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PETITIONED PUBLIC HEALTH ASSESSMENT

WEST PULLMAN IRON & METAL
(a/k/a WEST PULLMAN/VICTORY HEIGHTS)
CHICAGO, COOK COUNTY, ILLINOIS


APPENDIX E: ATSDR RESPONSE TO PUBLIC COMMENTS

ATSDR released the West Pullman/Victory Heights Public Health Assessment for public review and comment during the period from September 9 through October 25, 1998. ATSDR appreciates the written comments provided by residents of the West Pullman area of Chicago and the Illinois Department of Public Health. This section contains the comments received and ATSDR's response to these comments. General editorial comments were addressed, where appropriate, within the final document.

Comment: 1. Page 4, Paragraph 2 (DB)
It appears that only a very limited amount of sampling of residential properties has been accomplished, and ATSDR's summary should reflect that lack of data. However, based upon the Environ Draft EOC Report, it appears that significant lead contamination of soils near residential properties has occurred. This could have had a major impact on exposure of residents to lead.

Response: ATSDR realizes that a limited number of samples have been obtained from off-site residential soils and that is stated in the first paragraph on page 5 in the PHA. We do recommend further off-site soil sampling in the Recommendation Section of the document. It should be pointed out that residential soils could contain high lead content from other potential sources of lead, such as the existence of other industries in the area and from lead-based paints on older residences in the area. Also, although the use of lead-based gasoline has been discontinued, it has contributed to lead contamination in soil near road beds. We believe that informing the community of the many sources of lead-contaminated soil will help to minimize exposures.

Comment: 2. Page 4, Paragraph 3, Sentence 2 (DB)
Insufficient data are available to state that the concentrations of "polycyclic aromatic hydrocarbons (PAHs) and polychlorinated biphenyls (PCBs) in on-site soil do not constitute a current public health hazard." It is known that there is extensive gasoline and diesel fuel contamination in the northwestern area of the site. Even if it could be concluded (which it cannot be) that this posed no risk to residents, it is not known if these levels are sufficiently high to pose a risk to workers during site remediation.

Response: Based on the data that were available for review, the levels of polycyclic aromatic hydrocarbons and polychlorinated biphenyls are not likely to result in adverse health effects in the future. At the Dutch Boy site, noncarcinogenic PAHs detected in the soil did not exceed health based comparison values for chronic exposures. Although the maximum concentration of carcinogenic PAHs exceeded the cancer-based comparison value, this value is based on a 70 year exposure duration which is not likely to occur because the site is being remediated. The PCBs that were detected at a concentration of 0.516 ppm at 3 inches below the ground surface did not exceed ATSDR's Chronic Environmental Media Evaluation Guidelines (EMEGs) for noncancer effects. Workers at the site during remediation activities are required to follow the Occupational Safety and Health Administration's rules to prevent exposures. Currently, access to the site is effectively restricted, the site is an empty lot, overgrown with vegetation, and additional remedial activities are being planned to reduce the potential for future exposures.

Comment: 3. Page 4, Paragraph 4 (IH)
As we stated above, to our knowledge no comprehensive (or even basic) residential sampling has been accomplished. The data for PAHs and zinc are not presented in the document. (Those data should be included in Table 5.) The location where samples were taken is not noted; this is important information on which to draw conclusions. Without this information, the conclusion that "exposure to the levels present at the site are not likely to cause adverse health effects" is unsubstantiated.

Response: Please see the response to the first comment which addresses the issue of limited sampling. Page 4, paragraph 4, refers to on-site surface soils, not off-site surface soils. The text has been amended. Contaminants are referenced in table 4, page 13. For locations and results, please refer to the IEPA document, Site Inspection Prioritization, International Harvester Site, Chicago Illinois of March 1995.

Comment: 4. Page 4, Paragraph 5 and 6 (IH)
The levels of contamination are not known for the extended period of time during which the site was unfenced. As stated in the PHA, "site security was not established until the summer of 1997, making it possible for pedestrians to enter the site." The community members have documented that the site was frequented until it was fenced. Even after the site was fenced, maintaining a secured property has been difficult. Photographs showing children playing on the site are available; photographs were taken both before and after the site was fenced. Given the high level of contamination on the site and the frequent access during the period when the site was unfenced, the conclusion that "adverse health effects are unlikely to occur" is unsubstantiated. If the concentrations of contaminants are high now, they must have been greater in the past, before site security. Additionally, ATSDR presents no justification on which to base the assumption that the duration of exposure was insufficient to result in any adverse health effects.

Response: ATSDR agrees that the level of contaminants in the past at the IH site is unknown, and stated on page 4 and on pages 12-13 and pages 28-31 that workers and trespassers were exposed to contaminants. With the exception of lead, however, on-site contaminants were found at concentrations below the more relevant, noncancer, comparison value (see page 25 of the PHA). Based on the data reviewed, the on-site contaminants that exceeded the cancer risk evaluation guides (PAHs and PCBs in soil, and asbestos and arsenic in air) were not considered likely to cause adverse health effects to individuals who occasionally gained access to the site. Individuals frequenting the site would not be continuously exposed to the maximum concentration of contaminants for the 70-year exposure period upon which the cancer guidelines are based.

Comment: 5. Page 5, Paragraph 1, Sentence 1 (IH)
The report states that "currently, for people trespassing on-site, both the Dutch Boy and International Harvester site represents (sic) a potential health hazard." This statement contradicts the repeated dismissals (by ATSDR) of the potential for historic exposures to PAHs and lead (see, for example, page 4, paragraphs 5 and 6 of the PHA). If the sites represent a current potential health hazard, given the extreme lack of data for historic concentrations, how did ATSDR determine that historic exposures did not cause health problems?

Response: The International Harvester site represents a current potential health hazard to people trespassing onto the site because the site still has contaminants at levels that exceeded ATSDR comparison values. ATSDR makes this statement to inform community members that they should not continue to go onto the site. ATSDR also recommends that remedial activities at the site continue. Please see the response to comment 4 for additional information about the site contamination.

Comment: 6. Page 5, Paragraph 3, Sentences 3, 5, and 6 (DB)
The PHA states that demolition and salvaging activities occurred from 1983 to 1986 and that "demolition activities were stopped after they were found to pose an imminent danger." However, if the lead poisonings occurred in 1985 and demolition activities occurred in 1986, it appears that demolition continued for a significant period after the threat to human health was known.

Response: On page 5, paragraph 3, sentence 6, the PHA states that after the IEPA was informed that people who had gained access to the site during demolition activities were diagnosed with lead poisoning and that the site activities posed an imminent danger to the surrounding community, the demolition activities were stopped .

Comment: 7. Page 5, Paragraph 4 (DB)
If some of the basements and open chambers on-site are now only "partitioned off with yellow tape," those locations must have been accessible to people entering the site before site security. No mention is made as to when the basements or open chambers were filled with soil. Is it not possible that, before site security, those areas were also accessible? What better location for children to explore? Those locations are likely places for "forts and the like, and would therefore represent a significant potential for exposure. In the past, as the debris was uncovered, the materials present in the pile could have been distributed both on and off-site by the wind. The PHA reports that presently the debris pile is only covered with torn plastic sheeting. As such, the materials in the pile continue to present a risk to human health as area residents may be exposed to these chemicals because of air deposition.

Response: ATSDR has previously commented on the potential for exposure to these on-site locations and agrees that until the site is further cleaned up, potential for exposure continues to exist and people should no longer go onto the site.

Comment: 8. Page 6, Paragraph 3
The Maple Park/Victory Heights Advisory Council is misidentified in the paragraph.

Response: Thank you for the clarification, the text has been amended to correctly identify the Maple Park/Victory Heights Advisory Council.

Comment: 9. Page 7, Paragraph 1
ATSDR seems to imply that the only adverse health effects with apparent clinical signs were the elevated blood lead levels noted in 1985 and 1986. However, ATSDR overlooks the pertinent questions. How complete were those sampling events? Was it possible that those individuals who were frequenting the site did not have their blood lead levels tested? How many individuals were tested during the 1985 and 1986 sampling events? Are those numbers sufficient to make any statistically valid conclusions? Since the relationship between contact with the site and blood lead level cannot be made, no conclusions can be drawn from any of the sampling events.

Response: Although ATSDR requested more information regarding blood lead testing during this time period, we were unable to obtain additional information. We recommend that individuals who had their blood tested for lead contact the health department for results. People who have not been tested but believe that they may have been exposed to high levels of lead should have a blood test for lead.

Comment: 10. Page 8, Paragraph 2, line 10
To better assist the community in understanding the risk to their health, it would be useful for ATSDR to be more specific when describing health problems. Rather than referring to pica as an "uncommon behavior," TOSC suggest that ATSDR define the rate at which pica occurs in the general population and in this population, which is at risk. This would assist the community in understanding whether they need to be concerned with the additional risks associated with pica children.

Response: PICA behavior is defined as the craving or eating of bizarre substances that have no food value (such as starch, clay, ice, plaster, paint, hair, or gravel). Children between the ages of 1 and 6 and some pregnant women are most affected. Pica behavior varies widely in the population and may be due to an instinctive need to replace minerals absent in a persons diet, especially in persons eating clay that contains iron. The physiological factors are not well understood but may be related to poor nutrition, poverty, family history, anemia, or other factors. (www.thriveonline.com). Pica behavior during pregnancy usually ends with childbirth. Although pica behavior occurs for a limited period of time, providing a proper diet or nutrient replacement, child supervision, examining the home environment (especially for the presence of lead-based paints), can reduce or eliminate this behavior. For more information please visit ATSDR's web site (http://www.atsdr.cdc.gov/HAC/HAGM/appd.html).

Comment: 11. Page 8, Paragraph 3, line 4
ATSDR introduces another criterion for lead, one that is higher than that set for this site, without any clear explanation. TOSC recommends that the 1,400 ppm lead level, as set by the U.S. EPA (UAO, March 1996) be used, for on-site soils.

Response: ATSDR has changed the 500-ppm lead level in the text to the current EPA (June 1998) lead level of 400 ppm for residential soils and 1,400 ppm level for industrial areas.

Comment:12. Page 8, Paragraph 4
The UAO should be listed as the reference document for the actions "recommended" by U.S. EPA (a better term being "ordered" as they are found in an Administrative Order). In addition, the word "elevated" should be substituted for "increased" on the fifth line of paragraph 4.

Response: The EPA June 1998 document for action levels for lead at 400 ppm in residential soil has been referenced. ATSDR has replaced the word "increased" with "elevated" in the sentence in paragraph 4.

Comment: 13. Page 8, Paragraph 5
TOSC questions the argument that this "condition...does not apply to this site." In analyses conducted in 1993 (Simon Hydro-Search, Inc. Environmental Assessment Report, 120th and Peoria Streets, Chicago, IL, Nov. 1993. (as cited in the PHA)) it was found then that some of the PAH concentrations in on-site samples exceeded ATSDR's comparison levels. The concentrations of PAHs that would have occurred during and after the termination of the demolition operation are predictably higher than that in the 1993 samples. It is highly possible that, in the past, workers and the residents were exposed to much higher concentrations of PAHs, and as discussed previously, for extended periods of time.

Response: Based on the data available for ATSDR to review, the on-site contaminants that exceeded ATSDR CREGs (only PAHs and PCBs in soil, and asbestos and arsenic in air) were not considered likely to have caused adverse health effects in individuals who gained access to the site periodically. It is unlikely that people who periodically went onto the site would have been exposed to the maximum concentrations. The potential amount of time these people would have been exposed was less than the 70 years time on which ATSDR's CREGs are based.

Comment: 14. Page 9, Paragraph 1
ATSDR needs to acknowledge the presence of petroleum-type compounds on the DB site (EOC Report, ENVIRON, July 1997). Although specific compounds were not identified, the concentrations of gasoline-related organics (GROs) and diesel-related organics (DROs) exceeded 25,000 ppm in the northwestern corner of the site. It should also be stated by ATSDR that all VOC analyses conducted in 1997 by ENVIRON were inconclusive because the minimum detection limits were excessively high (25,000 ppb) in many cases.

Response: ATSDR is not clear about the reference to contaminants made in this comment. However, on page 11 under the heading of Sediment and Standing Water, ATSDR describes the report (EOC report, ENVIRON, July 1997) of 25,000 ppm of lead at 0 to 0.2 feet below ground surface detected in sediment from the former mill building. Also, VOCs and SVOCs were detected below the detection limits of 10 to 50 ppb and 10 ppb, respectively, in standing surface water samples taken in the mill building basement.

Comment: 15. Page 9, Table 1
ATSDR needs to discuss more completely the possible presence of PCBs on the site, especially given the likelihood that transformers were located on the site. Where were the transformers located? Were they located near the sample with a PCB level of 0.52 ppm? How many samples` were tested for PCBs? Has the site been sufficiently characterized for the presence of PCBs?

In using the 500-ppm action lead level for residential soils, the ATSDR risk assessors use comparison values that may be too high to protect the health of the residents (Tables 1 and 3, page 12). In fact, if the lead concentrations in the soil and dust are 500 ppm, EPA's IEUBK model predicts that 18% of the children would likely have elevated blood lead levels. This value (18%) is three times the national average of children (6%) that have elevated blood lead. To provide an environment that would allow children in this community to have a blood lead level at the national average, as predicted by the IEUBK model, a soil (and dust) lead level of 200 ppm or less should be used for comparative purposes. It is important to recognize that the action lead level of 10 ug/L for children was not accepted as a no-effect level; instead it was accepted as an action level at which public health concerns can be managed. Many researchers do not consider this an acceptable level due to possible effects on children's mental development.

Response: ATSDR has reviewed previous site investigation reports from 1986 to the present and finds no reference to the presence of transformers on the Dutch Boy site. Polychlorinated biphenyls (PCBs) were sampled for and detected in soil samples taken at the site in 1995 (Ecology and Environment, August 1995). PCBs were detected in two samples (S003 located at the northwest corner of the former mill building and S004 located near the western area of the concrete dock area) at levels of 0.22 and 0.52 mg/kg (or ppm), respectively. ATSDR's comparison value for PCBs is 1 and 10 ppm for a child and an adult, respectively.

ATSDR has changed the 500 ppm lead level in the table to the current EPA (June 1998) lead level of 400 ppm. The EPA biokinetic model predicts that 5% of children will have blood lead levels above 10 µg/dL with average soil lead concentrations at 400 ppm. However, it should be pointed out that neither EPA's IEUBK model nor any other model can predict actual blood lead levels from soil lead concentrations. They can provide only theoretical estimates which, in the present case are far less accurate and useful than the biomonitoring data that were available for ATSDR's review.

Comment: 16. Page 9, Paragraph 2
ATSDR mentions only the results of sampling that was conducted in 1994. Sampling in 1997 by ENVIRON revealed lead concentrations exceeding 40,000 ppm near the loading dock (northwest sector) in soils up to 2' below grade. In soils and sediments at 2' to 4' below grade, the lead concentration exceeded 40,000 ppm in some locations. Even at depths of greater than 4' below grade, lead was found at concentrations greater than 40,000 ppm. It is imperative that ATSDR note these levels as they reflect the very high levels of contamination on the DB site.

Response: ATSDR states on page 8, paragraphs 3 and 4, that lead concentrations were highest in the western half of the site, particularly near the loading docks. ATSDR also mentions that sampling conducted in July 1997 by ENVIRON also indicated that lead concentrations were highest in the surface soils. This section has been amended to include mention that lead concentrations exceeded 40,000 ppm in subsurface soil samples from 1 to 4 feet below grade collected near the loading dock (ENVIRON, 1997, Table 1, SS08, SS09, SS10, SS11, SS12).

Comment: 17. Page 9, Paragraph 3
ATSDR notes that elevated VOC levels were detected on the DB site in 1987. Since those levels "were due to a surface spills" (according to ATSDR), the level of contamination must have been much higher at the time of the spills. Therefore, VOCs in surface soil may have been a health hazard in the past for the workers and the trespassers. This possibility needs to be identified in the risk assessment.

Response: No air data were available for review to determine possible past exposure to VOC levels that might have occurred during the surface spills. However, ATSDR did review the data that were available. These data demonstrated VOC levels in surface soil at 0.2 to 1 feet below ground surface (bgs) (E & E study 1995), subsurface soil at 1 to 8 feet bgs (sampled 1994, 1995), and in sediment and surface water (1993). These sample levels were found to be below ATSDR's comparison values.

Comment: 18. Page 10, Paragraph 1
ATSDR states that "standing water no long occurs on-site." How was that statement tested? What data are available to substantiate it?

Response: During the site visit, ATSDR noted that standing water was not observed on the site. The sentence is misleading and has been deleted from the final document.

Comment: 19. Page 10, Paragraph 3
One should not dismiss the significance of air lead of 26.1 mg/m3 (value measured during the 1996 demolition activities) at a site so close to a school and a residential area. Based on EPA's IEUBK model, at a 26.1 mg/m3 air lead concentration, it is likely that more than 50% of the children exposed will have elevated blood lead levels. This figure is certainly not acceptable when nationally 6% of the children have elevated blood lead. Additionally, what is the "residual release" of lead? That is, what happened to the lead that left the site? Is information about wind direction available?

ATSDR compares the air quality data collected during the demolition activities conducted in 1996 to the OSHA permissible exposure limits. This comparison is invalid since the residents of this community are likely to be exposed for longer than an 8-hour period (used in promulgating the OSHA standard). As such, the National Ambient Air Quality Standard (NAAQS) of 1.5 mg/m3 should be used for comparative purposes. While this level is more appropriate than the OSHA PEL, even at this level, neighborhood children would be expected to have elevated blood lead levels. The IEUBK model predicts that 18% of children will have elevated blood lead levels if the air lead concentration is 0.1 mg/m3 and the soil and dust lead concentrations are 500 ppm.

Finally, ATSDR reports that one air sample had a lead concentration greater than 25 mg/m3 (26.1 mg/m3). This single value alone does not indicate whether the "true value" is either below or above the action level (25 mg/m3). Therefore, the statement that "ATSDR does not consider this exceedance significant" is unjustified. On the contrary, one could argue that since lead toxicity occurred in workers during the 1986 demolition (as noted in the PHA on page 17), it is plausible that the elevated air lead concentration in combination with elevated soil lead levels posed a health problem to individuals residing in the proximity of the demolition site in 1996.

In addition, any examination of lead exposures associated with demolition activities needs to note that no monitoring or sampling occurred during the demolition activities from 1983-1986. Residents may have had exposures that lasted for years, not the shorter period during the 1996 demolition.

Response: In the first sentence on page 10, paragraph 3, under the heading Air, ATSDR states that, "No air monitoring or sampling occurred during the demolition activities from 1983-1986." The 1997 report by ENVIRON stated that the predominant wind directions are to the north and northeast (detailed in the 1996 Sampling and Analysis Plan, Environ). The results of the regression analysis for the Dutch Boy site demonstrated that the concentrations of lead above 1,400 ppb were in soils sampled in the south and northeast transect (Environ, Figures 8 through16).

ATSDR did not dismiss the significance of the one air sample that measured lead at 26.1 mg/m3 during the 1996 demolition activity, but puts it into the proper perspective. Harza Evironmental Services, Inc. (Harza) was hired by the city of Chicago to provide monitoring during the demolition activities at the Dutch Boy and International Harvester sites. The demolition activities were conducted from April 30, 1996, through May 23, 1996 (August 27, 1996, final report, Harza Environmental Services, Inc., Perimeter Air Monitoring During Demolition). The site perimeter air monitoring program conducted during the 4-week demolition activity consisted of continuous real-time monitoring for respirable dust levels and approximately 10 to 20 filter samples for respirable dust and lead per day. The action levels suggested by Harza and adopted by the city of Chicago for this project were 2.5 mg/m3 for respirable dust and 25 mg/m3 for lead (Dutch Boy site only). According to 29 CFR 1910.1025, the permissible exposure limit (PEL) for lead in air is 50 mg/m3 as an 8-hour-time-weighted average (TWA) for cleanup at an industrial site. The PEL, according to the "Lead Exposure in Construction: Interm Final Rule", (29 CFR 1926.62), has an action level of 30 mg/m3, and a PEL of 50 mg/m3, both as 8-hour TWA. Respirable dust measured as particulate has an OSHA PEL of 5 mg/m3 as an 8-hour TWA for industrial sites. Therefore, the action level for respirable dust at the site was set at one- half the OSHA PEL, or 2.5 mg/m3.

Only one filter sample (26.1 mg/m3), measured on Thursday, May 2, 1996, exceeded the action level for lead (25 mg/m3). That sample was taken downwind at station 3, located at the northeast corner of the mill building, across Peoria Street from the Dutch Boy site, "not at a site so close to a school and a residential area." The respirable real-time monitoring range at this location was 0.06 to1.90 mg/m3.

All other air sample results for lead and respirable dust, as well as the real-time monitoring respirable dust levels, were below both the voluntary action levels for the Dutch Boy/International Harvester Demolition project and OSHA PELs.

In addition to analyzing all of the environmental data available from 1987 to the present, ATSDR reviewed the data for community members who had their blood tested for lead in 1985, 1986, 1995, and 1996. Based on the data available for review, which included the results of several thousand tests for blood lead, ATSDR was unable to identify a clear relationship between the Dutch Boy site and any elevated blood lead levels off site, other than the 10 cases of acute lead poisoning identified in 1985 and 1986. The data fluctuated over such a wide range of area codes and years of sampling that it was not possible to identify any single site as the primary source of lead contamination. The relatively high background levels of blood lead in these 12 area codes were potentially due to past (and, in some cases, continuing) exposures to lead from other sources: paint chips in older housing, auto exhausts, and other light industrial sources in southeast Chicago.

Comment: 20. Page 12, Paragraph 2
ATSDR implies that since PCBs were detected in the soil in 1987, but were below detection limits in 1995, PCBs do not represent a threat to the community. This finding begs the question: Where did the PCBs go? Since PCBs are not reactive, the PCBs either were distributed in wind-blown dust or were transported mechanically (movement of soil on feet, by children, etc.) These questions are important in terms of the impact of the PCBs on community health.

Response: According to the 1995 Ecology and Environment survey, PCBs were identified in surface soils on site (Ecology and Environment, 1995). PCBs were found at 0.52 ppm 3 inches below ground surface in only one of the samples taken on the Dutch Boy site. This level exceeded the CREG, but not the EMEG. PCBs were detected in 1987 at a maximum concentration of 18 ppm in surface soils at the International Harvester site. In June 1995, surface soils were sampled for PCBs. PCB levels were reported to be below the minimum detection limit.

Comment: 21. Page 13, Paragraph 3
It is inappropriate to use one-half of the OSHA PEL (25 mg/m3) as the comparison value for air lead concentrations when children have access to the area (through breaks in the fence). Instead, the national average of 0.1 mg/m3 air lead concentration should be used. With lead concentrations of 25 mg/m3 in the air and 500 ppm in the soil (resulting in dust lead concentrations of the same level), the IEUBK model predicts that more than 50% of the children will have elevated blood lead levels. This is unacceptable when the national profile indicates that 6% of the children have elevated blood lead.

It is also inappropriate to use one-half of the OSHA PEL (2.5 mg/m3) for respirable dust. Instead, either the NAAQS PM-10 value of 50 mg/m3 (annual value) or the PM 2.5 value of 15 mg/m3 should be used.

Response: Please see response to comment 19. Air sampling performed in December 1996 detected a maximum lead level of 3.1 mg/m3 (PEL = 50 mg/m3 for airborne lead) and real-time air monitoring measured airborne concentrations of respirable dust at 0.035 mg/m3. The concentration of respirable dust was below the NAAQS PM-10 and PM-2.5 values of 50 mg/m3 and 15 mg/m3, respectively.

Comment: 22. Page 14, Paragraph 1.
ATSDR reports that a black oily sludge sample was taken from the bottom of an on-site (IH) manhole. This sludge is reported (by ATSDR) to be similar to that found in the basement of area residences after rainfall events. (A video documenting the presence of this sludge is available from the Council). As the concentrations of the contaminants in the on-site sludge exceeded ATSDR comparison levels, this material may represent a long-term exposure of many residents to the contaminants in the sludge. The black sludge needs to be removed immediately. The exposure and the potential health effects on residents should be assessed as soon as possible.

Response: During ATSDR's availability session, residents expressed concern about the sludge in their basements that occurred during periods of rain. The sludge in manholes located on the International Harvester site was reported to be similar to the sludge found in residential basements. Samples were taken in the manholes and analyzed for contaminants (IEPA, March 1995). ATSDR reviewed the data, and determined that the levels of PAHs and metals were below levels of health concern. However, ATSDR has determined that off-site contaminants are not clearly defined and has suggested further off-site soil sampling to determine the extent of contamination.

Comment: 23. Page 14, Paragraph 3
ATSDR states that metals were detected in off-site surface soils taken at the Edward White Elementary School, a residence and along the western and northern borders of the IH site. The sampling locations and the concentrations of metals need to be provided to allow for a proper evaluation of the risk associated with these contaminants. ATSDR should consider that the presence of these contaminants might pose a long-term risk to the community.

Response: ATSDR has recommended that further soil sampling be performed off-site within the community. ATSDR will review these data when they becomes available.

Comment: 24. Page 15, Table 5
The alphabetic notations (B, J, etc.) used in this table and others (see Table 4 and Tables A, B, and C in Appendix C) should be defined or eliminated.

Response: ATSDR has made the appropriate changes to the final document.

Comment: 25. Page 15, Paragraph 2, line 4-6
The second sentence should be deleted. The last sentence should be reworded to read: "The analyses, conclusions and recommendations in this health assessment are only as valid as the data presented in the supporting documents. Where the quality control/quality assurance (QA/QC) measures used in preparing those supporting documents cannot be validated, any statements relating to those data are inconclusive."

Response: ATSDR reviews and considers the quality assurance(QA) and quality control (QC) data presented with the environmental data. In the public health assessment, ATSDR stated whether QA/QC information was available for the specific data reviewed for the document. No changes were made to this section because the conclusions made in this health assessment were determined by the availability and reliability of the data and information regarding sampling, sample analysis, and the concentration of contaminants identified.

Comment: 26. Page 17, Paragraph 2
ATSDR states, "These elevated levels (in two adults and three children) were attributed to the demolition activities at the Dutch Boy site." To our knowledge, this claim is made without factual data. Based on the existing data, a significant percentage of the children living in this community are likely to have had elevated body burdens of lead before 1983-1985 demolition activities. It is conceivable that the additional exposure to air and dust lead during the demolition brought the body burden of a small number of children above the apparent toxicity level. It is reasonable to predict that other children also had elevated levels of lead in their bodies, but that no apparent signs of toxicity were reported. Such a highly plausible scenario must not be dismissed. The blood lead concentrations from a "mass screening" in 1986 are not a good indicator of total lead body burden, because it was at least a year after the demolition activity and several years after the closing of the plant operations. Blood lead concentration is an acceptable indicator of lead exposure only when the exposure is consistent (i.e., the environmental levels are maintained) and concurrent with the blood sampling.

ATSDR states that "there are no supporting data" on which to base the assumption that "workers were also likely to be exposed via inhalation or ingestion of contaminated soil during the operation of this site." On the contrary, there is sufficient information pertaining to on-site contamination to assume on-site workers were exposed previously to several contaminants. The likelihood of past exposure should not be dismissed. In the absence of information on past exposure and given the blood lead concentrations measured at the time of exposure, one must consider the past exposure.

Response: ATSDR stated on page 17, paragraph 2, that people going to the site before, during, or after the demolition activities were exposed via inhalation of lead in air, or by dermal contact, inhalation, or ingestion of lead contaminated air, dust, or soil. It is not possible to speculate on the levels of lead in the community because data were not available prior to 1986. While blood lead levels do not give a complete indication of past exposure and the levels in the blood will vary, they can indicate whether the levels are above the levels of a background population or of an unexposed population. Except for the 9 persons identified with blood lead levels above 31 µg/dL, the blood lead levels obtained for residents in the West Pullman area, while higher than the National Health and Nutrition Examination Survey (NHANES III, 1988 to 1991), were not higher than the levels found in other urban populations. Industrial operations, leaded gasoline, and lead paint are all sources of lead exposure and contribute to continued chronic low levels of lead exposure. However, with remediation of the Dutch Boy site and education on the potential sources of lead near industrial sites and within the communities, the exposure to lead can be reduced and in some cases eliminated.

Comment: 27. Page18, Paragraph 2-4
Extensive trespassing through the contaminated sites before the area was fenced off has been reported. ATSDR states that the fence around the IH site has been difficult to maintain. We do know that children frequented the sites and as reported by the Council, children dug tunnels, made forts, entered the basements, and created dust as they rode their bikes and made trails. As such, the potential for exposure to the contaminants is great. The on-site lead and PAH levels observed in 1995 indicate potential health hazards at the Dutch Boy site for on-site workers and trespasses in the past. The soil lead concentrations detected in 1997, both on-site and off-site, indicate that lead is a past and a current potential hazard to the community through multiple routes of exposure.

Response: ATSDR agrees that the potential for past exposure existed for workers, people who accessed the site, and potentially off the site. Based on the preliminary soil data obtained from soil sampling conducted off the DB site, the potential for current and future off-site exposure is plausible and further characterization of areas surrounding the site is recommended. Additionally, the community should be well informed of the potential hazards of walking onto the site and other potential sources of lead contamination within the community.

Comment: 28. Page 19, Table 7
Why was the off-site soil exposure not considered as a possible source of past lead exposure? If its presence is evident now, its presence in the past is reasonably predictable.

Why was dermal contact omitted as a possible exposure pathway for surface soils and air? In the PHA (under "Surface Soil") it should be stated that workers and trespassers might have been exposed to the contaminants via ingestion, inhalation (of contaminated dust) and dermal contact (with contaminated dust).

Potential off-site air lead exposure is possible when children play on the contaminated soil, even on vegetation-covered soil. Additionally, it is conceivable that children dug in these soils or played on the ground on grassy locations. This source of exposure must be considered.

Response: ATSDR identified in the health assessment media on and off the Dutch Boy site that was contaminated with lead. Dermal exposure to contaminants by workers was plausible, although not the major route of exposure. Lead is not readily absorbed into the body through the skin; rather, the main routes of exposure are by ingestion or inhalation of lead-contaminated soil. Tables 6 and 7 have been amended to include dermal routes of exposure. Because limited data existed, the past off-site exposure to lead in soil was considered indeterminant as to the source. Other potential sources of lead exist within the community from unleaded gasoline deposits along roadbeds, previously contaminated industrial sites, and paint chips containing lead-based paint. However, the table has been amended because the data that were available indicated that lead levels in soil sampled off site were above comparison values and potential exposures were plausible no matter what the source. Further remedial activity and vegetative cover will help reduce these potential exposures in the future.

Comment: 29. Page 20, Paragraph 2, line 3
Since ATSDR is considering the effects of off-site contamination, the data generated from all of the DB and IH reports should be pooled. Due to the proximity of the sites, it is impossible to ascertain if off-site exposure was the result of contamination from one or the other of the sites. Given this, ATSDR must consider the findings obtained in the ENVIRON EOC report (1997) which revealed off-site soil lead concentrations ranging from 46 to 16,200 mg/kg, with 43 of 66 samples exceeding 500 mg/kg.

Response: ATSDR has reviewed the ENVIRON EOC 1997 report and defined the potential for exposures to occur from contamination identified by limited off site sampling. ATSDR has recommended that further off site sampling be implemented to further define contaminants in soil surrounding both sites. It is not likely that anyone will be able to ascertain definitively which site contributed to which area of contamination since some contaminants were identified on both sites.

Comment: 30. Page 20, Paragraph 2, line 5
ATSDR states, "The presence of vegetation decreases the likelihood of exposure to contaminated soils and dust." That point should be re-assessed, because it provides no information indicating that the exposure is decreased to a level that no longer presents a health concern. A quantitative analysis of the exposure is required to make this statement meaningful.

Response: ATSDR disagrees that this information is not meaningful. It is well-documented that groundcover and vegetative characteristics of a site will influence the rates of soil erosion, percolation, and evaporation. This methodology has been used for containment and reduction of contaminated soil transport. This technology has been researched and used extensively in the application of ground covers for landfills (Design and Construction of RCRA/CERCLA Final Covers, EPA/625/4-91/025). Vegetative covers will decrease the amount of soil transported off the site. Other methods of reducing exposures to contaminants, such as further site remediation and denying access to the site, will help to further reduce the amount of exposure likely to occur in the future. For more information community members may contact the Soil Conservation Service of the U.S. Department of Agriculture, or there are many Internet web sites that provide examples of innovative treatment technologies used for soil remediation and thereby reduce potential exposures.

Comment: 31. Page 20, Table 8
Both present and future exposures to citizens may occur from access gained through gaps in the fence. Keeping the fence intact has been a long-term problem.

Response: ATSDR agrees that it is imperative that the fence be maintained to prevent people from going onto the site. In addition, the community should be informed via flyers and during community meetings that the sites still are potential health threats until they are cleaned up further.

Comment: 32. Page 20, Paragraph 4
ATSDR states, "However, not enough information is available to conclude whether PAHs are migrating off-site." On the contrary, elevated concentrations of PAHs were found in off-site soil samples collected in 1995 (Table D), 12 years after the cessation of the operation. The black oily sludge, which may contain PAHs, continues to back up into the basements of residences even now! There is not only the possible past off-site PAH exposure, but also possible present "indoor" exposures.

Response: ATSDR made the statement because the few soil samples and limited data available; off-site sampling was considered to be limited. PAHs detected in off-site soil samples were not above comparison values established for pica child, child, and adult exposures. Only the maximum concentration of benzo(a)pyrene (0.660 ppm) was above the EPA risk-based comparison value (0.087 ppm). On-site PAH concentrations in soil were above comparison values. ATSDR has recommended that further soil samples be obtained in residential areas near the site to characterize the extent of contamination. However, it must also be pointed out that while the level of contamination can be defined, the source of the contamination may be difficult to locate because there are other possible sources of PAH contamination in industrial areas.

Comment: 33. Page 21, Table 9
Table 9 should state that potential exposures may have occurred in the past, may be occurring in the present and may occur in the future. This is because off-site soil is still contaminated (Table D) and because of the presence of the black oily sludge, which may be contaminated, in area residences.

Response: ATSDR states in Table 9 that a completed exposure pathway existed in the past for off-site surface soil. In Table 11, ATSDR states that a potential pathway exists currently and in the future for off-site surface soil. This statement was made because preliminary sampling data indicated that off-site soils were contaminated and further sampling was necessary to identify those areas near the site.

Comment: 34. Page 23-24, Paragraph 4
We agree that a conservative approach must be taken in order to protect human health. However, we do not agree that these chemicals should be viewed as "harmless contaminants." If these chemicals were harmless, then why would EPA mandate and enforce drinking water maximum contaminant levels (MCLs) for many of the same chemicals? Many of the MCLs are very low: in fact, the maximum contaminant level goal (MCLG) for lead is zero.

Response: As a matter of policy, EPA's MCLGs are set at zero for virtually all compounds that are known to be carcinogenic in animals, regardless of the doses required, the mechanisms of action involved, or the availability of corroborating evidence in humans. However, almost half of all substances tested, whether natural or man-made, give positive results in carcinogenicity bioassays conducted at the maximum tolerated dose (MTD). For most of these "conditional" animal carcinogens, there is no evidence that they might be carcinogenic to humans under more realistic conditions of exposure. ATSDR's health assessors distinguish carefully between regulatory policy and basic, biological science, and between risk assessment and health assessment, if the information they provide is to be truly useful to either the EPA or the general public.

The most fundamental principle of toxicology is encompassed by the oft-quoted phrase, "the dose is the poison." Conversely, the dose also determines whether or not a given chemical is "harmless," or even therapeutic. Any chemical can be harmful, if the dose is high enough, and harmless, if the dose is low enough. This principle is also the rationale behind environmental regulations, the goal of which is to ensure that human exposures to potentially hazardous substances will be sufficiently low as to render them effectively "harmless." ATSDR's comparison values enable its health assessors to identify the great majority of these "harmless" substances (as defined by their maximum concentrations) so that attention can be focused on those substances that pose a less obvious degree of "hazard." Without such screening tools, effective public health assessment would be virtually impossible.

Comment: 35. Page 24, Paragraph 4
The argument presented here begs the question: Should U.S. EPA not enforce drinking water MCLs for communities having a population of 10,000 or less, since "there is no such thing as one tenth of an excess case of cancer"? A risk of one in 100,000 does not preclude the possibility that at that concentration, the chemical of concern will cause multiple cases of cancer in the community (of 10,000). Conversely, it does not mean that in another community (population 700,000) seven additional cases of cancer will result because of exposure of the population to this contaminant. This entire paragraph needs to be rewritten to better explain to the community the relevance of risk-based criteria.

Response: In fact, the first two introductory pages of the toxicological assessment and all of Appendix D (Comparison Values) were expressly designed to better explain to the community the relevance of risk-based criteria. Because it is the purpose of ATSDR's public health assessments to characterize the human health implications of site-specific chemical contamination under site-specific conditions of exposure, the "argument" referred to by the respondent actually has no bearing on purely regulatory decisions based on nationwide standards such as MCLs. It was intended, rather, to address a common misunderstanding of the statistical rationale underlying such standards. That common misunderstanding is exemplified by the respondent's statement that "a risk of one in 100,000 does not preclude the possibility that, at that concentration, the chemical of concern will cause multiple cases of cancer in the community (of 10,000)." Actually, it does preclude that possibility, since the reported risk represents an upper bound and it is entirely possible, even likely in many cases, that a given "chemical of concern" will, in fact, cause no cancer at all, under conditions of low-level, environmental exposure.

As stated elsewhere in the first two pages of the toxicological evaluation section, comparison values (including MCLs and virtually all other health-based benchmarks) do not represent strict demarcations between hazardous and nonhazardous levels. In particular, cancer-based comparison values and this most especially includes EPA's quantitative cancer risk assessments and the comparison values based on them are designed to identify hypothetical population thresholds corresponding to acceptable levels of risk (arbitrarily defined as 10-6), thresholds that do not apply toany real individual. A hypothetical risk of one excess cancer in a population of one million (to which ATSDR's CREGs correspond) implies that a single individual in a population of 1,000,000 would get cancer, while no excess cancer risk would exist for the remaining 999,999. However, it is unlikely since this type of susceptibility would be incompatible with life or, at least, with surviving to adulthood. Accordingly, all such quantitative cancer risk assessments are qualified by the caveat that "the true risk is unknown, and may be as low as zero" (EPA, 1986). Thus, notwithstanding the implications of the term itself, "quantitative cancer risk estimates" do not actually estimate (let alone "quantify") true cancer risk. That is why EPA stipulates that they cannot be used to predict cancer incidence in exposed populations (EPA, 1986).

These considerations in no way invalidate regulatory practices designed to conservatively protect a U.S. population of over 300,000,000 people. In the absence of any reliable data in the relevant low-dose region of the dose-response curve, such regulatory practices must, necessarily, be based on conservative assumptions and inferences as surrogates for the unavailable data. Perceived inconsistencies occur only when these conservative assumptions and inferences are misconstrued as scientific "facts" that actually do not exist and probably never will. It is precisely because protective comparison values alone cannot predict human health effects that, in 1980, ATSDR was created to provide both EPA and the general public with supplemental assessments of the human health effects that could actually result from exposure to site-specific contaminants. When done properly, these assessments are based on "the best medical and toxicologic information available," and distinguish clearly between fact, inference, and assumption (PHAGM, 1992, pg. 7-4).

Comment: 36. Page 25, Paragraph 4
"ATSDR considers that those on-site contaminants that exceeded CREGs only (i.e., PAHs and PCBs in soil, and asbestos and arsenic in air) represent little or no hazard to public health off-site, due to the limited duration of potential on-site exposures." That statement may be accurate for PCBs and asbestos, if fences eliminated access to the site. However, the statement is not true for past exposure, during operation and before the areas were fenced off. In addition, the statement may not be true for current exposures as black oily sludge is still backing up into houses.

Response: As indicated in the statement quoted by the respondent, these substances "represent little or no hazard to public health off-site" because of the "limited duration of potential on-site exposures." All cancer risk assessment values are based essentially on lifetime exposure. However, because ATSDR was specifically petitioned to address the public health implications of potential exposures to these sites, the only relevant, site-specific exposure scenarios are (1) acute on-site exposures incurred by trespassers, and (2) off-site exposures that will be very much lower. The last part of the statement in question (which was not quoted by the respondent) referred to "the attenuated concentrations off-site" as another reason for the inapplicability of the CREGs for on-site contaminants.

Comment: 37. Page 25, Paragraph 5 (continued on P26)
Concerning the Dutch Boy site, ATSDR states that "based on the data that was available for review, off-site (lead) exposures do not appear to have been associated with any readily identifiable public health hazard in the past." ATSDR provides little scientific basis for this statement, and for good reason: critical information is lacking to evaluate historic contamination levels and historic exposures. Nobody knows the extent to which over 43 years of operation of the Dutch Boy facility, people were exposed to on-site or off-site contaminants. TOSC suggests that, because so little is known about past "exposure conditions," the conservative assumption, one that is protective of human health, would be:

  • The Dutch Boy site has been repeatedly accessed by children during periods when lead was present in surface soils at high concentrations.

  • The type of activities that were carried out on the site is unknown, but the community members indicated that such activities as riding bikes, playing ball games, digging in soils and other activities that actively disturb soils occurred on the Dutch Boy site.

  • Because of the uncertainties associated with historic contamination levels and historic exposures, no definitive conclusions can be made on those issues. However, the present high on-site and off-site lead concentrations indicate a strong likelihood for historic exposures to lead.

Response: It is reasonable to expect that young children would have been actively excluded from the Dutch Boy site when it was an active industrial facility. The significantly elevated blood lead levels that were documented in 1986 were the result of salvaging operations being conducted amidst contaminated materials (which have since been removed), and not of "riding bikes," or "playing ball games." The potential for adverse health effects is a function of the magnitude and duration of exposure, and not of the mere "likelihood" of exposure. If the casual childhood activities referred to by the respondent had, in fact, been associated with toxicologically significant levels of exposure, then one might have expected the magnitude and frequency of elevated blood levels in area codes near to or encompassing the site to have been significantly higher than those in area codes farther away from the site. This, however, was not the case. The frequency of elevated blood levels in area codes 60628 and 60643 was within the range of those in 10 other 606-area codes in 1995 and 1996. The blood lead levels in area code 60628 (which contains the Dutch Boy and International Harvester sites) during 1995 and 1996 was also comparable to that in 1986. Although the frequency of elevated blood lead levels declined considerably over the course of the 3 years of sampling, the change was not specific to the area surrounding the Dutch Boy/International Harvester site, or even the 12 area codes studied. Indeed, the decline has occurred nationwide.

This is not to say that the frequency of elevated blood leads in the12 area codes was not undesirable, because it is. However, based on the data available for its review, which included the results of several thousand tests for blood lead, ATSDR was unable to identify a clear relationship between the Dutch Boy site and any elevated blood lead levels off site, that is, other than the nine well-publicized cases of acute lead poisoning. Indeed, the available data fluctuate over such a wide range between the various area codes and years of sampling that it was not possible to identify any single site as the primary source of lead contamination. The relatively high background levels of blood lead in the 12 area codes were most probably due to past (and, in some cases, continuing) exposures to lead from, for example, paint chips in older buildings, auto exhausts, and any number of other industrial sources in southeast Chicago.

Comment: 38. Page 26, Paragraph 1
Firstly, no sufficient effort was ever made to identify the public health hazards associated with lead exposure. Secondly, it is more than likely that women of reproductive age have been exposed to elevated concentrations of lead in the soil, dust, and air. For the lead exposure in children, one should also consider the maternal body burden during pregnancy when lead can be transmitted from mother to fetus. Consistently throughout the PHA, ATSDR has failed to acknowledge the past exposure. The risk assessor could not, and shouldn't even try to explain the problem away stating, "However, based on the data that was available for review, off-site exposures do not appear to have been associated with any readily identifiable public health hazard in the past: nor is any such public health hazard likely to exist now or in the future."

Response: In addition to analyzing all of the environmental monitoring data available from 1987 to the present, ATSDR reviewed the results of over 1,000 blood leads screened in 1985 and 1996, over 19,000 in 1995 and over 23,000 in 1996. Whether this constitutes a "sufficient effort" in the minds of some, it was, nevertheless, all that ATSDR could do in the absence of more data. However, the fact that all personal identifiers were removed from these data severely limited the specificity of any conclusions that could be drawn from them. Even under the best of circumstances, it is seldom a simple, straightforward matter to establish a causal link between any one individual's health problem and one specific source of exposure. An exception would be acute episodes such as the one that lead to nine cases of lead poisoning in 1986.

Transfer of lead from mother to fetus occurs normally in every pregnancy, which is one reason why blood lead levels typically start out relatively high in the first few years of life. Sometime around puberty, lead levels normally tend to reach a lifetime low as the developing skeleton removes lead from the systemic circulation. Lead then climbs slowly over the next two to three decades, reflecting cumulative adult exposure. It was unnecessary to speculate about the relative contribution of maternal lead to a child's total exposure because data from the blood lead screens of 1985, 1986, 1995, and 1996 integrated exposures from all sources.

In the Pathways Analysis section, it is stated that "A past completed exposure has been identified for deposition of airborne lead onto surface soil on the Dutch By site," and that "persons going on to the site during or after the demolition activities of 1983-1985 were exposed via inhalation or ingestion of contaminated air, dust or soil." In the same paragraph, ATSDR alluded to the likelihood that "workers in the plant when it was operational were also exposed via inhalation or ingestion of contaminated air, dust, and soil." However, as indicated in the sentence immediately following, actual data in support of this reasonable assumption simply were not available. Since mere "exposure" to lead, which is a natural, elemental component of all soils, is both inevitable and universal, it was not the purpose of this public health assessment to either "acknowledge" or refute the self-evident fact of past exposure. Rather, it was ATSDR's purpose to determine whether those exposures (as well as current and future ones) were likely to have been sufficiently high to produce adverse health effects and, if so, to characterize as far as possible the relationship of such exposures to the site in question.

Finally, it was the intention of the passage quoted by the respondent to characterize, insofar as the available data would allow, the extent of the problem, and not to "explain away the problem." Virtually all of the documented, elevated exposures that were clearly attributable to the Dutch Boy site involved on-site exposure. Based on the available data, ATSDR was unable to conclude that off-site exposures were likely to be associated with any readily identifiable adverse health effects. Furthermore, given the currently limited access to the site, and the latter's ongoing remediation, it is reasonable to conclude that the site is not likely to pose any public health hazard, either now or in the future. This is not to say, however, that lead exposure in this area will cease altogether or that other sources of excess lead exposure do not exist in the larger area surrounding the Dutch Boy/International Harvester sites. Background levels will, no doubt, remain relatively high throughout southeast Chicago, as they tend to do in similar urban areas across the country.

Comment: 39. Page 26, Paragraph 2
Again, we wish to emphasize that, to our knowledge, there was not a sufficient extent of blood lead sampling conducted in 1986. While we might be able to state that those individuals with elevated blood lead levels were exposed on-site, we cannot state that these were the only individuals exposed or that those were the only individuals with elevated blood lead levels. Additionally, the PHA needs to clarify the number of people with lead toxicity (previously stated on page 5, paragraph 3 of the PHA, as five, here the PHA states 5 adults and four children).

Using 1986 standards for risk evaluation for lead is unacceptable. An action level of 10 µg/dL should be used to evaluate the children's blood lead, rather than 25 µg/dL. Unfortunately, using blood lead as an indicator of past exposure is not acceptable. Blood lead only reflects body burden when exposure has been at constant environmental levels and is still ongoing.

In the past two decades, the percentage of U.S. children with elevated blood lead levels has dropped from 88% to 6%. Blood levels in children of this community should have followed a similar trend of decline if the environmental impact from the site contamination was negligible. Site-specific children's blood lead levels, which reflect only current exposure, should be compared with recent national data reported in, for example, "America's Children: Key National Indicators of Well-Being, July, 1998." The most that one can conclude based upon the existing information is that there is insufficient data to predict the blood lead levels of children in this community, and no test was performed to determine the total lead body burden to indicate past exposures. As for current lead exposure, the known soil lead levels, on-site and off-site, and the likelihood of elevated maternal burden due to long-term exposure to lead provide sufficient evidence for one to be concerned over the current children's blood lead levels. A community-wide blood lead screening of children should be recommended by ATSDR.

The lack of apparent signs of toxicity does not negate the possibility, however small, that the blood lead levels were sufficiently high as to cause low scores on cognitive ability and decreased nerve conduction in children, high blood pressure in middle-aged men, and increased likelihood of pre-term deliveries in women. The reported five cases of apparent lead toxicity do not eliminate the possibility of developmental and nervous system toxic effects in the rest of the community.

Response: ATSDR can analyze and make health recommendations based only on data that both exist and are available for review.

As noted in the PHA, the 5 people with lead poisoning who were identified on page 5, paragraph 3, were diagnosed from 1985 to1986 and had been on the Dutch Boy site during the period when demolition activities were occurring. An additional four people were diagnosed in 1986 during an extensive screening program.

The 1986 standards were applied to the data because (1) the blood lead levels themselves were specific to 1986, and (2) the 1986 standards are more consistent with levels generally recognized by the scientific community as being associated with health effects that are readily attributable to low-level lead toxicity. The more subtle effects that have often been attributed to even lower blood lead levels in recent years are detectable only as a statistical, group phenomenon (for example, as differences in mean intelligence quotient between groups). They are not clinically significant effects that can be identified on an individual basis and attributed to lead exposure. Also, the average I.Q. differences identified in some studies are too small to have any impact on an individual's lifetime achievement, even if one were to assume that the alleged differences are, in fact, real effects attributable to lead exposure. The small differences reported are typically within the intrinsic variability or standard error of the test instruments used. In some of the largest and best studies (for example, the Southampton Study), the apparent differences between groups disappears altogether when other factors known to have a much stronger affect on I.Q. than lead are properly controlled for (Child Neurology 25(Supplement):47, 1983).

As was indicated in the PHA (page 27), the 1986 blood lead screening results were, in fact, intermediate between the results from NHANES II and NHANES III, as one would expect given the nationwide decline in blood lead levels during that period of time. However, more specific conclusions could not be drawn from this comparison, because the data were not matched with the data from West Pullman according to age, sex, race, income level, and geographic location.

There is no strong justification for ATSDR to recommend even more sampling, considering the very large amount of blood lead screening data (for the years 1985, 1986, 1995, and 1996) already available for the larger area around the Dutch Boy/International Harvester site, as well as the low likelihood that the site constitutes a potential source of significant lead exposure now or in the future. More immediately useful would be the release of certain personal identifiers (for example, address, age, sex, race, and household income) associated with individual blood leads already available. The absence of such information severely limits the conclusions that can be drawn from the existing data. Thus, the collection of even more blood lead data that does not lend itself to specific comparisons would serve no useful purpose.

ATSDR thanks the respondent for pointing out that the available data, while indicating no apparent signs of toxicity, nevertheless do not remove the "possibility, however small," that sub-clinical or unmeasurable effects, or both, which might or might not be attributable to lead exposure, might still exist somewhere in the community. However, since it is impossible to prove a negative, ATSDR has no choice but to concentrate on what the data do or do not indicate.

Comment: 40. Page 26, Paragraph 3
It is inappropriate to compare the blood lead levels for 1986 with the national data for 1976 through1980. In the United States, there has been a consistent decline in blood lead levels from late 1970s up to now. Significant decreases in blood lead levels took place in the majority of the U.S. population, especially in urban populations.

Response: See response to the previous question (#39).

Comment: 41. Page 26, Paragraph 4
The potential for off-site exposure still exists with lead concentrations as high as 16,200 mg/kg. The PHA should call for remediation activities to be conducted in a way that is, truly, protective of human health.

Response: ATSDR has recommended in the health assessment that additional soil sampling be conducted off site to identify areas of potential high lead contamination that may subsequently be remediated to reduce exposure.

Comment: 42. Page 27, Paragraph 1
The PHA should call for remediation activities to be conducted in a way that is, truly, protective of human health.

Response: Please see response to Comment 41( Page 26, Paragraph 4).

Comment: 43. Page 27, Paragraph 2
ATSDR again concludes that "PAHs in soil at the Dutch Boy site did not constitute a probable past hazard to public health because neither the levels nor the exposure conditions were sufficient to produce any known adverse health effects in humans." TOSC requests that ATSDR provide the scientific basis on which to make such an argument (e.g., sampling and analysis from the period of potential historic exposure). To our knowledge, this data does not exist. PAH data taken 15 years after the plant operations ceased cannot be used to assess either the past concentrations or the past exposure. Because of the degradation of PAHs (albeit slow for many) and the irreversible sorption onto soil particles, it is expected that PAH concentrations would have been much higher when the plants were in operation than what were detected at the time of sampling.

The comparison to "eating grilled steak" trivializes the concerns of the community and should be removed from the report. To our knowledge, there is no scientific basis on which to make this comparison.

Response: The referenced conclusion, numerically analyzed environmental monitoring data (for example, "sampling and analysis from the period of potential historic exposure") do not, by themselves, constitute a "scientific basis" for any conclusion regarding the potential health consequences of an exposure. (toxic exposures cannot be identified by just comparing an environmental concentration to some numerical estimate of safety to see which one is larger.) Such conclusions must derive from the knowledgeable interpretation of such data in the light of "the best medical and scientific information available" (PHAGM, 1992, pg. 7-4). The most relevant information for that purpose relates to (1) the toxicology of the substance in question; (2) its fate in the environment; and (3) the degree of exposure that is feasible through contact with the specific, contaminated medium of concern. In the case of PAHs in on-site soil at Dutch Boy, such relevant information supports the same conclusion regardless of the concentrations involved. For example:

(1) PAHs are, for the most part, readily metabolized and eliminated and, with the exception of some allergic reactions, the acute toxicity of PAHs is relatively low. Few adverse health effects clearly attributable to PAHs have ever been demonstrated in humans.

(2) Inhalation of complex PAH mixtures (for example, cigarette smoke, roofing tar or coal tar pitch volatile, and coke oven emissions) might cause cancer in humans, but the doses required are typically high and of long duration. More to the point, however, there are no studies that provide evidence of a direct association between oral or dermal exposure to PAHs and cancer in humans. Therefore, any attribution of risk to humans exposed via these routes must be based solely on animal experiments.

(3) A few PAHs have caused cancer in laboratory animals treated with extremely high doses by skin-painting or gavage. However, the unusual treatment protocol (including TPA promotion) in the former case and the most commonly affected organ (forestomach) in the latter render such studies of little relevance to cancer risk in humans. People are not repeatedly treated with promoting concentrations of TPA; nor do humans possess an organ analogous to the forestomach of rodents.)

(4) The systemic PAH exposures that result from occupational inhalation exposures are quite simply impossible to achieve with PAHs in soil. Since PAHs bind tightly to soils (as the respondent points out) and exhibit very low volatility, any significant exposure to PAHs in soil would, necessarily, entail direct contact with or ingestion of the soil itself. However, the total doses that might have been associated with such exposure to the most highly contaminated soil at the Dutch Boy site did not approach the levels that might occur in a normal diet.

5) It is not necessarily true, as the respondent suggests, that PAH concentrations in soil "would have been much higher when the plants were in operation." Because PAHs bind tightly to soil particles, they tend to accumulate with time. Also, it is reasonable to expect that, when the plants were in operation, chronic exposure would have been limited to full-time, on-site employees, and the default soil intake rate for adults is only half that of children.

ATSDR also does not concur with the respondents opinion that the grilled steak comparison "trivializes the concerns of the community." The function of this type of comparison is to place estimated data, such as PAH exposures expressed as mg/kg/day, into a meaningful perspective that is readily accessible to all readers. The exposure in this case actually is trivial, from a public health standpoint. But the community's concerns about those exposures most certainly are not. That is why ATSDR takes very seriously the need to put environmental exposures into proper perspective, whether those exposures represent genuine hazards or not. Technical explanations often do more to mystify, than to clarify, scientific matters for the general public; everyday examples, where applicable, are generally much more effective. However, for the benefit of those readers who might be interested in the mathematical background of the "grilled steak" comparison, some sample calculations are presented below.

Assume, as an intermediate estimate, that an average grilled steak or hamburger patty contains approximately 11 mg benzo(a)pyrene, the most toxic, natural PAH) per kilogram of meat. (Depending on the fat content and the method of cooking, the amount could be as much as ten times higher. See page 92 in Food Safety & Toxicology, DeVries, 1996, or page 439 in Handbook of Human Toxicology, Massaro, 1997.) Each ounce (0.0284 kg) of such a steak would then contain 11 X 0.0284, or 0.3 mg benzo(a)pyrene.

Now, assume that the maximum BaP concentration in soil at the Dutch Boy site (expressed as total BaP TEQs, to introduce even more conservatism into the analysis) is 1.17 mg/kg, and further assume that all of a child's default daily soil intake of 200 mg comes exclusively from this maximally contaminated "hotspot." Even under these unrealistic conditions, a child's daily soil-related BaP intake would still be only 0.0002 X 1.17, or 0.234 ug/day.

Of course, one might argue that a child might not eat one ounce of steak (or hamburger) every day. But then, neither will any child actually eat 200 mg of maximally contaminated soil from the Dutch Boy site every day. Note also that hamburgers from fast food establishments typically contain two to four times the amount of meat used in the preceding example (1 oz). The important point here, however, is not what the absolute concentrations or specific values of default intake rates might be. Rather, if the PAHs in the tens of thousands of hamburgers that Americans eat every day are not associated with any detectable adverse health effects, then even smaller exposures to PAHs in the dirt that they walk on should not be either.

 

Comment: 44. Page 28, Paragraph 1
ATSDR concludes, "there is no evidence that any of these PAHs individually are carcinogenic to humans, especially by the ingestion route." This statement is irrelevant since the PAHs would not have been ingested as a single compound but as the complex mixture present on the soils or in the dust. Furthermore, there is evidence that chewing tobacco causes a variety of cancers, and any PAHs to which a tobacco-chewer would be exposed, would be ingested. There have been thousands of hours dedicated by toxicologists, health officials and other scientists to set the risk-based criteria for PAHs. Why does ATSDR present a very limited data set (two studies) to try to dispute all of the previous efforts by EPA and others? This entire paragraph should be eliminated.

The reasoning in this paragraph also ignores the fact that the black, oily sludge continuously backs up in residential houses, and the possibility that this sludge contains significant concentrations of PAHs.

Response: ATSDR's choice of data is not designed to "dispute all of the previous efforts by EPA and others." To the contrary, it is designed to supplement the "very limited data set" that regulatory agencies use to assign substances to specific cancer categories. (Generally, the basis of such classifications is one or more animal bioassays conducted at the maximally tolerated dose or, much less often, one or more occupational studies that typically involve dose levels or exposure routes, or both, that are irrelevant to the conditions of exposure that pertain at the sites being investigated by ATSDR.) These categorical designations simplify the process of regulating substances in the environment that might pose a threat to public health. However, they were never intended to be used to predict actual health effects in people under radically different conditions of exposure from those in the reference studies. The fact that these "risk-based criteria" all too often have been (and continue to be) misused in precisely that way does not in any way justify or validate the discredited practice. (Note that, using standard regulatory methodology, perhaps 40% or more of all chemicals, both man-made and natural, might be categorized as "carcinogens.") ATSDR is required by law (CERCLA, 1980) and by its own published guidance (PHAGM, 1992) to go beyond simplistic cancer classifications and risk-based criteria and comment fully on the likelihood that specific adverse health effects will actually occur, under site-specific conditions of exposure, in people living on or near contaminated sites, and to advise EPA and potentially affected residents accordingly.

Comments: 45. Page 28, Paragraph 2
Again, there have been many hours dedicated by toxicologists, health officials and other scientists to set the risk-based criteria for asbestos. ATSDR presents a very limited data set ("several epidemiological studies" presented in a secondary reference) to dispute all the previous efforts by EPA and others. This entire paragraph should be rewritten to reflect the scientific evidence that the maximum level of asbestos measured in air in 1996 exceeded ATSDR's CREG for asbestos, but that the health effects due to this exposure cannot be determined, since the length of exposure is unknown.

Response: The "health effects due to this exposure" could not have been determined even had the length of exposure been known. Again, the respondent appears to be confusing regulatory standards and user-friendly risk management tools with the medical and toxicological data that are actually relevant to the realistic, site-specific assessment of potential health effects in chemically exposed human beings. (See the response to the previous comment, # 44).

Comment: 46. Page 28, Paragraph 3
The paragraph should end with the third sentence ("...did or did not exceed the GREG"). There is insufficient scientific evidence to make the additional conclusions made in this paragraph. In particular, because the detection limit was so high, ATSDR does not know whether hazardous exposures occurred. In addition, ATSDR ignores past arsenic exposures, which may have occurred during the 1983-1986 demolition work.

Response: If ATSDR were to edit the indicated paragraph in the way that the respondent recommends, the agency would be eliminating the only useful information available on which to base an assessment of the probable health implications of the exposures of concern.. The resulting truncated paragraph would convey no useful information at all, and the resulting information vacuum would only invite unfounded and needlessly alarming speculation which would not serve the best interests of the affected community. In support of its conclusions, ATSDR is frequently unable to provide solid evidence that proves satisfactory to all interested parties. However, it is always possible, at the very least, to use any and all available and relevant information to put the exposures of concern into some kind of meaningful perspective.

Because ATSDR could not comment on the unknown concentration of an undetected substance, the next best thing was to consider the possibility that concentrations only slightly below the detection limit would produce adverse health effect in exposed humans. While the CREG for arsenic in air (0.0002 mg/m3 ) was 700 times lower than the detection limit of 0.14 mg/m3, the detection limit itself was 70 times lower than the lowest cancer effect level ever reported in humans (10 mg/m3), and there was no way of knowing how much lower still the true concentration of arsenic in air at Dutch Boy might have been. Thus, even under worst case conditions, for example, assuming that the true concentration of arsenic in air was the highest it could be without being detected and that people were chronically exposed to this highest concentration throughout their entire lifetimes, no detectable adverse health effects would be expected. Under more realistic conditions of exposure, any theoretical health risks would have been proportionately lower, if indeed they existed at all.

Comment: 47. Page 28, Paragraph 4
How does ATSDR know the frequency of trespassing ("occasional")? Could it not be possible that residents from the West Pullman and Victory Heights neighborhoods cross through the site twice each day, five days per week, on their way to and from the Metroline stop?

Response: Yes, it most certainly is "possible." But it would, in ATSDR's opinion, still constitute "occasional" trespassing, which is to say, an activity pattern that would occasion only intermittent (nonchronic) exposures of little or no toxicologic significance.

Comment: 48. Page 29, Paragraph 1
In a discussion of hazards associated with PAHs, ATSDR states, "The maximum concentrations of PAHs in on-site soils at IH were actually higher than the maximum concentrations detected in 'black, oily-sludge' from the bottom of on-site manholes, suggesting that these heavily contaminated 'soil' samples would probably not qualify as the type of soil that might be incidentally (and especially not intentionally) ingested by workers or trespassers." ATSDR appears to be stating that, because the concentration of soil PAHs were higher than in the sludge, people will not tend to ingest the soil. As written, this statement appears to be an attempt to justify an unsubstantiated conclusion that the soil PAHs do not present a health hazard. This paragraph should be rewritten.

Response: ATSDR considers that the meaning of the paragraph is clear as written. It expresses the entirely reasonable expectation that adults and children alike are far more likely to avoid foul-looking, sludge-like material than they are to habitually ingest it.

Comment: 49. Page 29, Paragraph 2
ATSDR again concludes, "...PAHs in soil at the IH site are not likely to have caused adverse health effects in workers." TOSC requests that ATSDR provide the scientific basis on which to make such an argument (e.g., sampling and analysis from the period of potential historic exposure). To our knowledge, those data do not exist. PAH data taken 15 years after the plant operations ceased cannot be used to assess either the past concentrations or past exposure. Because of the degradation of PAHs (albeit slow for many) and the irreversible sorption onto soil particles, it is expected that PAH concentrations would have been much higher when the plants were in operation than what were detected at the time of sampling.

Response: See the response to Comment 43.

Comment: 50. Page 29, Paragraph 3
The risk assessors write that there was "limited potential for exposure (i.e., ingestion of on-site soil)." As we have stated previously, ATSDR should recognize the potential for children playing on the site, digging in soils and then putting their fingers in their mouths, riding bikes, and breathing contaminated dust. Does ATSDR have data to suggest that the presence of "asbestos in the soil at this site is not likely to pose a public health hazard?"

Response: See responses to Comments 36, 45, and 50.

Comment: 51. Page 29, Paragraph 4
What is the relevance of blood lead screening on 10 children by the city of Chicago? Were these children from this community? Where are their homes located? Do they attend Edward White Elementary School? Do they play on the site? More information is needed in order to make any sense of those data.

Response: The "relevance of blood lead screening on 10 children by the city of Chicago" is that those 10 constitute all of the children from the West Pullman neighborhood who received the blood lead screening offered by the city health department to area children in 1996. Unfortunately, the law required that all personal identifiers be removed from the data provided to ATSDR. The absence of such identifiers severely limited the conclusions that might have been drawn from the data. However, while the data did not allow for sweeping conclusions about either the neighborhood population as a whole, or specific individuals, they also did not indicate any pervasive public health problems related to off-site lead exposure.

Comment: 52. Page 30, Paragraph 1
ATSDR states that "none of the chemicals of concern identified at the Dutch Boy and International Harvester sites are known to have caused any of the above-indicated human health effects." However, this does not negate the possibility that health problems occurred, but were not identified. It is known that nine cases of lead toxicity occurred. Is it not plausible that other, more subtle, health problems occurred, but were not identified?

If the sludge that creeps into homes is similar in chemical composition to that in the on-site manholes, then there is sufficient cause for concern. ATSDR should address the possibility that the "in-home" sludge contains PAHs.

Response: ATSDR endeavors to focus on what existing data do or do not indicate, when interpreted in the context of the best available medical and toxicological information, and to offer judgements based on what is known or is likely to be true, rather than on what is merely "possible."

As for the "sludge" question, ATSDR did "address the possibility that the in-home sludge contains PAHs," and it did so in the very same passage cited in the comment. Quoting Page 30, Paragraph 1, sentences 2 and 3: "The sludge in manholes was reported to be similar to sludge found in some basements. This on-site sludge was analyzed and did contain some PAHs, metals, and VOC contaminants, but not at levels likely to result in adverse health effects."

Comment: 53. Page 30, Paragraph 2
ATSDR correctly states that "sustained dermal contact with complex mixtures of PAHs (e.g., coal tar) can cause skin irritation." Children are known to have played on the IH site. Photographs have been taken of the children surrounded by a cloud of dust. Is it possible that those children sustained dermal contact if they were playing regularly on the site? In addition, allergic skin rashes are not necessarily caused by dermal exposure alone; all possible routes of exposure, including inhalation and oral exposures, can result in systemic allergic responses, including skin rashes.

Response: Yes, it is possible that children playing on-site "sustained dermal contact," but such contact would not likely have resulted in any adverse health effects. If merely incidental contact does results in a skin rash, then an allergic condition is clearly indicated. Health-based comparison values are not applicable to allergic conditions, because allergic reactions are neither dose dependent nor predictable. The only way for allergic individuals to protect themselves is to avoid contact with the allergen or to take treatments to become desensitized.

Comment: 54. Page 30, Paragraph 3
There is a consensus among toxicologists that elevated lead levels may be associated with aggressive behavior. The statement that any "amount of aggressive behavior is normal" is suspect. ATSDR presents no evidence for the assertion that aggression among children in this neighborhood is the result of child abuse, low self-esteem, drugs, alcohol or mental illness. Community members viewed this statement as insulting and insensitive. We challenge ATSDR to tell a citizen in a public meeting that his/her concern about his/her child's aggressive behavior may be linked, not to lead exposure, but instead to mental illness or child abuse! This paragraph must be eliminated.

Response:
The statement ATSDR made regarding aggressive behavior was not intended to be insensitive and the document has been modified. The statement on page 30, paragraph 3, was presented to point out that other risk factors are more effectual, than lead exposure, in influencing aggressive behavior. These risk factors are widely recognized, by scientists and laymen alike, as being among the most important causes of excessively aggressive behavior.

Comment: 55. Page 30, Paragraph 5
Terms like sarcoidosis and granulomatous should be defined.

Response: The reference to sarcoidosis was made in response to a specific community health concern which used the same term. Sarcoidosis is a chronic disease, the cause of this disease is unknown. It is characterized by the formation of nodules in the skin, lymph nodes, lungs, and bones.

Comment: 56. Page 30-32, Child Health Initiative
We commend ATSDR for this entire section as it portrays a much more accurate picture of the risks associated with the DB and IH sites. The author of this section should be commissioned to edit/rewrite the rest of the document. However, we have several suggestions to improve this section.

Response: ATSDR thanks you for the comment, however it should be noted that this section was written by the same person. We welcome your suggestions.

Comment: 57. Page 31, Paragraph 2, Line 5
"Metals" should be added to the list of contaminants to which children playing on the IH site may have been exposed.

Response: The word "metals" has been added to the last sentence in paragraph 2 on page 31.

Comment: 58. Page 31, Paragraph 4 (Current Exposure, DB)
The presence of lead in off-site (roadway) soils needs to be mentioned.

Response: It is mentioned in sentence 4 of paragraph 4 on page 31.

Comment: 59. Page 32, Paragraph 2
Children may be exposed to any chemicals in the black oily sludge until that material is removed.

Response: The sentence, "ATSDR recommends that persons who are concerned with black oily sludge in their basement periodically when it rains, should have it tested for contaminants," has been added to paragraph 1, page 32. However, the presence of the sludge might only occur when there is so much rainfall in a short period of time that the sewer may backup.

Comment: 60. Page 32, Conclusions
ATSDR should state that present levels of lead in the air surrounding the fences, on-site and off-site are unknown and need to be addressed through additional characterization.

Response: This information is stated on Page 32, Conclusions, Bullet Item 3, #1.

Comment: 61. Page 32, Bullet Item 1, #1
There is no evidence to suggest that significantly elevated blood lead levels were limited to those individuals exposed while on-site.

Response: Please refer to ATSDR's response to Comment 26 (Page 17, Paragraph 2) and response to Comment 38 (Page 26, Paragraph 1).

Comment: 62. Page 32, Bullet Item 1, #2
There is no data to support the conclusion that the concentrations of PCBs, asbestos, and PAHs were not sufficiently high as to cause any adverse health effects because of the uncertainty over historic levels of contamination and historic exposures.

Response: Please refer to ATSDR's response to Comment 2 (Page 4, Paragraph 3. Sentence #2) and response to Comment 43 (Page 27, Paragraph 2).

Comment: 63. Page 32, Bulleted Item 2, #2
The lack of vegetation during the winter months creates the potential for contaminated dust to be blown from the site into residential areas. Additionally, the lack of vegetation during the winter months creates the potential for contaminated dust to be blown from the site into residential areas.

Response: Exposure to soil blown off the site in the winter months would be reduced because the ground in the winter months is often wet, frozen, or covered with snow and when people are less likely to be outside as often.

Comment: 64. Page 32, Bulleted Item 2, #3
Proper air monitoring will not reduce exposure, proper safety precautions will.

Response: ATSDR stated that, "additional remedial activities will further reduce potential exposure." Air monitoring is proposed as a safety precaution to monitor for potential on and off-site exposures during remedial activities.

Comment: 65. Page 33, Bullet Item 1
On what basis is the statement made that "past exposures to these on-site contaminants are not likely to have caused any health effects?" The problem is that those data do not exist. Additionally, the lack of air quality data needs to be addressed.

Response: Please refer to ATSDR's response to comment 19, page 10, paragraph 3 regarding the air data. ATSDR made this statement based on the types and concentration of contaminants identified from the data reviewed, the method of exposure, the length of exposure, a toxicological evaluation on the amount of contaminant that is likely to be taken into the body, and the expected health effects known from previous studies. Also refer to responses to Comments 36 (Page 25, Paragraph 4) and 49 (Page 29, Paragraph 2).

Comment: 66. Page 33, Bullet Item 4
On what basis is the statement made that "off-site exposures to site related contaminants do not appear to have been associated with any identifiable public health hazard in the past?" While the effects may not have been identified, the hazards clearly have been documented. There is no basis on which to make the statement that there is not "any health hazard likely to exist now or in the future." In fact the data suggest otherwise.

Response: Please refer to response to Comment 38.

Comment: 67. Page 34, Item 2
Details on the topics to be presented during any community education efforts are warranted.

Response: ATSDR has expanded the recommendations on health education to include information on the potential hazards of going onto either the Dutch Boy or International Harvester sites and education on potential sources of contaminants identified on and off the sites.
Please refer to Page 33, recommendation 2 for Dutch Boy and recommendation 4 in the health assessment.

Comment: 68. Page 35, Item 1
Maintaining the fence around the site should be mentioned.

Response: ATSDR has made this recommendation throughout the document and has also sent a letter to the EPA and ILDEP regarding this issue. Please refer to Appendix B in the health assessment.

Additional Recommendations to ATSDR

There is an urgent need to determine the concentrations of lead in the air around the fences, in the residential and school areas, and on the site. The concentration of lead in the dust in the classrooms of the Edward White Elementary School and in area houses should also be determined as soon as possible. Air samples should also be obtained for other contaminants, including PAHs, asbestos and various volatile organic chemicals that might be present in the GRO- and DRO contaminated soils. Air samples should be taken in houses when black oily sludge backs up in the sewer, especially since one advisory council member stated that his house reeks of a petroleum-like odor for several days after the sludge backs up in his basement.

Response: ATSDR has made recommendations to conduct perimeter air monitoring for lead, polycyclic aromatic hydrocarbons, volatile organic compounds, and asbestos during future remediation of the Dutch Boy site. Perimeter air monitoring will detect contaminants at the perimeter of the site to determine if there are potential off-site releases occurring during remedial activities.

1. The infiltration of the black oily sludge in residential houses should be stopped.

Response: ATSDR has recommended that people who are concerned with black oily sludge in their basements periodically when it rains, should have it tested for contaminants.

2. An effective community-wide program to test children's blood lead and to examine the relationship between aggressive behavior and other possible causative factors ATSDR has suggested on page 30, needs to be implemented.

Response: According to local health department reports, several meetings to discuss screening residents in the area for lead already have occurred. Public Meetings were held on May 17 and June 7, 1986, prior to and after a court order was issued on May 19, 1986, to stop demolition activities at the sites. The Chicago Department of Health and the Cook County Health Department provided screening services with support and consultation from the Illinois Department of Public Health. The screening effort extended to all adults and children residing in the area and all adults who had been employed by the factory. It was anticipated that 3,000 people would be screened by this effort. On June 10 and 11, 1986, the Chicago Department of Health and the Cook County Health Department provided screening services at two locations, screening over 2,500 residents living nearby.

3. Currently children and other residents having free access to the lead-contaminated soils along the railroad could be exposed to undesirable amounts of lead. The lead-contaminated dust and soils can be carried to their homes. This area should be identified as hazardous, public access to the area should be stopped, and a public health advisory warning should be issued.

Response: ATSDR will discuss the option of placing signs along the fence line to warn people of potential hazards.

4. A plan to determine the body burdens of lead in women of reproductive age and in children needs to be developed as soon as possible.

Response: Please refer to responses to comments 38 (Page 26, Paragraph 1) and 39 (Page 26, Paragraph 2).

5. Additional analysis for PCBs on the IH site is warranted to determine the fate of the PCBs that were found in 1987, but not in 1995.

Response: Sampling in 1987 detected PCBs at a concentration of 18 ppm in soil samples taken on the IH site. PCBs were not detected above the minimum detection limit during further soil sampling conducted in 1995. The site is currently covered with vegetation, and with proper maintenance of the fence, exposures should be minimal. Also, additional remedial activities are planned by the EPA to further reduce the potential for future exposure.

6. Residents that have black oily sludge in their basements should be examined for health effects potentially related to the chemicals that may be found in the sludge.

Response: During ATSDR's availability session, residents expressed concern about the sludge in their basements that occurred during periods of rain. The sludge in manholes located on the International Harvester site was reported to be similar to the sludge found in residential basements. Samples were taken in the manholes and analyzed for PAHs, PCBs, and metals (IEPA, March 1995). Refer to Appendix C, Table C, for a list of the contaminants detected. ATSDR reviewed the data and the levels of PAHs and metals were above ATSDR child comparison values, but below levels of health concern. VOCs were below comparison values. Please refer to the response to Comment 48 (regarding Page 29, Paragraph 1, in the health assessment).

Comment: 69. ATSDR did not address the age of housing in the neighborhood surrounding the site, and the likely impact of lead-based paint on health. Studies have clearly shown that leaded dust in older homes is a major contributor to elevated blood lead in children compare to lead in outdoor soil.

Response: ATSDR stated in the public health assessment that off-site soil data were limited. While surface soil sampling conducted in March 1995 did not demonstrate concentrations of lead at levels of health concern, a small number of samples were taken to evaluate exposures to off-site contaminants. Therefore, ATSDR made a recommendation in the health assessment to further sample residential soils within the community. When these data become available, the potential off-site exposure pathways, including non-site-related potential exposures will be further evaluated.

Comment: 70. On page 5, there is mentioned that demolition at the Dutch Boy site resulted in the lead poisoning of 5 people. IEPA considered the activities to be an "imminent danger: due to lead and asbestos airborne exposure. On page 7, the elevated blood lead levels are "attributed to the demolition activities at the Dutch Boy site." This should be mentioned as a past completed exposure pathway in the toxicological evaluation.

Response. ATSDR has included this information in the completed exposure pathway section of the document in the text (page 17), in Table 6 (page 17), and in the toxicological evaluation section on page 26. ATSDR requested but was not provided the information to review the blood lead data regarding exposures that occurred on the Dutch Boy site and relied on references made in other documents.

Comment: 71. In Tables 1 and 3, shouldn't the comparison value (if the term is used correctly here) be 400 ppm (USEPA, June 1998) rather than 500 ppm.

Response:. The EPA recommended action level for lead in residential soils is 400 ppm. Tables 1 and 3 have been amended and corresponding changes have been made within the text.

Comment: 72. In the conclusions, both "potential" and "indeterminate" public health hazards are no longer acceptable. The authors should make conclusions from the data that is available, and then recommend the additional data needed to better characterize the site.

Response: Currently, ATSDR is using five hazard categories for ranking sites, including "indeterminate public health hazard." Revised categories are being proposed but have not been formally adopted. Therefore, the existing categories were used within the document. In addition, "potential" was never a health hazard category, but is used to define a pathway of exposure. When ATSDR's revised categories are available they will be provided upon request.

Comment: 73. In the recommendations, what is meant by "provide community education?" Education about what? What is the purpose of the education? Michigan State University has already provided considerable education in the community, but this is not mentioned.

Response: ATSDR has modified the recommendation section of the document to read, "provide community education regarding potential exposures when trespassing on the site." This pertains to both sites, but in particular to the International Harvester site where fence security remains a concern. Also, see page 34, of the public health action plan section. ATSDR has recognized the completed community health activities provided by the Technical Outreach Services (TOSC) for the community living near the International Harvester and the Dutch Boy sites. TOSC is a service provided by Michigan State University.


REFERENCES

1. Determination of Background Concentrations of Inorganics in Soils and Sediments at Hazardous Waste Sites. EPA/540/5-96/500, Office of Solid Waste and Emergency Response, 12/95.

2. Report on the West Pullman/Victory Heights Site, Chicago, Cook County, Illinois. Eastern Research Group. March 1997.

3. Agency for Toxic Substances and Disease Registry (ATSDR). Southeast Chicago Health Outcome Data Study. June 1998. Atlanta, GA.

4. Simon Hydro-Search, Inc. Environmental Assessment Report, 120th and Peoria Streets, Chicago, IL; NOV 1993.

5. Ecology & Environment, Inc. Site Assessment Report for International Harvester/Dutch Boy Sites. Part 2 of 2; 25 AUG 1995.

6. ENVIRON Corp. Draft Extent of Contamination Survey, Dutch Boy Site, Chicago, IL; 31 JULY 1997.

7. Toxicological Profile for Lead. April 1993. ATSDR. Atlanta, GA.

8. Harza Environmental Services, Inc. Limited Soil Investigation and Paint Sampling, Former Dutch Boy Paint Site, Chicago, IL; JUNE 1994.

9. Professional Service Industries, Inc. Subsurface Exploration, 120th Street and Peoria Avenue, Chicago, IL; 7 JULY 1987.

10. Harza Environmental Services, Inc. Perimeter Air Monitoring During Demolition, Dutch Boy and International Harvester Site. AUG 1996.

11. Roy F. Weston, Inc. Site Assessment; 5 MAY 1988

12. Ecology and Environment, Inc. Site Assessment Report; 7 OCT 1993.

13. Site Inspection Prioritization, International Harvester Site, Chicago, Illinois. Illinois Environmental Protection Agency. March 1995.

14. Ecology and Environment, Inc. Site Assessment Report for International Harvester/Dutch Boy Site, Chicago, IL. Part 1 of 2; 18 AUG 1995. REFERENCES: Toxicology

15. ATSDR (1995). Toxicological Profile for Polycyclic Aromatic Hydrocarbons (PAHs) (Update). Agency for Toxic Substances and Disease Registry, Atlanta, Ga., August 1995.

16. Williams and Weisburger (1991). "Chemical Carcinogenesis". In: Casarett and Doull's Toxicology, (Mary O. Amdur, John Doull, and Curtis Klaassen, Eds.), Pergamon Press, New York, New York, 1991.

17. ATSDR (1995b). Toxicological Profile for Asbestos (Update). Agency for Toxic Substances and Disease Registry, Atlanta, Ga., August 1995.

18. ATSDR (1993). Toxicological Profile for Arsenic (Update). Agency for Toxic Substances and Disease Registry, Atlanta, Ga., April 1993.

19. Needleman, HL; Riess, JA; Tobin, MJ; Biesecker, GE; and Greenhouse, JB (1996). "Bone Lead Levels and Delinquent Behavior." J. Am. Med. Assoc. 275(5): 363-369.


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