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In spring of 2003, the Illinois Department of Public Health (IDPH) learned about several changes regarding the Outboard Marine Corporation (OMC), Waukegan Harbor, and proposed land uses in the area. This health consultation discusses our evaluation of changes that have occurred at the Waukegan Manufactured Gas and Coke Plant (WCP) portion of this site since the Site Review and Update completed in 1998 (SRU IDPH, 1998). Separate health consultations address other parts of this site (Waukegan Harbor and OMC Plant 2/polychlorinated biphenyl (PCB) containment cells).


The OMC/Waukegan Harbor Superfund Site (Figures 1 and 2) contains three Operable Units designated by the U.S. Environmental Protection Agency (USEPA): 1) Waukegan Harbor, 2) the Waukegan Manufactured Gas and Coke Plant, and 3) OMC Plant 2 and the polychlorinated biphenyl (PCB) disposal cells. USEPA, in consultation with the Illinois Environmental Protection Agency (Illinois EPA), anticipates adding a fourth Operable Unit, OMC Plant 2.

On April 20, 1989, the Agency for Toxic Substances and Disease Registry (ATSDR) published an initial public health assessment (PHA) for the OMC/Waukegan Harbor site (IDPH 1989). The final PHA for the site was published on September 30, 1994 (IDPH 1994).

In July 1998, USEPA awarded the City of Waukegan (City) a Brownfield Development Grant to bring abandoned and contaminated properties back to use. This includes properties near Waukegan Harbor (USEPA 2001).

On August 7, 1998, ATSDR released a Site Review and Update for the OMC/Waukegan Harbor site. The SRU (IDPH 1998) considered exposure negligible at the WCP site because of restricted access and limited site use.

About 4,500 cubic yards of contaminated soils were excavated during construction of a new harbor slip and were placed in a temporary on-site storage area constructed for that purpose. The temporary storage area is lined and is covered with a high-density polyethylene liner (USEPA 2002a, USEPA 1999). On September 30, 1999, USEPA signed a Record of Decision (ROD, USEPA 1999) for the cleanup of the WCP site. The selected cleanup remedy included the following tasks (USEPA 2002a, USEPA 1999):

  • The stockpile of polycyclic aromatic hydrocarbon (PAH)-contaminated soil generated from the new slip construction and impacted soil excavated from other areas of the site will be sent off the site for disposal.

  • About 3,300 to 7,200 cubic yards of arsenic-contaminated soil will be solidified or stabilized in place. Alternatively, the arsenic-contaminated soil can be excavated and sent off the site for disposal, if on-site management conflicts with future land use.

  • Marginally contaminated soils will be covered by asphalt (parking lot), building, or vegetated soil cover (cap).

  • A soil management plan will be developed for the site to aid in site reuse efforts.

  • A mobile pump and treat program will treat contaminated water from the site. Water will be pumped from individual disposal cells on a rotating basis and treated to remove contaminants. Treated water will be re-injected into the groundwater upgradient from the pumping wells.

  • After groundwater cleanup targets are met, groundwater monitoring will be implemented to ensure the remaining contaminant levels decrease to acceptable levels.

  • Site soils will be cleaned to acceptable levels for an industrial or recreational reuse scenario.

  • Institutional controls (deed restrictions and groundwater use prohibitions) will be placed on the property to ensure that future site uses are compatible with the cleanup actions.

The City of Waukegan bought the WCP site on June 24, 2002 after OMC filed for bankruptcy. In September 2002, the City re-zoned the WCP site as high-density residential housing (Blazer 2003b, USEPA 2002a). The clean-up criteria of the ROD (USEPA 1999) were based on industrial or recreational use and may not be protective for residential use. USEPA is evaluating whether residential use would require altering the planned cleanup (USEPA 2002a).

On April 22, 2003, USEPA announced that a Waukegan redevelopment project was selected as an environmental justice demonstration project. This designated the City as an environmental justice community, because of the large population of low-income and minority residents. The designation will help the City obtain federal money for redevelopment (USEPA 2003a).

On July 17, 2003, the City requested that USEPA change the ROD (USEPA 1999) to require a cleanup of the WCP property to residential standards. USEPA is considering the proposed changes. The City plans to develop the WCP property and other properties along Waukegan Harbor and the lakefront. The WCP land will be mixed use, with marina, commercial, recreational, and urban residential property. The residential housing will have both affordable housing and middle-income housing; however, the City has not finalized the plans. The City is doing a new risk assessment to evaluate the on-site hazards using a residential exposure scenario (Blazer 2003a, Blazer 2003b).


As described in the 1994 PHA, land use around the harbor is commercial and industrial. The harbor serves commercial shipping, including raw materials and cement delivery, and barge and tug mooring. It also provides access to marinas and maintenance facilities for recreational boating. A public beach is east of the site. Residents of the area get drinking water from the Waukegan Municipal Water Supply, which obtains its water from offshore in Lake Michigan and should not be affected by contamination at WCP.

Currently, the nearest residences are about 0.3 miles from the site; however, they are about one mile from the site by road. According to the 2000 U.S. Census, 10,492 people lived within one mile of the site. Hispanic persons comprised 47% and African Americans comprised 19% of the total population. USEPA (Theisen 2003) reported that within one mile of Waukegan Harbor, 44% of the residents were low-income.

The City has re-zoned the WCP property as high-density residential housing and plans to use some WCP property for affordable housing. Some housing also may be for people with pleasure boats moored in Waukegan Harbor.

Community Concerns

In summer 2002, during their second five-year review of the site, USEPA (2002a) asked for public comments. They verbally asked for comments from the Waukegan Community Advisory Group (CAG) and placed notices in local newspapers, in both English and Spanish. USEPA received the following comment regarding the WCP site (USEPA 2002a):

  • Although the cleanup of the WCP site is in the design phase, the City of Waukegan had very recently proposed changing the zoning of the site from marine recreational/industrial to residential. Several people expressed reservations about this proposal. Aside from the implied impacts on the remedy selected in the 1999 ROD, comments indicated that this is a premature act by the City. This is because the WCP has not been cleaned up yet, and the adjacent OMC Plant 2 may become another part of the Waukegan Harbor site, requiring years of study and then cleanup.

Residential use of the WCP site without a cleanup could increase human exposure to contaminants. USEPA is evaluating whether a residential scenario will require a change in the remediation plans. Also, the City is doing a risk assessment for the WCP using a residential exposure scenario.


Chemicals of Interest

IDPH compared the maximum level of each contaminant detected during environmental sampling with appropriate screening comparison values. This was to select contaminants for further evaluation for both carcinogenic and non-carcinogenic health effects. Chemicals that exceeded comparison values were selected for further evaluation. A description of each of the comparison values is found in Attachment 1.

These comparison values do not represent thresholds of toxicity. Although some of these chemicals may exist at levels greater than comparison values, the contaminants can affect only someone exposed to sufficient doses. The amount of the contaminant, the duration and route of exposure, and the health status of exposed individuals are important factors in determining the potential for adverse health effects.


Exposures to contaminated groundwater are not occurring because people are not consuming groundwater at the site. This is an incomplete exposure pathway.


Table 1 shows the concentrations of organic and inorganic chemicals in surface soil that exceeded state and regional background levels (for inorganic compounds only) and comparison values. Table 1 also lists chemicals with no comparison values available. Figure 3 shows the WCP areas with contaminated soils.

Waukegan Harbor Fish

For possible future residents of WCP site, the primary health risks probably would be from the consumption of contaminated fish from Waukegan Harbor and Lake Michigan. These risks are discussed in a separate health consultation on Waukegan Harbor.

Exposure Pathways

A hazardous chemical can affect people only if they contact it through an exposure pathway at a sufficient concentration to cause a toxic effect. An exposure pathway consists of 1) a source of contamination, 2) an environmental media and transport mechanisms, 3) a point of exposure, 4) an exposure route, and 5) a receptor population.

A pathway is complete if all of its components are present and exposure of people occurred in the past, is occurring, or will occur in the future. If 1) parts of a pathway are absent, 2) data are insufficient to decide whether it is complete, or 3) exposure may occur at some time (past, present, future), then it is a potential pathway. If a part of a pathway is not present and will never exist, the pathway is incomplete and can be eliminated from further consideration.

Surface Soil

People may be exposed to surface soil at WCP by inhalation (dust), incidental ingestion, or skin contact. Exposure is more likely in areas of bare soil. Vegetation or pavement minimizes exposure to contaminated soil. The WCP site currently is not being used. The nearest residences are about 1 mile by road from the WCP, so trespassing probably is infrequent. Current exposure to contaminated surface soil probably is negligible. However, the City has re-zoned the property for residential use. Without a cleanup, daily occupational or, especially, residential use may increase exposure to contaminants in surface soil. Excavation during construction also may expose contaminated subsurface soil.

For exposure estimates, IDPH assumed that a 10-kilogram (kg) child would ingest 200 milligrams per day (mg/day) of soil, and a 70 kg adult would ingest 100 mg/day of soil. Residential exposure of a child or adult to cresols at the WCP site would be well below the chronic minimal risk level (MRL) and well below levels associated with non-cancer adverse health effects.

Sampling found PCBs in surface soil of the WCP site (Table 1). Incidental ingestion of soil with the highest PCB concentration at the WCP site would not exceed the chronic oral MRL for either children or adults, even under a residential scenario. Noncancerous adverse health effects are not expected. Incidental ingestion of soil with the highest PCB concentration would result in no increased risk of cancer in a 70 kg worker exposed eight hours per day, 50 days per week, for 30 years. Lifetime residential exposure to this soil for 24 hours a day, 50 weeks per year, for 70 years would result in no apparent increased risk of cancer.

Surface soil at the WCP site had areas with high arsenic concentrations (Table 1, Figure 3). Incidental ingestion of WCP soil with the highest arsenic concentration by a 70 kilogram adult would result in no apparent increased risk of cancer for a worker exposed eight hours per day, 5 days per week, 50 weeks per year, for 30 years. Lifetime residential exposure to this soil for 24 hours a day, 50 weeks per year, for 70 years would result in a low increased risk of cancer. Incidental ingestion of this soil by an adult or child would be insufficient to produce noncancerous effects, even in a residential scenario.

USEPA (1993, cited in ATSDR 1995) has established relative potency factors for carcinogenic PAHs. Using these relative potency factors, incidental ingestion of WCP soil with the highest PAH concentration would result in no apparent increased risk of cancer in a worker exposed eight hours per day, 5 days per week, for 30 years. Lifetime residential exposure to this soil for 24 hours a day, 50 weeks per year, for 70 years could result in a low increased risk of cancer.



Arsenic is a naturally occurring element. Arsenic has been used for wood treatment; however, it was not used for wood treatment in the early 1900s, when a wood treatment facility operated on the site. At that time, creosote probably was used. USEPA, the National Toxicology Program, and the U.S. Department of Health and Human Services consider inorganic arsenic to be a known human carcinogen. The International Agency for Research on Cancer (IARC) considers inorganic arsenic carcinogenic to humans. Studies have mainly associated the ingestion of arsenic with skin cancer. Studies have also shown that ingestion of arsenic can cause cancers of the bladder, kidneys, liver, lungs, and prostate (ATSDR 2000). Cancers caused by chemical exposure often do not appear until 10 or more years after exposure. Also, cancers caused by chemicals cannot be distinguished from cancers that occur spontaneously.

Polycyclic Aromatic Hydrocarbons (PAHs)

PAHs are common combustion products that also are found in coal tar. In humans, studies have associated the inhalation of PAHs with lung cancer and skin contact of PAHs with skin cancer. Animal studies have associated ingestion of PAHs with leukemia and cancers of the breast, esophagus, larynx, and lung (ATSDR 1995).


IDPH recognizes that children are especially sensitive to some contaminants. Presently, exposure of children at the WCP site is unlikely. However, converting the property to high-density residential housing without a cleanup would make the exposure of children much more likely. Given the same contaminant concentrations, children likely receive greater exposure than adults do. This is because children play in soil, wash hands less frequently than adults, and commonly exhibit hand-mouth behavior. Children also have a smaller body size, so they receive a greater dose from the same amount of absorbed contaminant.


The WCP site currently poses no apparent public health hazard because site access and site uses are limited. The City has re-zoned the property for residential use, however, developing the property prior to completing a cleanup could result in a public health hazard. Without a cleanup, daily residential use could increase exposure to contaminants in surface soil. Lifetime residential exposure to current levels of arsenic and PAHs in surface soil could result in a low increased risk of cancer. Excavating soil could expose subsurface soil with higher contamination levels. Life-time residential exposure to current levels of PCBs in surface soil would not likely result in an increased risk of cancer.


IDPH recommends that:

  • USEPA continue to pursue the cleanup of the WCP site.

  • USEPA re-evaluate whether the cleanup levels for contaminants at the WCP site must be modified to protect public health, given a residential exposure scenario.


Thomas A. Baughman, Ph.D.
Environmental Toxicologist
Illinois Department of Public Health


ATSDR. 2000. Toxicological Profile for Arsenic. September. Accessed April 18, 2003.

ATSDR. 1995. Toxicological Profile for Polycyclic Aromatic Hydrocarbons. August. Accessed April 18, 2003.

Blazer, M. 2003a. Phone log sheet of August 7, 2003. The Jeff Diver Group, L. L. C.

Blazer, M. 2003b. Outboard Marine Corporation Superfund Site/Operable Unit 2, Waukegan Coke Plant Site: Application of the City of Waukegan, Illinois, for Amendment of the Remedial Action Record of Decision Issued September 30, 1999. Letter to T. Skinner, USEPA. The Jeff Diver Group, L. L. C. July 17.

IEPA. 1994. A Summary of Selected Background Conditions for Inorganics in Soil. IEPA/ENV/94-161.

Shacklette, H. T. and Boerngen, J. G. 1984. Elemental Concentrations in Soils and Other Surficial Materials of the Conterminous United States. U.S. Geological Survey Professional Paper 1270.

U.S. Environmental Protection Agency. 2003a. EPA, Corps of Engineers Announce Selection of Waukegan Revitalization Project. April 22. Accessed August 12, 2003.

U.S. Environmental Protection Agency. 2003. NPL Factsheets for Illinois: Outboard Marine Corp., EPA ID# ILD000802827. January. Accessed April 17, 2003.

U.S. Environmental Protection Agency. 2002a. Five-year Review Report: Second Five-year Review Report for Outboard Marine Corporation Superfund Site, Waukegan, Lake County, IL. September.

U.S. Environmental Protection Agency. 2002b. Outboard Marine Corporation, Waukegan, Lake County, Illinois: Discovery Site Visit Report. Prepared by Tetra Tech EM, Inc. May 10.

U.S. Environmental Protection Agency. 2001. Waukegan Harbor Area of Concern. December 18. Accessed May 13, 2003.

U.S. Environmental Protection Agency. 1999. EPA Superfund Record of Decision: Outboard Marine Corp. OU 2, Waukegan, Illinois. September 30. Accessed June 2003.

U.S. Environmental Protection Agency. 1993. Provisional guidance for quantitative risk assessment of polycyclic aromatic hydrocarbons. Environmental Criteria and Assessment Office. Cincinnati, OH. Final Draft. ECAO-CIN-842. March., cited in ATSDR 1995.


The Illinois Department of Public Health prepared this Waukegan Manufactured Gas and Coke Plant site health consultation under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It was done in accordance with methods and procedures approved at the time the health consultation was begun.

W. Allen Robison
Technical Project Officer
Superfund Site Assessment Branch (SAAB)
Division of Health Assessment and Consultation (DHAC)

The Division of Health Assessment and Consultation, ATSDR, has reviewed this health consultation and concurs with its findings.

Roberta Erlwein
Team Leader, State Programs

Table 1.

Concentrations of inorganic and organic chemicals in surface soil of the Waukegan Manufactured Gas and Coke Plant site (USEPA 1995).
Inorganic Element Concentration (ppm) Illinois Background1 (ppm) U. S. Background East of the 96th Meridian2 (ppm) Comparison Value (ppm) Source of Comparison Value
Arsenic 1.2-87.8 0.35-24 N.D.-73 0.5 CREG
Organic Compounds
Acenaphthylene N.D.-24 -- -- -- --
Benzo(a)anthracene N.D.-30 -- -- -- --
Benzo(b)fluoranthene N.D.-21 -- -- -- --
Benzo(k)fluoranthene N.D.-22 -- -- -- --
Benzo(g,h,i)perylene N.D.-7.5 -- -- -- --
Benzo(a)pyrene N.D.-21 -- -- 0.1 CREG
Carbazole N.D.-18 -- -- -- --
Dibenzo(a,h)anthracene N.D.-4 -- -- -- --
Dibenzofuran N.D.-20 -- -- -- --
Indeno(1,2,3-c,d)pyrene N.D.-12 -- -- -- --
Phenanthrene N.D.-220 -- -- -- --
PCBs N.D.-0.79 -- -- 0.4 CREG

ppm = Parts per million
N.D. = Not detected
- = Data not available
1IEPA (1994).
2Shacklette and Boerngen (1984)


Approximate Location of Outboard Marine Company Site
Figure 1. Approximate Location of Outboard Marine Company Site

Site Features
Figure 2. Site Features

Anticipated Area of Soil Remediation
Figure 3. Anticipated Area of Soil Remediation


Environmental Media Evaluation Guides (EMEGs) are developed for chemicals based on their toxicity, frequency of occurrence at National Priorities List (NPL) sites, and potential for human exposure. They are not action levels but are comparison values. They are developed without consideration for carcinogenic effects, chemical interactions, multiple route exposure, or exposure through other environmental media. They are very conservative concentration values designed to protect sensitive members of the population.

Reference Dose Media Evaluation Guides (RMEGs) are another type of comparison value. They are developed without consideration for carcinogenic effects, chemical interactions, multiple route exposure, or exposure through other environmental media. They are very conservative concentration values designed to protect sensitive members of the population.

Cancer Risk Evaluation Guides (CREGs) are estimated contaminant concentrations based on a probability of one excess cancer in a million persons exposed to a chemical over a lifetime.

Table of Contents The U.S. Government's Official Web PortalDepartment of Health and Human Services
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