PUBLIC HEALTH ASSESSMENT
FREEPORT, STEPHENSON COUNTY, ILLINOIS
September 22, 2004
Attachment 1: Approximate Location of Bordner Manufacturing Company
ATSDR 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 Priorities List (NPL) sites, and potential for human exposure. They are not action levels but are comparison values. They are developed without consideration for carcinogenic effects, chemical interactions, multiple route exposure, or exposure through other environmental media. They are very conservative concentration values designed to protect sensitive members of the population.
Reference Dose Media Evaluation Guides (RMEGs) are another type of comparison value. They are developed without consideration for carcinogenic effects, chemical interactions, multiple route exposure, or exposure through other environmental media. They are very conservative concentration values designed to protect sensitive members of the population.
Cancer Risk Evaluation Guides (CREGs) are estimated contaminant concentrations based on a probability of one excess cancer in a million persons exposed to a chemical over a lifetime.
Maximum Contaminant Levels (MCLs) have been established by the U.S. Environmental Protection Agency (USEPA) for public water supplies to reduce the chances of occurrence of adverse health effects from use of contaminated drinking water. These standards are well below levels for which health effects have been observed and take into account the financial feasibility of achieving specific contaminant levels. MCLs are limits that public water supplies must meet, and they are enforceable by USEPA.
Lifetime Health Advisories (LTHAs) USEPA has established LTHAs for drinking water. LTHAs are concentrations of specific chemicals in drinking water that are not expected to cause any adverse, noncarcinogenic health effects over a lifetime (70 years) of exposure. These are conservative values that incorporate a margin of safety.
Attachment 3: Illinois Department of Public Health Memorandum Regarding Cancer in Stephenson County, Illinois, August 8, 2003 [PDF:274KB]
A copy of the draft Public Health Assessment for the Bordner Manufacturing Company site was available for public review and comment at Freeport Public Library, 100 E. Douglas Street, Freeport from June 16, 2004 to July 30, 2004. The following comments were received.
- Altho [sic] your report doesn't state it as such, there are some inaccuracies in just which companies and agencies were involved in the initial assessment and clean-up of the Bordner site clean-up. There are also conflicting reports over the prime contractor involved in the clean-up as well as jurisdictional claims by both the USEPA and IEPA.
The Health assessment states on page 4 that the USEPA initiated an immediate removal action at the request of the IEPA. This conforms to the 1995 report on the Bordner report. However the original report states that the USEPA requested the IEPA to do the initial assessment. It is such conflicting reports over the years on the Bordner site that this and other reports must be viewed.
IDPH uses documents available from Illinois EPA and USEPA to gather information about site history. The reports used by IDPH are cited at the end of the public health assessment. If individuals find conflicting information in the reports cited, that information should be reported to the agency that released the original, cited report.
- In the background report also on page 4 of this assessment, it states that the stored hazardous material was removed from site in Feb. 1993. This is not quite accurate. The material removed from the main building in Feb-Mar 1993 was stored in a storage building on site known as the "barn" until the materials could be made safe enough to be transported off-site. The storage building which is now heavily overgrown and in very poor shape, is still standing never the less. The building is also accesable [sic] to some degree. This is fact as I visited and photographed this building in April 2004.
The text states that, "Beginning in February 1993, stored hazardous materials and most of the dilapidated buildings were removed from the site." This does not imply that all materials and buildings were removed during the month of February, but rather that removal activities began in that month. It also states that "most" buildings were removed, not all.
- Also stated in the USEPA Removal Actions on page 5 of this assessment it states that the surface-soil contamination was removed and backfilled with clean soil. This is true up to a point. The contaminated soil was not removed off-site immediately, but stored on part of the original building foundation slab that was left after building demolition. This soil was still stockpiled on this slab when the heavy flooding hit in April 1993 and continued into summer 1993. Neither the USEPA nor IEPA could make an estimate of the potential contamination that may have resulted from contaminated material being migrated over the affected area, both on and off-site as well as into the natural current flow of the Pecatonica River. The best estimate is a 15-mile radius downriver from the point of contamination.
There is no way to reconstruct the effect flooding events of 1993 would have had on any contaminated soil being stored on the site. If contaminated soil was washed away by floodwaters, there is no way to know how that impacted downstream areas. Given the volume of floodwater, considerable dilution of any contaminated soil and sediment should have occurred. Surface soil sampling would characterize any impact on the immediate area.
- Also on page 5 under the Removal Action, it states that only limited soil samples were collected off-site. It also states that the testing did not show any elevated levels of cadmium, chromium, lead or zinc. However, most of these samples were taken north and west of the site. The flow of the flood waters would have been to the south and southeast, following the land elevations toward the river. Only two soil samples were taken on-site and not in the path of the floodwater flow.
When the flooding initially occurred, it would have spread north and west toward the residential areas. As the floodwater receded, they would have drained in a southerly direction toward the river. Sampling north and west of the site near residential areas helps characterize the area where people are most likely to be exposed.
- The drainage ditch that was located on the north end of the Bordner property was not cleaned in the same manner as other parts. The shallow water table depth (i.e. 2 to 2-1/2 feet) prevented the usual removal of contaminated soil and sediments. Different methods were tried, including pumping the groundwater into the sewer system. However, the groundwater continued to accumulate at the same rate as it was being pumped out until pumping was halted. It is for this reason that the present chain-link fence was installed surrounding the part of the site. How eever [sic], the groundwater still carries water-soluble metals and chemicals. This groundwater will still migrate even with the fence in place. The fence is only to keep out animals and humans. However, not all of the contaminated soils are within the fence perimeter. There is an area southeast of the fence line that is marked off in yellow caution tape only.
Based on the surface topography of the area, groundwater would flow in a southerly direction from the site (toward the river). No residential wells exist south of the site. The fence keeps trespassers from coming into contact with any contaminated soil and sediment on the site.
- A point of note: there are 2 old underground cisterns (as referred to by the Freeport Water and Sewer Dept.) located on the Bordner property. The cisterns do not show up on any map or drawing of the Bordner site that I'm aware of. I also photographed these cisterns in April 2004. I have been informed that the Freeport Water and Sewer Dept. has since filled in the cisterns with gravel; as they constituted not only a possible contamination hazard, but also a safety hazard to residents in the area as both lacked any kind of lid to prevent anyone from falling in. However, I don't believe that the cisterns were tested environmentally. Nor can I confirm that they were indeed filled in.
IDPH is not aware of any cisterns on the property and have referred this comment to Illinois EPA so they can determine whether or not any cisterns are, or were ever present.
- In summation: Due to the years of conflicting reports about the clean-up of the Bordner site, and the on-going controversy of environmental contamination within the Taylor Park area, not only with the Bordner site but also with other industrial sites, I would hesitate to approve any report or assessment. In your own report, it is stated on page 8 that no one currently uses or is exposed to on-site groundwater. This would lead the reader to assume that no health hazard exists. However, as I stated earlier, the groundwater still will migrate out of the area, the fence notwithstanding. Also, the continued existence of the former chemical storage building, which may also be a contamination source point presents a possible health risk. The undisclosed cisterns on the Bordner property should also be tested (if possible) for water contamination.
A proposed Phase 1 environmental evaluation is to be conducted by the City of Freeport and supporting agencies within in [sic] the next 30 days. The entire Taylor Park area will be evaluated, including the Bordner site. Until such an evaluation is completed, I cannot accept the fact or your assessment that there is no ongoing health risk.
As stated previously, groundwater would flow in a southerly direction from the site (toward the river). No residential wells exist south of the site. No one would be drinking water from any abandoned cisterns on the site.
IDPH prepares public health assessments based on available data. If additional data is collected at the Bordner Manufacturing site, IDPH will review the data and give a health-based opinion.
- We note a change from the earlier version that is inappropriate. The last sentence in the "Background" section on page 4 states that, "Access to the site is unrestricted." The initial release version more accurately stated that access to the site was unrestricted.
The text has been changed to reflect the current conditions of the site.
- Additionally, it is unclear from the text in the second bullet of the "Recommendations" section on page 10 whether Illinois EPA will conduct additional sampling or if sampling is only being considered at this time.
IDPH recommends sampling for metals on properties adjacent to the Bordner Manufacturing site. This recommendation is under consideration by the Illinois EPA Site Assessment Unit.
- If levels of contaminants sampled exceed ATSDR Comparison Values, which values are presumably health risk-based standards, can this data support a conclusion of no expected adverse health effects? We suggest that more information or analysis be included in the report to demonstrate why, as IDPH concludes, the site and areas near the site do not have the potential to cause adverse health effects. Such a conclusion appears to be inconsistent with the information contained in Tables 2, 3, and 4.
ATSDR comparison values are a screening tool used to select chemicals of interest for further evaluation. Exceeding a comparison value does not mean that adverse health effects will result, but rather that further evaluation of the chemical is necessary. IDPH further evaluates the chemicals of interest by evaluating potential and completed exposure pathways and then using dose calculations to determine whether or not health effects could occur from exposure to that chemical. The Exposure Analysis section details this process and the conclusions for the chemicals of interest at the Bordner Manufacturing site.
- The report provided a background section at page 4, which states that public water is available to the school and to all residents of the area. The report does not indicate the source of the water for the public water supply system, or that the school is using this source of water. Apparently, some homes are not using the public water supply system.
The text has been changed to reflect that the school and area residents are connected to the public water supply. All public water supplies are tested on a regular basis for chemical and bacterial contamination.
- The report indicated that the disposal of plating waste was to the ground surface and into a drain that discharged directly into the ditch located north of the facility. We propose that the report describe the chemical composition of the plating waste. It is important that the analysis of the samples include all of the chemicals present in the waste stream. We also recommend that the report specify the methods used to analyze the various samples. Arsenic, cadmium, chromium, and lead are hazardous waste under the TCLP test methods.
Illinois EPA ensures that samples are tested for appropriate chemicals depending on the history and use of the site in question. The specific chemicals tested for and the methods of analysis can be found by obtaining a copy of the Illinois EPA CERCLA Expanded Site Inspection for Bordner Manufacturing Company. It is the first reference listed after the conclusion of the public health assessment.
- The report indicated in the purpose section at page 4 that the actions recommended for the site are intended to reduce or prevent potential health effects and to identify any areas for which additional data are needed to assess potential health effects. We concur with this above stated purpose and suggest that an assessment of the health effects of the site and nearby areas be held in abeyance until a complete and full delineation and characterization of the site and nearby areas have been completed, and the nature and extent of the contamination have been determined.
Complete and full delineations at hazardous waste sites can take long periods of time to complete. IDPH prepares public health assessments based on available data and also helps identify any additional data that needs to be collected. When additional information on a site is obtained, or additional data collected, IDPH reviews the data and gives a health-based opinion.
- The report indicated at page 5 that in December 2002 the Illinois EPA analysis of samples from the site detected elevated levels of several site related metals in subsurface soil, sediments and shallow groundwater. The analytical results were not included in the report but the summary indicated that on-site groundwater contained elevated levels of cadmium, lead and chromium. These are all RCRA toxic metals. Notably absent from the list of chemicals found at the site are chemical plating solutions such as cyanide which are typically used in cadmium plating. We recommend that the report include a list of chemicals used not only in the plating process but also in the preparation of the articles before plating.
IDPH lists only chemicals that exceed ATSDR comparison values in the public health assessment. A complete list of chemicals and sample results can be found in the Illinois EPA CERCLA Expanded Site Inspection for Bordner Manufacturing Company. It is the first reference listed on page 11 of the public health assessment.
- The report's summary indicated that no chemicals of interest were found in the private well water located upgradient of the site. It is not expected that upgradient wells would be affected by the site. The report does not indicate whether there are any private wells downgradient of the site, and whether they have been affected. The third paragraph of the summary states, in relevant part, that, off-site sampling of soil and private wells has been limited, and properties adjacent to the site have yet to be characterized. We believe that this information is critical and is needed to support an opinion on the safety of the areas near the site. Any downgradient private water wells being used as a potable water source should be identified.
The land use south of the site (downgradient) is a rail line and a farm field. No residential wells exist south of the site and north of the Pecatonica River. If additional information is obtained, or additional data collected, IDPH will review the data and give a health-based opinion.
- We concur with the recommendations in the summary for sampling of soil in the residential areas adjacent to the Bordner Manufacturing site to determine whether former on-site contamination has affected nearby properties. It may be advisable to postpone rendering an opinion on the potential adverse health effects from these residential properties until after this sampling has been completed.
IDPH will continue to monitor site activities and will give a health-based opinion on any future data. Additional documents will also be prepared as necessary to update the status of the site.