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PETITIONED PUBLIC HEALTH ASSESSMENT

KEIL CHEMICAL
HAMMOND, LAKE COUNTY, INDIANA


SUMMARY

Residents of Hammond, Indiana petitioned the Agency for Toxic Substances and DiseaseRegistry (ATSDR) to conduct a health assessment in response to concerns of child brain cancerand emissions from the Keil Chemical plant. Specific concerns were the release of 1,2-dichloroethane (EDC) and vinyl chloride during the Pyro-Chek process started in 1980. ATSDRreviewed air, water, and soil data provided by state and local environmental agencies and fromKeil Chemical. ATSDR conducted an exposure investigation in cooperation with the HammondDepartment of Environmental Management and volunteer community members to assess currentair emissions from the plant. No data were available to review prior to 1988 and the siterepresents an indeterminate health hazard prior to this time. Contaminants detected in samplesfrom an air monitoring station located 1.5 miles from the site were not at levels of healthconcern. Only EDC was detected at low concentrations during the exposure investigation but notat levels of health concern. No contaminants were detected in the soil or wastewater abovehealth comparison values and people would not be exposed to wastewater generated by the plantor exposed to on-site contaminated soils. Therefore, this site does not currently represent ahealth hazard. The Pyro-Chek process is no longer in operation at this site and supplies of EDChave been removed. The Indiana State Department of Health (ISDH) conducted a review ofreported cases of childhood cancers to determine if cancer rates in children living in the LakeCounty area are elevated. The ISDH is concurrently releasing its findings in a healthconsultation, concluding that rates of childhood cancer were not elevated for Lake County and for the community surrounding the Keil Chemical Company.


PURPOSE AND HEALTH ISSUES

On February 9, 1999, Representative Peter J. Visclosky (1st District, IN) requested the Agencyfor Toxic Substances and Disease Registry (ATSDR) to conduct a health assessment on behalf ofpetitioners concerned with potential air emissions from the Keil Chemical Company in LakeCounty, Indiana. Residents were concerned that the incidence of pediatric cancers within theirneighborhood may have been caused by the release of 1,2- dichloroethane (ethylene dichloride orEDC) and vinyl chloride (VC) from this plant. The purpose of this health assessment is toevaluate data and information on the release of hazardous substances into the environment in order to assess any current or future impact on public health and to identify actions necessary to prevent future health effects.


BACKGROUND

The Keil Chemical Company (Ferro Corporation), at 2850 Sheffield Avenue in Hammond, islocated within a mixed residential/industrial area of Indiana (Figure 1). In 1980, FerroCorporation started the Pyro-Chek process at the Keil Chemical plant in Hammond. In thisprocess, EDC is used as a solvent to produce brominated polystyrene. Prior to 1995, over 900tons of EDC were purchased per year by Keil. Most of the EDC and a breakdown product, VC,were thought to have volatilized into the air rather than released into the wastewater. In 1994,Keil Chemical Company entered into a consent agreement with the Indiana Department ofEnvironmental Management (IDEM) which required stack tests, leak detection and repair, and acarbon absorption system. According to this agreement, fugitive and stack emissions would belimited to 25 tons per year of volatile organic compounds (VOCs). In September 1995, IDEMwas informed that EDC purchases were expected to be in excess of 80 tons. IDEM andHammond Department of Environmental Management (HDEM) investigated concerns regardingEDC emissions into the community. Discrepancies existed in the reported level of fugitiveemissions, the use of the EPA Protocol for Equipment Leak Emission Estimates, and EDCdegradation (1). In 1997, IDEM prepared a draft permit for the process. During a publicmeeting, a number of residents complained of health problems which they felt were attributed toemissions from this facility. The issuance of the permit was subsequently delayed.

In June 1998, an inspection of the facility was conducted by EPA, IDEM, and HDEM focusingon Keil's compliance with the 1994 consent agreement. In October 1998, stack emission testresults indicated VC emissions of 13 tons per year. IDEM informed Keil Chemical of futureenforcement actions due to violations of the agreement order. Although Keil Chemicalsubmitted a plan to reduce EDC and eliminate VC emissions, it would not agree to a voluntarilyshut down. IDEM sought a restraining order to shut down operations, a 15 day shut down began on November 23, 1998.

ATSDR accepted a petition to assess potential exposures to the community living near the KeilChemical Company and the facility's operations. On August 3, 1999, ATSDR conducted a sitevisit of the Hammond community and the area around the plant. A meeting was held with thecommunity to discuss their concerns and to explain ATSDR's health assessment process. FromAugust to December 1999, ATSDR conducted an exposure investigation, sampling for VOCs inambient air within the community and near the plant. The results were presented at two publicmeetings held in June 2000. The Indiana State Department of Health committed to reviewreported cancer cases (all childhood cancers combined, brain and central nervous systemcombined, and leukemia) of children less than 20 years of age living in Lake County. In June2000, Keil Chemical Company removed EDC supplies on-site and eliminated the Pyro-Chekprocess at this location.

Community Concerns

ATSDR was petitioned by the community to assist in addressing two issues: 1) residents'concerns regarding children in the community who have been diagnosed with brain and othercentral nervous system cancers, and 2) whether emissions from the Keil Chemical Company are a threat to their health.

Demographics

Hammond, Indiana is a semi-industrial city near the suburbs of southeast Chicago, Illinois. Thepopulation of Hammond, within a one mile radius of Keil Chemical Company is 1209 (Figure 2). According to the 1990 United States Census, 97% (1175) are Caucasian and 3% (34) are citizens of other origins. Children represent 8% (94) of the population, adults age 65 and older 22% (260), and females aged 15-44 represent 20% (247).


DISCUSSION

During a health assessment, ATSDR obtains the community's concerns, environmental data, andother medical, toxicological, demographic, and environmental information that may affect thehealth of a community. To determine if health effects are likely to occur within the community,ATSDR health professionals consider various factors: the toxicity of the contaminant, theconcentration (how much), the time of exposure (how long), and how the chemical gets into thebody (breathing, eating, drinking, or skin contact). Other factors: occupation, personal habits,age, nutritional status, general health, and genetics are also considered. These factors affecthow a contaminant is absorbed, distributed, metabolized, and eliminated from the body. A healthassessment evaluates contaminants to determine whether exposure to them has public healthsignificance. ATSDR selects and compares on- and off-site concentrations of contaminants withATSDR comparison values for noncarcinogenic and carcinogenic effects (Appendix B). Comparison values are concentrations of contaminants in specific environmental media (air,soil, and drinking water) that are not expected to produce adverse health effects in people whoare exposed. These values are used only as screening values; therefore listing a contaminant ina table of "chemicals of concern" does not mean that it will necessarily cause adverse healtheffects if exposure occurs at that specified concentration. When the concentration of acontaminant detected on or off the site is above the comparison value, it is further evaluated todetermine the potential for adverse health effects. The focus of the evaluation is on health effectsthat could plausibly result from exposures to site-related contaminants. ATSDR considers bothadults and children when developing comparison values. The potential health effects on childrenis considered separately because in certain situations children may be more sensitive and moreexposed to contaminants. ATSDR then presents its conclusions and recommends appropriateactions. (See Appendix B for additional information regarding comparison values). In thishealth assessment, ATSDR reviewed air, water, and soil data provided by state and localenvironmental agencies and from the Keil Chemical Company.

Air

Past Exposure

Past air monitoring (1988-1998) data obtained by IDEM from the Lake County air monitoringstation located 1.5 miles to the south-southeast of the community was reviewed by ATSDR. Thelocation of this station was not selected specifically to capture emissions from the Keil plant andis not directly located downwind from the facility. The available data were reviewed for thepresence of volatile organic compounds including EDC and VC in ambient air. Vinyl chlorideproduced during the Pyro-Chek process and released to the atmosphere varied during this period,with lower amounts produced prior to 1993 and in the late 1990s. Operations at the plantresulted in the release of varying amounts of VC on some days in 1994 and 1995. Ethylenedichloride and VC were not detected above 1 parts per billion (ppb) in air samples collected fromthe monitoring station in 1998 and 1999.

The highest concentrations of EDC and VC detected off-site over an 8-year period (1988-1996)was 22 ppb and 15 ppb, respectively. However, the 24-hr sampling period may dilute short-termconcentrations and emissions may have been higher in the past. While these maximumconcentrations did not exceed ATSDR's environmental media evaluation guide for chronicexposure for EDC (cEMEG = 200 ppb) or the intermediate exposure in air for VC (iEMEG=30ppb), they did exceed ATSDR's cancer risk exposure guide (CREG) for EDC (0.01 ppb) and VC(0.04 ppb). However, this data may not be representative in capturing maximum concentrationsof contaminants within the community due to the location of the monitoring station from theresidential areas, wind fluctuations due to lake effects, and the episodic and short duration of releases of EDC and VC from the Keil facility during this period.

Current Exposure

In 1999, an air exposure investigation was conducted by ATSDR in cooperation with HDEM andvolunteer community members to assess current air emissions from the Keil Chemical plant. Airsampling was conducted within the Hammond community from 8/03/99 to 12/07/99 for prioritypollutants including VC and EDC (2). A total of 18 air samples were taken, Figure 1 shows thesampling locations (1-21). Sampling dates were not announced and air samples were collectedduring normal operations of the facility. Hourly stack emission data from the facility and currentmeteorological data obtained from a 10-meter tower located at the Keil facility were alsoreviewed to determine whether the facility was emitting EDC and VC during the exposureinvestigation.

Stack data indicated that emissions of EDC and VC occurred during the sampling dates and thatthe facility's control of VC emissions continued to fluctuate. Dispersion modeling (EPA'sIndustrial Source Complex Short Term Model [ISCST3]) of the air sampling data was used todetermine whether the sampling locations were adequate to predict potential maximumcommunity exposures to Keil's emissions occurring on those dates (3). Due to variations inmeteorological conditions (wind shifts due to the lake effect), the maximum impact area alsovaried during the sampling period. However, on days when the sampling station was directlydownwind during the sampling period, the maximum concentration detected in air samples takenwithin the community matched closely the maximum predicted concentration modeled fromstack emissions released during the same period. Refer to the Keil Health Consultation-ExposureInvestigation (December 2000) for a complete discussion of the air sampling methodology (2).

Results from the exposure investigation showed that VC and other target contaminants were notdetected at levels of health concern. EDC was only detected at concentrations of 4.2 ppb and0.86 ppb at the Keil fence-line during the last sampling date. These concentrations exceed theCREG (0.01 ppb) for inhalation, but not the chronic EMEG (200 ppb). It is unlikely thatresidents would experience adverse health effects since they would not be exposed continually to the maximum emitted concentration (it would be diluted at a distance from the fence-line).

Groundwater

Wastewater Data

ATSDR reviewed wastewater data collected by the Hammond Sanitary District to monitordischarges from Keil Chemical into the municipal sewer (4). Quality control/quality assuranceinformation for this data was not provided and this evaluation is based on the assumption that thecollection procedures and laboratory analysis were appropriate. From January 1994 throughDecember 1998, wastewater samples were taken approximately every seven days during Keil'sdischarge into the Hammond sewer system. Water samples were tested for volatile and semi-volatile organic compounds and metals, including EDC and VC. The concentrations of EDC inwastewater ranged from less than 5 ppb (0.007 pounds per day) to 63,000 ppb (85.7 pounds perday). The average concentration detected for EDC was 829.9 ppb. Concentrations of VC inwastewater ranged from 2 ppb (0.003 pounds per day) to 500 ppb (0.933 pounds per day), theaverage concentration was 18.5 ppb. Ethylene dichloride, VC, and other contaminantsperiodically exceeded the permit limitation for the daily maximum release. However, it is unlikely that residents would be exposed to this wastewater and adverse health effects would not occur.

Monitoring Wells-On site

In November 1992, groundwater monitoring wells were installed near the north property line(MW-1), the south (MW-2 and MW-23), and to the north of the Keil facility (MW-4 and MW-3)(5, 6). Additional samples were collected from MW-1 through MW-4 in January 1993. Sampleswere tested for VOCs, PCBs, and metals. 1,1-dichloroethane was detected in MW-1 (20 and 66ppb), below the chronic EMEG for either a child (90 ppb) or adult (300 ppb). People receive theirdrinking water from a municipal supply and would not be drinking this groundwater.

Soil

During a community meeting, some residents expressed concern with contaminated soil on-sitethe Keil facility. ATSDR reviewed available soil sampling data. Onsite soil samples werecollected in various locations at the Keil Chemical facility from 1992 to 1999 (6). From 1992 to1996, sampling data is limited and no quality assurance/quality control data was available forATSDR to review. Between August and October 1992, two soil samples were collected at thesoil stockpile at 84 tank. No VOCs, SVOCS, pesticides, or polychlorinated biphenyls weredetected. From May to June 1993, soil samples were collected at three locations; pre-excavationsoil sampling at tracks #1, #2, and #3 (5/14/93 and 6/02/93); soil stock at Track #1 and #2(6/29/93), and pre-excavation soil sampling at tracks #1 and #2 (6/30/93). This samplingpreceded the installation of a concrete spill containment pad in this area. A total of twenty-twosoil samples were collected in the areas near the railroad tracks in the central portion of thefacility. No information on the soil depth was available. No SVOCs were detected and reportedconcentrations of VOCs and metals were below comparison values. Ethylene dichlorideconcentrations ranged from 0.15 to 4.2 ppm, below ATSDR's iEMEG comparison values for achild (400 ppm) or adult (1,000 ppm).

In 1996, soil samples were collected at three onsite locations; tank #14 (2/23/96), tank wagon 13spill (2/01/96), and soil stock pile at track #3 (5/03/96). A total of 11 samples were tested forVOCs, SVOCs, and metals. No contaminants reported were above ATSDR comparison values.On November 19, 1996, nine soil samples were collected off site at the Northern Indiana PublicService Company (NIPSCO), immediately west of the Keil facility. No VOCs were detected inthe nine samples. Polynuclear aromatic hydrocarbons (PAHs) were detected in five of ninesamples at concentrations from 0.39 to 32 ppm, above ATSDRs CREG of 0.1 ppm and EPA'sRBC of 0.78 ppm for industrial soils. Arsenic was detected in five samples (4.0 to 11 ppm)above the RBC of 3.8 ppm for industrial soils.

Contaminants detected in two soil samples collected near buildings #5 and # 6 (June 20 and 24,1997) were not above health comparison values. Between October 20, 1997 and February 20,1998, ten soil samples were tested for VOCs, SVOCs, and metals during construction of a pavedspill containment area near building #5. No contaminants detected in these samples were aboveATSDR comparison values.

During the week of March 22, 1999, 66 soil samples were collected from 24 soil boring locationson site as part of a site assessment plan agreement between the Ferro Corporation and the IDEM.Locations sampled were beneath paved surfaces at depths of 0 to 5 feet. These samplesdesignated S1, S2, S3/S4, S6/S7, S8, and BB (Background), indicating the location sampled,were tested for VOCs, SVOCs, and metals (Figure 3). Four contaminants, VC, arsenic,cadmium, and lead were selected for further review. All contaminants detected abovecomparison values were located in the S1 and S2 sampling area, underneath the concrete betweenthe tank farm and the waste pads (Figure 3). Vinyl chloride concentrations ranged from 4.0 to140 ppm, above the chronic EMEG for child (1 ppm and adult (10 ppm). The metals arsenic(0.4- 313 ppm), cadmium (0.2-20.4 ppm), and lead (555-3350 ppm) exceeded comparisonvalues. It is ATSDR's understanding that currently workers and visitors on the site would notcome into contact with chemicals detected in subsurface soils. Therefore, no adverse healtheffects would be expected. However, the Ferro Corporation should continue to conduct a siteassessment to further characterize on-site contamination, particularly if the property is considered for alternative land use in the future.


PUBLIC HEALTH IMPLICATIONS

Toxicological Evaluation

Some contaminants were detected in the air, soil, and wastewater sampled on-site at the KeilChemical facility and off-site in the ambient air. These exposure pathways are the routes bywhich chemicals travel through the environment and may reach residents. In order for exposureto occur, people must come in contact with theses contaminants at levels and durations that mayresult in ill health effects. The presence of contaminants in one of these media does notnecessarily indicate a health hazard and a potential pathway of exposure may be eliminated ifcontaminants are not reaching the residents, the concentration is below health effects levels, theperiod of exposure is short or occasional, or the contaminants are not known to cause health effects.

Soil

Contaminated soil on-site was identified below paved areas and contact with these chemicals isunlikely. Arsenic was detected in five samples (4.0 to 11 ppm) above the RBC of 3.8 ppm forindustrial soils. Arsenic and polyaromatic hydrocarbons found in off-site soil samples near theNorthern Indiana Public Service Company are not believed to be related to operations at the KeilChemical facility. The concentrations detected are below levels of health concern and thegeneral public would not be in these areas on a regular basis. However, people and children inparticular should be cautioned not to frequent or play in industrial areas.

Wastewater

Wastewater generated on the Keil Chemical site enters a sewer and is carried to the municipaltreatment plant. The general public would not come into direct contact with this water, therefore,even though there are chemicals present, they are not a health hazard. Additionally, aftertreatment at the municipal treatment plant, the water must meet the Federal and state waterquality requirements. It is unlikely that people were exposed to these chemicals from sewer off-gassing.

Air

Air emissions have been the community's primary concern regarding the Keil Chemical facilityand is considered a potential pathway of exposure. Air emissions have varied during differentperiods of the facility's operation, especially during production and emission controlmodifications. Both EDC and VC were seen at higher concentrations in the air in past years. Thetwo highest detections of EDC occurred at the monitoring station in 1988 (maximum of 22 ppb)and are twice what has been detected since then. The highest VC concentrations were seen in1994 and 1995, the highest at 15 ppb in 1994. The peak concentrations detected represent dayson which the monitoring location was down wind, days of greater emissions at the stack or somecombination of both influences. Neither chemical has been detected at the IDEM station since the beginning of 1996.

Ethylene Dichloride (1,2-Dichloroethane)

Based on the air monitoring data for 1988-1996, the daily concentrations of EDC averaged only 2.2 ppb and never exceeded 90 ug/m3 or 22 ppb; only 4 data points for that 8-yr period exceeded 40 ug/m3 or about 10 ppb. Currently, ATSDR's chronic minimal risk level (MRL) for EDC is 600 ppb and includes a safety factor of 90 (7). The concentration of EDC detected in air during that period did not exceed the MRL or the lowest observed adverse effect levels (LOAEL). Except one, all known lowest LOAELs for EDC in air are at or above 100,000 ppb (7). In one study where the potential immunosuppressive effects of inhaled EDC was tested, female mice exposed for 3 hours to 5,400 ppb EDC reportedly exhibited an increased susceptibility to infection when challenged with massive doses of bacteria. No effect was observed at 2,300 ppb EDC. In contrast, male rats exposed to 200,000 ppb for 5 hours or 100,000 ppb for 5 hours/day for 12 days did not exhibit any increased susceptibility to infection. However, the species-specific effects observed in this particular study cannot be extrapolated to human beings.

Only the cancer risk evaluation guide (CREG 0.04 ug/m3 or 0.01 ppb) for EDC was exceeded. However, this CREG is not relevant to the site-specific conditions of exposure near the KeilChemical facility because exposures occurred by inhalation. The CREG for EDC is based on anEPA slope factor which is based on an oral gavage study (8) not an inhalation study. In the oralgavage study, rodents were force-fed amounts of EDC that were high (i.e., toxic) enough toinduce stomach tumors (9, 10). When administered in drinking water, EDC was notcarcinogenic in rodents (7, 11). None of the relevant studies in animals or humans implicateEDC as a carcinogen by the inhalation route (7, 11).

No adverse health effects are likely to result from inhalation exposures to EDC that may have occurred near the Keil Chemical facility since 1988. The CREG is not relevant in this case, and the single highest daily concentration of EDC in ambient air measured over an 8-yr period (ca. 22 ppb) was 27 times smaller than ATSDR's chronic MRL (600 ppb) and was 2,454 times smaller than the LOAEL on which that MRL was based.

Vinyl Chloride

The single highest daily concentration of VC in ambient air (37 ug/m3 or about 15 ppb) detectedover the course of an 8-yr monitoring period was less than half of ATSDR's intermediateEMEG/MRL for VC (30 ppb, UF=300) and 643 times lower than the LOAEL on which thatEMEG/MRL was based. Vinyl chloride was not detected in 88% of the samples and assumingthe latter were equal to one half the detection limit, the average exposure over the entire periodwas only 0.92 ppb or only 3% of ATSDR's intermediate EMEG/MRL.

The CREG for VC (0.1 ug/m3 or 0.04 ppb) is not relevant to the site-specific conditions ofexposure that might occur near the Keil Chemical facility. The CREG is based on theassumption of chronic lifetime exposure, while off-site exposures near the Keil Chemical facilitywere intermittent, infrequent (VC was detected in only 12% of samples) and well below thelowest recorded cancer effect level (CEL) for angiosarcoma of the liver (50 ppb) in animals (12). The single highest daily concentration of VC in ambient air measured over an 8-yr period (1988-1996) was slightly over 35 ug/m3 or about 15 ppb. With the exception of dizziness at very highatmospheric concentrations (NOAEL = 4000 ppm), angiosarcoma of the liver (a rare cancer) isthe only adverse health effect that is known to be conclusively or causally linked to highoccupational exposures to VC (12, 13, 14). Non-occupational exposure to VC has not yet beendemonstrated to pose any discernable hazard to public health. There are, for example, noconfirmed non-occupationally exposed cases of angiosarcoma among residents living near a VCsite in Great Britain (15). The lowest CEL for angiosarcoma of the liver recorded in animals is50,000 ppb in mice and female rats exposed for 52 and 30 weeks, respectively, i.e., between 25and 50% of the animals' normal life-spans (12). This is almost 3600 times the highest dailyconcentration (14 ppb) and more than 54,000 times higher than the average concentrationmeasured between 1988 and 1996. Therefore, adverse health effects are not likely to occur at theconcentrations detected in ambient air.

No adverse effects would be expected to result from a lifetime of chronic exposure to even thehighest levels of EDC or VC measured off-site over an 8-year period (1988-1996). The cancerrisk evaluation guides for EDC and VC are not applicable to the site-specific conditions or off-site exposure near the Keil Chemical facility. Both peak and average off-site exposures to EDC and VC were well below ATSDR's lowest non-cancer-based comparison values.

Health Outcome Data

Some community members raised concerns regarding a perceived increase in the number ofchildren diagnosed with brain and central nervous system (CNS) cancers and living near the Keilsite. The Indiana State Department of Health evaluated data obtained from the Indiana CancerRegistry to determine if the rates of cancer in children younger than 20 years living in LakeCounty are elevated compared to rates expected for the county or state. Child cancer rates forLake County were not elevated compared to the state and other counties. Specifically, brain andcentral nervous system cancers (individually and combined) were not elevated in Lake County compared to the state and other counties.


CHILD HEALTH INITIATIVE

ATSDR recognizes that children react differently than adults when exposed to contaminants intheir environment. They are more likely to be exposed for several reasons; children play outsidemore often than adults, increasing the likelihood that they will come into contact with chemicalsin the environment, and because they are nearer to the ground, children breathe more dust, soil,and heavy vapors. Children are also smaller, resulting in higher doses of chemical exposure perbody weight. The developing body systems of children can sustain damage if toxic exposuresoccur during certain growth stages.

ATSDR evaluated the likelihood of children being exposed to contaminants at levels of healthconcern while living in the Hammond area. Based on ATSDR's review of environmental data,past air exposures represent an indeterminate health hazard. No data is available prior to 1988. Results from an exposure investigation conducted in 1999, indicate that children are not currentlybeing exposed to chemical emissions at levels of health concern. As of June 1999, Keil Chemical Company will no longer be conducting the Pyro-Chek process at this facility.


CONCLUSIONS

1. Air emission data prior to 1988 do not exist for review and potential exposures to EDC andVC during this period represents an indeterminate health hazard.

2. Potential exposures to EDC and VC concentrations measured at the IDEM air monitoringstations from 1988 to 1998 may not fully capture maximum exposure occurring within thecommunity due to the location of the IDEM air monitoring station from the residential areas,wind fluctuations due to lake effects, and the episodic and short duration of releases of EDC andVC from the Keil facility during this period.

3. A review of the sampling data collected at the air monitoring station from 1988 to 1998indicates that ethylene dichloride, vinyl chloride, and other target chemicals detected over thatperiod, where not at concentrations likely to result in adverse health effects.

4. Vinyl chloride and other target contaminants were not detected, while EDC was detectedbelow levels of health concern at the Keil's fence line during ATSDR's exposure investigationconducted within the community in 1999.

5. Residents are not receiving their drinking water from sources near the Keil facility and wouldnot likely be exposed to contaminated wastewater released by Keil into the municipal sewer fortreatment. Assuming applicable drinking water standards are maintained, continued consumptionof municipal water by area residents will not result in adverse health effects.

6. The Keil Chemical Company closed its Pyro-Chek operation at this site in June, 2000 andsupplies of EDC were removed from the property, therefore emissions are not expected to occurin the future.

7. Childhood cancer rates were not elevated in Lake County and the community surrounding Keil Chemical compared to the state and other counties for 1987-1997.


RECOMMENDATIONS

1. ATSDR concurs with the Hammond city administrations decision to conduct air monitoring at the Keil Chemical site for one year to be extended depending on future operations at the site.

2. The Ferro Corporation should continue to conduct a site assessment to fully characterize contamination on-site.

3. ATSDR will review other data collected at the Keil facility, when it becomes available.


PUBLIC HEALTH ACTION PLAN

Completed

1. On August 3, 1999, ATSDR conducted a site visit of the Hammond Community and Keilplant site.

2. On August 3, 1999, ATSDR conducted a public meeting in the Hammond community togather health concerns and explain the health assessment process.

3. From August to December, 1999, ATSDR in cooperation with Hammond Department ofEnvironmental Management and community volunteers conducted an exposure investigation

4. On January 2000, ATSDR provided health education packets containing information on cancerand other health concerns to Hammond residents, community groups, media outlets, libraries,town and state officials.

5. On May 2000, ATSDR conducted a health survey requesting information from residents livingin Hammond and Whiting, Indiana related to general health issues, the Keil Chemical site, andother concerns.

6. On June 27 and 28, 2000, ATSDR conducted public meetings at two locations in theHammond community to present results from the exposure investigation of the Keil Chemical site, findings from the community survey, and proposed future health education initiatives.

Planned

1. The Indiana Department of Environmental Management in cooperation with the Hammondcity administration will conduct air monitoring at the Keil Chemical site for one year to beextended depending on future operations at this site.

2. ATSDR will review air monitoring data as it becomes available.

3. ATSDR will continue to provide health education to interested community members.


SITE TEAM/AUTHORS

Adele M. Childress, PhD, MSPH
Environmental Health Scientist
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Exposure Investigations and Consultation Branch

Frank C. Schnell, Ph.D., D.A.B.T.
Toxicologist
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Exposure Investigations and Consultation Branch

Danielle Devony. MS
Toxicologist
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Exposure Investigations and Consultation Branch


REFERENCES

1. Hammond Department of Environmental Management (HDEM). Letter to Agency for ToxicSubstances and Disease Registry. Mar. 18, 1999.

2.Agency for Toxic Substances and Disease Registry (ATSDR). Keil Chemical HealthConsultation. Atlanta: U.S. Dept. of Health and Human Services, 2000 Dec.

3. Lockheed Martin Technology Services Group. Environmental Services REAC. Hammond,Indiana Dispersion Modeling Study. 2890 Woodbridge Avenue, Building 209 Annex. Edison.NY 08837-3679. Mar. 16, 2000.

4. Hammond Department of Environmental Management (HDEM). Waste Water analysisobtained from the Hammond Sanitary District from 1994 to 1996.

5. Kelly-Buck Company. Laboratory analytical results associated with soil and groundwatersamples collected at the Ferro Corporation, Keil Chemical Facility, Hammond, Indiana. ProjectNo. 97007.07. 2130 Superior Avenue, Suite 3-A. Cleveland, Ohio. 44114. Jul. 29, 1999.

6. Kelly-Buck Company. Site Assessment Report. Ferro Corporation, Keil Chemical Facility,Hammond, Indiana. Project No. 97007.03. 2130 Superior Avenue, Suite 3-A. Cleveland, Ohio.Jul. 22, 1999.

7. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological Profile for 1,2-Dichloroethane (Update). Atlanta: U.S. Dept. of Health and Human Services, 1999 Aug.

8. NCI. Bioassay of technical grade 1,2-dichloroethane for possible carcinogenicity. Bethesda,MD: National Cancer Institute, Division of Cancer Cause and Prevention, CarcinogenicityTesting Program. NCI-CG-TR 55. 1978

9. Weisburger EK. Carcinogenicity studies on halogenated hydrocarbons. Environ. HealthPerspect 21: 7-16. 1977.

10. Bhanayem BI, Maronpot RR, and Matthews HB. Association of chemically inducedforestomach cell proliferation and carcinogenesis. Cancer Lett 32(3): 271-8. 1986.

11. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological Profile for 1,2-Dichloroethane (Update). Atlanta: U.S. Dept. of Health and Human Services, 1997 Sept.

12. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological Profile forVinyl Chloride (Update). Atlanta: U.S. Dept. of Health and Human Services, 1997 Sept.

13. Lester D, Greenberg LA, Adams WR. Effects of single and repeated exposures of humansand rats to vinyl chloride. Am Ind Hyg Assoc J 24:265-275. 1963.

14. McLaughlin JK and Lipworth L. A critical review of the epidemiological literature on healtheffects of occupational exposure to vinyl chloride. J. Epidemiol. Biostat. 4(4): 253-75. 1999.

15. Elliot P and Kleinschmidt I. Angiosarcoma of the liver in Great Britain in proximity to vinyl chloride sites. Occup. Environ. Med. 54(1): 14-18. 1997.


APPENDIX A: MAPS AND FIGURES

Area Map
Figure 1. Area Map

Intro Map
Figure 2. Intro Map

Keil Chemical Division, Ferro Corporation, Hammond Indiana
Figure 3. Keil Chemical Division, Ferro Corporation, Hammond Indiana


APPENDIX B: ATSDR'S COMPARISON VALUES

ATSDR comparison values are media-specific concentrations that are considered safe underdefault conditions of exposure. They are used as screening values in the preliminaryidentification of "contaminants of concern" at a site. "Contaminants of concern" may be anunfortunate term because "concern" may be misinterpreted as implying "hazard." For ATSDR, however, a "contaminant of concern" is merely a site-specific chemical substance that the healthprofessional has selected for further evaluation of potential health effects.

Generally, a chemical is selected as a "contaminant of concern" because its maximumconcentration in air, water, or soil at the site exceeds one of ATSDR's comparison values. However, comparison values are not thresholds of toxicity. While concentrations at or below therelevant comparison value are considered safe, any environmental concentration that exceeds acomparison value does not automatically mean it will produce adverse health effects. Indeed, thepurpose behind highly conservative, health-based standards and guidelines is to enable healthprofessionals to recognize and resolve potential public health problems before they becomeactual health hazards. The probability that adverse health effects will actually occur as a result ofexposure to environmental contaminants depends on site-specific conditions, individual lifestyle,and genetic factors that affect the route, magnitude, and duration of actual exposure, and not onenvironmental concentrations alone.

Screening values based on noncancer effects are obtained by dividing NOAELs or LOAELsdetermined in animal or (less often) human studies by cumulative safety margins (also calledsafety factors, uncertainty factors, or modifying factors) that typically range from 10 to 1,000 ormore. By contrast, cancer-based screening values are usually derived by linear extrapolationfrom animal data obtained at high doses, because human cancer incidence data for very lowlevels of exposure do not exist. In neither case can the resulting screening values (i.e., EMEGsor CREGs) be used to make realistic predictions of health risk associated with low-levelexposures in humans.


The following list describes the various comparison values used by ATSDR to select chemicals for further evaluation.
CREG Cancer Risk Evaluation Guide
MRL Minimal Risk Level
IMRL Intermediate Risk Level
CMRL Chronic Risk Level
EMEG Environmental Media Evaluation Guide
aEMEG Environmental Media Evaluation Guide based on acute Minimal Risk Level
IEMEG Intermediate Environmental Media Evaluation Guide
RMEG Reference Dose Media Evaluation Guide
RfD Reference Dose
RfC Reference Dose Concentration
EPAIII EPA Region III
DWEL Drinking Water Equivalent Level
CLHA Child Longer-Term Health Advisory
LTHA Drinking Water Lifetime Health Advisory
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal (µg/L)
MCLA Maximum Contaminant Level Action
NAAQS National Ambient Air Quality Standards
PEL Permissible Exposure Limit (OSHA)
REL Recommended Exposure Limit (NIOSH)
TLV Threshold Limit Value (ACGIH)
FDA Food and Drug Administration
ppm parts per million, e.g., mg/L or mg/kg
ppb parts per billion, e.g., g/L or g/kg
kg kilogram (1,000 grams)
mg milligram (0.001 grams)
µg microgram (0.000001 grams)
L liter
m3 cubic meter (used in reference to a volume of air equal to 1,000 liters)

Cancer Risk Evaluation Guides (CREGs): estimated contaminant concentrations in water, soil, or air which, based on EPA's cancer slope factors. CREGs would correspond to a hypothetical risk of one excess cancer in one million persons exposed over a lifetime. However, "the true risk is unknown and may be as low as zero" (USEPA, 1986).

Minimal Risk Levels (MRLs): estimates of daily human exposure to a chemical (for example,doses expressed in mg/kg/day) that are unlikely to be associated with any appreciable risk ofharmful noncancer effects over a specified duration of exposure. MRLs are derived for acute(under 14 days), intermediate (between 15 and 364 days), and chronic (over 365 days) exposures. MRLs are published in ATSDR's toxicological profiles for specific chemicals.

Environmental Media Evaluation Guides (EMEGs): concentrations of a contaminant inwater, soil, or air that are unlikely to be associated with any appreciable risk of harmfulnoncancer effects over a specified duration of exposure. EMEGs are derived from ATSDRminimal risk levels by factoring in default body weights and ingestion rates. Separate EMEGsare computed for adults and children, and where the corresponding MRLs are available, acute(under 14 days), intermediate (between 15 and 364 days), and chronic (over 365 days) exposures.

Intermediate Environmental Media Evaluation Guides (iEMEGs): media-specificconcentrations that correspond to a minimal risk level, factoring in body weight and ingestionrates for intermediate exposures (over 14 days and under one year).

Reference Dose Media Evaluation Guide (RMEG): the concentration of a contaminant in air,water, or soil that corresponds to USEPA's RfD of RfC for that contaminant when default valuesfor body weight and intake rates are taken into account.

USEPA's Reference Dose (RfD): estimate of the daily exposure to a contaminant unlikely tocause noncarcinogenic adverse health effects over a lifetime of exposure. Like ATSDR's MRL,EPA's RfD include safety factors and are expressed in terms of dose (mg/kg/day).

Reference Concentration (RfC): concentration in air expected to be associated with nohazardous health effects over a lifetime of exposure, assuming default body weights andinhalation rates.

Risk-Based Concentrations (RBCs): values are similar to ATSDR's RMEGs and CREGsbecause they are derived for carcinogens and noncarcinogens from RfDs and cancer slopefactors, respectively, assuming default values such as body weight, exposure duration, andfrequency. However, unlike EMEGs, they are available for fish, water, soil, and air.Environmental Protection Agency Region III (EPA III) derives RBCs.

Drinking Water Equivalent Levels (DWELs): based on EPA's oral RfD. DWELs representcorresponding concentrations of a substance in drinking water that are estimated to havenegligible hazardous effects in humans over a lifetime of exposure, at an intake rate of two litersdaily, and assuming that drinking water is the sole source of exposure to the contaminant. DWELs are similar to ATSDR's RMEG for drinking water.

Child Longer-Term Health Advisories (CLHAs): contaminant concentrations in water thatEPA deems protective of public health (taking into consideration the availability and economicsof water treatment technology) over a period of seven years, using a child's weight (10kilograms) and ingestion rate (one liter daily).

Lifetime Health Advisories (LTHAs): calculated from the DWEL. LTHAs represent theconcentration of a substance in drinking water estimated to have negligible hazardous effects inhumans over a lifetime of 70 years, assuming two liters of water per day for a 70-kilogram adult,and taking into account other sources of exposure. In the absence of chemical-specific data, theassumed fraction of total intake from drinking water is 20%. Lifetime HAs are not derived forcompounds that are potentially carcinogenic for humans.

Maximum Contaminant Levels (MCLs): contaminant concentrations in drinking water thatEPA deems protective of public health (considering the availability and economics of watertreatment technology) over a lifetime of 70 years assuming two liters of water per day.

Maximum Contaminant Level Goals (MCLGs): drinking water health goals set at levels atwhich no known or anticipated adverse effect on the health of persons occurs, and which allowan adequate margin of safety. Such levels consider the possible impact of synergistic effects,long-term and multi-stage exposures, and the existence of more susceptible groups in thepopulation. The MCLG is typically set equal to zero for known and possible carcinogens.

Maximum Contaminant Level Action (MCLA): levels set by EPA under Superfund thattrigger a regulatory response when the contaminant concentration exceeds this value.

National Ambient Air Quality Standards (NAAQS): established by the EPA, as mandated inthe Clean Air Act, for six criteria pollutants (carbon monoxide, sulfur dioxide, nitrogen dioxide,ozone, particulate, and lead). NAAQS are classified as either primary, which define levelsdeemed protective of public health, or secondary, which in some instances establish lower levelsto prevent adverse effects on vegetation, property, or other elements of the environment.

Permissible Exposure Limits (PELs): air standards developed by the Occupational Safety andHealth Administration (OSHA) for the workplace. They are time-weighted averageconcentrations of contaminants considered safe for healthy workers over the course of an 8-hourworkday and a 40-hour workweek. A PEL may be exceeded for brief periods, but the sum of theexposure levels averaged over eight hours must be equal to or below the PEL.

Recommended Exposure Limits (RELs): established by the National Institute for OccupationalSafety and Health (NIOSH) and are similar to OSHA's PELs. They are time-weighted averageconcentrations for the workplace deemed to be safe over a course of a 10-hour workday and a 40-hour workweek.

Threshold Limit Values (TLVs): established by the American Conference of GovernmentalIndustrial Hygienists (ACGIH). The TLV is the time-weighted average concentrations for anormal 8-hour workday and a 40-hour workweek, to which nearly all workers may be repeatedlyexposed, day after day, without adverse effect. Many of ACGIH's TLVs were adopted by OSHAfor use as PELs. TLVs and PELs, which were designed to protect healthy workers, are usuallymuch higher than the health-based values of ATSDR and EPA, which were designed to protectthe health of the general population, including the young and the elderly. Although ATSDR doesnot base any of its community health decisions on TLVs or PELs, it sometimes cites such valuesin public health assessments to concentrations of site-specific contaminants into a meaningfulperspective for the reader.

The Food and Drug Administration (FDA) has recommended concentration levels for certainsubstances in food, including fish. Levels above FDA levels mean that the food may be unsafefor human consumption.

Comparison Value References

1. Agency for Toxic Substances and Disease Registry. Health Assessment Guidance Manual.Atlanta: ATSDR, October 1992.

2. National Institute for Occupational Safety and Health. Pocket Guide to Chemical Hazards.Washington D.C.: U.S. Department of Health and Human Services, June 1994.

3. U.S. Environmental Protection Agency. New Interim Region IV Guidance for ToxicityEquivalent Factors Methodology for Carcinogenic PAHs. February 11, 1992.

4. EPA, 1986. Environmental Protection Agency. Guidelines for Carcinogenic Risk Assessment. Fed. Reg., 51: 33997-33998, September 24, 1986.

5. Williams, Gary M., and Weisburger, John H. (1991). Chemical Carcinogenesis. In: KlaassenCD, Amdur, MO, Doull J, editors. Casarett and Doull's Toxicology: the basic science ofpoisons. 4th ed. Pergamon Press 1991. p 127-200, p. 154-155.

6. Pitot, Henry C., III and Dragan, Yvonne P. (1996). Chemical Carcinogenesis. In: KlaassenCD, Amdur, MO, Doull J, editors. Casarett and Doull's Toxicology: the basic science of poisons.5th ed. New York: McGraw-Hill; p. 201-267.

7. Cunningham, M.L., Elwell, M.R., and Matthews, H.B. (1994). Relationship ofcarcinogenicity and cellular proliferation induced by mutagenic noncarcinogens vs carcinogens. Fundam. Appl. Toxicol. 23: 363-369.]


APPENDIX C: PUBLIC COMMENTS

ATSDR released the Keil Chemical Public Health Assessment for review and comment fromJanuary 24 through March 30, 2001. The following written comments were received fromcommunity members during this period and this final document contains those comments and ATSDR's responses.

Comment 1. The information in the report is misleading. The report did not include all residentswho have been exposed. A study should include all residents exposed-whether they live inIllinois, toxins do not stop at the state line. Some case diagnosis were left out of the analysis.

Response: The health consultation that you refer to is the "Analysis of Childhood CancerIncidence from 1987 to 1997 for Lake County, Indiana, released to the community in January24, 2001. The document addressed concerns regarding the incidence of child cancers in LakeCounty from potential emissions from the Keil Chemical Company. Child cancer data (allcancers and further cancer groupings) for ages 19 and younger were obtained from the IndianaCancer Registry for the reported time period from 1987 to 1997, who lived in Lake County. Rates of childhood cancers for a six zip code area most likely to be exposed to emissions fromthe Keil Chemical Company were also examined. For both Lake County residents and thecommunity located near the Keil Chemical plant, the rates of new childhood cancers were notelevated.

This time period was selected to match the time period of potential air emissions from thefacility, latency for development of illness (cancer) in children, and for years the registry data arethe most complete. These case (cancer) data are collected by the registry and containsinformation on the patient including residence at time when the illness was diagnosed and othermedical data. The data are verified for completeness and accuracy. Most neighboring stateshave agreed to send patient information back to the state registry where the patient resides. Thisstate-to-state reporting process may take up to two years. The following six zip codes were usedto identify the community surrounding Keil Chemical for a meaningful descriptive analysis forthe incidence of child cancer: 46312, 46320, 46323, 46324, 46327, and 46394. These zip codesincluded areas where people were likely to be exposed from emissions released by the KeilChemical plant during its operation. During the exposure investigation conducted by ATSDR in1999, air samples were collected at the Keil site and within the community. Dispersion modelingof emissions predicted the locations where downwind exposures were likely. For thisinvestigation, all residents within 1.5 miles from the facility were considered the targetpopulation. These zip codes were within this predicted area. Results from this investigationdemonstrated that only ethylene dichloride was detected and only at the Keil fence-line. Allcontaminants detected were below levels of health concern.

These cancer incidence data are used to broadly describe child cancer status for the communityfor that time period. It cannot demonstrate a "cause and effect" relationship with a communityand a particular site. This issue was communicated to area residents during the past two years,and before undertaking this cancer analysis. Air pollutants may cross the state line, however, thecancer analysis considered the environmental (air) data provided to ATSDR which affords aninformed estimate of who was possibly impacted. It is difficult to identify and include all peoplewho might have been exposed to Keil's emissions, because the air monitoring data are limited forpast exposures and some people have moved away from the area. However, the majority ofpeople remain and are a reasonable, even good, representation of the incident child cancer statusfor that community.

Comment 2. Even though your evidence clearly states that there is not an increased risk ofcancer due to Keil Chemical, I believe that something, or a combination of all things (ie.pollution) in the area has to increase diseases. Have you measured other companies or looked atall of them together?

Response: ATSDR was petitioned to address concerns regarding emissions from the KeilChemical site. ATSDR reviewed air, soil, and water data regarding this site. Pollution fromindustrial sources, especially in urban areas is a major concern of all environmental agencies. However, ATSDR addresses petitions regarding specific sources of potential pollution such ashazardous waste sites. There are local environmental agencies currently addressing air pollutionin your area and will be monitoring general air emissions in your community within the nextyear. Contact the Hammond Department of Environmental Management for current air samplingresults.

Comment 3. What about people who swam in area water?

ATSDR was asked to review environmental data regarding air emissions from the Keil Chemicalfacility. As part of our review, we evaluated waste water and on-site monitoring well data forhazardous substances. Please refer to pages 9 and 10 in this health assessment for the evaluation. People would not be in contact or ingesting waste water released from the Keil process into themunicipal sewer. Also, this water would not be released into areas used for public swimming. This water would be tested and treated at the municipal treatment plant and must meet Federaland State water quality requirements before it is discharged. Therefore, ATSDR did not sampleor evaluate sampling results of water from surrounding swimming areas. However, if you areconcerned with the quality and safely of surrounding lakes and ponds, the Hammond Department of Environmental Management should have current information or will direct you to the appropriate department in your area.


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