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PUBLIC HEALTH ASSESSMENT

LANSON CHEMICAL COMPANY
EAST ST. LOUIS, ST. CLAIR COUNTY, ILLINOIS


ENVIRONMENTAL CONTAMINATION AND OTHER HAZARDS

The following tables list the chemicals found from the testing of various environmental media in and around the Lanson Chemical site. IDPH evaluated the chemicals identified in the remaining sections of the health assessment to decide if they pose a danger to public health. Because of the practical limitations associated with evaluating the many chemicals often found at a hazardous waste site, IDPH and ATSDR screen those chemicals with levels too low to affect exposed populations adversely and eliminate them from discussion.

The Agency for Toxic Substances and Registry (ATSDR) and other agencies have developed comparison values to select contaminants for further health evaluation. These include Environmental Media Evaluation Guides (EMEGs), Cancer Risk Evaluation Guides (CREGs), Reference-Dose Evaluation Guides (RMEGs), USEPA Lifetime Health Advisories for drinking water (LTHAs), and USEPA Maximum Contaminant Levels for drinking water (MCLs). The selection of a contaminant for further evaluation is based on consideration of all the following factors: 1) the concentration of the contaminant; 2) data quality and adequacy of the sampling plan; 3) comparison of environmental residues with appropriate comparison values; and 4) the health concerns of the community.

If a site-related contaminant exceeds a comparison value in any media or if no comparison value exists for the chemical, it is investigated further to decide if it poses a significant threat to public health. A chemical that exceeds these comparison values does not necessarily represent a threat to public health. That determination is based on the toxicity, and factors including levels, mobility, and persistence. However, the most important consideration is whether an exposure has occurred, is occurring, or will occur in the future. If exposure is occurring, the duration and frequency of exposure and the bioavailability of the chemical are considered.

The comparison values are selected from the following sources:

  1. EMEGs are media-specific (i.e., soil, air, water) comparison values developed by ATSDR for noncarcinogenic chemicals often found at hazardous waste sites. They are conservatively derived and intended to be protective of sensitive individuals exposed on a daily basis to chemicals in a specific media. EMEGs do not consider multiple routes of exposure, possible interactions, or carcinogenic effects. Only an EMEG is used for noncarcinogenic chemicals.
  2. CREGs are media-specific comparison values developed by ATSDR for carcinogenic chemicals that are often found at hazardous waste sites. They are also conservatively derived based on the occurrence of one added cancer case per million people exposed over a lifetime. CREGs do not consider multiple exposure, possible interactions, or noncarcinogenic endpoints.
  3. RMEGs are comparison values based on USEPA's Reference Doses (RfDs) or Reference Concentrations (RfCs). A RfD or RfC is the daily oral or inhalation exposure that is unlikely to result in adverse, noncarcinogenic effects over a lifetime. Unlike EMEGs or CREGs, which use media-specific contaminant concentrations, RMEGs are based on the absorbed dose from the various exposure routes, and so the evaluation requires additional steps. As with EMEGs, these are designed to be conservative and protective of sensitive individuals. They can take into account multiple routes of exposure; however, they do not consider chemical interactions or take into account carcinogenic effects.

The following comparison values are used only if EMEGs, CREGs, or RMEGs are not available:

  1. LTHAs are USEPA-derived levels for drinking water and represent concentrations to which individuals can be exposed daily for their lifetime without suffering adverse health effects. Again, these numbers are designed to protect sensitive individuals and take into account exposures from other sources and carcinogenicity. Chemical interactions are not assessed.
  2. MCLs are legal limits established by USEPA for potentially hazardous chemicals that sometimes occur in public water supplies. They are set at levels below which health effects are known to occur and are intended to prevent adverse health effects. MCLs take into account questions of economics, treatability, and detectability to modify the standards. Secondary MCLs have been established for residues that cause aesthetic problems (taste, odor, or discoloration) as opposed to health concerns.
  3. If a compound is detected that is potentially hazardous, occurs in high volumes, and has a strong probability of human contact, but lacks the comparison values above, IDPH can derive a comparison value independently. This is done by reviewing the toxicological literature to select the most appropriate data and applying this information with standard assumptions to derive the needed value.

Again, a chemical that exceeds a comparison value does not necessarily pose a threat to the public health. It merely indicates that further detailed evaluation of the potential exposure and hazard is warranted.

A. On-site Contamination

Surface Soil

In 1985, a USEPA contractor collected 2 samples in connection with the Site Inspection and Hazard Ranking Scoring process (Tables 1 and 2). These were surface soil samples taken from the southeast area of the site near the stormwater catch basin. This may have been an area of ponding, although it does not appear to be the lagoon area. The low levels found may have been because the entire area had been back-filled.

In conjunction with the RI/FS, an IEPA contractor collected six surface soil samples in 1990 for organic and inorganic analyses from soil near the loading dock and inside the bermed area containing storage tanks. Tables 3 and 4 present the chemicals detected, and Figure 6 gives a graphical representation of the total PCB contamination. Figure 7 shows surface soil sampling locations.

Because PCBs that undergo heat stress may form dioxins and furans, one surface soil sample (X1-SS07) was analyzed for dioxins and furans and was found to contain the equivalent of 0.43 parts per billion of 2,3,7,8-TCDD. The adult comparison value for dioxin is 0.7 parts per billion (ppb) (Table 5).

Following the remedial activity in December 1992, USEPA collected on-site grab and composite surface soil samples analyzed for PCBs. These samples were taken to determine the success of the PCB cleanup effort. Soil containing more than 10 parts per million PCBs was removed or covered. Table 6 presents the results of the analysis, and Figure 8 is a map of the sampling locations.

Sub-surface Soils

As part of the 1990 RI/FS, IEPA's contractor conducted soil borings in ten locations throughout the site to a depth of 25 feet (Figure 9). These borings were used to install groundwater monitoring wells (4) on the site and to characterize the site soils. Additionally, some borings were analyzed for chemical residues. Samples were collected every 2 feet in the top 10 feet (50) and every 5 feet in the underlying 15 feet (30) for a total of 80 samples. Of these, 21 samples were analyzed for PCBs, volatile and semi-volatile organic compounds (VOCs and SVOCs), and metals. From the 59 remaining samples, 2 additional samples were analyzed specifically for PCBs, and 6 samples were analyzed for VOCs (Table 8). The remaining samples were not analyzed.

One sub-surface soil sample (X1-SB05A) taken from a depth of 1.5 feet was also analyzed for dioxins and furans (Table 9). It contained fewer isomers and lower levels than the surface soil sample analyzed. This finding is consistent with a surface spill of heat-stressed PCB oils. The 2,3,7,8-TCDD equivalent in this sample was 0.009 ppb. The adult comparison value for dioxin is 0.7 ppb.

Sediment Samples

As part of the RI/FS, a sediment sample was collected from the accumulated material at the bottom of the on-site stormwater catch basin (Figure 10). Tables 10 and 11 present the analytical results of this sampling.

Concrete Samples

Concrete chip samples were collected from the loading dock where the PCB release reportedly occurred. The sample was a composite of three random sampling locations on the dock. Both Aroclor 1248 and 1254 were detected in the concrete sample and a duplicate of this sample. The average concentrations were 15.5 ppm for Aroclor 1248 and 13.5 ppm for Aroclor 1254.

Groundwater Samples

One round of groundwater sampling, associated with the RI/FS, was undertaken. Samples were collected from the four monitoring wells on the site. The results of these analyses are in Tables 12 and 13. Figure 11 shows the location of the monitoring wells and the level of total VOCs found in these wells.

Tank and Spill Sampling

As part of the 1992 site assessment process, the USEPA contractor sampled the contents of three inside tanks and the resin spill resulting from the vandalism (Figure 12). The samples were subjected to the Toxicity Characteristic Leaching Procedure (TCLP) tests to determine if they qualified as a hazardous waste. The TCLP test assesses the likelihood that the waste will escape into the groundwater if spilled or disposed on land. The four samples were analyzed for TCLP metals, VOCs, SVOCs, PCBs, total organic halides, BTUs, and flashpoint. The resin spill was positive for PCBs and cresols (1,200 and 51 ppm, respectively). The PCB content qualified it as a hazardous waste. Tables 14 and 15 show the results of the tank tests.

The regulatory limit was exceeded for benzene, tetrachloroethylene, trichloroethylene, cresols, and PCBs in this test. This qualified the waste in the tanks as hazardous and required special disposal.

B. Off-site Contamination

Surface Soil

USEPA collected 6 composited residential surface soil samples in August 1992 and analyzed them for PCBs, metals, and various organic chemicals. The samples were taken randomly from homes in the 2600-3300 blocks of Trendley Avenue. No PCBs above the detection limit (2 ppm) were found. Tables 16 and 17 present the USEPA sampling results for inorganic and organic chemicals that exceeded comparison values.

IEPA collected 16 surface soil samples for PCB analysis in October 1992 from yards and gardens of several homes near the Lanson site. No PCBs were found in any surrounding gardens or yards. However, four of the five sediment samples taken from a drainage ditch that flows northeast from the site across the area used for residential gardens showed low levels of Aroclor 1254 ranging from 0.19-0.54 ppm. Figure 13 is a map of IEPA's sampling locations with sample results shown.

IDPH conducted additional residential surface and sub-surface soil sampling in March 1993 (Figure 14). Soil was collected at one and six inches below the surface. Nine samples of residential yards were analyzed for PCBs and SVOCs. No PCBs were detected in any of the residential yards or gardens. However, a soil sample taken elsewhere in East St. Louis as background was found to contain PCBs (Aroclor 1254) at a level of 0.25 ppm. One sample taken from a cultivated field east of the site contained polycyclic aromatic hydrocarbons (PAHs) above the IDPH laboratory detection limit (0.4 ppm). The PAHs detected were phenanthrene (2.56 ppm), fluoranthene (6.6 ppm), and pyrene (7.7 ppm).

C. Quality Assurance and Quality Control

The sampling undertaken in the RI/FS is assumed to have been validated through the IEPA and USEPA contract laboratory quality assurance program. In the organic analysis of soil and groundwater, methylene chloride, acetone, chloroform, and various phthalates were detected in the laboratory blanks. These chemicals are commonly found in the laboratory, and their presence in the trip or field blanks at levels similar to those found in the samples suggests that their presence is probably due to laboratory contamination. Tentatively identified organic chemicals also found in blanks include 2-methyl-1-heptane, 4-methyl-3-pentene-2-one, and dimethylbenzene. While all these chemicals could have originated as laboratory contaminants, they are also consistent with the type of chemicals used at the Lanson Chemical site. Therefore, the possibility remains that these residues are associated with site activities.

Inorganic analysis of the samples taken in 1985 and 1990 had various parameters that failed to meet one or more quality assurance criteria. This may have caused the results to be biased high or low in some instances. Overall, however, the sampling protocols and analytical results provided data deemed to be of sufficient quality and reproducible enough to be judged as representative of site conditions.

D. Physical and Other Hazards

The fence on the south-southwest side is still down and the site is accessible at this point. The latest site visit also found evidence of trespass through a gap in the east-southeast fence. The main building has been partially dismantled, but could attract metal scavengers or other trespassers. The structural integrity of the building remains unknown and could be subject to collapse at some point in the future. Additionally, exposed metal edges could result in punctures, cuts, or scrapes. It is possible to climb on exposed structural steel and the loading dock area where the danger of a fall exists. The remedial action emptied the building of much of its contents, dismantled exterior tanks, removed and regraded surface soils, and removed drummed waste material. The stormwater sump is still present, although it has been mostly filled and is covered with a grate. An open pool of standing water of uncertain depth was observed near the loading dock. The ground was level and largely free of debris. The storage shed still stands and may be in use.

E. Other Environmental Exposures

The population near the Lanson Chemical site is in an area that has been highly industrialized for more than a century. As such, the residents are exposed to emissions from former and ongoing industrial operations. The primary route of resident exposure from operating facilities is from vapor, gases, mists, and particulates escaping into the air. Disposal of wastes to landfills, water bodies, or injection wells may also have the potential to cause exposure to neighboring populations. IDPH reviewed the USEPA's Toxic Chemical Release Inventory for the years available for the zip code containing the Lanson Chemical site (62207). Additionally, adjoining zip codes upwind of the Lanson Chemical site were also reviewed. This includes 62206 (Sauget and Cahokia - south and west of Lanson Chemical), 62205 (East St. Louis - north and east of Lanson Chemical), and 62201 (East St. Louis and Sauget - north and west of Lanson Chemical). Detailed information on releases by zip code is presented for 1991 and 1992 (Tables 18 - 22). Most materials were reportedly released into the air.


PATHWAYS ANALYSES

Several chemicals were found in soil, sediments, and groundwater at levels exceeding the comparison values used for screening purposes. These chemicals of interest are evaluated to decide if human exposure to site-related contaminants has occurred, is occurring, or is likely to occur. To determine whether the residents near the Lanson Chemical site have been, are being, or will be exposed to chemicals originating from this facility, IDPH evaluates the environmental and human elements that result in chemical exposure. An exposure pathway consists of five parts--

1) a source and release of contaminants;
2) contaminant movement through at least one environmental medium;
3) a point of human contact;
4) a route of human exposure; and
5) a population to be exposed.

All five components of an exposure pathway must be present to have a completed pathway. Without a complete pathway, no exposure exists, and without exposure there is no health hazard present.

Exposure pathways are either completed or potential. Completed pathways require that all five elements existed at one time or are currently present. In contrast, potential pathways indicate that at least one of the five components is missing, but could have existed, could exist, or might exist in the future. Potential pathways can be eliminated from further consideration if the site or contaminant characteristics make past, current, or future exposures unlikely.

The potential for human exposure to contaminants originating from the Lanson Chemical site is discussed in the following subsections. Tables 23 and 24 summarize the completed and potential pathways for exposure.

A. Completed Exposure Pathways

As previously discussed, the remediation conducted at the site removed contaminated surface soils and sediments, decontaminated the concrete loading dock and flooring, and partially dismantled and removed the building. Additionally, storage and process vessels were emptied, decontaminated, and scrapped. Drums containing waste liquids and solids were also disposed off the site. This action effectively eliminated many current or future exposure pathways for on-site contaminants. Completed exposure pathways, therefore, are associated primarily with past occurrences at the site.

The completed exposure pathways associated with the Lanson Chemical site include:

  • residential and worker exposure to chemical vapors and contaminated dust in the air during and after site operations;
  • worker and trespasser exposure to contaminated on-site surface soils, dusts, and building surfaces;
  • worker and trespasser direct contact with liquids and solids contained in process vessels and drums on the site;
  • remediation worker contact with contaminated surface and sub-surface soils, sediments, dusts, and building surfaces; and
  • residential exposure to contaminated off-site soil as the result of air deposition of dust and surface runoff of waste liquids from the site.

Air

Initial attention was drawn to Lanson Chemical as the result of odor complaints. Odors originating from the facility and from the sewers serving the facility were persistent and irritating enough for the city to threaten the facility with closure and for IEPA to take a regulatory interest. The reports of sewer explosions suggest a high vapor level in this confined space. The complaints occured mainly in the late 1970s, although solvent-like odors were apparent during IDPH's 1992 site visit. Given the type of operation and the physical behavior of the chemicals, it seems likely that odors would have been associated with the facility since it began in 1962, although the major odor complaints seem to center on facility operations after Morris Industries acquired it.

Presumably the odor problems abated somewhat after manufacturing ceased around 1980; however, the presence of solvents on the site in poorly maintained or leaking containers would suggest a constant vapor release into the air. Unfortunately, no data are available for air exposure either during or after the operation of the facility. The history of citizen complaints, observations of city and state officials, the physical and chemical characteristics of the solvents used on the site, and the presence of solvents in waste materials, sub-surface soils, sediments and groundwater suggest that exposure to releases of VOCs did occur. The end of manufacturing and the removal of stored wastes and surface contamination have effectively ended this exposure.

On-site Soil

Before remediation, surface soils were contaminated, primarily with PCBs and low levels of metals, solvents, dioxins, furans, and PAHs. During plant operations, workers were exposed to these contaminants through skin contact with soils and dusts and through incidental ingestion or inhalation of dusts caused by truck traffic and wind erosion. After closure of the plant, a mobile home on the property was reportedly used to house a day care facility. It is possible that children visiting or trespassing on the property were exposed to surface soil contamination. Younger children display significant hand-to-mouth behavior during play, making soil ingestion a significant route of exposure. Additional exposure through skin contact with soil and dust and inhalation of dust was also likely. Trespassing is supported by the fence openings, foot prints, and the vandalism before the USEPA emergency removal activities. The completion of the removal of contaminated soils effectively eliminates this exposure pathway.

Waste Material

Waste materials were abandoned on the site in tanks and drums following cessation of facility operations. Many of these vessels were leaking, and IEPA, USEPA, and their contractors observed pooled liquid and semi-solid wastes in their investigations. Workers would have been exposed to these materials through inhalation of vapors, dermal absorption from handling drums or cleaning up leaks or spills, and incidental ingestion following transfer of materials from hands to food or tobacco products. Similar exposures would have occurred to site trespassers or visitors, including children. The abandoned building, tank farm, and drums are attractive to children as play areas. Additionally, the former day care facility on the property, the incomplete fencing, and the nearby residential area suggest that the potential for exposure to children was likely. The fact that adult trespassers triggered the release of tanked waste by stripping valves off the tanks demonstrates at least a short-term direct contact and vapor exposure. As before, the removal of the tanked and drummed wastes has effectively eliminated this pathway.

Remediation Workers

The cleanup activities would have brought remediation workers into contact with contaminated surface and sub-surface soils, sediments, building surfaces, surface water, and tanked or drummed wastes. Remediation workers are required to wear personal protection including respirators, eye protection, gloves, boots, and chemical-resistant clothing. As such, their exposure should have been small and confined to some dermal absorption associated with any exposed area of the body. This, together with the short amount of time that they were actually on the site, would suggest a relatively low exposure potential. With remedial activity completed and the workers gone, this exposure no longer exists.

Residential Soil

Soil sampling conducted in residential yards and gardens detected low levels of chemicals including PCBs, PAHs, solvents, and metals. The PCBs were found in the sediments of the drainage ditch that crosses the vacant lot used for residential gardens northeast of the site across Piggott Street. PAHs were detected in garden soils southeast of the site and in the composited yard and garden samples. Trace amounts of solvents and metals were found in the soil samples collected by USEPA; however, since these were composited samples, the sample sites in which these residues actually occurred cannot be known with certainty. None of these residues were above cleanup standards, and no removal took place. Exposure to these residues could occur through skin contact with the soil through gardening activities, yard work, or play activities. Incidental inhalation exposure to dust can also occur to gardeners, residents, or children. Soil ingestion may also occur, although this is a more significant exposure route for young children due to their tendency to place non-food items and fingers in their mouths than for older children and adults for whom soil ingestion is largely accidental and incidental.

B. Potential Exposure Pathways

Sub-surface Soils

The sub-surface soils on the site remain contaminated with a variety of chemicals including VOCs, PAHs, PCBs, dioxins, and furans. The properties of the solvents promote their leaching into the soil followed by sub-surface movement. The fact that solvent contamination was found in some sub-surface samples, but not in the surface soil samples, supports the notion of movement of contaminants in the sub-surface from areas of surface waste disposal. This may also suggest that sub-surface samples represent former surface soil that has been covered in the past with fill. The other soil contaminants (PCBs, dioxins, furans, and PAHs) are relatively immobile in soil. Very little leaching into the sub-surface soils occurs with these chemicals unless solvents have mobilized them. This behavior is reflected in the observation that levels of these contaminants are higher in surface soils than in sub-surface soils.

The remediation of the surface soil probably removed a large amount of the contamination in the shallow sub-surface as well, although USEPA sampling still found PCBs above the surface soil cleanup standard of 10 parts per million after completing the surface removal. These areas were subsequently covered with clean fill and graded. Since the sub-surface contamination is confined to the site property, the potential exposure to sub-surface contaminants would be limited to individuals digging in or excavating site soils at depths below the clean fill. Such exposure might include skin contact with contaminated soil and incidental inhalation and ingestion of dusts. Since most of the sub-surface contaminants are VOCs, vapors may also be released from digging. Construction on the site seems unlikely since it is a hazardous waste site. Additionally, given the high water table in the area, extensive excavation for purposes other than soil removal would probably not be attempted. Since no future remedial action is planned for this site, soil excavation seems unlikely.

Groundwater

The site has contributed to the contamination of groundwater. The shallow groundwater (15-20 feet below the surface) beneath the site is contaminated with a variety of solvents similar to those detected in site soils and sump sediments. The most highly contaminated well (MW-4) is near the on-site stormwater sump. This supports the idea that this area became contaminated from surface water runoff and direct disposal of wastes into the sump.

The direction of groundwater flow would be expected to be westward toward the Mississippi River. However, limited testing of the wells suggested an easterly flow on one occasion and static conditions on a second. An easterly movement could result in a plume of contamination traveling off the site in the direction of the residential neighborhood. Monitoring wells (MW1 and MW2) east of the contaminated wells showed little contamination when tested in 1990, showing no appreciable movement of the plume in an easterly direction. There are no monitoring wells west of the contaminated monitoring well to allow determination of potential plume movement in that direction. If the plume moves to the west towards the river, future exposure is unlikely since that area is comprised largely of wetlands and industrial development. The few dwellings and businesses between the Lanson Chemical site and the Mississippi River in Sauget rely on the public water supply as opposed to private wells.

If the plume moves eastward toward the residential properties next to the site, two means of exposure are possible: contamination of private drinking water wells and infiltration of VOCs from the soil into homes. The existence of private wells in the neighboring areas is unknown, but seems unlikely due to the presence of the available public water supply. It is also unlikely that any new private wells would be drilled. If a private well did exist and became contaminated with VOCs, exposures would result from ingestion of drinking water, inhalation of vapors, and skin absorption from bathing or other domestic water uses. If a plume existed under housing, the rising vapors might penetrate homes through cracks or drains in the basement or slab flooring and expose residents through inhalation of vapors. Experience indicates the exposure is usually very low, but can occur. Both exposures, however, require the presence of a plume of contaminated groundwater off the site. As previously mentioned, the 1990 groundwater sampling found contamination confined largely to the area near the stormwater sump with no contamination in other monitoring wells between the site and the residential area. This would suggest that contaminated groundwater has not spread off the site to the east.

Based on this evaluation, the above-mentioned pathways are considered potential, although unlikely, sources of future exposure.


PUBLIC HEALTH IMPLICATIONS

A. Toxicologic Evaluation

The following discussion explores the potential for adverse health effects to occur in people exposed to the chemicals detected at the levels found in the environment. This evaluation considers both short-term and long-term health effects for both children and adults, including cancer. This final step of the assessment involves not only the level of the substances found in the various environmental media, but also the duration and frequency of exposure and the bioavailability of the substances. In other words, it is not enough simply to establish that someone has been exposed to a substance. One must also be exposed long enough and often enough to high enough levels to absorb sufficient amounts of the substance to do harm. For instance, we ingest a small amount of arsenic daily along with our food. In fact, a little arsenic may be essential for good health and growth. It is only when we ingest high levels in a short time that arsenic results in poisoning.

Polychlorinated Biphenyls (PCBs)

PCBs were the main chemicals of concern that led to the clean up of the Lanson Chemical site. High levels of PCBs were contained in the storage tanks (up to 1.3%), in the spilled resin (up to 0.12%), and in the soil next to the loading dock (3 to 240 ppm). PCB levels away from the facility were lower. Levels in the sediment of the drainage ditch northeast of the site were all below 1 ppm total PCBs. Mean soil concentrations of PCBs in the U.S. varies from less than 10 to 40 ppb (maximum level of 1.5 ppm). Urban areas, particularly near PCB sources, have had background levels between 0.02 and 12 ppm.

PCBs are a group of man-made chemicals that include more than 200 different compounds. A major source of their manufacture was the Monsanto plant in Sauget. They are very stable chemicals and were used for more than 50 years as heat exchange fluids in electrical equipment and as lubricants and hydraulic fluids. PCBs were marketed in the U.S. under the trade name Aroclor. They are classified by a four-number system, generally beginning in 12 and ending with the percent weight of chlorine. For instance, Aroclor 1260 is 60% by weight chlorine. The exception is Aroclor 1016, which contains 41% chlorine. Because of their wide use and improper disposal, PCBs are widely distributed in the environment. Because of their persistence and other chemical properties, PCBs tend to accumulate in living tissue. Most people have low levels of PCBs in the body largely as the result of exposure through the diet. People who work with PCB-containing equipment, live near PCB sources, or eat large amounts of contaminated foods (for instance, river fish like carp or catfish) may have higher than average PCB levels.

PCBs tend to bind very tightly to soil and are virtually immobile. They are not well absorbed by plants. In root crops, only small amounts of PCBs were taken up, and this was confined to the peel. Therefore, no particular hazard exists in growing crops in PCB-contaminated soil if the simple precaution of washing the fruits and vegetables and peeling root crops is taken. PCBs also display very low vapor pressure and do not escape into the air unless the soil they bind with is re-entrained as dust. PCBs are not well-absorbed across the skin, and their binding to soil reduces their absorption from the gut or lung. Studies have found that populations exposed to even highly contaminated soil show no appreciable increase in their PCB body burden as a result. Regulatory criteria dictate that soil containing more than 50 ppm PCBs be treated as hazardous waste. The cleanup level for site soils at Lanson Chemical was 10 ppm. In residential soils, cleanup levels for PCBs have ranged from 1 to 5 ppm. The Food and Drug Administration allows between 2 and 3 ppm PCBs in food products.

PCBs have been shown to cause cancer in experimental animals; however, not all PCB mixtures are carcinogenic. A reevaluation of earlier animal tests suggests that only Aroclor 1260 appears to increase the carcinogenic response. Additionally, the potency of the mixture is only 80% of that originally assumed by USEPA. Studies of workers exposed to high levels of PCBs have not provided strong evidence of PCB cancer risk to humans to date.

PCBs also cause non-cancer adverse health effects in animals. Liver damage, skin effects, reproductive toxicity, and developmental effects have been noted in animals given large doses of PCBs. In humans, however, the major symptom of PCB exposure has been chloracne, a persistent skin condition resembling teenage acne. Some studies have suggested developmental effects on children exposed to PCBs in the womb, but whether these observations are correct or significant is debatable. The levels currently found off the site and their location would not be expected to result in a significant exposure to area residents. The risks from these residues would be considered low. Since no Aroclor 1260 was found on or off the site, it is questionable whether a cancer risk from PCBs exists at all from this site. The higher levels found on the site in the past could have resulted in higher exposures; however, the bioavailability of PCBs in soil and the infrequent nature of residential contact with this soil probably reduces the significance of any potential exposure.

Past worker exposure may have been higher, and workers could have carried PCBs and other contamination home on their work clothing. However, studies of PCB workers have not identified any consistent health impacts (besides chloracne) even in individuals working with pure PCB oil. The import of this potentially higher exposure among Lanson Chemical workers or trespassers is uncertain, but could have slightly increased their risk.

Dioxins and Furans

Subjecting chlorinated chemicals to incomplete combustion forms chlorinated dibenzodioxins and furans. These chemicals are also unwanted by-products of the chemical processes that produce chemicals like PCBs. Dioxins and furans are chemically similar to PCBs and behave in the environment in much the same way. They tend to be persistent, although virtually immobile in soil. They will accumulate in living tissue if consumed and can be concentrated as they pass up the food chain. They are primarily found in soils and sediments but can be detected at low levels in the air, particularly if a source of combustion is nearby. They are not taken up well by plants but can enter the food chain through ingestion of soils or sediments by grazing or rooting animals or fish. Dioxins and furans are not well absorbed across the skin, particularly when bound to soil. Soil binding also decreases gastrointestinal absorption by at least 50%.

As with PCBs, many dioxin and furan congeners exist, each have differing degrees of toxicity. To assess the significance of the various congeners, USEPA developed a toxicity equivalence factor (TEF) approach in which the various congeners are weighted in reference to the most toxic congener, 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD). For Lanson Chemical, the TEF approach provided a 2,3,7,8-TCDD equivalence of 0.4 ppb for surface soil contamination. The congener mixture found at Lanson is consistent with a PCB mixture subjected to heat stress. PCBs at Lanson are largely confined to the surface soil, suggesting a past spill. Background dioxin levels reportedly range from less than 0.0002 to 0.004 ppb, although a background sample from the St. Louis area was reported at 0.12 ppb. The criteria for evacuating Times Beach, Missouri was 1 ppb, although the individuals who developed this level have recently said that it is too restrictive in light of later research.

Dioxins and furans cause cancer in experimental animals exposed to relatively low doses. Additionally, they seem to affect the immune, endocrine, hepatic, and reproductive system. Humans seem less sensitive to the effects of dioxin, however, than the experimental animals. Except for the chloracne also associated with PCBs and other chlorinated chemicals, most evidence linking low level dioxin and furan exposure with human health effects are equivocal. A recent large study of workers exposed to dioxin reported an association between high exposure and certain cancers (for instance, lung cancer) in workers. However, since dioxins and furans are unwanted by-products in chemical manufacture, it is unclear whether the dioxins and furans were responsible for the observations, or if it were other chemicals to which the workers were exposed, lifestyle choices (cigarettes), or some combination of exposures.

No off-site dioxin and furan analysis was done at Lanson Chemical. However, if the same relationship holds between the on-site and off-site dioxin and furan levels as between on-site and off-site PCB levels, then one would assume less than 0.001 ppb TCDD equivalents in off-site soil. This is consistent with urban background. While the higher levels found on the site could have resulted in higher exposure to workers and trespassers, the dioxins and furans are largely confined to the area contaminated as the result of the explosion and spill. This must be tempered with the knowledge that, like PCBs, the bioavailability of dioxins and furans bound to soil is extremely low. The worker exposure would be confined to the short interval between the reactor explosion (1978) and closing of the facility (1980), and trespasser exposure would be infrequent in nature.

As with PCBs, there is a limited potential for an increased cancer risk among individuals who contacted dioxin and furan contaminated soil or surfaces on the site on a regular basis. The actual degree of risk is unknown due to the uncertainties involved, but appears to be small based on the current evaluation.

Organic Solvents (VOCs)

Operations at Lanson Chemical involved the use of several organic solvents to make the resins and other commercial products. Inspection reports mention the presence of xylene, mineral spirits, naphtha, glycol ethers, butanol, vinyl acetate, isobutyl acetate, toluene, ethylbenzene, and butyl acrylate on the site or in dumping incidents.

The analysis of tank contents identified benzene, methyl ethyl ketone, tetrachloroethylene, trichlorethylene, and cresols. On-site sediments, sub-surface soil, and groundwater were found to be contaminated with 1,1-dichloroethylene, 1,2-dichloroethylene, 1,1-dichloroethane, 1,2-dichloroethane, 1,1,1-trichloroethane, 1,1,2-trichloroethane, trichloroethylene, benzene, ethylbenzene, xylene, 4-methylphenol, dibenzofuran, methyl ethyl ketone, 2-butanone, and tetrachloroethylene.

All solvents have the common property of high vapor pressure, which promotes their escape into the air. Heat will increase the amount and rate of solvent release to the air. In the air, they are attacked by light, moisture, and other chemicals, and may only last a few hours or days. Dumped onto the ground, a certain amount will evaporate into the air over a period of days, weeks, or months. Their mobility also allows them to enter groundwater where they may persist for many years. This behavior explains the complaints of odors that were associated with the site during and after its operation and the presence of solvents in the groundwater and sub-surface soils while only traces remained in site surface soils. Area residents were exposed to solvent vapors both as a result of their escape into the air from the facility processes and disposal and the penetration into indoor air as a result of discarded solvents following the sewer lines and the vapors entering the neighboring buildings. Since no air monitoring data exist, any assessment of exposure and risk must be largely qualitative.

At high levels, all solvents have similar effects on mammals, indicating the effect is most likely due to the solvent properties. These include eye, nose, and throat irritation, respiratory irritation, nausea, headache, loss of coordination, sleepiness, inability to concentrate, dizziness, and irritability. Some solvents can also produce cardiac arrhythmia at high levels. Many of these symptoms are consistent with complaints associated with the odors from Lanson Chemical. These symptoms generally disappear within a few minutes to a few hours after the exposure. Long-term exposure to solvents has resulted in reported neurotoxicity in some workers. Transient damage to other organ systems (e.g., skin, liver, kidney, etc.) has been associated with exposure to chemicals with solvent properties.

Certain solvents found on the site have been associated with cancer. Benzene is a known human carcinogen and increases the risk of certain forms of leukemia and other blood disorders. Tetrachloroethylene, trichloroethylene, and 1,2-dichloroethane have caused liver tumors in experimental animals, but adequate studies in humans confirming this risk are lacking. Effects on liver and kidneys have been noted in high dose animal studies; however no permanent effects have been seen in workers exposed to levels higher than those likely to be encountered environmentally from this site.

In this situation, the solvent exposure explains some or all of the acute effects and complaints seen in the population neighboring the Lanson Chemical site. The symptoms should have generally abated after the exposure ended, with little potential for permanent damage. The levels encountered in the air (indoors or outdoors) and the duration of potential exposure are unlikely to have been high enough to cause permanent injury to the liver, kidneys, or nervous system. Likewise, the levels encountered would not significantly increase the cancer risk to residents in the midst of the other air pollutants occurring in the same area. The cancers observed in the population are also generally not of the type associated or suspected with exposure to these solvents.

Metals

Surface and sub-surface soils, sediments, and groundwater were analyzed for metals. The levels of metals in soil and sediment are similar to those occurring naturally in U.S. and Illinois soils and are below levels considered hazardous for human health.

Lead was found at levels typical of urban soils due to industrial emissions, automotive emissions, and paint. Although lead can be a serious hazard (especially to children) and damage the nervous system, the levels found in and around Lanson Chemical are not sufficient to appreciably increase an exposed child's body burden of lead. These levels are not believed to present a hazard.

Cadmium, likewise, was slightly elevated over U.S. background levels, although Illinois soils tend to be higher than these national levels. Cadmium is also emitted from some upwind sources in Sauget. At high enough levels over a long enough period, cadmium can damage the kidneys. If encountered as a fume or dust in the workplace, cadmium has caused lung damage. It can accumulate in some food plants, particularly green, leafy vegetables. In this case, however, the levels encountered in soil are less than those that might raise a concern for human health. Since metals were not used in the industrial processes conducted at the site, it is unlikely that the metal levels found in area soils are attributable to the Lanson Chemical site, except perhaps for some used as paint pigments.

Polycyclic Aromatic Hydrocarbons (PAHs)

PAHs are a family of organic chemicals made up of three or more fused benzene rings. PAHs are generally associated with the incomplete combustion of fossil fuels. They are found in vehicle exhaust, asphalt, creosote, coal tar, charbroiled meats, cigarette smoke, soot, ash, and decaying vegetation. PAHs also occur naturally and are widespread in the environment. They tend to bind tightly to soil and are not very mobile in the environment. PAHs are not well absorbed by the body when bound to soil. They are also not readily taken up by plants and will degrade in time through the action of microbes. PAHs generally have a low vapor pressure and do not readily evaporate into the air, especially when bound to soil. Some PAHs are carcinogenic in animal studies and may be contributors to human cancers because of their occurrence in cigarette smoke (lung and bladder cancers), the diet (colorectal cancer), and the workplace (skin, lung, and bladder cancers). Specific PAHs implicated as carcinogens include benzo(a)pyrene, benzo(a)anthracene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, and chrysene, among others. There are few non-cancer effects associated with PAHs, although some effects on the blood-forming and lymph systems have been noted in experimental animals.

Typical urban soils can contain between 25 and 500 ppm total PAHs while rural and agricultural soils contain between 0.13 and 2.5 ppm. The sub-surface and surface soils in and around Lanson Chemical contained between 0.5 and 3 ppm total PAHs. These levels are not felt to pose an unusual risk to area residents. The likely source of PAHs in residential soils include area industries, automobile exhaust, residential trash burning, and decaying plant material.

Summary of Toxicological Evaluation

The probable release of organic solvents during and after the operating life of the facility is consistent with the reports of odors, sewer explosions, and acute health complaints among neighbors of Lanson Chemical. Without air monitoring results, establishing exposure levels, duration and frequency of exposure, and the exact agents comprising the exposure is difficult. It seems unlikely that this type of exposure could account for the type of diseases that concerns community members. Likewise, off-site exposure to the low-level soil contamination with metals, PAHs, or PCBs does not carry significant risk to the residents and again, would not account for the diseases of concern. Surface soil and building contamination may have resulted in higher exposure to workers or trespassers. This is particularly true for PCBs, dioxins, and furans. However, the significance of this exposure is reduced by the low bioavailability of these soil-bound contaminants, the short period over which exposure would have taken place, and the infrequent nature of that exposure. A slight increase in cancer risk to on-site workers and trespassers seems likely under worst-case conditions; however this is uncertain. The remediation of the site has removed tanked and drummed wastes as well as contaminated surface soil and building components. The risks posed by fire or tank failure and on-site contamination are thus eliminated.

B. Health Outcome Data Evaluation

Cancer Incidence

The IDPH Division of Epidemiologic Studies conducted a review of cancer incidences in the Lanson Chemical site zip code (62207) using the Illinois State Cancer Registry (ISCR). Cancer incidence is preferred over cancer mortality as a measure of health and cancer risk since not everyone who gets a cancer dies of it. ISCR has been collecting data since 1985, with hospitals reporting new cases as mandated by law. This reporting is considered 97 percent complete. Data are also shared between bordering states. In this case, Missouri provides data on any Illinois resident diagnosed with cancer in Missouri. This particular study was limited to data from 1986 to 1990. All cancer cases from the study area were grouped by tumor site, sex, and age. Race and sex-specific cancer rates from a comparison population were applied to each age group of the study population to obtain an expected number of cases for the 62207 zip code. In this case, the standard population was drawn from an African-American population in an area of Illinois with a similar population density and similar age and sex distribution as the study area. The observed number of cases was then compared with the expected number of cases.

The results of this evaluation did not identify a statistically significant excess for total or individual cancers in either sex. There were 104 male cases observed with 109 cases expected. In females, 115 cases were observed with 122 cases expected. The pattern of specific anatomic sites reported was also similar to that of all cancers reported to ISCR.

The types of cancers observed are not typically associated with environmental exposures. Stomach and colorectal cancers are most often dietary in origin. Likewise, breast, cervical, ovarian/uterine, and prostate cancers are most strongly influenced by hormonal and reproductive factors. Lung cancer is strongly associated with smoking, although certain occupational and environmental risk factors may play a role. Bladder and kidney cancer are also associated with smoking, alcohol use, and some occupations. Only a few cancers in a population are attributable to environmental risk factors, with the vast majority attributed to lifestyle choices (i.e., smoking, diet, alcohol, and reproductive factors), and occupation or other factors.

Most cancers have long latency periods that are often measured in decades. For example, cancers that are now appearing had their origin 10 to 20 or more years ago and result primarily from continual and multiple low-level insults to the body. A single high exposure or intermittent moderate exposure is usually insufficient by itself to significantly increase any individual's cancer risk. Access to medical care and early diagnosis and treatment are important means to lower cancer mortality. Minority or economically deprived communities are often medically underserved so, even if their cancer occurrence is similar to more prosperous communities, their cancer death rates may be higher because the disease is not caught and treated in time. Comparing a 20-year average for cancer death rates in East St. Louis to Illinois and St. Clair County rates supports this idea. From 1969 to 1989, the average cancer mortality rate (per 100,000 population) in the state, county, and city was 198, 194, and 222, respectively. These differences indicate a trend toward higher cancer deaths in the East St. Louis population, although the cancer incidence is similar.

Other Diseases

Overall, the rate of death from all causes was higher in East St. Louis compared with the rest of the state (1,096 per 100,000 compared with 884 per 100,000). The differences occur mainly due to excesses in cardiovascular disease and homicide rates, although there are slight increases in deaths due to accidents and pulmonary diseases when compared with the rest of the state. Information on other disease endpoints of concern (i.e., liver and kidney disease) is more difficult to assess. These are not reportable diseases, so incidence data are not available for either the study or comparison populations. The terms are too general to provide a ready comparison since they cover literally dozens of conditions with varying causes and outlooks.

It is generally accepted, however, that African-Americans may suffer a greater incidence of certain diseases that put them at risk of kidney disease (e.g., hypertension). In East St. Louis, the death rate due to diabetes is twice that of the state rate in 1989. One consequence of untreated diabetes is an increased risk of end-stage renal dysfunctions. Statewide, mortality from kidney diseases was higher in non-whites than whites. Likewise, cirrhosis of the liver was higher in non-whites than in whites. In East St. Louis, mortality from liver disease, indicated by cirrhosis of the liver, was not reported as elevated compared to state rates. Rates could not be reliably calculated given the low number of reported deaths. Other liver and kidney disease mortality rates are not readily available. While there are a few occupational and perhaps environmental risk factors for these diseases, most chronic kidney and liver diseases result from genetic predisposition, chronic infection, or lifestyle. Again, preventive medical care and treatment are essential to controlling or preventing these diseases. A community medically underserved is expected to experience an increase in deaths due to these and other chronic illnesses.

C. Community Health Concerns Evaluation

IDPH has summarized the community health concerns heard at various public forums as follows:

1. Is the high incidence of cancer among persons living along Trendley and Piggot Avenues a result of living near Lanson Chemical?

Two questions need to be asked to address the larger question posed above:
1) Is the cancer incidence around the Lanson Chemical site higher than expected?
2) Are the chemicals and exposures originating from this site sufficient in themselves to explain any observed excess in cancer?

In this instance, the answer to both questions is no. Based on a review of cancer incidences in the zip code containing this area by the ISCR, there does not appear to be any excess of cancer among the residents. Cancer is a much more common disease than most people realize. It will strike one out of every three people at some time in their life, and its prevalence increases as the population ages. There are many causes of cancer, and much of the mechanism of cancer remains unclear. The length, duration, and level of exposure to the types of chemicals originating from Lanson Chemical seem unlikely to have resulted in an appreciable cancer risk.

The cancers observed in this population are also not those associated with the potentially carcinogenic chemicals identified at Lanson Chemical. It has been observed in minority and economically deprived communities that, while cancer occurrence is similar to that observed in more prosperous communities, cancer deaths are often higher. This has been attributed to a lack of preventive medical care among these minority and economically deprived communities. Without regular medical care and checkups, cancers are not caught at a treatable stage and so take a greater proportional toll on members of these communities than those in communities with access to regular medical care. One public health goal in a community such as East St. Louis should be to provide preventive health care education to the citizens and access to regular medical care.

2. Has the proximity of Alta Sita residents to Lanson Chemical caused them to have an excess of kidney and liver disease?

Again, the same questions need to be asked in this regard as with cancer: 1) Is the incidence of liver and kidney disease elevated in this population? 2) Are the chemicals and exposures originating from the Lanson Chemical site sufficient to explain an excess of these diseases?

The first question cannot be reliably answered, while the answer to the second appears to be no. Liver and kidney disease are generally not reportable conditions, so little information exists as to their occurrence in various populations. Information is lacking both in terms of the occurrence in East St. Louis as well as the baseline expected occurrence of such conditions in the population as a whole. Death records would list contributing factors, but the terms "liver and kidney disease" are very general and cover many ailments with varying causes. Death records also may be inaccurately or incompletely filled out, raising concerns over how useful they may be.

IDPH lacks sufficient information to judge whether there is any excess of any single disease affecting the liver or kidneys in this population. While some chemicals associated with Lanson Chemical have caused liver and kidney toxicity in workers and experimental animals exposed to high concentrations of solvents, the effects are generally mild and readily reversible once exposure ends. The primary effect of solvent intoxication would involve the nervous system. Area residents were primarily exposed to solvents that escaped into the air during the operation of the facility and after. The level, duration, and frequency of exposure, as well as the type of chemicals involved in such circumstances, would be unlikely to result in chronic liver or kidney diseases.

African-Americans may suffer disproportionately from hypertension (possibly due to genetic predisposition, lifestyle, or a combination of both) and other conditions that can lead to endstage renal disease. Likewise, liver disease can result from a variety of chronic infections or lifestyle choices. As previously mentioned, the best way to address these problems in a community like East St. Louis is to provide for and encourage preventive health care and health education.

3. Are nearby residents being exposed to chemicals, primarily PCBs, from the site through contaminated air, groundwater, soil, and surface water runoff?

Neighbors of Lanson Chemical were probably exposed to organic solvents and associated chemicals during and after the plant's operation. This is evidenced by the many odor complaints reported by citizens and various officials during the facility's life. PCBs, however, were probably not released to the air in significant amounts, if at all. PCBs have extremely low volatility and do not readily escape into the air. The only potential for air exposure would be through the dispersion of PCB-contaminated dust from the site. Since such dust would settle out of the air quickly, and PCBs are highly persistent in the environment, it would be expected to see PCB contamination in off-site soils if a significant release had occurred. The lack of widespread, off-site PCB soil contamination does not support the contention that residents were exposed to PCBs through the air. Currently, no air exposures are expected to occur from this site.

Groundwater is contaminated at this site due to improper disposal of waste chemicals and, perhaps, leaking storage tanks. No PCBs, however, were detected in groundwater. This is consistent with their low water solubility and their tendency to cling tightly to soils. The groundwater contamination off the site, if any, is unknown. If off-site groundwater is contaminated, residents could be exposed by ingestion, inhalation, or direct contact with the skin if they use private wells as a source of domestic water. Since most area residents rely on a public water supply that draws water from the Mississippi River and treats it before distribution, this route of exposure appears unlikely.

While the direction of groundwater flow is uncertain, at least one measurement identified it as flowing east toward the residential properties. The two groundwater monitoring wells between the facility and the residential property showed little if any groundwater contamination. This indicates no appreciable movement of a plume off the site in this direction at that time (1990). No private wells are known to exist in the anticipated or suspected path(s) of groundwater flow, but any that do exist should be identified and tested. In the absence of private wells, VOCs in groundwater could move up through the soil in a gaseous state and enter buildings at low levels. If the groundwater plume is determined to be under area homes, this route of exposure should be further evaluated.

Testing of residential soil has not found significant contamination. PCBs were found in one off-site location (a drainage ditch northeast of the site). The trace levels found and the low potential for exposure are not felt to pose a significant risk to the residents of the area. Other chemicals found in off-site soil (PAHs and metals) were found at levels typical of urban soil and do not appear to be site-related. Overall, there does not appear to have been any significant contamination of residential soils from the Lanson Chemical operations or cleanup.

The fact that on-site soils and sediments in the storm water catch basin were contaminated suggests that surface water runoff could have spread some contamination off the site, either dissolved in the water or bound to eroded soils. However, the residential soil sampling from areas likely to have received such runoff does not reveal substantial contamination. PCBs were found in trace levels only in the drainage ditch northeast of the site and are probably the result of releases from the site. Based on this, it does not appear that appreciable levels of persistent contaminants left the site in surface water runoff. Site topography and history would suggest that the most likely surface water discharge was to the wetlands south-southeast and to the vacant ground northeast of the site.

4. Are the vegetables from residential gardens near the site safe to eat?

Yes, no appreciable site-related contamination has been detected in garden soils next to the Lanson Chemical site. Low levels of PAHs consistent with urban soils were found in yard and garden soil. The PCBs found off the site were confined to the drainage ditch soils. Fruits or vegetables do not take up PCBs or PAHs to any degree. Washing or peeling crops, particularly root crops, would serve to eliminate any surface contamination from clinging soil or settling dust. Supplementing the diet with fresh fruit and vegetables is an important contribution to good nutrition, and there is no reason to avoid consuming garden produce from area gardens.

5. Doesn't the fact that the disappearance of field mice, birds, rabbits, and snakes from the area mean it is unsafe to live near the site?

It is uncertain whether there has been any reduction in wildlife in the area. Many site visits have documented the presence of the typical profusion of small animals and birds expected in and around an urban area. No evidence of plant stress was observed on and around the site. Typically, most reduction of wildlife is due to habitat destruction or incursion by people. Some of the area around Lanson Chemical was previously wetlands. Since the wetlands were developed and cultivated, some loss of wildlife would be expected. The site cleanup may also have temporarily disturbed and displaced wildlife; however, wildlife appears to have returned since remedial activities have ended. The site is a relatively small area, and its impact on the area in terms of contamination spread appears limited. It seems unlikely that it played any major or permanent part in loss or reduction of area wildlife.

6. Aren't dangerous wastes leaking from storage drums at the site?

There were obviously leaks and spills during the operation of the facility and after, as witnessed by the results of the vandalism of the storage tanks. During USEPA and IEPA inspections and the site cleanup, liquid wastes, tanks, and drums were removed for proper disposal. Contaminated soil, concrete, and building components were also drummed and removed. All potential surface hazards have been remediated or covered so this should no longer be a concern.

7. If there is nothing to worry about, why is USEPA spending two million dollars to clean up the Lanson Chemical site?

The situation as it existed at the Lanson Chemical site before the emergency removal action constituted a potential hazard to the health and safety of area residents due to the potential for chemical release from tank failure, fire, or explosion. The vandalism that resulted in the release of the PCB-contaminated resin showed the site was not secure and risks existed. Since IEPA's funds for site cleanups were exhausted, they requested emergency funds from USEPA. The cleanup was undertaken as a preventive and remedial action to protect the area residents from possible exposures from the site.

8. Are race and socioeconomic status barriers to an adequate and timely cleanup of the site and the community being compensated and relocated?

This is a difficult question and in many ways beyond the scope of the public health assessment. There are thousands of waste sites in Illinois awaiting some evaluation and remedial action. Many of these sites are in poor and minority communities. Sometimes, this is because the presence of industry lowered the value of the land and economically deprived groups moved in due to affordable housing and the proximity of jobs. In other cases, industries may have chosen to locate in poorer communities who would welcome the jobs and tax base, and were unable to offer any effective opposition to the siting of undesirable factories or landfills.

The selection of sites for clean up is, and should be, based on a scoring system that ranks sites in terms of their potential to harm public health and the environment. Many factors affect how quickly such sites can be addressed, including legal, technical, financial, and policy issues. IDPH is aware of several IEPA and USEPA cleanup projects ongoing in minority and economically deprived communities. All agencies feel that the limited funds ought to go to the communities with the greatest need. Additional dialogue with affected communities would help all parties in ensuring this goal.

9. Is the environmental sampling that has been done adequate, or has it failed to detect off-site contamination?

USEPA, IEPA, and IDPH have performed soil sampling for a variety of organic and inorganic chemicals, including many associated with the site. These samples have been taken both at random through the neighborhood and in areas most likely affected by runoff or deposition from the site. In our view, these samples and results are sufficient to judge the extent of the site's impact on residential and garden soils.

This sampling did not include off-site groundwater monitoring, which ought to be considered if private wells are in use in the area, or if the groundwater plume has the potential to affect the indoor air quality of area buildings. Additionally, this sampling only addressed current conditions. Past exposures, primarily through the air, cannot be known with certainty and can only be judged qualitatively, based on past complaints and knowledge of facility and process operations.

10. Is it safe to remain in the residential area near the Lanson Chemical site?

The action taken by USEPA and IEPA has effectively eliminated the potential threat that this site posed to the community. Off-site sampling indicates that no significant contamination occurs in residential soils. While the impact of Lanson Chemical on the community is now negligible, other exposures from area industries are ongoing and may pose a concern.

Comments made by Reverend Jones concerning the 1994 draft health assessment are addressed as follows:

1. The health assessment lacked a semblance of democratic participation and self-determination.

A public health assessment is a comprehensive, written evaluation of data and information on the release of hazardous substances into the environment used to assess past, current, or future impacts on public health. The key objectives are to determine exposures of public health concern and identify communities in need of public health activities. Although a public health assessment can be a technical exercise of data review and interpretation, there is an opportunity for citizen involvement. This citizen participation is essential to achieve the public health assessment objectives.

During this public health assessment process, public meetings have been held to gather community questions and concerns that have helped focus the document. Information from the community helped IDPH qualitatively reconstruct possible routes of past exposure. IDPH's offer of biomonitoring was another opportunity for community involvement, but the community declined to participate.

2. IDPH did not properly exchange information with the community or seek resident input.

IDPH conducted and participated in several public meetings and availability sessions from 1992 to 1995, during the activity at the site. The gathering and addressing of community concerns and the offer to attend additional meetings were attempts to share information with the community. The community was provided with draft copies of the public health assessment for comment in 1994. This revised document was also made available for public comment. Residents were, and still are, encouraged to identify their wants, needs, and concerns.

3. IDPH failed to consider micro-environmental exposures resulting from personal activities (such as hobbies) and the range of exposures resulting from cultural patterns.

The purpose of this public health assessment was to gauge the exposure to substances originating from the Lanson Chemical site. The micro-environmental exposures mentioned do not play a role in this evaluation, although we acknowledge they are important factors in the overall health of the people in the community.

4. IDPH was biased in favor of the polluters in conducting the health assessment and flawed in the epidemiological approach to investigating the Lanson site.

The claim of bias among IDPH representatives is untrue. Linking chronic diseases and environmental exposures is very difficult. Given that cancers may take decades to develop, it is impossible to say with certainty what single factor is most responsible for their occurrence. The purpose of a public health assessment is to determine if exposure has occurred, and if it has occurred, were the exposures at levels large enough and for periods long enough to be consistent with the health outcome of concern.

IDPH did not use an epidemiological approach in the public health assessment. The approach used was an exposure and toxicologic review. The review of health outcome data was done to establish if an elevation in cancer rates were observable in the area without attribution of cause. An elevation would suggest the need for further study to attempt to identify any causal relationships. Such an elevation was not found.

5. The recommended blood and urine sampling will not find contaminants and will be used to silence community groups concerned about toxic waste.

Previously, IDPH was criticized for not collecting biological samples. The blood testing offered by IDPH might have identified any body burdens of PCBs in residents due to past exposure. Project H.O.P.E. and the community declined to participate in 1995.

6. IDPH ignored the damaging effects of chronic stress and anxiety caused by living near a hazardous waste site.

IDPH agrees that there is a great deal of anxiety and stress associated with living near a hazardous waste site. We are learning much more about this aspect. However, there is no way to quantify such effects in an assessment of this sort. We can, however, acknowledge that anxiety and stress do contribute to the overall health of community members.


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