of the fibers,and the NESHAP removal techniques are designed to confine the free fibers and preventexposure of the workers or the public.
Similarly, lead-based paint sequesters the metal away from people, unless the paint startspeeling, a child chews on the painted material, or the paint is removed during renovation ordemolition. The preliminary facility investigation report suggests that some of the lead-basedpaint in Building 50 is peeling, though it does not offer any estimate of how much peeling lead-based paint there is (Traverse Group 2000). Potentially lead-based paint should be removedusing appropriate techniques to contain the removed paint and prevent it from coming intocontact with the workers or the public. Ingestion of large amounts of lead, such as eating lead-based paint flakes, could cause blood anemia, kidney damage, colic, muscle weakness, andbrain damage (ATSDR 1999).
Lead was detected in six surface soil and four groundwater samples at concentrations exceedingMDEQ criteria (Tables 2 and 3). Most of the exceedances occurred to the west of Building50, with one exceedance detected at the northeast corner of the building. While the DCC wasnot exceeded in the samples taken in the area of the childcare and daycare centers' playgrounds,there is currently no restriction of access to the remainder of the property. Although exposureto lead via incidental ingestion and dermal contact is possible, it is unlikely to occur frequentlysince children are not expected to spend any significant amount of time in the contaminatedareas under current conditions. It is believed that businesses and neighbors of the GTC50property use the municipal water supply, and it is not expected that future residents andbusinesses will be using groundwater for drinking water. Therefore, exposure to lead throughgroundwater is unlikely. If future development of the property includes the digging of a pond,there is a possibility that any lead in the surface soil surrounding the pond could leach into thesurface water, exposing individuals who may ingest that water, such as children playing in thepond. However, the concentration would be very diluted in the pond. As well, the frequency ofexposure to any chemicals of concern in pond water would be expected to be minimal and not,of itself, be expected to cause adverse health effects.
One surface soil sample exceeded the DCC and DWPC for arsenic (Table 2), which are basedon cancer effects (U.S. EPA 1998, ATSDR 2000). These criteria are calculated assuming alifetime (70 years) of exposure. (The soil sample did not exceed the ATSDR EnvironmentalMedia Evaluation Guide of 20 ppm, which is based on non-cancer effects and assumes a shorterexposure time.) The sampling location containing the arsenic exceedance was SS09, toward thewestern boundary of the GTC50 property. It is unlikely that the public would frequent this areato the extent that exposure would be problematic. Inhalation of inorganic arsenic may lead tocancer of the lung. Individuals inhaling dust generated on the property as a result ofconstruction or utility work may be at a slightly increased risk for developing lung cancer. However, the duration of such work and of the exposure resulting from it would be expected tobe minimal and not be expected to cause adverse health effects. Long-term ingestion of arsenicin drinking water may lead to cancer of the liver, bladder, kidney, skin, or lung. As discussedearlier, it is unlikely that current and future users of the property will obtain their drinking watersupply from groundwater. Therefore, it is unlikely that people will be exposed to arsenic in thismanner, should any arsenic leach from the soil into the groundwater.
For the other inorganic compounds detected at concentrations exceeding MDEQ criteria, thecriteria of concern deal with groundwater as drinking water, and, as discussed earlier, it isunlikely that groundwater is or will be used for drinking water at or near the GTC50 property. If a pond is dug on the property, there is a possibility that some of these chemicals may leacheither from the groundwater or the surface soil surrounding the pond into the surface water andthat individuals would be exposed to these compounds via incidental ingestion. However, it isexpected that the frequency of exposure to and concentration of any chemicals of concern inpond water would be minimal and not cause any adverse health effects.
The concentrations of various SVOCs in subsurface soil, surface soil, and groundwater samplesexceeded MDEQ criteria (Tables 1-3). As discussed earlier, the one subsurface soil sample(SB11) with exceedances was questionable in its validity as the reported detection limits forthat sample were elevated. The subsurface soil in that location must be better characterizedbefore it can be appropriately evaluated. Only two surface soils samples, SS04 and SS11,exceeded DCC values. Individuals exposed to mixtures of SVOCs and other compounds bybreathing the vapors or by dermal contact can develop cancer (ATSDR 1995). However, dueto the intermittent nature of soil contamination and the likelihood that exposure to contaminatedsoil would be infrequent, it is unlikely that inhalation of or dermal contact with SVOCs on theGTC50 property pose a health risk. The DWPC, GSIPC, DWC, and GSI were exceeded by anumber of SVOCs in the surface soil, but, as discussed earlier, it is not expected that currentand future users of the GTC50 property will be using groundwater for drinking water. If a pondis dug, there is a possibility that some of the SVOCs may leach from the surface soilsurrounding the pond or the groundwater into the surface water of the pond. However, it isexpected that the frequency of exposure to and concentration of any chemicals of concern inpond water would be expected to be minimal and not expected to cause any adverse healtheffects.
Children may be at greater risk than adults from exposure to hazardous substances at sites ofenvironmental contamination. They engage in activities such as playing outdoors and hand-to-mouth behaviors that may increase their intake of hazardous substances. They are shorter thanmost adults, and therefore they breathe dust, soil, and vapors closer to the ground. Their lowerbody weight and higher intake rate results in a greater dose of hazardous substance per unit ofbody weight. The developing body systems of children can sustain permanent damage if toxicexposures are high enough during critical growth stages. Even before birth, children areforming the body organs they need to last a lifetime. Injury during key periods of growth anddevelopment may lead to malformation of organs (teratogenesis), disruption of function, andpremature death. Exposure of the mother may lead to exposure of the fetus, via the placenta, ormay affect the fetus because of injury or illness sustained by the mother (ATSDR 1998). Inaddition, teenagers may accidentally wander or deliberately trespass onto or into restrictedlocations. The obvious implication for environmental health is that children can experiencesubstantially greater "doses" than adults to toxicants that are present in soil, water, or air.
Lead has been detected in surface soil at the GTC50 property at levels exceeding MDEQcriteria for direct contact with soil. Young children, particularly those under the age of fiveyears, and fetuses are sensitive to the neurodevelopmental effects of lead. These effects canoccur at low levels of exposure and can include slowed mental development and lowerintelligence later in childhood. The available evidence suggests that these effects will persistinto adulthood (ATSDR 1999). It is likely that children will continue to have unrestrictedaccess to the GTC50 property but, under current conditions, are unlikely to frequent areas withunsafe levels of lead. Women frequenting the property now or in the future, either as workers,customers, or residents, may be at risk for exposing their unborn children to lead in certain areas of the site.
Under current site conditions, the surface soil at the GTC50 property is classified as posing noapparent public health hazard. Although the soil in the area where the daycare and childcarecenters are situated does not appear to have levels of concern, unrestricted access to theremainder of the property could place children at an increased risk for exposure to lead. Additional soil sampling is necessary to fully identify the extent of lead contamination in someof these areas. However, it is questionable if children would routinely frequent the westernportion of the property, where the exceedances occurred.
The intended future use for the GTC50 property is mixed residential and light commercial. Assuch, the property poses an indeterminate public health hazard for the future. Additionalinvestigation into the extent of lead contamination in surface soil and the redevelopment plansof the property is necessary to determine if future residential yards will contain hazardous levelsof lead. New environmental data or information concerning the future use of this property may require future health consultations.
- The extent of lead contamination in the soil should be better characterized and the data related to any redevelopment plans in order to mitigate elevated levels in future residential areas.
- The GTCRC should plan to have the lead-based paint and asbestos materials as well as other hazardous material remaining in the old buildings contained or removed, if the buildings themselves are to remain. (The U.S. EPA policy is to contain ACM in place where feasible.) Whether or not structures are demolished, the containment/removal should be done in a manner consistent with preventing exposure of workers and the public to any materials hazardous to human health.
- Current users of the GTC50 property, especially the daycare and childcare centers,should be informed of the presence of lead in the surface soil and the health hazards associated with exposure to lead, especially for children. Parents and caregivers should take steps to prevent excessive exposure of children to soil in lead-contaminated areas, discouraging hand-to-mouth behavior and encouraging frequent hand-washing.
- It is not recommended at this time that blood lead testing be performed on children who attend the daycare or childcare centers. However, it may be conducted in the future if the community has health concerns.
- It is not recommended at this time that contaminated areas of the property be restricted. It is likely that children will frequent the play areas in the eastern portion of the GTC50 property rather than the western portion, where the exceedances were located. Also, the presence of a physical barrier might be seen more as a challenge or "invitation" than a warning. Until the soil contamination is more fully characterized and the redevelopment plans are known, infrequent exposure to chemicals of concern in the soil would not be expected to increase the risk of adverse health effects.
A copy of this health consultation will be forwarded to the owner of the GTC50 property. Asowner of the GTC50, the GTCRC should address the recommendations listed above.
The MDCH will be available to consult on the appropriateness and efficacy of future remedialactions.
If any citizen has additional information or health concerns regarding the Grand TraverseCommons/Building 50 Area property, please contact the Michigan Department of CommunityHealth, Environmental Epidemiology Division, at 1-800-648-6942.
ATSDR. 1995. Toxicological Profile for Polycyclic Aromatic Hydrocarbons. Agency forToxic Substances and Disease Registry, Division of Toxicology.
ATSDR. 1998. Agency for Toxic Substances and Disease Registry, Division of HealthAssessment and Consultation. Guidance on Including Child Health Issues in Division of HealthAssessment and Consultation Documents. July 2, 1998.
ATSDR. 1999. Toxicological Profile for Lead. Agency for Toxic Substances and DiseaseRegistry, Division of Toxicology.
ATSDR. 2000. Toxicological Profile for Arsenic. Agency for Toxic Substances and DiseaseRegistry , Division of Toxicology.
EDR (Environmental Data Resources, Inc.). 2001. Sanborn Fire Insurance Maps dated 1899,1904, 1910, 1920, 1929, 1946, and 1965.
MDEQ. 2000. Michigan Department of Environmental Quality. Memorandum to ERD staff,subject: Interim Environmental Response Division Operational Memorandum #18: Part 201Generic Cleanup Criteria Tables. June 7, 2000. Available at<http://www.michigan.gov/deq/0,1607,7-135-3311_4109_9846-20527--,00.html >.
MDEQ. 2001a. Michigan Department of Environmental Quality. Brownfields RedevelopmentAssessment Work Plan for Grand Traverse Commons/Building 50 Area. March 26, 2001.
MDEQ. 2001b. Michigan Department of Environmental Quality. Brownfields RedevelopmentAssessment Report for Grand Traverse Commons/Building 50 Area. September 27, 2001.
MDNR. 1991. Michigan Department of Natural Resources, Waste Management Division. Michigan Background Soil Survey. Revised April 1991.
MDNR. 1993. Howard, A., Michigan Department of Natural Resources, EnvironmentalResponse Division. Memo to staff, subject: MERA Operational Memorandum #15: DefaultType A Cleanup Criteria. September 30, 1993.
MDPH. 1989. Michigan Department of Public Health. Public Water Supply Intakes inMichigan. September 19, 1989.
Spielberg. 2001. Spielberg, J., MDEQ. Personal Communications. September 17, October 3,2001.
Traverse Group. 2000. The Traverse Group, for the Grand Traverse Commons RedevelopmentCorporation. Preliminary Facility Assessment and Environmental Site Assessment, Building50, Grand Traverse Commons. August 27, 2000.
U.S. EPA. 1996. U.S. Environmental Protection Agency, Office of Water. Drinking WaterRegulations and Health Advisories. EPA 833-R-96-001. February 1996.
U.S. EPA. 1998. Arsenic, organic (CASRN 7440-38-2). U.S. Environmental ProtectionAgency, Integrated Risk Information System.
Michigan Department of Community Health
Christina Bush, Toxicologist
John Filpus, Environmental Engineer
Robin Freer, Resource Specialist
Linda Larsen, Principal Investigator
ATSDR Regional Representative
Regional Services, Region V
Office of the Assistant Administrator
ATSDR Technical Project Officer
Division of Health Assessment and Consultation
Superfund Site Assessment Branch
This Grand Traverse Commons/Building 50 Area Health Consultation was prepared by theMichigan Department of Community Health under a cooperative agreement with the Agencyfor Toxic Substances and Disease Registry (ATSDR). It is in accordance with approvedmethodology and procedures existing at the time the health consultation was begun.
Alan W. Yarbrough
Technical Project Officer, SPS, SSAB, DHAC, ATSDR
The Division of Health Assessment and Consultation, ATSDR, has reviewed this public health consultation and concurs with the findings.
Chief, State Programs Section, SSAB, DHAC, ATSDR
1 Including arsenic, barium, cadmium, chromium, copper, lead, mercury, selenium, silver, and zinc.
2 Copper and zinc were detected in both samples; as well, chromium and silver were detected in the water sample from the sump.
3 The detected chemicals were acenaphthene, arsenic, barium, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, chromium, copper, dibenz(a,h)anthracene, fluoranthene, indeno(1,2,3-cd)pyrene, lead, mercury, naphthalene, phenanthrene, and zinc.
4 The soil boring sites corresponding to Temporary Monitoring Wells 1, 2, 3, 4, 5, 6, and 7 are SB01, SB03, SB07, SB04, SB09, SB10, and SB11, respectively.