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Public Comment Release



The Chemical Commodities Inc. (CCI) site, which occupies about 1½ acres, is in a largely residential area of Olathe, Kansas. The facility was in operation from 1951 until 1989, and stored chemicals that were surplus, off-specification, recycled, or had exceeded their specified shelf life (1). Contamination for the site and the area includes a shallow groundwater plume of dissolved chlorinated solvents, air emissions of this plume through the soil, and heavy metal soil contamination. Past soil vapor and crawl space sampling indicate a potential for volatile compounds in the soil and groundwater to transport through soil vapor into indoor air (1,3,4). Two health consultations were completed, one in June 2001 and a second in September 2001 (7, 8). These reports concluded that warehouse and residential indoor and outdoor air, soil, and sump water data were not expected to cause adverse health effects at the levels detected. The September 2001 health consultation recommended continued soil and air sampling for seasonal variation and sampling to determine if dioxins were formed by chlorinated pesticides involved in a fire at the warehouse in 1972. A complete history with previous recommendations is available in the June 2001 ATSDR health consultation (7). The Environmental Protection Agency (EPA) Project Manager for the CCI site requested that the Agency for Toxic Substances and Disease Registry (ATSDR) review sampling results for the CCI site and adjacent homes to determine if contaminant levels are of public health concern (2).


The EPA collected a third round of samples in September 2001 to better characterize onsite and offsite contamination for the CCI site. Residential outdoor air, residential soil, and soil from the CCI warehouse were collected. Twenty-four hour air samples were collected at homes A, F, and G through N near the CCI site (6). Soil samples were collected at homes A and C. Houses were labeled with letters A-N from south to north starting with blocks closest to the CCI site (Figure 1). This identification has remained the same throughout the investigation. The major volatile contaminants in the CCI plume are trichloroethylene (TCE), tetrachloroethylene (PCE), trichloroethane (TCA) cis-1,2-dichloroethene (DCE), carbon tetrachloride and 1,1,2,2-perchloroethane (PCA) (5). Chloroform, methylene chloride, benzene, toluene, xylene and other chlorinated solvents were found in the groundwater at lower levels (1). Soils at selected residences were analyzed for dioxins, pesticides (i.e., dichlorodiphenyltrichloroethane (DDT), dieldrin, and chlordane), volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), polychlorinated biphenyls (PCBs) and metals (i.e., lead, arsenic and cadmium) that may have been deposited from the CCI site.

General Pathways:

Soil gas exposure pathway

It is possible for contaminants which volatilize, to travel through the air spaces in soil above groundwater and enter buildings. These volatile chemicals can collect in the home and expose dwellers. Many variables can influence the levels of volatile chemicals in the home from the soil. Soil density, whether the soil is clay or sandy, can allow more or less volatile chemicals to pass from a contaminant plume to the surface. House construction, like concrete slab or pier and beam can influence the travel of volatiles into the home.

Soil exposure pathway

Soil can be an exposure pathway for contaminants through incidental ingestion, dermal exposure, and inhalation of small dust particles. Incidental ingestion can occur when soiled hands are brought into contact with the mouth or articles that are eventually placed in the mouth. Children are most susceptible to this route of exposure as hand to mouth activity is more prominent, especially in toddlers. Gardening, digging, playing, tracking soil in home, smoking, eating home grown unwashed vegetables, or other related activity can bring skin into contact with soil, completing a dermal exposure pathway to soil contaminants.

Air exposure pathway

Inhalation is an important pathway for human exposure to contaminants that exist as atmospheric gases or are adsorbed to airborne particles or fibers. Inhalation exposure to contaminants from hazardous waste sites can occur as a result of direct release of gases and particles from an on-site facility, volatilization of gases from contaminated soils or water bodies, or resuspension of dust and particles from contaminated soil surfaces. Factors contributing to air exposure are inhalation volume, temperature, altitude, background air quality, pulmonary quality, weight, height, and smoking.

Public health evaluation

The presence of contaminants in any media does not necessarily present a health hazard. The amount of contaminant an individual is exposed to, as well as the duration of exposure, must be taken into account in order to determine if health effects would be expected. These two factors together define the exposure conditions and the dose of the chemical. The duration of exposure to a contaminant in a home can vary greatly. The duration would be the amount of time per day, or per week an individual spent in the home or contacting soil. Although many individuals work, go to school or leave the home for periods of time over the week, this may not always be the case. Therefore, in an effort to protect all individuals, a full time exposure, 24 hours a day, is assumed in this evaluation. Additionally, when evaluating theoretical cancer risk, this full time exposure is taken as a lifetime exposure of 70 years. Although it is extremely unlikely that an individual will meet these conditions, the most conservative exposure scenario is chosen to be protective of public health.

Non-cancer health effects

ATSDR uses comparison values (CV's) to select which substances and environmental media at a site need additional evaluation to address possible health concerns. CV's are concentrations or amounts of substances in air, water, food, and soil that are unlikely, upon exposure, to cause adverse health effects. If the maximum detected concentration of a contaminant exceeds its specific CV, additional evaluation of potential health effects is necessary. Estimates of exposure to a contaminant by an individual (both child and adult) were calculated and compared with minimum risk levels (MRLs). ATSDR has established MRLs for exposures to many chemicals based on available medical, toxicological and epidemiologic data. The MRL is an estimate of daily human exposure by a specified route and length of time to a dose of a chemical that is likely to be without a measurable risk of adverse, noncancerous effects. MRLs are established for a route of exposure (breathing, ingestion, or dermal contact) and a duration (acute, intermediate or chronic). Acute MRLs are for up to 14 days of exposure, intermediate MRLs are established from 14 - 365 days of exposure, and chronic MRLs are established for a lifetime exposure. Information used to establish MRLs often include studies of people exposed to chemicals in the workplace, and laboratory animal studies. There are uncertainties in applying both the worker studies and animal studies to the general population. Therefore, MRLs are often 100 to 1000 times lower than the level which may have resulted in a health effect. As such, the MRLs are conservative values below which no adverse health effects are expected.

CCI Warehouse Site Soil Sampling

Dioxins may be formed by the degradation of chlorinated compounds, including fires. Fire events have been documented at the CCI property involving chemicals stored in drums on the site. To check for possible contamination, one residential surface soil sample and four surface soil samples (0 to 2 inches) taken from the CCI warehouse propertywere analyzed for dioxins. None of the samples contained dioxins above the CV's, therefore, the levels detected are not expected to cause adverse health effects, including sensitive populations.

Residential soil sampling

Surface soil samples were collected (0 to 2 inches) and analyzed for metals, organo-phosphate pesticides, PCBs, pesticides, dioxins, and SVOCs (6). Pesticides, VOCs and metals were among the contaminants detected in the soil. None of these contaminants were above their CV's and therefore are not expected to cause adverse health effects. The presence of some of these chemicals may be consistent with previous pesticide applications in the 1960's, 70's and 80's, as these compounds are very persistent in the soil and do not breakdown readily. However, these data cannot establish a source. Regardless of the source, there is no apparent health hazard indicated.

Residential air sampling

Possible exposure to site-related air contaminants was evaluated at eight homes near CCI property. Outdoor air samples were taken for 36 consecutive hours. The samples were collected in a pressurized metal cylinder (SUMMA© canister) and sent for laboratory analysis. Each air sample was analyzed for volatile chemicals. The 36-hour samples are an average air concentration for that period of time. Contaminants detected included SVOCs and VOCs. These contaminants were compared to CVs and none exceeded their respective CV, therefore the contaminates are not expected to cause adverse health effects.


As with non-cancer health effects, the levels of contaminants found in residential surface soil, outdoor air and CCI property surface soil are far below levels that are known or believed to cause cancers, either in human or animal studies.

For all contaminants addressed in this consult, the measured levels in these samples are far below the levels which have been seen to produce cancers in animal and human studies. Therefore, the ability for these exposures to result in increased cancer is highly unlikely.

Children and other sensitive populations

ATSDR recognizes that infants and children may be more vulnerable to exposures than adults in communities faced with contamination of their air, water, soil, or food. As part of its Child Health Initiative, ATSDR is committed to evaluating children's special interests. Considering exposure to indoor residential air at the CCI site, children may have an increased vulnerability due to the following factors: 1) children weigh less than adults, resulting in higher doses of chemical exposure relative to body weight, 2) the developing bodily systems of children can sustain permanent damage if toxic exposures occur during critical growth stages, 3) children have a breathing zone lower to the ground and 4) children are more likely to have object to mouth contact. Similarly, the elderly may be susceptible due to changes in the body's ability to detoxify chemicals and repair damage which come with aging. As a conservative screening tool, the MRL is designed to account for these factors. When considering how well the experimental data can be applied to the general population, an uncertainty factor for human variability is used in developing the comparison value. This uncertainty factor addresses the application of the comparison value to sensitive populations, including children and the elderly, which may not have been involved in the study population on which the comparison value is based. Therefore the comparison values are considered protective of these sensitive populations. Although, there are still many unknowns about the carcinogenic process and the bodies ability to defend against it, the cancer estimates, are believed to be protective of the general population by their conservative nature.


Contaminants detected in the surface soil at the CCI warehouse property are not expected to be a public health hazard, as none of the contaminants exceeded comparison values.

Chemical contaminants found in surface soil of residences near the CCI facility are below comparison values and are not expected to pose a public health hazard.

Chemical contaminants found in outdoor air samples of residences near the CCI facility are below comparison values and are not expected to pose a public health hazard.


Data evaluated for this health consultation indicate that contaminants detected in surface soil at the CCI warehouse property, and contaminants detected in surface soil and outdoor air samples of residences near the CCI facility are below comparison values and are not expected to pose a public health hazard. Therefore, ATSDR presently considers the site to be a no apparent public health hazard.


1. ATSDR recommends continued periodic air monitoring to ensure that site related contaminants found in the shallow groundwater plume do not transport through soil vapor into indoor air of residences near the site.


Robert B. Knowles, M.S., REHS
Superfund Site Assessment Branch
Division of Health Assessment and Consultation

Shawn Blackshear, M.S.
Health Service Officer, USPHS
Office of Regional Operations


Adverse Health Effect:
A change in body function or the structure of the cells that can lead to disease or health problems.

Minimal Risk Level. An estimate of daily human exposure--by a specified route and length of time--to a dose of a chemical that is likely to be without a measurable risk of adverse, noncancerous effects. An MRL should not be used as a predictor of adverse health effects.

No Apparent Public Health Hazard:
The category is used in ATSDR's Public Health Assessment documents for sites where exposure to site-related chemicals may have occurred in the past or is still occurring, but the exposures are not at levels expected to cause adverse health effects.

No Public Health Hazard:
The category is used in ATSDR's Public Health Assessment documents for sites where there is evidence of an absence of exposure to site-related chemicals.

A line or column of air or water containing chemicals moving from the source to areas farther away. A plume can be a column or clouds of smoke from a chimney or contaminated underground water sources or contaminated surface water (such as lakes, ponds, and streams).

Public Health Hazard:
The category is used in ATSDR's Public Health Assessment documents for sites that have certain physical features or evidence of chronic, site-related chemical exposure that could result in adverse health effects.

Uncertainty Factor:
When scientists don't have enough information to decide if an exposure will cause harm to people, they use "uncertainty factors" and formulas in place of the information that is not known. The factors and formulas can help determine the amount of a chemical that is not likely to cause harm to people.

A compound that evaporates and becomes a vapor in the air. How quickly a compound becomes a vapor is measured by its vapor pressure, in either millimeters of mercury or atmospheres.


  1. Groundwater Technology, Inc. Site Characterization Report Former Chemical Commodities, Inc.; 1996.

  2. Environmental Protection Agency. Memorandum from Mary Peterson, EPA Remedial Project Manager, to Denise Jordan-Izaguirre, ATSDR Senior Regional Representative: Request for Health Consultation, Chemical Commodities, Inc. Site, Olathe, Kansas. Kansas City, Kansas. November 15, 2001

  3. Tripp, R.W. Final Report for Toxic Air Monitoring in Residences Near Chemical Commodities, Inc. Region VII Environmental Services Division, U.S. Environmental Protection Agency; 1989, November 13.

  4. Grissom, B. Agency for Toxic Substances and Disease Registry. Health Consultation: Chemical Commodities Inc.. April 30, 1996.

  5. Agency for Toxic Substances and Disease Registry. Site review and update for Chemical Commodities, Inc. Olathe, Johnson County, Kansas. Atlanta: US Department of Health and Human Services; 1996, December 24.

  6. Mazzeo A. Quality Assurance Project Plan for Removal Site Evaluation Activities at the Chemical Commodities, Inc. Site, Olathe Kansas: Environmental Protection Agency, Region VII Superfund Division; October 31, 2001.

  7. Agency for Toxic Substances and Disease Registry. Health Consultation: Chemical Commodities, Incorporated. June 11, 2001.

  8. Agency for Toxic Substances and Disease Registry. Health Consultation: Chemical Commodities, Incorporated. September 25, 2001.

  9. Agency for Toxic Substances and Disease Registry. Toxicological profile for chlorinated dibenzo-p-dioxin. Atlanta: US Department of Health and Human Services; 1998.

  10. Missouri Department of Health in cooperation with Agency for Toxic Substances and Disease Registry. Final report for dioxin incinerator emissions exposure study, Time Beach, Missouri. Atlanta: US Department of Health and Human Services; 1999.

Location of thirteen residences near the CCI Site, Olathe, Kansas
Figure 1. Location of thirteen residences near the CCI Site, Olathe, Kansas

Table of Contents The U.S. Government's Official Web PortalDepartment of Health and Human Services
Agency for Toxic Substances and Disease Registry, 4770 Buford Hwy NE, Atlanta, GA 30341
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