905R80105
&EPA
tmited States
Environmental Protection
Agency
Region V
230 South Dearborn
Chicago, Illinois 60604
January- 1980
Water Division
Environmental
Impact Statement
Supplemental EIS
Metropolitan Sanitary
District of
Greater Chicago
O'Hare Water
Reclamation Plant
Final
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FINAL SUPPLEMENTAL ENWRQIMENTAL IMPACT STATEMENT
FOR TiE
METROPOLITAN SANITARY DISTRICT OF GREATER CHICAGO
DES PLAINES - O'HARS WATER RECLAMATION PLANT
Prepared by the
UNITED STATES ENVIRa^-lENTAL PROTECTION AGENCY
REGION V
CHICAGO, ILLINOIS
Approved by:
John McGuire
' ional Administrator
.3. Environmental Protection Agency
January, 1980
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FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT
METROPOLITAN SANITARY DISTRICT OP GREATER CHICAGO
O'HARE WATER RECLAMATION PLANT
DES PLAINES, ILLINOIS
Prepared by
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION V
Abstract
On January 13, 1975, a Notice of Intent to file an Environmental Impact
Statement (EIS) was issued on the Metropolitan Sanitary District of
Greater Chicago's (MSDGC) Des Plaines-O'Hare facilities plan. Two EIS's
were prepared on this facilities plan, one on the proposed O'Hare Water
Reclamation Plant (WRP) and Solids Pipeline, to be constructed in the
City of Des Plaines, Cook County, Illinois, and the other on the proposed
wastewater conveyance system for the Des Plaines-O'Hare service area.
The final EIS's were published in May of 1975.
A primary issue addressed in the WRP EIS was the potential health effects
resulting from respiration of aerosols generated from the WRP's aeration
tanks.
The WRP EIS concluded that funding the project was acceptable to USEPA,
provided the recommended measures were implemented. Since knowledge on
the potential health hazards from aerosol generation at treatment plants
was sparse and inconclusive at that time, the EIS recommended inclusion
of a condition in the grant agreement which required aerosol suppression
at the WRP. To ascertain the effectiveness of potential aerosol suppres-
sion facilities, the EIS recommended that MSDGC demonstrate the level of
aerosol reduction that could be achieved by the suppression facilities.
USEPA's original decision to require aerosol suppression facilities at the
O'Hare WRP was based on the lack of scientific evidence regarding the
relationship of wastewater aerosols and human health as well as our
responsibility under NSPA to avoid health risks. Since chat time, liowever,
considerable research has been conducted to evaluate the potential dis-
cernible effect on human health from exposure to wastewater aerosols.
The USEPA prepared this document to examine the quality of the recent
research, and to decide whether the grant condition should be retained,
rescinded, or modified.
The recommendation of this final supplemental EIS is to rescind the grant
condition to allow operation of the O'Hare WRP without suppression facili-
ties, and continue to monitor the research on health effects and wastewater
aerosols.
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TABLE OF CONTENTS
Page
SUMMARY iii
A. Background iii
' B. Events Since May, 1975 iv
I. RJRPOSE AND NEED FOR FURTHER ACTION 1
II. ALTERNATIVES CONSIDERED AND THEIR COMPARATIVE ENVIRONMENTAL IMPACTS 1
A. Alternatives Considered 1
B. Comparison of Environmental Impacts 2
III. AFFECTED ENVIRONMENT 2
IV. ENVIRONMENTAL CONSEQUENCES 3
A. Basis of Evaluation 3
B. Evaluation of Alternatives 33
V. PUBLIC PARTICIPATION 39
VI. LIST OF PREPARERS 171
VII. LEST OF AGENCIES, ORGANIZATIONS, AND PExlSONS TO WHOM COPIES OF THIS 171
STATEMENT WERE SENT
VIII. SELECTED REFERENCES 172
IX. GLOSSARY OF TERMS 173
"N
X. INDEX 177
XI. FIGURES 1 THROUGH 11 179-189
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I. SUMMARY
A. BACKGROUND
On January 13, 1975, a Notice of Intent,to file an Environmental Impact
Statement (EIS) was issued on the Metropolitan Sanitary District of
Greater Chicago's (MSDGC) Des Plaines-O'Hare facilites plan. Two EIS's
were prepared on this facilities plan, one on the proposed O'Hare
Water Reclamation Plant (WRP) and Solids Pipeline, to be constructed
in the City of Des Plaines, Cook County, Illinois, and the other on
the proposed wastewater conveyance system for the Des Plaines-O'Hare
service area. The Final EIS's were published in May of 1975.
The O'Hare WRP is an activated sludge plant with a design capacity of
72 million gallons of sewage daily (MGD), and is to serve 277,000
residents located in a 52.8 square mile area of northwestern Cook
County.
A primary issue addressed in the WRP EIS was the potential health effects
resulting from respiration of aerosols generated from the WRP's aeration
tanks.
The WRP EIS concluded that funding the project was acceptable to USEPA,
provided the recommended measures were implemented. Since knowledge of
the potential health hazard from aerosol generation at treatment plants
was sparse and inconclusive at that time, the EIS recommended inclusion
of a condition in the grant agreement which required appropriate aerosol
suppression at the WRP. To ascertain the effectiveness of potential
aerosol suppression facilities, the EIS recommended that MSDGC denonstrate
the level of aerosol reduction that could be achieved by the suppression
facilities.
After the Final EIS was published, the City of Des Plaines filed a suit
against the MSDGC and USEPA, alleging that the two Final EIS's issued by
EPA failed to comply with the requirements of the National Environmental
Policy Act (NSPA). The U.S. District Court entered judgment against the
City. The City appealed this judgment, but the U.S. Court of Appeals
upheld the District Court's judgment and ruled, in City of Des Plaines
v. Metropolitan JganitaryDistrict.of Greater Chicago, 552 F.2d 736~~"
(7th Cfr. 1977), that:
1) "Our review of the adequacy of an EIS and of the merits of a decision
reflected therein, while careful, has real limits. On the merits,
the review should be limited to determining whether the agency's
decision is arbitrary or capricious." (552 F.2d 737.)
2) "We believe the EIS unquestionably contains a fair statement of the
problem and the solutions intended, insofar as was possible, and we
do not believe more was required in this case.", (552 F.2d 739.)
"As to the procedure followed, we believe it is clear from the
material of record that EPA took the requisite hard look at this
problem and reacted sensitively to it." (552 F.2d 738.) Because
no definitive answer could be made, "... EPA took a conservative
approach and required MSD to design, construct, and install devices
to suppress aerosol emissions." (552 F.2d 739.)
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3) "The uncertainty regarding the very existence and scope of the
potential health hazard is ignored by the City in its argument
that the failure to specify standards and specific devices renders
the pertinent EIS inadequate and in its insistence that the entire
project be held in abeyance until definitive answers and solutions
can be obtained." (552 F.2d 739.)
B. EVENTS SINCE MAY 1975
t
Since the court ruling, MSDGC has undertaken studies sponsored by the
USEPA to evaluate the performance and costs of alternatives for
suppression of aerosols.
In addition, other research listed below has been sponsored by the USEPA
to evaluate aerosol emissions and the potential health effects from
exposure to wastewater aerosols emanating from activated sludge treat-
ment processes.
1) Report entitled "Health Effects of Aerosols Emitted from an Acti-
vated Sludge Plant," available as EPA-600/1-79-019.
2) Report entitled "Health Implications of Sewage Treatment Facilities,"
available as EPA-600/1-78-032.
3) Report entitled "Health Effects of a Wastewater Treatment System,"
available as EPA-600/1-78-062.
4) Report entitled "Assessment of Disease Rates among Sewer Workers
in Copenhagen, Denmark," available as EPA-600/1-78-007.
5) Draft report entitled "Environmental Monitoring of a Wastewater
Treatment Plant," in prepublication review by USEPA.
6) Final Report entitled "The Evaluation of Microbiological Aerosols
Associated With the Application of Wastewater to Land: Pleasonton,
CA.," available from the Department of the Army.
7) Draft Report entitled "Health Risk of Human Exposure to Wastewater,"
in prepublication review by USEPA,
Also, other research on the potential health effects from aerosol
exposure has been conducted.
Since May 1975, the construction of the interceptors leading to the
O'Hare WRP, and construction of the plant itself, have been virtu-
ally completed. The plant was available for operation as of November 1,
1979.
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II. PURPOSE AND HEED FOR FURTHER EPA ACTION:
USEPA's original decision to require aerosol suppression facilities at the
O'Hare WRP was based on the lack of scientific evidence regarding the
relationship of wastewater aerosols and human health, as well as our
responsibility under NBPA to avoid health risks. Since that time,
however, considerable research has been conducted to evaluate the
potential discernible effect on human health from exposure to wastewater
aerosols. The USEPA prepared this document to examine the results
of the recent research, and to decide whether the grant condition
should be retained, rescinded, or modified.
III. ALTERNATIVES CONSIDERED AND THEIR COMPARATIVE ENVIRONMENTAL IMPACTS:
A. Alternatives Considered:
1. Action.
a) Remove the grant condition requiring MSDGC to construct
aerosol suppression facilities at the O'Hare WRP.
b) Modify the grant condition and allow operation of the
O'Hare WRP without aerosol suppression facilities, and
continue ongoing analyses to demonstrate whether or not
the potential transmission of wastewater aerosols is a
significant health concern.
2. No Action. Retain the grant condition requiring MSDGC
to construct appropriate aerosol suppression facilities at
the O'Hare WRP prior to operation of the plant. This would
necessitate the installation of temporarly suppression facilities
until permanent facilities could be designed and constructed.
B. Comparison of the Environmental Impacts:
There is no indication that a direct or indirect health hazard will
result from operation of the O'Hare WRP without aerosol suppression
facilities.
If aerosol suppression facilities are constructed, there will be a
significant expenditure of monetary, natural, and depletable resources
in their construction and operation. Other adverse impacts include
noise and dust associated with construction.
Based on our analysis of the studies, it is our conclusion that the
grant condition can be rescinded without a health hazard.
IV. AFFECTED ENVIRONMENT:
The environment potentially affected by this action is that nearby the
O'Hare WRP, including the areas's residents. For a thorough description
of the area's land use, population, and environment, see Section III of
the May 1975 O'Hare EIS (Reference 8).
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V. ENVIRONMENTAL CONSEQUENCES:
A. Basis of Evaluation:
The research projects referenced in this document are used in the
evaluation of the environmental consequences of alternatives.
B. Evaluation of Alternatives:
1. Action:
a) Rescind the grant condition requiring MSDGC to construct aerosol
suppression facilities at the O'Hare WRP:
Testing of a thorough, critical, and sensitive nature,
representing the feasible limit of scientific and economic
capability, have shown that no direct and indirect health
hazards result fron exposure to aerosols.
b) Modify the grant condition and allow operation of the O'Hare WRP
without aerosol suppression facilities, and continue ongoing ana-
lysis of potential health effects:
i) If further study shows need for aerosol suppression:
Monetary, natural and depletable resources would be ex-
pended on further study and in the construction and operation
of aerosol suppression facilities. Other adverse impacts
include noise and dust associated with construction.
ii) If further study shows no need for aerosol suppression:
Beyond the expenditure of monetary resources to further
study the potential effects of aerosol exposure, no direct
or indirect impacts will result from this action. Thorough
research has shown that no health hazards result from ex-
posure to aerosols emanating from activated sludge waste-
water treatment processes within the envelope of accepted
U.S. design and operational practice.
2. No Action:
Retain the grant condition requiring MSDGC to complete construction
of aerosol suppression facilities prior to or concurrently with
commencement of operation:
Monetary, natural, and depletable resources would be expended
on the construction and operation of aerosol suppression
facilities. Other adverse impacts include noise and dust
associated with construction. These impacts would be incurred
a second time if the temporary facilities are replaced by permanent
suppression facilities.
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If operation of the O'Hare WRP would be delayed to construct
temporary aerosol suppression facilities, the overloaded system
presently used would cause continued combined sewer overflows
and flooding of basements with combined sanitary and stormwater,
thereby threatening public health.
VI. PUBLIC PARTICIPATION:
*
A Notice of Intent to prepare a Supplemental WRP BIS was issued on July 18,
1979. A public hearing was held on October 29, 1979. The comment period
was extended through November 30, 1979 to allow further comments on matters
brought up at the public hearing. The comments have been addressed
in this final EIS.
VII. LIST OF PREPARERS
Richard Beardslee, Environmental Engineer, USEPA, Region V.
Gene Wojcik, Chief, EIS Section, USEPA, Region V.
Stephen Poloncsik, Chief, Technology Section, USEPA, Region V.
James Novak, Enviroamental Engineer, USEPA, Region V.
VIII. LEST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THIS
STATEMENT WERE SENT:
The following Federal, State, and local agencies were requested to
comment on the Draft Supplemental Environmental Impact Statement:
Council on Environmental Quality
Department of Agriculture
Soil Conservation Service
U.S. Army Corps of Engineers
Chicago District
North Central Division
Department of Energy
Argonna National Laboratory
Department of Health, Education and Welfare
Department of Housing and Urban Development
Department of the Interior
Fish and Wildlife Service
Geological Survey
Heritage Conservation and Recreation Service
Department of Transportation
Federal Aviation Administration
Governor of Illinois
Illinois Sanitary District Observer
Illinois Environmental Protection Agency
Illinois Institute for Environmental Quality
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Illinois Division of Waterways
Illinois Department of Conservation
Illinois Department of Public Health
Northeastern Illinois Planning Commission
Cook County Department of Environmental Control
Metropolitan Sanitary District of Greater Chicago
City of Des Plaines
Village of Elk Grove
Village of Arlington Heights
Village of Mount Prospect
Village of Palatine
Village of Wheeling
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FINAL SUPPLEMENTAL ENVIROSIMSNTAL IMPACT STATEMENT
FOR THS
METROPOLITAN SANITARY DISTRICT OF GREATER CHICAGO
DES PLAINSS-O'HARE WATER RECLAMATION PLANT
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I. PURPOSE AND NEED FDR FURTHER EPA ACTION
USEPA's original decision in May, 1975 to require aerosol suppression
facilities at the O'Hare WRP was based on two considerations. The
first involved the state of scientific knowledge at the time with re-
spect to the health impacts associated with the respiration of wastewater
aerosols. Our review of the literature at that time revealed that no
conclusive evidence could substantiate either a health effect existed
or that it did not exist. We did find that aerosols were generated
and could be transmitted by winds to the areas in the vicinity of the
O'Hare WRP. There was also some evidence relating to the viability
of bacterial and viral organisms under differing atmospheric conditions.
While this evidence indicated that organisms were adversely affected
by transport on aerosol particles, we felt there was still a possibility
that viable organisms could reach some residents near the O'Hare WRP.
The second consideration came directly from the National Environmental
Policy Act of 1969 (NEPA), which declares that it be National policy
that the Federal Government use all practicable means to assure a
healthful environment and to attain the widest beneficial uses of the
environment without undue risk to health or safety. Therefore, given the
state of scientific knowledge, the possibility of exposure to residents,
and our responsibility to avoid health risks, we chose to require
the appropriate suppression of aerosols generated at the O'Hare WRP.
In the past four years, considerable research has been undertaken to
explore the relationship between health and the respiration of waste-
water aerosols. The purpose of this document is to examine this
new information regarding the health risks of human exposure to aerosols
and to decide whether the grant conditions should be retained, rescinded,
or modified.
II. ALTERNATIVES CONSIDERED AND THEIR COMPARATIVE ENVIRONMENTAL IMPACTS
A. Alternatives Considered:
1. Action:
a) Rescind the grant condition requiring MSDGC to construct
aerosol suppression facilities at the O'Hare WRP, since the
conclusions of the studies to date indicate that no health
hazards result from exposure to aerosols emanating from
activated sludge wastewater treatment processes within
the envelope of accepted U.S. design and operational practice,
either to proximate residents or to plant workers, and by
inference to the general public apart from these categories.
b) Modify the grant condition and allow commencement of functional
operation of the O'Hare WRP without aerosol suppression
facilities, and continue ongoing analysis to demonstrate
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whether the potential emission of wastewater aerosols
at the O'Hare WRP is a significant health concern.
2) No Action:
i
Retain the grant condition requiring MSDGC to complete construction
of appropriate aerosol suppression facilities at the O'Hare
WRP prior to or concurrently with the commencement of functional
operation. In order to allow operation of the WRP as soon as
possible, temporary suppression facilities would be necessary.
B. Comparison of the Environmental Impacts of the Alternatives
There is no indication that health hazards will result from operation
of the O'Hare WRP without aerosol suppression facilities.
While it is always desirable to study an issue in more detail, it is
our conclusion that further study would only have the direct impact
of expending monetary resources, and would not alter the conclusions
that the health risk associated with close proximity to wastewater
aerosols, and hence the O'Hare WRP, is not any greater than that pre-
sented by routine environmental exposure to bacterial and viral
organisms.
If aerosol suppression facilities are constructed, there will be a
significant expenditure of monetary, natural, and depletable resources
in their construction and operation. Other adverse impacts include
noise and dust associated with construction.
If operation of the O'Hare WRP would be delayed to construct the tempor-
ary aerosol suppression facilities, the overloaded system presently
used would cause continued combined sewer overflows and flooding of
basements with combined sanitary and stormwater, thereby threatening
public health.
Based on our analysis of the studies, it is our conclusion that the
grant condition can be rescinded with no significant impacts.
III. AFFECTED ENVIRONMENT
The environment potentially affected by this action Ls that close to the
O'Hare WRP, particularly the 1200 residents within 2000 feet of the
plant boundaries, and is shown in Figure 2. Figure 1 delineates the
O'Hare WRP and adjacent service areas. The northern and southern boundaries
of the O'Hare Service Area follow the Cook County boundary lines. The
eastern boundary extends from Lake County south along the Des Plaines
River to the intersection of Rand and River Roads, thence in a southwesterly
direction along the Chicago and Northwestern Railway to the DuPage County
line. The western boundary separates the O'Hare and Salt Creek Service
Areas, and generally follows the ridge line dividing the Salt Creek
and Das Plaines River drainage areas.
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The O'Hare Service Area lies in the northwest portion of Cook County. It
encompasses an area of 37,250 acres of which 26,400 acres are residential,
5,000 acres are industrial and 5,850 acres are rural or otherwise unsewered.
The 1970 census population for the O'Hare Area was 223,000 people.
The area includes the older (but growing) communities of Arlington Heights,
Mount Prospect, Wheeling, and a part of the City of Des Plaines, as well as
newer urban developments such as Elk Grove Village, Rolling Meadows and
Buffalo Grove.
IV. ENVIRONMENTAL CONSEQUENCES
A. Basis of Evaluation:
Since May, 1975, MSDGC has undertaken studies sponsored by the USEPA, to
evaluate the performance and costs of alternatives for suppression of
aerosols. Phase I of the study which is projected to be completed by
March of 1980, is to measure the physical, chemical, and biological
properties of aerosols emanating from the aeration tanks of the J. E.
Egan WRP and relate these to measurements of the wastewater aeration
process parameters of the plant and environmental parameters which may
have an influence on aerosol properties. Using these data, MSDGC
would prepare engineering estimates of the potential efficiency of
alternative aerosol suppression methods identified for consideration,
and select up to five (other than covering or vegetative barrier)
alternates for detailed testing by pilot plant performance trials.
The performance characteristics of the Egan WRP are presumed to
be representative of the planned operation of the O'Hare WRP.
The proposed Phase II and III portions of the study were designed to
construct a pilot plant, representing a segment of the O'Hare WRP
aeration tanks, emitting aerosols comparable to a demonstrated degree,
in physical, chemical, and biological properties, to those of the
entire Egan WRP, and to construct full-scale short segment prototype
equipment for up to five selected alternative aerosol suppression
systems to be tested on the pilot plant. Aerosol suppression efficiency
of each alternative would then be measured, and the most appropriate
alternative would be recommended, and detailed design criteria presented.
Since virtually nothing was known about the possible health effects of
wastewater aerosols on populations living near activated slu-J-je wastewater
treatment plants, the USEPA sponsored several research efforts to
investigate potentially related health effects. Tne first study funded
by USEPA was an investigative study conducted at MSDGC's Egan WRP
to determine if a potential problem existed for residents which would
warrant further investigation. Since this study revealed a possible
association of certain symptoms with nearby operation of a wastewater
treatment plant, further investigation was initiated.
The USEPA also sponsored a study at Pleasanton, California which obtained
detailed information on the types and concentration of microorganisms
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in aerosols, and the factors affecting their viability after aerosoliza-
tion in order to estimate exposure of those nearby.
To further evaluate potential health effects from exposure to wastewater
aerosols, the USEPA sponsored studies conducted by the University of
Michigan and the University of Illinois to investigate potential
health effects of those residents near a wastewater treatment plant.
Meanwhile, a study conducted by Hebrew University was investigating the
incidence of disease on Kibbutzim utilizing wastewater irrigation and
those not using wastewater. This study showed some evidence of
increased incidence of disease associated with wastewater use. However,
there was doubt indicating the possible pathway of infection, so USEPA
is sponsoring further study to clarify this issue.
Another study sponsored by the USEPA to evaluate potential health
effects from aerosol exposure involved the health experience of students
attending schools adjacent to the wastewater treatment plant in Tigard,
Oregon.
Health reports of sewer maintenance workers in Copenhagen, Denmark
were also reviewed by the USEPA.
To evaluate potential health effects from close occupational exposure
to wastewater and their aerosols, the USEPA then sponsored a study
of sewage treatment plant workers and sewage maintenance workers, to
be conducted by the University of Cincinnati.
The research studies are discussed in the following pages.
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Health Implications of Sewagei Treatngnt
This study was conducted by the Southwest Research Institute to identify
the health implications of operating a recently constructed activated
sludge sewage treatment plant. The general study design was to make baseline
(pre-operational) period versus operational period comparisions at the
Egan Water Reclamation Plant (WRP) in each of two seasons on the same par-
ticipants and sampling areas.
The Egan WRP was chosen since the design of this epidemiological study
required that the sewage treatment plant had to be a new plant being built
on a new site and could neither be an expansion of an existing plant nor
built on the site of an old plant. The design capacity of the plant had
to be one millions gallons per day (MOD) or larger and use the activated
sludge method of treatment. Other constraints also limited the choice of
plant. The plant had to serve a residential area with no heavy industry
contributing to the waste influent, and there could not be another sewage
treatment plant within a six-mile (approximately 10 Krn) radius.
The other major factor which influenced the selection or rejection of a
plant was the population living around the plant site. Within a 5.0 kilo-
meter (Km) (3-mile) radius of the plant, a minimum of 1,000 households
had to be present. Ideally, a uniform population density was needed
throughout the study area.
The Egan WRP was placed in service December 16, 1975, serving a design
population of 160,000 people in an area of 49 square miles. A generalized
flow diagram is presented in Figure 3. The wastewater treated at
the STP is primarily normal to low strength domestic-coraraercial waste.
The area served has limited light industry. The influsnt biochemical
oxygen demand (BOD) concentration averages approximately 100 to
150 milligrams per liter (mg/1). The total suspended solids (TSS)
concentration is in the same range (100 to 150 mg/1). The waste
flow at plant start-up was in the range of 10-15 MOD.
The daily waste flow presently is in the range of 15 to 20 MGD. The
monthly average daily flow is aproximately 17 MGD. The flow into the plant
is somewhat equalized by a wet veil and by allowing the collection system
(sewer lines) to act as a holding device. This is done in an attempt to
distribute the daily flow variations in a more uniform fashion. The
design dry weather daily average flow capacity is 30 MGD.
The plant is presently operated in the conventional mode; that is, the
raw sewage is discharged into the head end of a series of long tanks and
aerated. The flow process of the plant is given in Figure 3.
A map of the study site is provided in Figure 4. The Egan Sewage
Treatment Plant is located at the center of the map, on Salt Creek, a
tributary of the Des Plaines River. The area is located in the northwest
portion of the Chicago Metropolitan area, approximately 35 miles from
the downtown business district. A number of suburban communities
and villages surround the Egan Plant. These are the villages of
Rolling Meadows, Arlington Heights, Elk Grove Village, Itasca,
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Schaumburg, and Hoffman Estates.
The area occupies a plain, which for the most part, is only some tens of
feet above Lake Michigan (579 feet above mean sea level). Topography
does not significantly alter air flow, except that lesser frictional drag
over Lake Michigan causes winds to frequently be stronger along the lakeshore.
The quadrant from the east to about due north of the Egan treatment plant
is a designated forest preserve. Two four-lane highways (Higgins and
Arlington Heights Roads) pass through portions of this preserve. Esti-
mated traffic patterns for each of these roads would be between 20,000
and 30,000 cars/day.
The remaining three quadrants of the study area can be described as a
mixture of residential, agricultural, and small business tracts. Resi-
dential areas are estimated to comprise about 30-40 percent of these
quandrants. However, rapid growth in the area is taking over the avail-
able farmland and would appear to substantially increase the residential
percentage within the next few years. The agriculture usage is predominately
for grain crops such as corn, wheat, and oats. An estimated 10 percent
of the study area is presently commercial enterprise such as shopping
malls and business zones along the major thoroughfares.
The study design provided for a self-paired comparison of individual health
observations from the operational period against those from the corresponding
baseline period is a very sensitive procedure for detecting changes
because it eliminates the substantial inherent variability between human
subjects and between locations. For an epidemiological investigation
of microbiological hazards to have the power to identify any health
hazards that are present, newly exposed human subjects were necessary,
because sporadic inhalation of low concentrations of pathogens may confer
a degree of immunity. With a new sewage treatment site, all the potential
participants are newly exposed.
The original human subjects selected as participants were not, to be replaced
if they dropped out of the study. Each participant was to be his own control,
so very sensitive self-paired comparisons of the corresponding operational
and baseline results could be performed. In the health surveys and for
the soil and water environmental samples, the same locations were to be
used in each sampling period, again to improve the sensitivity of the
comparisons.
Pathogens might come from various sources both within and adjacent to the
study area. Local farmers use a combination of chemical and biological
fertilizers for their grain crops. As manure is spread by machine over
the fields some form of particulate matter would be emitted to the atmos-
phere. ND feedlots were observed within the study area.
Environmental monitoring was conducted to characterizo the ambient air, surface
soil, and surface water in the vicinity of the WRP aeration basin, outward to
residential distances of 0.3 to 5.0 Km in all four sampling periods. The
researchers' concurrent extensive aerosol and wastewater monitoring study
of spray irrigation at Pleasanton, California helped develop a superior
microbiological aerosol sampling and analytical protocol. Six high volume
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air samplers operating simultaneously were used to perform ten aerosol
sampling runs over a seven-day period, with one upwind and five downwind.
The upwind station was intended to describe the background levels of airborne
microorganisms and trace metals.
For sampling off the plant grounds, 24 sampling sites were preselected to
describe the windrose pattern at 1.6 and 5.0 Km distances from the plant.
Twelve additional sites were preselected in case the wind direction was
different than that predicted by the windrose pattern charts for the
area. The sampling sites were changed each day to follow the wind direction.
If the wind direction changed drastically during any one sampling period
attempts were made to move the samplers. Sampler location distances in
meters (m) from the edge of the aeration basin fell into the following
distance ranges: 15-30; 50-75; 100-150; 200-400; 600-1200. An upwind station
was located directly upwind at a distance of 500-1600 m for each run.
In the event wind direction and physical obstructions prevented placement
of samplers at one of the distance ranges, the sampler in question was
placed at the nearest unobstructed point.
Sampling occurred only if the mean wind direction remained fairly constant
and if no marked changes in meteorological conditions were expected over
the next 30 minutes. The run was continued as long as there was no marked
change in mean wind direction prior to the completion of 15 minutes of
sampling.
Each of the 60 aerosol samples was analyzed for total viable particles (TVP),
total and fecal coliform, coliphage, pathogenic bacteria-salmonella, Shigella,
Pseudoironas, streptococcus, proteus, and viruses: polio, adeno, coxsackie,
and echo. Air samples were also analyzed for concentrations of lead, zinc,
copper, cadmium, and mercury. In the operational periods, the mixed liquor
being aerated in the aeration basins was also sampled for trace matals,
viruses, parasitic worms, protozoa, and enteric and respiratory human
pathogenic bacteria.
A health survey was conducted to obtain personal information on households
and detailed background information on volunteer participants. The household
health survey was also used to obtain disease and symptom incidence on the
household members through a door-to-door interview. Half of the households
were within 3.5 Km in all directions from the plant site, with the other
half residing between 3.5 and 5 Km in all directions from the plant. Clinical
specimens were obtained from the participating subjects for microbiological
and trace metal analyses. The clinical specimens selected were blood, feces,
hair, throat swabs, sputum, and urine. One hundred of the participants'
baseline and operational blood samples were analyzed using 23 additional
viral serology tests.
The household health survey was conducted only in the baseline and oparational
sampling periods, with health information being collected on the members
of 1000 households in each survey, but there were no residents within
one-third mile of the plant. From 200 to 240 participants were selected from
the baseline household volunteers residing within the 3.5 kilometer radius,
so at least 140 to 160 would remain to provide clinical specimens through
all four sampling periods. The participants were equally distributed
to 45 years; 60 years or older. The months during which the samples
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for each sampling period were actually obtained were: September-October
1974, February 1975, September 1975, February 1976, September-October 1976.
The data from the household health survey was in the form of frequency
counts for occurrence of a particular chronic illness, symptom, or disease.
The statistical methodology used was designed to determine if any significant
changes in the frequency of occurrence were detectable between the baseline
(pre-operational) period and the operational (post-operational) period. In
addition, any increase in incidence should be related to the distance of the
household to the Egan plant, if the sewage treatment plant was to be implicated
as a potential health hazard.
In order to determine whether the occurrence of pathogens in the clinical
specimens had increased after the plant began operating, the analytical re-
sults of the samples taken from each participant were matched according to
season (February or October) and compared for each of the bacteria, para-
sites, and viruses analyzed in the four sample media (feces, throat swabs,
sputum, and blood).
The study concluded that the Egan plant appears to be a source of indicator
bacteria, coliphage, pathogenic bacteria, enteroviruses, and mercury in the
aerosols emanating from its aeration basins.
However, the levels of microbiological or chemical agents of the air, soil,
and water samples in the neighboring residential areas were not distinguishable
from the background levels monitored before plant operation.
From the patterns observed in the household health survey, the reported incidence
of skin disease, and the symptoms of nausea, vomiting, general weakness, diarrhea,
and pain in chest on deep breathing may have been associated with the nearby
operation of the wastewater treatment plant. However, a more sensitive testing
procedure, checking 31 viral antibodies and attempted isolations of many
pathogenic bacteria, parasites, and viruses yielded no evidence of an adverse
wastewater treatment plant effect.
Results for alpha- and gamma-hemolytic streptococci isolations in the throat
swabs for the subjects from the Lexington Green Apartments provide some evidence
that the pattern may relate to exposure to the wastewater treatment plant
aerosols. However, alpha- and gamma-hemolytic streptococcus species are part
of man's normal flora in the intestinal tract, upper respiratory tract and
skin, and of his environment (e.g./ vegetation, insects, and animal feces)
and do not normally produce disease. Therefore, their presence in the vicinity
of the wastewater treatment plant or in the throat swabs is of little practical
health concern. Thirty-one viral antibody tests and attempted isolations of
many pathogenic bacteria, parasites, and viruses yielded no evidence of an
adverse wastewater treatment plant effect.
The combined baseline-operational and distance experimental design used in this
study is very sensitive for identifying potential health hazards and inferring
whether or not the wastewater treatment plant may be their source. However- the
findings obtained in this study, when considered overall, did not detect a
public health hazard for persons living beyond 400 m from a well-operated
wastewater treatment plant.
Q
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The Evaluation ofjyiicrobiolpgical Aerosols _^sqciated jvi^th^jt
~~
_ ^
of Wastewater to Land: Pleasanton, California 2/
This research project was conducted by the Southwest Research Institute to
determine to what extent individuals living near sites practicing spray
irrigation are exposed to microorganisms.
A water reclamation plant in the City of Pleasanton, California was
selected as the study site: the City of Pleasanton Sunol Sewage Treatment
Plant (STP). The plant was modified just prior to the study by the addition of
an activated biofiliter process following the trickling filter to enhance
the treatment system's biochemical oxygen demand (BOD) removal efficiency.
The City of Pleasanton STP utilized physical and biological processes in the
treatment of its sewage flow. This STP is unique in that it combines
two biological waste treatment systems, fixed film and fluidized culture.
The fixed film is conveniently termed "trickling filter" and the fluidized
culture is termed "activated sludge". Additionally, the STP has aerated
ponds which serve as polishing and equalization for the land application
phase. Provisions have been made for odor control, such as lime addition,
partial chlorination, and off-gas ozonation. Figure 5 presents the
general plant layout flow scheme for liquid wastes.
A schematic of the study area is shown in Figure 6. A population with
middle-class socioeconomic characteristics is located within one mile to
the east/southeast of the plant. The prevailing winds in this area are from
the southwest to northwest quadrant; thus, this inhabited area would be down-
wind of the spray fields. There is a population in this subdivision to conduct
an epidemiological study, and there are also suitable control populations in
Pleasanton with middle-class socioeconomic characteristics located more than
2000 m from the spray fields.
The principal objectives of the first phase of the study were to establish
the relationship in wastewater between pathogen levels and levels of the
traditional indicator organisms (total and fecal coliform and standard bac-
terial plate count), to determine microorganism levels in air within 100 m
of the spray source, and to begin the assessment of factors thought
to affect the levels of pathogenic organisms collected in aerosol samples,
including aerosolization efficiency, pathogen survival upon becoming
airborne (impact), and microbiological die off with time (viability decay).
Routine monitoring of the wastewater was accomplished by taking a 20 liter
composite sample from the aeration basin during the hours of spraying.
Analyses included total and free chlorine, pH, total organic carbon, total
solids, and total suspended solids. In addition, one-half of the composite
samples were tested for biochemical oxygen demand, chemical oxygen demand,
total phosphorus, hardness, and the nitrogen series (nitrite, nitrate, ammonia,
and organic nitrogen). Microbiological analyses run on all wastewater samples
included total and fecal coliform, total viable particles (TVP), coliphage,
and assays for selected pathogens (Kl^bsie_lla, Pseudomonas, fecal streptococci,
Clostridium perfringens, and enteroviruses).
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The objectives of the second phase of the study were toward the development
and validation of a predictive model of aerosol dispersion and pathogen
survival. To accomplish this goal, 50 successful aerosol runs (each utilizing
a minimum of 8 samplers) were made using large volume electrostatic precipitator
samplers. These samplers were selected because the large volume of air sampled
over a 30-minute period increases the sensitivity for the microbiological assay.
Air sampling was conducted upwind and up to 600 ra downwind in configurations
to obtain the information necessary to perform the mathematical modeling. The
samples were analyzed for the same microbiological parameters as the wastewater,
with the exception of one run for which the collecting fluids from all samples
were pooled for conduct of a pathogen screen.
Two special virus aerosol runs were conducted with all available samplers
operating close to the spray line under meterological conditions expected to
result in high virus aerosol concentrations. The sampler collection medium was
changed every 30 minutes and the samplers ran for a total of about three hours,
therefore the results were based upon a total of over 5000 cubic meters (m3) of
air. Additionally, 17 aerosol runs were made after the injection of dye into the
wastewater to allow estimation of the proportion of the sprayed effluent that
became aerosolized. All glass impingers were used to collect the aerosols from
the dye runs, to determine the aerosolization efficiency of the sprinklers.
An explicit model for predicting downwind concentrations of pathogens was developed
by expanding more general mathematical dispersion models. The model adds factors
for microorganism impact, viability decay, and aerosolization efficiency, to the
standard diffusion model estimate of pathogen concentration based on source strength.
The distributions of aerosolization efficiency and the impact and decay values for
each organism were determined and these were used to allow evaluation of the model
using monitoring data from the Egan WRP study and the Tigard, Oregon study.
The dispersion model developed in this study was then validated. It was shown
to produce satisfactory results when used to predict aerosol concentrations
at three sites. Most of the predicted results fell within a factor of five of
the measured concentrations when non-chlorinated effluent was being sprayed.
Through wastewater monitoring it was found the wastewater effluent applied
was of relatively consistent day-to day quality (BDD, 18.7 mg/1; Chemical Oxygen
Demand (COD), 99.5 mg/1; Total Organic Carbon (TOC), 33.0 mg/1; pH, 8.4; hardness,
235.2 mg/1; T5S-33.0 mg/1; total phosphorus—5.6 mg/1; and nitrite, nitrate, ammonia,
and organic nitrogen: 0.15 mg/1, .06 mg/1, 23.9 mg/1, and 5.6 mg/1, respectively).
Pathogenic bacteria and viruses were found consistently in the pre-application
effluent samples, and coliphage was found in all pre-application effluent samples,
A wide range of levels of these microbial components was found. Concentration
levels routinely varied by one order of magnitude, and variation often approached
two orders of magnitude.
A special study of respiratory viruses in wastewater found confirmed viruses in
five of forty cultures. Typing disclosed that four of the five tubes contained
echovirus 6, while the other viral isolate could not be identified. Echovirus
6 may occur as either a respiratory-tract virus or as an enteric virus. The
failure to isolate respiratory viruses in the Pleasanton wastewater confirmed
the researchers' suspicion that the likelihood of finding respiratory viruses
in wastewater is very small.
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There was no significant difference in the coliforra or coliphage concentration
in corresponding effluent samples taken from a spray-head during the aerosol runs
and from the effluent composite samples at the pond pump. The standard bacterial
plate count, however, was significantly higher in the spray-head wastewater
samples. The correlations of the spray-head and pond composite microorganism
concentrations were generally significant, but not adequate for prediction.
The median aerosolization efficiency obtained for the sprayers over 17 dye
runs at Pleasanton was 0.33 percent. There was over an order of magnitude
'of variation in aerosolization efficiency estimates. Eighty percent of
this variation in aerosolization efficiency at Pleasanton appears to have
resulted from changes in meteroological conditions (air temperature, wind
velocity, and solar radiation) that affect the evaporate capability of the air.
The median impact factor estimates for the microorganism groups studied
were 0.13 for fecal coliform (13% survive aerosol impact), 0.16 for total
coliform, 0.21 for standard bacterial plate count, 0.34 for coliphage, 0.89
for mycobacteria, 1.2 for Clostridium perfringens, 1.7 for fecal streptococci,
14 for Pseudomonas, about 10 for three-day enteroviruses (mostly polioviruses),
and about 40 for all (3-day and 5-day) enteroviruses. Most individual impact
factor estimates were quite imprecise, reflecting the imprecision of the
microbiological aerosol concentration measurements. Since the middle range
of impact factor values (fortieth to sixtieth percentiles) for each microorganism
group were quite consistent, they were considered to be characteristic of
the microorganism groups' typical survival through aerosol impact.
As indicated by impact factors exceeding 1.0, the enteroviruses and sane hardy
bacterial pathogens were frequently found in wastewater aerosols at higher con-
centrations than could be expected based on their wastewater concentrations.
Mechanical splitting of colony forming units (CPU) may account for this phenomenon.
The range of impact factor estimates for each microorganism group was broad,
generally covering two orders of magnitude from the tenth percentile to the
ninetieth percentile. The detectable viability decay rates of each micro-
organism group also covered a wide range. Limited data suggest ambient condi-
tions such as low relative humidity, high wind velocity, and a large temperature
differential between wastewater and air all may reduce the initial survival.
Viability decay may be more rapid with high solar radiation, high tem-
peratures, and middle or low relative humidity.
The viability decay rates for total coliform and fecal coliform were more rapid,
more reliable, and more frequently detectable than those of the other micro-
organism groups. Viability decay was less rapid for coliphage, Clostridium
perfringens, and standard bacterial plate count and its effect could only be
ascertained within 100 m on about half the runs. Viability decay could
seldom be ascertained for fecal streptococci, mycobacteria, and Pj^udjDjronas.
No attempt was made to determine the viability decay of enteroviruses due to
insufficient data.
The geometric mean aerosol concentrations obtained at 50 m downwind of
the wetted spray area were:
1) standard bacterial plate count 460.0 /m3
2) total coliform 2.4 MFC/m3
3) fecal coliform 0.37 MFC/m3
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4) coliphage 0.38 PFU/m3
5) fecal streptococci 0.61 CFU/ra3
6) Pseudomonas 34.0 CFU/m3
7) Klebsiella 5.0 CFU/m3
8) Clostridium perjEjringens 0.9 CFU/m3
9) mycobacteria 0.8 CFU/m3
10) enteroviruses (3 and 5 day) 0.014 PFU/m3
PFU = Plaque Forming Units
CPU = Colony Forming Units
MFC = membrane filter count
ra3 = cubic meters
Individual aerosol measurements frequently differed by more than an order of
magnitude from these mean values.
Limited particle size data obtained with two-stage Andersen samplers showed a
substantial portion in the respirable range. The median percent respirable
particle values downwind of the spray line were 44 percent for total count and
74 percent for total coliform. In general, there was a higher percentage of
respirable particles at close downwind distances (5 to 25 m), than at back-
ground and farther downwind distances. This meager data is in general
agreement with more thorough particle size studies performed at the Egan WRP.
Particle size was not considered in the mathematical modeling.
Wastewater quality as measured by chemical and physical parameters was
unrelated to the generation or transport of microbiological aerosols from
spray irrigation. In addition, little correlation was found in the wastewater
between levels of the traditional indicator organisms; total coliform, fecal
coliform, standard bacterial plate count, and coliphage, with the levels
of the pathogens which they are intended to indicate.
Aerosol studies indicated that use of the traditional indicator organisms
to predict human population exposure results in extreme underestimation
of pathogen levels. The pathogens studied survived the wastewater aerosol-
ization process much better than did the indicator organisms. Based upon
the results of this study, fecal streptococci may be an appropriate indicator
due to ease of assay, levels routinely seen in wastewater, and the similarity
of their hardiness upon impact and viability decay rate to those of the
pathogenic organisms of interest. However, an apparent problem was the
occasional presence of fecal streptococci in aerosols due to non-wastewater
sources.
Although Klebsiella was relatively prevalent in the wastewater, it was far less
prevalent in the wastewater aerosol. It appears that Klebsiella die off
repidly during the aerosolization process. This finding was in contrast to
data seen in the literature which consistently report Klebsiella as the pre-
dominant pathogen found in the air near spray irrigation sites and near sewage
plants. More analytical confirmation steps were used in this study than
in earlier studies. If the confirmation steps had been stopped at the
point used by other investigators more values would have been reported
as Klebsiella when, in fact, they were primarily other organisms of the
mucoid type.
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The study was supported by an extensive quality assurance program. Chemical,
physical/ and microbiological methods used were subjected to accuracy and pre-
cision studies, and alternative laboratories were used, where feasible, to verify
the results.
Studies conducted on the aerosol collection media, the temperature at which the
samples are shipped, and the total time from collection to analysis were examined
in detail in the laboratory. The results led to the design of adequate methods
(for sampling and analysis so that pathogenic organisms were found consistently.
Some difficulties were encountered in contamination of the high-volume aerosol
samplers between aerosol runs. This problem appeared primarily in the standard
bacterial plate count and Pseudomonas assays. Special care must be taken to
adequately decontaminate high-volume aerosol samplers between aerosol runs.
The microbiological aerosol data varied substantially in quality and statisti-
cally usable information content. Accordingly, a suitable aerosol data
weighting procedure was employed, according to consistent rules, in con-
ducting the aerosol factor analyses. In the quality assurance aerosol runs
for systematic sampler differences, it was concluded that after correcting
for the air flow rates, there was no systematic bias in microbiological
collection efficiency among the high-volume samplers evaluated.
There was substantial imprecision using the methods employed in this study
for measuring microbiological concentrations in aerosol samples. The aerosol
measurement coefficients of variation were 17 percent for dye, 50 percent
for total coliforra and standard bacterial plate count, 58 percent for
fecal coliform and Pseudomonas, 60 percent for Clostridium perfringens,
73 percent for coliphage, 74 percent for Klebsiella, 77 percent for fecal
streptococci, and 81 percent for mycobacteria. While the microbiological
aerosol variation due to field sampling sources was considerable, even
more variation was caused by analytical sources such as sample processing,
shipping, and laboratory procedures. Relatively little of the analytical
variability was reflected in replicated analyses, which is the usual manner
of reporting analytical variation.
The accuracy and precision of microbiological dispersion model predictions have,
in general, been validated to 100 m downwind of spray sources of unchlorinated
wastewater aerosols. Most model predictions (e.g., 77 percent for standard bac-
terial plate count, 71 percent for total coliform, and 80 percent for coliphage)
were within a factor of five of the net measured aerosol concentrations evaluated.
Considering the imprecision and cost of measuring microorganism aerosol con-
centrations from spray irrigation by field sampling, using predictions of the
micorbiological dispersion model supplemented with minimal field sampling does
appear to be a preferable alternative to extensive field sampling when the sprayed
wastewater does not contain residual chlorine.
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Ifealth_E_ffects of a Wastewater Treatment System 6/
The University of Michigan and the IIT Research Institute utilized data obtained
as part of a comprehensive community health study conducted during 1965-71 to
examine the incidence of acute illness in a population surrounding an activated
sludge wastewater treatment plant and a control location in Tecumseh, Michigan.
The Tecumseh wastewater treatment plant (r/WTP) is located in the southeast
'quandrant of the city (Figure 7). The plant is at a lower elevation than
most of the populated study area and is surrounded by deciduous trees on the
east, west, and south. This plant processes approximately 1 million gallons
of wastewater per day (MGD) by activated sludge secondary treatment. Acti-
vated sludge has been in use since 1956, when the plant was redesigned
from a trickling filtration facility. Data that might be used to estimate
the fecal contribution to the wastewater, such as total or fecal coliform
concentrations, are not available for the study period. Wastewater flow
rates for the study period were not available from the Tecumseh VWrP, but
available data were obtained from the Michigan Department of Natural
Resources.
Average monthly flow rates at the Tecukmseh wastewater treatment plant
ranged between 0.64 and 1.18 MGD from 1965 to 1971. Data, however, were
not available for 1966, and some data for 1965, 1968, and 1969 are missing.
The study population was defined as those participants in the University
of Michigan Tecumseh Community Health Study from 1965 to 1972 who resided
in dwelling units at specific distance ranges from the Tecumseh wastewater
treatment plant (Figure 7). Dwelling units located within each of five
concentric rings and beyond, radiating from the plant in approximate multiples
of 600 m, were identified. Dwelling units were likewise identified with
a second set of concentric rings constructed around a nonemitting location.
This site was located in the northwest quandrant of the city in an undeveloped
area approximately 180 m west of Seminole and 275 m south of Brown Roads.
This control location was selected because it is upwind from the wastewater
treatment plant and had a surrounding population density comparable to
that of the study groups. The dwelling units within the study area were
primarily single family houses, although multiple family units occured
at various locations within the area. Confirmation of dwelling unit locations
near concentric ring boundaries was made by site visitation. All dwelling
units studied were assigned to concentric rings surrounding both the wastewater
treatment plant and control location. Data with reference to each index
point were analyzed separately.
The population used in nonseasonal-related analyses included those in-
dividuals who were contacted at least 50 weeks in a row with no absences
during four or more weeks. The illnesses included are those whose
onset occurred within this 50-week period. The entire population on
report from 1965 to 1971 was used for determination of true illness
incidence rates.
As used in this study, colder months included November through April
whereas warmer months included May through October. In each case, the
study population was defined as those persons on report for the entire
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26-week period, with no long periods (two weeks or more) off report. Ihe
illnesses included are those whose onset occurred during the 26-week period.
Data were obtained from the participating families regarding health history,
socioeconcmic factors, employment locations, and schools attended by all children.
After recruitment, each family was contacted weekly by telephone or personally,
and a single respondent was questioned regarding the occurrence of short
term illness within the family during the past week. When illness was
reported, the details of the specific event were recorded using a question-
. naire. The respondent was contacted during the weeks following the initial
report and asked whether the illness persisted and to describe the symptoms.
The date of illness termination was obtained, and the respondent was
questioned regarding other illness development within the family. An
illness occurring at least two days after a termination date was regarded
as a new event.
Acute illnesses were grouped into three general categories: total, respira-
tory, and gastrointestinal. Data are reported as incidence rates and as
individual illness rates. Age-sex-distance-specific true incidence rates
were determined by dividing the number of each kind of illness by the number
of person-years observed within each group. Age-sex-distance-specific indi-
vidual illness rates were calculated by number of illnesses during report
period/number of weeks on report.
Study participants were classified into concentric rings of approximately 600rn
each by dwelling unit distance from both the study and control site. School
children were classified by school attended in a similiar manner.
The objective of the statistical analyses was to determine whether the inci-
dence of illness varied with distance of the dwelling unit from the waste-
water treatment plant, and, in children, also whether incidence depended upon
distance of the school attended from the wastewater treatment plant. Dwell-
ing units and schools were also classified with respect to distance from a
control location.
Differences in illness incidence occurred during the May through October season
at varying distances from the wastewater treatment plant, but persons within
600rn appeared to have a greater risk of respiratory and gastrointestinal
illness than the control group. The data do not, however, demonstrate a
causal effect and factors other than the wastewater treatment plant, such as
higher rates of illness transmission in areas of higher densities of lower
socioeconomic families, could have contributed to these findings. Persons
dwelling within 600m of the plant had respiratory illnesses that exceeded
those of the control group by 20% and 27%, and gastrointestinal illnesses
that exceeded those of the control group by 78% and 50% when specified
for income and education, respectively. When specifying socioeconomic
factors, education and income exerted an unequal influence on the significance
of illness incidence variation and, in general, such variations between
geographiic locations were found to be greatest in groups having the lowest
income and education. Therefore, the data suggest the higher illness
rates are related to higher densities of lower socioeconomic families
rather than the wastewater treatment plant.
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The group within the 1800 to 2400m concentric rings from the wastewater treat-
ment plant had a greater than expected incidence of respiratory illnesses
during both warm and cold seasons. Significant differences were not
found in the control location related groups at this distance. However,
'the higher than expected illness cannot be related to the wastewater treat-
ment plant itself, since they appear to be related to socioeconomic status.
Differences in total illness were observed in the school children with regard
to distance of school attended from both the wastewater treatment plant and
'control location. But these results are inconclusive since the schools
were very unevenly distributed with reference to distance from
these locations.
These observations should be tempered with the recognition that the Tecumseh
wastewater treatment plant is located at a lower elevation than most of the
populated study area and is surrounded by deciduous trees on the east, west,
and south. Depending upon wind direction, velocity, and atmospheric stability,
surrounding trees may act as a partial barrier for parsons dwelling nearest
the plant while lofting the airflow, resulting in further downwind dispersion.
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Health Effects of Aerosols_ EmittedJFrom an__Activat_e_d_ _S1udge_£laLnt 4/
This research project investigated the potential health effects of aero-
sols emitted from an activated sludge plant. The University of Illinois
Medical Center conducted an 8-month environmental health study using a
stratified sample of persons residing near the North Side sewage treatment
plant (NSSTP) in Chicago.
The NSSTP was chosen for the study since the plant is nearly surrounded
by a substantial number of residences. Census information (1970) indi-
cated the population to be of homogeneous socio-economic status and to
consist of appropriate numbers of individuals in the desired high-risk
age groups. The sewage is not heavily industrial, and the prevailing
wind patterns and topography appeared to be conducive to exposure
of population groups.
Built in 1929, the NSSTP is one of the three main plants of the Metro-
politan Sanitary District of Greater Chicago (MSDGC). The plant is
located on Howard Street between Hamlin Avenue and McCormick Boulevard
in Skokie, Illinois (Figure 8), which is a northwest suburb of Chicago.
The NSSTP is an activated sludge plant employing diffused aeration with
tapered aeration. Chlorination occurs after the final settling process.
No sludge processing occurs at the plant. A schematic of the plant
is shown in Figure 9. The maximum capacity of the plant is 399 million
gallons of raw sewage per day. During the study period (April-November,
1977) the plant had an average daily flow rate of 292 million gallons
of sewage and a median air rate of 4.6 x 10 m3/day. The estimated
surface area of sewage in the aeration tanks is about 55,000 m2 in
settling tanks, concentration tanks, etc., exposed to the atmosphere.
The total retention volume of one battery of aeration tanks is 7.45 x 10 m3.
The tank levels are maintained at approximately 4.6 m. Residence
time of sewage in the aeration tanks is generally 5-1/2 hours.
The area within a 1.6 Km radius of the treatment plant as shown in
Figure 8 was designated as the study area. Previous studies at other
locations have found that the dispersion of viable particles does
not exceed 0.8 Km from the source. Therefore, the 1.6 Km radius study
area permitted analysis of exposed and unexposed populations. The
study area included portions of four communities: Skokie, Lincolnwood,
Evanston, and Chicago. As can be seen in Figure 8, the plant is located
in a small industrial area. Light industries are situated north, east,
and south of the plant, occupying most of the land within the first
0.4 Km (1/4 mile) radius of the plant. Residences are located about
152 m west of the aeration basins, and about 0.8 Km (1/2 mile)
directly east of the tanks. Housing also exists within 0.8 Km north
and south of the plant. The major residential section begins at
the 0.4 Km radius line and extends uniformly through the 1.6 Km radius
area.
The population of the study area was estimated to be 15,850 persons, or
5,600 households, based on the 1970 census. Considering property value,
age, and race, the population appeared to be relatively homogeneous.
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Although there were differences in several characteristics between
sane of the tracts, these 1970 figures were used for preliminary evaluation
of the population and not for subsequent demographic analysis.
1 In order to characterize the nature and degree of exposure of the study
population to pollutants emitted during treatment plant operation,
environmental air quality, measurements of total viable particles
(bacteria containing particles), total coliform bacteria, total suspended
particulates (ISP), and 19 metals and gases were made at regular intervals
• at different distances from the plant in ambient air. Concentrations
of total viable particles (TVP) were measured on a regular basis
(approximately every other day) at the plant and in the community
for eight months (April-November, 1977) using Anderson 2000 six-stage
(ASS) viable samplers. Initial attempts to monitor for total and
fecal coliform were made using an All-Glass-Impinger on six days during
April and May. These samplers were found to be below the sensitivity
required for detection of the concentrations present. Beginning in
September, airborne total coliform samples were taken with Andersen
samplers on days of total viable particle sampling and with a Litton Large
Volume Air Sampler (LVAS) one day per week. Airborne coliphage measure-
ments were originally scheduled to be taken once every other week. How-
ever, many equipment problems were encountered with the LVAS, and only
eight coliphage in air measurements were obtained. Animal virus in air
samples were obtained for two days using LVAS's (one upwind and one down-
wind each day). Monitoring of nonviable constituents was conducted every
five days from April through November on the plant and in the community.
The Andersen 2000 six-stage (A5S) viable samplers used are a multi-orifice
cascade impactor consisting of six aluminum stages accompanied by six
glass petri dishes and a pump. Each stage collects particles of pre-deter-
mined size range with stage six collecting particles of 0.65 to 1.1 m
diameter and stage one collecting particles of. 1.1 m and above. These
samplers were calibrated to sample air at 28.3 liters/minute.
The LVAS's use a liquid collection media to filter the air samplers which
are initially collected at approximately 1.0 m3/minute. The fluid con-
taining the air sample is then filtered through a membrane filter in a
Millipore filtration apparatus.
"x
Grab samples of sewage were collected from the aeration tanks concurrently
with the air measurements and were analyzed for total viable particles,
total coliform bacteria, trace metals, sulfates, and nitrates. A limited
number of measurements were also made of viruses and coliphage in
sewage.
The environmental measurements were used to develop study period exposure
indices for each household for total viable particles, TSP, and eight
metals and gases, a similiar 2.5-month exposure index was developed for
total coliform bacteria. Virus and coliphage measurements in sewage and
air were inadequate in number to determine their concentrations with any
confidence.
In an attempt to determine whether or not the sewage treatment plant was
hazardous to the health of the community exposed to the plant aerosols,
several measurements of health were made.
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An important requirement for this study was that the sample of households
be equally distributed throughout the study area. Therefore, three con-
centric sampling zones were designated around the sewage treatment plant
as follows: I) 0-.8 Km; 2) .8-1.2 Km, 3) 1.2-1.6 Km (from center of plant).
A random sample was chosen from each zone in order to obtain a more uni-
form geographic distribution of households throughout the study area.
The sample size for each zone was determined by the number of households
in the smallest zone (nearest the plant, 394 households). Thus, nearly
every family in this zone was included in the sample.
%
A history of the baseline health status of each participant was tabulated
in a health questionnaire developed in collaboration with the Survey Research
Laboratory (University of Illinois, Circle Campus). Specific questions
were asked regarding any acute illnesses the participant had experienced
in the past year. Additional questions concerned such factors as
chronic disease, smoking habits, demographic characteristics (i.e., age,
sex, race, income, occupation), length of residence in the study area,
travel, and vaccination history.
In order to obtain ongoing, prospective information about health in the
study population, a subsample of the persons interviewed in the Health
Questionnaire Survey was solicited into the Health Watch. Participants,
as family units, were asked first to maintain a health diary to self-report
any and all illnesses they encountered for an 8-month period. Secondly,
they were requested to provide blood samples at the beginning and again
at the end of the 8-month period, and finally, families with young chil-
dren were asked to provide clinical specimens, i.e., throat and/or stool
specimens, for biweekly microbiological surveillance.
The cross-sectional demographic and health survey carried out in the
area surrounding the activated sludge plant (which processes 292 million
gallons of sewage daily) revealed a relatively homogeneous, predominately
white, upper middle class group, with no remarkable prevalence of health
problans. Seven hundred and twenty four people (246 families) volunteered
to record self-reported illnesses at biweekly intervals. Throat and stool
specimens were collected from a selected subsample of about 161 persons.
In addition, 318 persons submitted paired blood samples at the beginning
and at the end of the study period to determine prevalence and incidence
of infections to five coxsackievirus and four Echovirus types potentially
associated with aerosol exposure.
In relating illness rates to total viable particle exposure, it was necessary
to limit the illnesses to those which potentially have a casual association
with viable particle exposure—respiratory, gastrointestinal, eye and ear,
skin, and total illness.
A dose-response approach was taken in the analysis of exposure and health
effects. Conceptually, if the sewage treatment plant was the source of
infections, trace metals and gases, or other hazardous materials, then the
level of exposure may be directly related to the number of infections
and/or diseases occurring in the exposed population. Standard techniques
such as regression analyses were performed to determine if health effects
increased with exposure, or if the two variables varied independently.
Scatter diagrams were prepared to further examine the relationship between
exposure and health effects.
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Results of the health survey and the specimen and serological analyses of
residents as close as 152 meters were compared with the household exposure
indices. l\b significant correlations were found between the exposure in-
dices and the rate of self-reported illnesses or of bacterial or viral
infection rates (antibody levels) determined by laboratory analysis. This
lack of correlation between 8-month total viable particle exposure and ill-
ness rates may be the result of an inadequate sample size (in terms of number
of households), an unequal frequency distribution of household exposure
indices in terms of not having enough households exposed at "low"
"or "high" levels of TVP concentrations, the inaccuracies in self-reported
illness rates, the existence of more complex functional relationships
between health and exposure variables, or no relationship at all.
The relationship between temporal illness and exposure was also evaluated on a
2-week averaging period basis. No linear relationships were found when analyzed
separately or together for all types of illnesses evaluated or for respiratory
illnesses alone.
In order to examine a possible lag effect between exposure and illness, a
2-week lag period analysis was carried out. Again, no linear relationship was
detected. A 2-week period was the smallest lag period possible to
analyze, since the health survey was conducted biweekly. In addition
to the possible reasons for lack of correlation provided above, it was
possible that the 2-week lag period was too long in terms of incubation
period for most bacterial and viral agents possibly associated with these
illnesses. It was also important to note that the 2-week exposure indices
were much less reliable than those based on the total study period.
An attempt was made to examine the relationship between illness and exposure
for various sub-populations potentially at high risk to the effects of TVP
exposure. Age (0-12, 13-18, 19-59, greater than 59 years), chronic respiratory
disease (chronic bronchitis, emphysema, or asthma), chronic gastrointestinal
problems, smoking, family composition (families with one or two adult mem-
bers, youngest children aged 0-5, 5-14, and greater than 13 years), and length
of residence (less than 1 yr., 1-5 yrs., 6-10 yrs., 11-20 yrs., and greater
than 20 yrs.) in the study area were considered potential risk factors. The
analysis did not reveal any linear relationships except for skin illnesses
for families with the youngest child between 5 and 14 years, and for skin
conditions in the over 20 years of residence sub-population. However it was
reported by the researchers that these linear relationships are of
questionable imrwrtance since the mean illness rates were i,o low.
No linear relationship was found for respiratory illnesses or for all illnesses
combined when compared to total coliform bacteria exposure. Exposure to metals,
gases, and T3P did rot exhibit a linear relationship when compared with household
illness rates for all illnesses combined, as well as for the separate illness
categories.
Throat bacterial infection rates were compared to TVP exposure and no dose-
response relationship was found. Analysis of virus infections was possible
through serosurvey. The differences observed were not statistically significant.
The overall conclusion that this activated sludge sewage treatment plant had
no obvious adverse health effects on residents partially exposed to aerosol
emissions should be tempered by the recognition that only a very small number
of people were exposed to the highest pollution levels.
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Environmental Monitoring of A Wastewater Treatment Plant I/
i This draft research report was compiled by the Southwest Research Institute
to evaluate aerosol emissions from the Durham activated sludge treat-
ment plant (DASTP, Tigard, Oregon) and their possible health effects.
The DASTP is situated next to Fanno Creek, a tributary of the Tualatin River/
• in an area which has recently (Fall 1978) been annexed by the City of
Tigard. The DASTP services the entire Fanno Creek drainage basin and
nearby areas. Figure 10 shows the location of the plant and the area
served. The DASTP commenced operation on July 6, 1976, with an initial
design capacity of 75,000 cubic meters (m3) per day (20 MGD) that can be
expanded to 227,000 m3 per day (60 MOD) by the year 2000 to meet the
needs of this rapidly growing area.
Designed as a modern activated sludge plant incorporating some advanced
processes for wastewater treatment, the DASTP is comprised of two parallel
plants which can be operated separately from primary clarification to the
point of effluent discharge. Alternatively, flows can be combined from
the separate plants after various stages of treatment. All plant influent
first passes through barminutors to screen out and reduce the size of
large objects. The flow is then divided to two primary clarifiers in
parallel where settleable solids and grit are removed. Secondary treat-
ment begins with the classical activated sludge process in four aeration
tanks.
After secondary clarification, the wastewater is subjected to advanced
wastewater treatment processes for reduction of phosphorus and solids.
Plant effluent is then filtered and chlorinated prior to discharge in the
Tualatin River. Organic sludge from the primary and secondary clarifiers
is processed in a series of gravity sludge thickeners, cyclone-type
grit separators, disc centrifuges and continuous bowl centrifuges. After
heat treatment and incineration, the resulting ash is landfilled.
A schematic flow diagram of plant processes is shown in Figure 11.
To accommodate plant flow during periods of extensive rainfall, two large
surge basins were built adjacent to the plant. The largest surge basin
has a capacity of 38,000 m3 (10 million gallons), while the others
have capacities of 19,000 m3 (5 million gallons). A small basin of
7,600 m3 (2 million gallons) capacity is situated adjacent to the
surge basins and has no surface aeration. Its purpose is to catch
backwash from the filters. Flow from any of the plant processes can
be diverted to the surge basins, but typically, primary clarifier
effluent is diverted to these basins in sufficient quantity to maintain
a relatively constant flow through the activated sludge process. Three
surface aerators in the second largest surge basin (No. 1 surge basin)
prevent the primary treated wastewater from becoming anaerobic. During
periods of low influent flow, wastewater from the surge basin can
be reintroduced into the secondary treatment process to equalize flow
through the secondary and tertiary treatment sections of the plant.
It was determined that there were three potential sources of aerosol
formation within the DASTP: the aeration basins, the surge basins, and
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the secondary recarbonation basin.
No chemical treatment (including recarbonation) was performed during
either of the sample periods. This eliminated the secondary recarbona-
tion basin as a source of aerosol.
Also, plant personnel determined that use of a single aeration basin
resulted in optimal operation of the activated sludge process. In this
mode of operation, all wastewater is mixed with activated sludge in a
3,800 m3 (1 million gallon) capacity aeration basin with a detention
time of 1.5 to 2 hours. Mr at a pressure of 0.39 to 0.53 kg/on
(5.5-7.5 psi) is introduced through a 10-cm (four-inch) diameter nozzle
located 1.5 m (5 feet) from the bottom of the basin.
Each nozzle is oriented vertically upward underneath a variable speed
turbine aerator that agitates the aeration basin liquor and disperses
the air stream from the nozzle. There are two nozzle mixer systems in
each 21 x 30 x 6 m deep (69 x 100 x 20 feet) aeration basin. Based on
the surface area of the aeration basins, perhaps one-fourth of the poten-
tial aerosol was being generated, since only one of the four aeration basins
was being utilized for secondary treatment during the monitoring period.
The third source of aerosol generation, surface aerators on the No. 1
surge basin, was functional during both sampling periods. When the waste-
water characterization samples were collected in November 1977, the No. 1
surge basin was being used to return surge to the aeration basin. A
total of 12,200 m3 (3.22 million gallons) were returned to the aeration
basins during 19 hours of the 24-hour operating day commencing at
midnight November 9. During the aerosol study in Mary 1978, the depth
of the only aerated surge basin (No. 1) remained constant at 4 m (13 feet)
since no wastewater was diverted to or removed from it.
One objective of this study was to measure the types and quantities of viable
microorganisms present in the ambient air 0-100 m downwind of the DASTP.
A second objective was to determine whether the absentee rate at Durham
Elementary school (next to the DASTP) was significantly different
fron the absentee rates at control schools located in the same area
but not near a wastewater treatment facility. This would provide some
preliminary indication of possible health effects which might be associated
with the treatment facility.
To address the first objective, large wastewater samples were collected from
each potential source of aerosols, to characterize the type and approximate
concentration of viruses and enteric bacteria available for aerosolization.
These results were used to select the types of organisms and methods to be used
during routine monitoring of wastewater and aerosols.
Six aerosol runs were conducted to simultaneously measure levels of micro-
organisms in wastewater and air. This was achieved using a sampler array of
eight high-volume air samplers (Litton Model M). Two samplers were paired upwind,
while the six downwind samplers were deployed as three pairs, at planned distances
of 30 m and 100 m downwind of the aeration basin and 50 m downwind of the surge
basin. During the six high volume aerosol runs, temperature, relative humidity,
wind direction, wind speed, and solar radiation intensity were monitored. The
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aerosol runs were taken over a wide range of solar radiation conditions, from
darkness during run 3 to noon during run 6.
Based on experience in detecting microorganisms in the aerosols monitored at
i the Egan WRP and at Pleasanton, California, the following microorganisms groups
were selected for routine monitoring: total coliform; fecal streptococci;
Pseudomonas, mycobacteria, and coliphage. A special enterovirus aerosol run
was also conducted to measure enterovirus levels at the aeration basin.
« The level of microbial aerosols reaching the school were then estimated. Since
previous experience had shown aerosol monitoring beyond 400 m downwind
of the aerosol source was infeasible, the only means to obtain exposure dose
information was by calculation involving a mathematical model, monitoring data,
and wind direction data. Since the calculation required data extrapolations
and assumptions whose validity is uncertain, the estimated peak exposure doses
do contain considerable uncertainty. However, the researchers have verified
the predictions of the model from extensive monitoring data at the Egan WRP
and at Pleasanton, California.
The frequency with which children at Durham Elementary were exposed to
aerosols from the DASTP was investigated. Two exposure locations at the
school (classroom and playground area) were considered. Wind direction
observations made at Portland International Airport (24 Km northeast
of the DASTP) by the Portland Weather Service office at 7 a.m., 10 a.m.,
1 p.m., and 4 p.m. on each of the school days were used in estimating
the frequency of student exposure.
A daily exposure index was computed for each exposure location-aerosol
sources combination, based on the four wind direction observations for the
day. Wind direction observations within 30 degrees of the schools direction
were considered to represent an occasional exposure, and the exposure index
was adjusted using a weighting factor.
Quarterly attendance for Durham Elementary and eight control schools were
obtained for the seven school years prior to DASTP operation and for the
first two school years of DASTP operation. If the DASTP had an adverse
health effect, one would expect higher absenteeism at Durham Elementary
(relative to the control schools) in the two operational years. Such absentee-
ism might take the form of a uniformly higher absence rate throughout the
two operational years, or because of acquired immunity, It might only be
evident during the first several months of aerosol exposure.
Wastewater monitoring detected the concentration levels for mycobacteria and
Klebsiella were fairly high relative to the microbiological indicators at the
DASTP. Also Pseudomonas were found at relatively high concentration levels.
However, Salmonella and Shigella, generally regarded as the most common bacterial
pathogens, were not prevalent in the wastewater samples. Microorganism con-
centration levels tended to be higher in the aeration basins than in the surge
basin, recarbonation basin or effluent pond. Consequently, the aeration basin
was selected as the most suitable source for monitoring the aerosols.
The geometric mean aerosol concentration at 30-50 meters downwind of the aeration
basin were 5.8 cfu per m3 of total coliforms, 2.0 cfu per m3 of fecal
streptococci, 9.1 cfu per m3 of mycobacteria, 7 cfu per m3 of Pseudomonas,
and 0.7 pfu per m3 of coliphage. ~
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Enteroviruses were not detected in the air 30 m downwind of the aeration
basin. This resulted from their low concentration in the wastewater
and from the association of 98 percent of the wastewater enteroviruses
with solid matter which is not readily aerosolized. Mycobacteria were
observed to be more prevalent at the DASTP than at the Egan WRP and
Pleasontcn, California wastewater aerosol monitoring sites.
The microorganism aerosol concentration levels tended to decrease with
increasing downwind distance from the wastewater aerosol source, and
'also tended to vary from one aerosol run to another due to variations
of microorganism levels in the wastewater. However, high and extremely
variable aerosol concentration levels were probably dus to contamination
of the high-volume aerosol samplers.
Aerosol runs indicated that levels of fecal streptococci, Pseudomonas,
and mycobacteria were generally as high or higher at 70-100 m downwind
than the levels of such indicator organisms as total coliform and coliphage.
Thus, the use of indicator microorganisms such as total colifom or
coliphage in wastewater aerosol monitoring appeared to be inadequate
to characterize the pathogenicity of the aerosols.
The calculated daily exposure index over the 355 school days the IX\STP was
operational showed that on the majority of school days the classroom area had
no exposure to aerosols. On ten days the classroom area was steadily exposed
to aeration basin aerosols and on five days to surge basins aerosols. The
playground area had steady exposure to E&STP aerosols more frequently, but
the number of days was still low. These calculations were based on four
wind direction measurements per day, and since wind direction is variable,
exposure was greater than indicated here.
The weather on the days of steady aerosol exposure in the classroom area was
reviewed, and revealed conditions conducive to survival of aerosolized
microorganisms. However periods of rainfall experienced on the days of
steady aerosol exposure would reduce the duration of exposure. The weather
on days of steady aerosol exposure in the playground area was similiar.
Based on precipitation during and proceeding the school day, the playground
was considered usable for student play on 13 of the 31 school days with
steady aerosol exposure.
Assuming a breathing rate of 0.25/m3/hr, the estimated peak microorganism
dose received by Durham Elementary students on a single, school day was as
high as 9 cfu of mycobacteria and 3,5 cfu of fecal streptococci during seven
hours while in the classroom area. Substantially lower doses were calculated
for one hour of playground exposure. Ffowever, since the bacteriological
strength of the surge basin wastewater may vary substantially, the peak play-
ground exposure may be considerably underestimated. In making this calculation
it was assumed that the wastewater and aerosols sampled during the one-week
monitoring period were representative of the levels and variability occurring
throughout the two-year DASTP operational period.
From comparison with usual outdoor background exposure, measured upwind of
the aerosol source, the peak exposure dose during a school day may exceed
the usual seven-hour outdoor background dose by two orders of magnitude
for fecal streptococci, and perhaps three or more orders of magnitude
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for myoobacteria.
In the two school years after the DASTP began operating, annual school attend-
ance at neighboring Durham Elementary School improved. The improvement at
1 Durham was evident in comparison both to prior school attendance at Durham and
to school attendance in the surrounding control schools. Hence, there was no
evidence that operation of the DASTP had any sustained adverse effect on school
attendance at Durham Elementary. Analysis of the school attendance data on a
quarterly basis also yielded no evidence of adverse effects having a shorter
'duration. However, very occasional transitory effects could not have been
identified from the quarterly attendance data available for this study.
The analysis of class attendance data showed some extended periods of elevated
absenteeism among first and second grade students at Durham Elementary (compared
to the control school class attendance) after operations at the DASTP commenced.
However, periods of even higher absenteeism among first and second grade students
at Durham Elementary also characterized many of the baseline years. Thus, it
was indeterminate whether the absenteeism among the younger students at Durham
Elementary had any relationship to DASTP operation.
This study illustrates both the advantages and disadvantages of using ele-
mentary school attendance data for an epidemiologic investigation of a
localized potential health hazard. The advantages are the uniformity,
availability, and copious volumes of school attendance data, which permit
the detection of many significant differences. The primary disadvantage is
the existence of many potentially confounding factors affecting school
attendance which are unrelated to student health and which can obscure the
potential hazard being investigated. School attendance is affected by school
factors under the principal's and teachers' control (e.g.. policies regarding
student progress, nature of curricular and extracurricular activities), as well
as student factors (e.g., personal stress, sickness in family, work at home,
poverty, inclement weather, parental difference, travel distance in rural
schools) 6/. While personal illness is one of the leading causes of absence, other
factors may also have sizable effect. Hence, school attendance is quite an
insensitive measure of adverse health effects. The lack of an effect on school
absenteeism does not necessarily imply the absence of any health hazard.
There were three principals at Durham Elementary during the school attendance
study period. The third principal served only during the two DASTP opera-
tional years, so the effects of his policies on school attendance are confounded
with those of the DASTP. This change in principal may have been responsible
for much of the improvement in attendance at Durham Elementary in the DASTP
operational years.
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Assessment of Disease Rates Among Sewer Workers in Copenhagen/ Denmark 7/
This report attempts to provide an assessment and discussion of pertinent
data as it applies to the health of sewer workers from a series of documents
published over the period of 1975-1977. The report was based on four
separate sources: 1) responses to a questionaire to sewer workers about
health and working conditions; 2) a study of sick leave records from
January 1957-December 1973 for sewer workers and a control group of all
city office workers; 3) a study of death records compared with national
mortality statistics; and 4) assessment of reports of analyses of sewer
atmospheres for toxic substances.
The municipality of Copenhagen serves 600,000 permanent residents, approxi-
mately 200,000 transients and commuters and has an industrial load equivalent,
on a 30D5 basis, to 1,600,000 additional persons for a total equivalent load
of 2.4 million. The sewage is strong with a BODS concentration of 750 mg/1.
Over the entire period covered by the reports, sewer work involved primarily
cleaning and maintenance of sewers, manholes, screens, and pump stations.
About eighty permanently employed workers were classified as sewer workers
in 1976.
Mortality statistics show that sewer workers die earlier than Copenhagen males
of comparable age, many of them within the year that employment terminates.
Workers who have spent 1 to 8 years in sewer work in the 15-year study period
have a death rate indistinguishable from the city rate. For the next 8 years
of employment, the rate is more than twice that expected for all Copenhagen
males.
Attempts to correlate the statistics with sick leave records or chemicals in
the environment were not successful. Sewer workers experience a high
rate of gastrointestinal tract disorders which the workers associate with
chemical odors and infectious agents. Workers have elevated levels of gamma
globulins. Analytical work has not identified any agents that might
be responsible for the observed death rates or gastrointestinal problems.
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Health Risks of Human Exposure to Wastgwater 5/
This draft research report was ccmpiled by the Department of Environmental
Health and Medicine at the University of Cincinnati (U of C) Medical Center
to determine the health effects, if any, associated with occupational
exposure to biological agents present in municipal wastewater. An additional
objective was to determine the sensitivity of the methodology used for de-
tecting potential health impacts of other wastewater exposures, such as
recreational contact with surface water receiving wastewater effluents.
About one year after this research began, its goals were expanded to include
a determination of the health effects, if any, associated with the dispersion
of airborne bacteria and viruses generated by the activated sludge wastewater
treatment process.
In order to evaluate potential health effects, a sero-epidemiologic study
was conducted with municipal wastewater workers and controls in three
metropolitan areas: Cincinnati, Ohio; Chicago, Illinois; and Memphis,
Tennessee. The study consisted of four aspects: epidemiological,
environmental monitoring, clinical aspects, and a serological survey. The
epidemiological phase involved selection of study population, recruitment
of volunteers, collection of biological specimens for the serological and
clinical survey, collection of illness information, collection of demographic
and medical history information, and worker activity observations.
The environmental monitoring portion of the study consisted of determination
of airborne bacterial levels at worksite locations, and assay of wastewater
for viruses and bacteria.
The clinical aspects consisted of yearly multiphasic and physical examina-
tion of study volunteers, and analyses of throat and fecal specimens for
bacteria, viruses, and parasites. Parasitic examinations were performed only
during the early period of the study in Cincinnati. The multiphasic and
physical examinations served three purposes: (1) to evaluate whether waste-
water exposure affected certain tests of liver function; (2) to assess the
overall comparability of study populations; and (3) to provide motivation
for volunteers to participate in the study.
The core of the study involved an extensive serological survey to determine
levels of antibodies to a group of viruses and bacteria and to assess overall
inmunoglobulin levels. Of concern in the serologic survey was whether overall
concentration of antibody concentration was different among the various study
groups.
Possible correlations among results from the epidemiological, environmental,
clinical, and serological phases of the study were investigated to evaluate
potential health effects.
As initially conceived, the study was to include four groups of workers in
Cincinnati, Ohio. Each group was to be a minimum of 30 in number. Two of
the groups were to be routinely exposed to municipal wastewater: one group
for a minimum of two years, and the other just beginning such exposure. The
other two groups were to be engaged in an occupation not involving wastewater
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contact, and, again, one was to have been on the job for at least two years and
the other just employed. In Cincinnati, the occupational group thought to be
most exposed to wastewater was sewer maintenance workers, who were thus chosen
as the exposed population. These workers maintained the combined sanitary and
storm sewer system. Highway maintenance workers of the Cincinnati Public Works
Department were selected as the control group, since they were similar in age
and race to the sewer maintenance workers, and the types of jobs they had
were similar.
Because of a moratorium on hiring new employees in the Cincinnati Public
Works Department, prospects for establishing a newly employed highway mainte-
nance study group could not be obtained, and the group of 30 inexperienced
sewage-exposed workers was expanded to include newly-hired wastewater treat-
ment plant workers as well as the newly-hired sewer maintenance workers. The
study design was then expanded to include two additional exposed population
groups: fifty (50) men at the Cincinnati Mill Creek Sewage Treatment Plant,
which was in the process of being expanded from primary wastewater treatment
to include the activated sludge process; and a total of one hundred (100) men
employed at activated sludge treatment plants. The purpose of including this
group was to differentiate between aerosol exposure and exposure to wastewater
and sludge through those operations associated with primary wastewater treatment.
In all cities the wastewater-exposed workers recruited were generally outdoor
workers engaged in various operational aspects of wastewater treatment. In
Chicago the inexperienced wastewater treatment plant worker groups that were
recruited were laborers and security guards. Laborers and selected operating
personnel at the two Chicago water filtration plants were chosen for control
groups because they were more similar in age and race than Chicago street
maintenance workers. (The choice of a control group in Chicago was also
based in part on an interest in using a different occupational group than in
Cincinnati, where during the first year of the study the highway maintenance
group repeatedly had higher immunoglogulin levels than the sewer maintenance
group.) In Memphis neither highway maintenance nor water treatment plant
workers were similar in age and race to the newly hired wastewater treatment
plant workers. A suitable control group were located at the Gas Service
Center of the Memphis Light Gas and Water Division (MLG&W).
In each city, meetings were held with appropriate management and employee
representatives to explain the study and what was expected of participants.
The study was identified as the Public Works Employees Health Study. It
was stated that participation was voluntary and that all results would be
treated in a confidential manner.
At the time of joining the study, a family history questionnaire was
administered by a member of the research team. Questions included ones
relating to chronic health conditions and previous major health problems
of household members. In addition, at the time of the annual health
evaluation, a more detailed medical history questionnaire was given.
Permission to share study results with the participant's personal physi-
cian was obtained at the time of recruitment.
Demographic information collected on each worker included age, race, years
of school, job classification, salary, total household income, number of
persons dependent on family income, household size, and household composition
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broken down as to adults, school-age children, and other children.
The breakdown of household composition was primarily for the purpose of
examining the number of school-age children, as they are likely to be
a source of infection.
Each worker was generally visited on his job several times during the
study to determine type of job, frequency of wastewater contact and aerosol
exposure contact, and other related work conditions. Results of these
observations were used to categorize the worker on a relative exposure
1 scale for direct wastewater contact and one for aerosol exposure.
The environmental monitoring program consisted of viral and bacterial
analyses of wastewater samples and bacterial analyses of aerosols. The
purpose of the aerosol sampling procedure was to provide data for the esti-
mation of the worker exposure to airborne microorganisms. The viral analyses
of wastewater were used in deciding what viruses to test for in the house-
hold member serologic survey.
Six stage Andersen samplers were used to collect the aerosols at about ten
sites at each treatment plant studied. The Andersen samplers were fastened
to tripods about 4 feet high. For all aerosol samples, calibrated pumps
pulling 1 cfm were utilized. Each sampler was specially equipped with
six molded Andersen glass petri dishes containing 27 ml of plate count agar.
In order to process the aerosol samples as scon as possible, preparation
and analyses of the plates for bacterial aerosol sampling was performed
in Chicago by the MSDGC, in Memphis by the Memphis State University, and
by the bacteriologist on the study staff in Cincinnati. At least
once during the study, duplicate samples were collected in Memphis and
Chicago for analyses by University of Cincinnati personnel.
A portable weather station was used during periods of airborne bacterial
sampling. This station consisted of instruments for wind directions and
speed, temperature, relative humidity, and barometric pressure readings.
During the quarterly specimen collection periods, 45 ml of blood were col-
lected from each worker, in three 15 ml portions. After clotting at room
termperature, the tubes were centrifuged, and the serum placed in
labeled vials.
Viral isolation specimens were obtained from a throat swab collected by
a medical technician or nurse, and a rectal swab collected by the participant.
Bacterial isolation specimens were obtained by a second rectal swab, collected
by the participant at the same time as the first.
During the early portion of the study, before the aerosol-exposed worker
expansion, stool samples rather than rectal swabs were collected and were
analyzed for parasites in addition to viruses and bacteria. At the sama
time rectal swabs were substituted for stool specimens for virus isolation,
stool specimen collection was continued for new sewage-exposed workers in
Cincinnati. Urine specimens were also collected during the early portion of
the study and were used for isolation of cytomegalovirus. These collections
were discontinued because no such virus was isolated during the first
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study year, probably because this virus does not survive long in
the environment.
Single blood specimens were obtained from the household members of study
volunteers during late summer of 1978. These specimens were obtained at
various locations in the study cities, including in homes of the volunteers.
These specimens were collected for use in a limited serologic survey to
look for differences among study groups in household-member antibody
levels.
i
Illness information was obtained through monthly family health diaries,
telephone contacts, and on-the-job contacts. The objective was to contact
each worker at least once a month. At the time of worker absence, tele-
phone contact was made by a study nurse to determine if an infectious
disease existed. If appropriate, a home visit was attempted for specimen
collection. In order to facilitate a worker in contacting a member of
the research staff in the event of illness, or to ask a question about the
study, telephone answering systems consisting of tapes with remote re-
trieval capabilities were installed in all three cities. Illness symptom
information from all sources was categorized as "respiratory," "gastro-
intestinal," "other," and combinations of these.
During periods of illness, attempts were made to collect a throat or
rectal swab from the study volunteer. These specimens were generally ob-
tained in the worker's home, but on occasion were obtained at the office
of his physician or at work.
Annual health evaluations of study participants and viral and bacterial
isolations from biological specimens were the primary sources of clinical
data. Stool samples from some Cincinnati workers were examined in the
early portion of the study for the presence of ova and cysts of parasites.
Results of the serological survey of sera collected quarterly provides the
basic core of data for the study. The sera were analyzed for antibodies
to 33 viruses or groups of viruses, 10 bacteria, and 3 classes of immuno-
globulins. Their purpose was to determine: (a) whether there were differ-
ences in antibody levels between groups, and (b) whether there were
significant increases in antibody levels within a group of workers over
a period of time, indicating infection. The researchers also investi-
gated the relationships between an increased antibody level in a volunteer
and the presence of illness symptoms.
In an effort to determine if there were any relationships among various
types of data, several comparisons have been made among the many possible
ones:
I. Worker Exposure - Virus Serology Comparisons
Every study participant was ranked into one of two categories for
wastewater/sludge and airborne bacteria exposure: (1) above average,
or (2) average or below average. These rankings are in all cases
relative to fellow workers in the same worker group (i.e., experienced
sewer maintenance). Job observations and environmental monitoring
-30-
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data even made it possible to separate the control group into
"clean" and "less clean" working environmental groups. None of the
comparisons had a significant correlation.
1. Control Group Comparisons—
Using data from January 1978 and October 1978 from the final virus
serology survey, the control group in all three cities were com-
pared by exposure. One exposure category referred to airborne
exposure and the others to solids and dirty water.
2. Exposed Group Comparisons—
The inexperienced sewage-exposed group in each city was ranked
according to their direct contact with wastewater and sludge
regarding the airborne bacterial levels of their workplace air.
Prevalence levels and seroconversion rates were compared between
combined-city groups with above average exposure to these
conditions with those having average or below average exposure.
Results indicate that for only one comparison is the correlation
significant. For sera collected in January 1978, the workers
with average or below average wastewater/sludge contact had
more titre levels less than the detection limit for the test
than above average exposure workers.
3. Comparison of Above Average Sewage Exposed Group with Control Workers
in Cleaner-Than-Average Working Environments
The inexperienced sewage-exposed workers ranked above average in
wastewater/sludge or airborne bacteria exposure were compared with
control workers ranked average or below average in either liquid/
solids or contaminated air exposure. January 1978 and October 1978
virus serology data were used in making the comparisons. No statisti-
cally significant differences were detected.
II. Illness Rate - Antibody Level Change Comparison—
Four-fold or greater increases in titer level to a virus antibody is
generally regarded as a medically significant increase. Such occurrences
signify an infection which may be either clinical or subclinical.
The study did not reveal statistically significant increases in viral
infections that might be related to occupational exposure to wastewater,
as indicated by virus isolations, distribution of antibody titers
(comparative antibody levels), or increases in antibody titer levels,
either in individuals or among work groups in Chicago, Illinois,
or Memphis, Tennessee. In Cincinnati, Ohio, experienced sewer maintenance
workers had higher antibody levels to Poliovirus Type 2 in January
1977. This same group had statistically significant increases in
Echovirus Type 6 antibody levels from January-September 1977.
Based on the testing to date, there is no indication that occupational
exposure to sewage increased the risk of Hepatitis A or B infection
in study participants.
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Analyses of single blood specimens from family members of study partici-
pants for antibody to six viruses did not reveal higher infection rates
among families of exposed workers than controls.
No evidence was found to suggest that occupational exposure to waste-
water by the study participants produced any increase in bacterial
infection by Salmonella, Leptospira, and Legionella pneumophila.
Examination of biological specimens from workers for bacteria and
parasites did not reveal any increase in isolation rates among sewage-
exposed workers.
Iimunoglobulin (Ig&, IgG, IgM) levels were not found to be consistently
higher in the sewage-exposed workers in any of the cities studied.
Testing of liver function did not reveal any consistent abnormalities
in either the sewage-exposed groups or control groups.
Airborne bacterial levels, TVP's, inside buildings where wastewater
sludge was being processed, were higher than those at aeration basins.
TVP levels at some highway maintenance work areas are on occasion as
high as those at aeration basins of activated sludge sewage treatment
plants.
From preliminary analyses of illness rates, inexperienced workers
exposed to sewage had a higher rate of gastro-intestinal illnesses than
that of experienced sewage treatment plant workers.
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B. Evaluation of Alternatives:
The aerosol monitoring procedure, used in 4 of the other 5 studies,
represents the state of the art, since the LVAS's used offer increased
sensitivity over other available methods. These instruments sample
at 1000 liters/min
and to increase sensitivity for the viral runs, the Tigard, Oregon,
and Pleasanton, California, studies pooled samples from LVAS's running
simultaneously, resulting in sample volumes of 1,980,000 liters and
5,000,000 liters, respectively. The less sensitive Andersen samplers
used in the University of Cincinnati study were considered adequate,
since the microorganism aerosol concentrations at the treatment plant
site itself are of the magnitude where these samplers' sensitivity are
adequate to characterize the exposure levels present.
Since experience in monitoring wastewater aerosols at Pleasanton,
California, stowed that statistically usable biological analysis
results could be obtained only up to 200 m away from the aerosol
source during the day, and 400 m during the night, models were used
to predict concentration levels beyond these distances in Pleasanton,
California; Tigard, Oregon; and at the Egan WRP. Although the model
used required assumptions whose validity is uncertain, the predictions
of the model have been verified to 100 m for all three sites and
were considered satisfactory by the researchers. This model represents
the feasible limit of scientific capability for estimation of microorganism
aerosol concentration levels.
To detect possible health effects, all but the Tigard, Oregon study
utilized health surveys to record infectious diseases, symptoms,
and frequency. In addition to using clinical samples (collectively:
blood, feces, urine, sputum, throat swabs) analyzed for bacteria,
viruses, and parasites, the Egan WRP, the University of Illinois,
and the University of Cincinnati studies utilized a sensitive measure
of antibody titer to detect infection. Antibody titer can detect
subclinical infection which might not be detected through a health
survey or other clinical specimens.
The Egan WRP and University of Cincinnati studies were designed to
make pre- and post-exposure measures of health on the same partici-
pants and sampling area. This self-paired comparison of the results
is a very sensitive procedure for detecting changes because it elimi-
nates the inherent variability between human subjects and between
locations. This study design also eliminates the possibility of
acquired immunity masking potential health effects, since some
participants are newly exposed.
The Tigard, Oregon study utilized a variation of the very sensitive
pre- and post-exposure study design to evaluate health effects of
a potential high risk group with exposure as close as 40 m from
the aerated surge basin. Even though not all of the same students
were investigated in the pre/post-exposure phases of the study, the
potential variability created by this should be minimized through com-
parisons with data from the control schools.
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1b evaluate possible relationships between wastewater aerosol exposure
and health effects, rigid statistical procedures were used to analyze
the data. The epidemeologic study design used in the Egan WRP, University
of Illinois, and the University of Cincinnati studies was the most sensi-
tive that could be devised at the time for determining if any relationship
between wastewater aerosol exposure and health effects exists.
The Tigard, Oregon and the University of Michigan studies also utilized
health related data; however, these studies' measure of health and
'exposure, respectively, were not as sensitive as those mentioned above.
Nonetheless, these studies should have detected any statistically significant
relationship between exposure to wastewater aerosols and significant
adverse health effects, if present.
The researchers concluded that several pathogens (Klebsiella / My_cobac_teria,
and Staphylococcus) in wastewater are usually higher in concentration
than, and appear to have no relationship to, the concentration of indicator
organisms such as T.C. and F.C. Viable enterovirus were found in low
concentration in the primary effluent because they are primarily associated
with the solids fraction of the wastewater.
The University of Illinois study concluded that activated sludge wastewater
treatment plants are a source of low concentrations of bacteria, coliphage,
pathogenic bacteria, and enteroviruses, but are not a source of trace
metals, particulates and gasses.
The study conducted in Tigard, Oregon concluded aerosol concentration
levels tended to vary from one run to another due to variations of micro-
organisms levels in the wastewater. However, high and extremely variable
aerosol concentration levels were probably due to contamination of the
LVAS's. The University of Illinois study found no correlation
between the concentration of TVP or T.C. in aerosols and sewage character-
istics. However, the Tigard, Oregon and Pleasanton, California studies
concluded that the use of such indicator organisms as T,C. and coliphage
appear to be inadequate to characterize the pathogenicity of aerosols.
Microorganism aerosol concentration levels 70-100 m downwind of the
aeration basin at Tigard, Oregon were generally as high or higher than
levels of such indicator organisms as T.C. or coliphage. The Pleasanton,
California, study suggested some microorganisms (Coliphage, Clqstridium
perfringens, TVP) have a lower decay rate than T.C. and F.C.
The higher concentrations of substances detected close to the aeration
basins have been found to rapidly decrease in concentration with
distance away from the aeration basins. For example, the very sensi-
tive enterovirus monitoring conducted at Tigard, Oregon (referenced
above) detected no enterovirus at 30 m downwind of the aeration basins,
indicating a concentration less than 0.0009 pfu per m3. The study conducted
at the Egan WRP concluded that the levels of microbiological or chemical
agents of the air, soil, and water samples in the neighboring residential
areas were not distinguishable from background levels monitored.
It has been suggested that other factors also affect the microorganism
concentration levels detected. The Pleasanton, California study
suggested ambient conditions, such as low relative humidity, high wind
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velocity, and large temperature differentials between wastewater and
air, may reduce initial microorganism survival, and die-off may be more
rapid with high solar radiation and high temperature. In contrast,
the University of Illinois study found no relationship between TVP
or T.C. bacteria concentrations and ambient conditions. However,
as stated above, the use of such indicator organisms as T.C. appears
inadequate to characterize microorganism aerosol concentration, and
since the Pleasanton, California study used more sensitive sampling
techniques, it appears a relationship does exist between ambient
conditions and microorganisms survival in aerosols.
Several studies investigated microbiological aerosol particle size
distributions to determine if certain microorganisms contained in
the aerosols could be inhaled. The Egan WRP study and University of
Illinois study found the majority of the T.C. and TVP were in the
respirable range, but no clear trend for change of particle size
distribution with sampler distance could be detected. The Pleasanton,
California, study of aerosols from spray irrigation equipment did
detect a relationship between some microorganisms particle sizes and
distance; however, this relationship would not be expected to apply
to aerosols generated from aeration tanks.
The studies conclude that residential populations as close as 152 m
from the aeration basins at activated sludge wastewater treatment
plants have no significant adverse health effects from aerosols
emitted during plant operation. In addition, elementary school
children—a potential high risk group, appeared to have experienced no
health hazard from aerosol exposure as close as 40 m from the aerosol
source at an activated sludge wastewater treatment plant.
Some preliminary analysis of illness rates indicates i.hat inexperienced
sewage plant workers had a higher rate of gastro-intestinal illness
than experienced workers. Since these workers have exposure both
from direct contact and aorosols, the appropriateness of extrapolating
these findings to a population residing near a sewage treatment plant
remains to be determined.
The isolated instances associating wastewater exposure to health effects
could be due to chance, or a i3su.lt of biased responses to health
questionnaires, and are not consiJ^red significant when v;eighed
against the preponderance of evidence indicating no health hazard
from exposure to aerosols emanating from activated sludge waste-
water treatment plants. This is especially true if considering
nearby populations rathr-r than intensely exposed workers.
Despite the fact it could be argued that weaknesses in individual
studios may lower their sensitivity, if any health hazards result
from exposure to activate sludge wastewater treatment plant aerosols
some substantial indications of health effects should have been
discovered.
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The O'Hare site and the sites studied are similar in the following ways:
All the plants are activated sludge plants and received the following
quantities of primarily residential sewage during the study period:
Study Plants
Egan
Northside
W-SW
Calumet
Tigard
Memphis Max son
Memphis North
Cincinnati
O'Hare
Flow (mgd)
17
292
821
223
11
10-20
10-20
120
45
72
Influent Concentration (mg/1)
BODS SS
(initially)
(design yr
2000)
127
85
138
168
112-162
146
196
106
196
328
187-262
180
2. Ihe aeration tank design parameters are identical for all MSDGC plants
and are similar to the other plants studied. Each MSDGC plant is
constructed using diffused plate aerators with the air rate adjusted
to provide 2 mg/1 of oxygen in the tanks. Since the influent for
each MSDGC plant is similar to the other plants studied, the aeration
rates should be similar. Below are the surface areas of the aeration
tanks for selected plants:
Surface Area of Aeration Tanks (acres)
Egan 2.58
Northside 13.6
O'Hare (initially) 3.2
(design flow) 5.16
(other data not available)
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3. The various studies monitored the following microbial concentration
levels:
Study
Background
Concentration
(number/m3)
MEAN/PEAK
TW TC
MSDGC
-Northside 411/804 l.l/ -
-Egan 1153/3200 <.3/.3
-W-SW
-Calumet
-O'Hare
N/A N/A
N/A N/A
400/ - *20/ -
Distance of Closest
Population Exposed
(meters)
152
400
at aeration
basins
at aeration
basins
117
Concentration at
That Distance
(number/m3)
MEAN/PEAK
TVP
TC
354/513 12/ -
indistinguishable
from background
253/544 13/ -
292/906 4/ -
**425/850 *21.2/42.4
Tigard - <. 07/<. 07
Cincinnati N/A N/A
Memphis
-Max son
-North
N/A N/A
N/A N/A
30-50
at aeration
basins
at aeration
basins
at aeration
basins
— 5.8/11
812/2967 8/ -
583/1827 68/ -
735/3258 43/ -
*Based on assumption that TC would be 5% of TW.
**Estimated by a model, see response to comment 9.
Because of the similarities between the O'Hare plant and those studied,
similar increases in microbial concentrations are expected to occur due
to the plant. Since health hazards were not detected in the studies
of situations similar to O'Hare, no health hazard is expected from
operation of the O'Hare facility.
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One possible health effect was detected through the household health
survey for residents 400 m away from the Egan plant. The illnesses quoted
increased from 1.2 percent to 3.5 percent. Not mentioned were the number
of illnesses shown to decrease during the same period based on questionnaire
results. Examples are colds, fevers, and sore throats for the people
living close in. A more sensitive testing procedure, checking 31 viral
antibodies and attempted isolations of many pathogenic bacteria, parasites,
and viruses yielded no evidence of an adverse wastewater treatment plant
' effect. Therefore, the questionnaire results, by themselves, cannot
be considered evidence of a health hazard.
Another health effect detected was for inexperienced sewage treatment
plant works who had reported a higher rate of gastro-intestinal illnesses
when compared to experienced sewage treatment plant workers.
This effect was only a short-term effect and, as can be seen, these workers
are exposed to a much higher level of aerosols than the residents nearby
the study plants or the levels expected to occur nearby the O'Hare plant.
Furthermore, STP workers come in direct contact with sewage and therefore
have more pathways of infection than the nearby residents.
1. ACTION
a) Rescind the grant condition requiring MSDGC to construct
aerosol suppression facilities at the O'Hare WRP:
Testing of a thorough, critical, and sensitive nature, repre-
senting the feasible limit of scientific and economic capability,
have shown that no health hazards result from exposure to aerosols.
b) Modify the grant condition and allow operation of the O'Hare
WRP without aerosol suppression facilities, and continue
ongoing analysis of potential health effects.
i) If further study shows need for aerosol suppression:
Monetary, natural and depletable resources would be expanded
on further study and in the construction and opeeration of
aerosol suppression facilities. Other adverse impacts include
noise and dust associated with construction.
ii) Further study shows no need for aerosol suppression:
Beyond the expenditure of monetary resources to further study
the potential effects of aerosol exposure, no direct or in-
direct impacts will result from this action. Thorough research
has shown that no health hazards result from exposure to
aerosols emanating from activated sludge wastewater
-38-
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treatment processes within the envelope of accepted
U.S. design and operational practice.
2. NO ACTION
Retain the grant condition requiring MSDGC to complete construction of
aerosol suppression facilities at the O'Hare WRP prior to or concur-
rently with the commencement of functional operation:
Monetary, natural, and depletable resources would be -expended on the
construction and operation of aerosol suppression facilities. Other
adverse impacts include noise and dust associated with construction.
If operation of the O'Hare WRP would be delayed to construct aerosol
suppression facilities, the overloaded system presently used would cause
continued combined sewer overflows and flooding of basements with combined
sanitary and stormwater, thereby threatening public health.
V. PUBLIC PARTICIPATION
A Notice of Intent to prepare a Supplemental WRP EIS was issued on July 18,
1979. Copies of this Draft Supplemental EIS were available to the public
approximately 30 days prior to the October 29, 1979 Public Hearing.
Because of the response to the public hearing, the record remained open
until November 30, 1979 to allow further comment on matters brought up at
the public hearing.
A number of comments were received at the public hearing and in letters
sent directly to the USEPA. The public hearing comments are reproduced
directly from the hearing transcript, and the comment letters are repro-
duced and presented in chronological order. The numbers in the margins
of the transcript or the letters numerically identify the response to
those specific comments. These responses are listed and presented on
those pages immediately following the comments.
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A. COMMENTS AT THE PUBLIC HEARING T- OCTOBER 29, 1979
• MR, WARD: It has been a lot of years.
There are people in the audience that have been
working-with us for fourteen years now, and a lot
of familiar faces, and we are all getting a little
older and grayer. Welcome back.
In 1975, the U.S. EPA was confronted
40
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by five conflicting factors summarized in this
transparency. The public was demanding a more
remote site to agree-with the isolation distance
required by HUD and every other state in Region
V. The White House was pushing for jobs to
stimulate the economy and help in any reelection
attempt.
The U.S. EPA's regulations required
a decision by June 30, 1975 or the funds reserved
for Illinois would be reallocated to the other
states. And the scientific community was concerned
that there was no proof that the aerosols were
safe.
The EIS team selected the more remote
site, Option A. But Francis Mayo overruled them
because of factors B, C and D. And the rough
draft EIS was rewritten selecting the site adjacent
to our homes with no provisions to control the
aerosols.
Public hearing testimony and further
scientific input convinced Francis Mayo that aerosol
suppression was a necessary EIS and draft condition
because there was no proof that aerosols were safe.
41 '
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The appeal procedures to the
President's Council on Environmental Quality
was attempted in June of 1975, and the CEQ staff
expressed concern over several serious deficiencies
in the U.S. EPA's final EIS at our meeting in
Washington. The subsequent follow-up by Congress-
man Crane's office resulted in four phone calls
not being returned in one week during July.
The silence by the CEQ has never been explained.
The challenge .by Des Plaines in
the federal -court on the adequacy of the final
EIS was successfully defended by a legion of
federal and MSD attorneys. It was never explained
why there were so many missing and incomplete
answers to our several hundred questions in the
final EIS.
In 1975 we were concerned that the
unspecified "aerosol suppression" draft condition
•
was merely a legal defensive ploy. ' We possibly
were right.
A number of studies were quietly
begun without the knowledge of Des Plaines officials
to attempt to show that aerosol suppression was
42
-------
51
neither "cost effective" or necessary.
In the meantime, the project that
was supposed to be done, examining alternative
methods of suppressing the aerosols, was somehow
delayed.- The public, the federal courts, Des
Plaines officials and even apparently the Illinois
EPA have been misled by these Region V actions.
Let us now review the various
studies that have .been accomplished since 1975.
And we will examine them to determine if-,,-they
"'*--.
provide the. guarantees in the National Environ-
mental Policy Act that "assures for all Americans
safe, healthful, productive and aesthetically
and culturally pleasing surroundings." This
includes the several hundred persons living
adjacent to the O'Hare sewage plant.
We will 'examine these studies to
find any health data applicable to young children
*
and senior citizens with bedroom windows within
a hundred and fifty feet of several acres of
aeration tanks. And we will determine if the
focus is on the adverse conditions of high humidity,
mild wind, low ceilings and cold temperatures.
' 43
-------
39
I will begin with my .conclusions
that none of the studies meet any of the above
requirements. That is a sad status report and
so important of a subject after it had supposedly
been a high priority of U.S. EPA for eight years.
In 1971> Region V concluded the
Highland Park Clavey Road study with this recommenda-
tion, and I quote: "The water program office of
the U.S. Environmental Protection Agency is advised
to initiate a study under controlled conditions
to ascertain the possibility of airborne infections
from sewage treatment facilities,"
And Region V required the aeration
tanks and retention basins to be "covered to protect
the local residents from objectionable odors and
potential airborne infections," That was eight
years ago, in 1971.
Before we xget to a critical examina-
tion of each of the studies, let me explain to the
audience here this evening that- the U.S. Environmental
Protection Agency held a three.-day symposium on
wastewater aerosols and disease in Cincinnati,- Ohio
44
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18
on September 19, 20 and 21st, 1979.- If I had been
Invited to participate in the symposium, my presenta-
tion may have been viewed as biased or too
conserative.
However, an individual selected by
the U.S. EPA to deliver the final assessment at
the symposium should be listened to very carefully,
especially if that individual had a good objective
knowledge of the studies.
The man responsible for coordinating
all of the individual studies being discussed here
this evening is Mr. Leland McCabe, the Director
of the Field Studies Division of the U.S. EPA
Health Effects Research Labs. He helped to sum-
marize the recent three-day symposium on wastewater,
aerosols and disease.
I think it is important enough to
quote his entire presentation that I transcribed
from the recording of the meeting. He said,
"Henry Longest asked if the challenge was only
scientific, and I would have to answer, based on
what we have heard in the last two and a half days,
-------
18
that we do not have the scientific know-how to
address this 'problem of sewage treatment plant
aerosols.
We have spent somewhat over $3
million in the last several years, and we have to
conclude that we do not know how to measure what
has. to be measured. Considering the impact to
the agency, I think the research money has been
constructively spent. The effort has not been
excessive, certainly, and it has not been lucra-
tive. 'But* the research in many cases has not
produced very helpful answers.
Mr. Longest was apparently con-
cerned that our assessment would be made and
would increase the cost of sewage treatment.
I think if we made an assessment of what we have
heard the last two days, we could probably save
him quite a bit of money J.n his construction
•
grant program because, pretty obviously, there
is no hazard to sewage, and we could all probably
get by with cess-pools in our back yard.
And certainly, as our colleague
18
46
-------
5Z
IB
from Baylor has indicated, that in this case, the
sewage, the kids would be playing in would be from
our own family, and obviously that is not hazardous.
in order to say that the sewage treatment plants
are not a hazard to the neighbors, I think we have
to have an instrument that can measure somewhat
along the dose response curve where we do have an
effect, if there really is one.
" Midday addressed the problem when
talking about the pov;er of tests to detect a real
effect when one existed. We have applied inquiry
systems, serological epidemiology and infection
rates. These have all been used by some of these
studies of sewer workers or sewage treatment plant
workers, and we do not have a demonstrated effect,
except possibly the one that Scott indicated in new
workers.
I think we*have to 'have a method to
show we have ah effect in a micromized exposed
population before we can conclude that the exposure
is much lower in the neighborhoods. I think your
problem is the sample size. Each one has been too
18
-------
small and inadequate, I think we are going to
have to pool the results from several studies.
But this might not be too hopeful because Scott's
'study in Cincinnati did not even have much of a
difference and sometimes not even in the right
direction.
To think if you had more data, you
would be able to show that a small effect would be
significant. I don't know what we are to dol
I guess he studied every new worker when he came
to work. It is not a question of sampling even
the entire universe of workers. What else could
he do?
• ' We did have one paper that indicated
Dr. Rylander*s techniques and demonstrated effects,
I think we have to consider what he has been doing
compares with what we have been doing and how it
might fit together.
Some of us at least took some comfort,
Cecil obviously did not from the comments he asked;
that we had a worse case situation occur in Israel,
and we can extrapolate down from that situation.
48
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But we are told that probably was a fluke also,
and we really did not have a worse case situation.
The effect of the environment on
enteric diseases has certainly been measured by
others. We have just equated a series of studies
relating to the bacterial indicators in water
quality and gastrointestinal illnesses in swimmers,
Even as a child I.was able to show the effects of
herpes on: dysentery rates.
It is possible that it is something
than an adult is really not responsive to an in-
fection and may like measurable antibodies. Scott
would rather have to study a group of Cub Scouts
led by seven-year old den mother and measure
something as they go along and clean up the pol-
luted river bank. We just' somehow have to do
something that we can have a measurable effect
we can back off from.
The chemical epidemiologists seem
to have solved their problem pretty effectively
with just a few studies of infection curves.
They can measure them and all that is required is
49
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to keep the neighborhood below the TLB or maybe
to keep it below the background level. The concept
of getting a viable count below background should
also be considered in the microbiological sense,
but I'm not sure we know how to measure the viable
count in the proper way.
We obviously need to be measuring
something that relates to infectious dose. It is
possible that what we have referred to as aerosol
shock is really the reducing, the size of microbiology
from clumps" and maybe an aerosol made up of only
singles of microbiological entities and these
could be less than the infected dose. To get at
'thisX'we would, probably need some kind of an
animal model which was done by some of the
early work at the VA Hospital on airborne infections
in Baltimore. We may have to get at this problem
of'microbiological measuring of what is in the
air by some other means than just' straight plates
or cultures.
If vie have to study real susceptible
populations, we obviously have to involve children.
We're not going to get those in a sewage treatment
• 50
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33
t
53
plant with that type of exposure. The children
we studied in the Tigard, Oregon exposure situation
received the maximum- dose only one day per year
with infectious organisms, and that is not reflected
in their absentee rates.
DanTs paper that he.gave here was
much easier to understand for me than the report
that was turned in by the group. Obviously, the
time allotted here got it down so that it was a
little more understandable. Now, he did not
specifically talk about children, but he did
indicate that there was an adjustment, that there
were children involved in the study.
When he adjusted for all other
factors, he did not get an effect at the 600-meter
distance. And if you look at the tables in the
report, you get some hint that maybe that was a
component made up of children.
Now, there probably won't be enough
'children in there alone to get some significant
results." At this point there was a short garbled
section of recording. One sentence is missing.
3:
51
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"It would be something that we may want to get
more data on especially for the younger ages and
probably a separate grant ought to be submitted
"to study those few people that live at 2^00 meters
to try to explain how come they are different from
the rest of the city.
Don Johnson also reported the effect
on neighbors; that some infections were higher
after the start-up of the operation at the Egan
plant. Here the illness effect, looking at the
tab le in the report, looks like it might be
greater on children. I was not able to note any
difference on the infection rates as it related
to children, but of course that study is done.
But it might be fruitful to
follow another start-up of a sewage treatment
plant where we would concentrate our concern on
the children and not factor the adults against
the situation. If we were requested to continue
health effect studies, I think it would be well
also to do the type of research that was commented
on this morning because the challenge we got on
52
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18
the first morning was that it is terribly costly
to do anything about aerosols. And a-lso if you
are able to do anything about that, to insist on
that type of control, you have to have some un-
equivocal health effects data.
But, if the suppression can be
accomplished, at least costs, then I do not think
the health effects would have been so unequivocal.
From what we have heard, I think there seems to be
a little justification as far as expenditures for
aerosol suppression at this time, but I think the
planners of sewage treatment plants must continue
to be concerned with what can be done in a reason-
able way to minimize aerosols.
Here is obviously a case where the
answer is more than scientific. I am sure the
public must feel that their interests have been
considered and that something could be done within
reason to minimize the potential or imagined hazard.
That is what I want to say."
May I have Slide No. 2,,please.
Let us examine the North Side Study.
53
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There ar-e seven studies that we are going to be
going through this evening. This is the long
presentation; bear w.Ith me. There's a lot of meat
in It, I am only highlighting the things that
the U.S. EPA neglected to highlight.
Let us examine now the North Side
Study; it was conducted In Skokie, Illinois by
the University of Illinois Medical Center. I will
not repeat any of the information contained in the
draft Environmental Impact Statement, but I will
highlight only the areas critical to the study.
Again, let me thank Dr. carnow and
Dr, Northrop and their associates for advising
those-who will use their work that, "The overall
conclusion that this activated sludge treatment
plant had no obvious adverse health effects on
residents potentially exposed to aerosol emissions
must be tempered by the recognition that only a
very small number of people were exposed to the
hi-ghest pollution levels,
It Is also important to note that
this plant was not a source of high concentration
54
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of viable particles, gases or metals to the study
area." That last sentence requires the further
explanation that this plant may'not be representa-
tive of other plants where the emissions are con-
siderably higher.
Let us further examine the very
small number of people exposed to the highest pol-
lution levels by looking at the make-up of the
847 participants living within one-half mile of
the center of the plant.
Prom page 62 of the study we find
that 5.1 percent or only ^3 participants living
within one-half mile were under six years old, and
that represents the most susceptible group. And
of these 4 3 children, only 7.1 percent or three
have lived in the area for less than one year.
And we do not "know if these hypothetical three
children live in the homes six hundred feet from
V
the tanks or twenty-five hundred feet from the
tanks.
And, further, we do not know if
immunities are built up in less than one year.
-------
If it only takes four months, then pur sample size
is down to one child. If this child gets infected
by the plant emissions, then the infection rate is
one hundred percent of this-most susceptible group.
But this"one hundred percent rate would be lost if
mixed with the other 846 participants living less
than one-half mile.
This is certainly an illustration of
the 'inadequate sample size that Mr. McCabe was
referring to in Cincinnati'last month.
The North Side Report included each
of the air sampling results, and I attempted to
partially reconstruct the data to see if the
environmental monitoring had a logical trend.
from upwind to downwind.
Prom the transparency, we can see
the upwind average of 141 total viable particles
per cubic meter is increased to 376 as it moves
across the plant and then rapidly dies off until
only 181 are left at the one-half mile point and
155 at the one mile point.
I began to plot the individual runs
56
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of four samples per day, and you see here the first
twenty percent of the runs, the second page of five
and a half pages. I. ran out of time and space on
this particular plot, but youcan see that the—
you can see the irregular data on this first eleven
runs. Most of the upwind values actually decreased
after crossing the plant and the frequent irregulari-
ties continued to do odd things downwind. Apparently,
they just continued to take data until the averages
ended up where they wanted them.
The U.S. EPA's staff in Cincinnati
should reconstruct this data to see if the implica-
tions or conclusions are justified.
Let me depart frcm my written text
and further explain: The green dotted line is --
actually, the purple line is probably what you
expect for the aerosols to be. The background is
141; it moves, it does not change, of course, until
it hits the plant and then, the plant adds con-
siderably to the viable count. So, it gets up
to 376, drops off very rapidly. I do not know how
rapidly it drops off.
-------
Of course, the only data points we
have are at the plant and at the half-mile point,
but I presume from other literature that it drops
off approximately with that slope. From the upwind
point to the plant, all the individual samples
should logically increase. The background level,
of course, should be one thing, as you move across
the plant they should increase.
All the red lines you see between —
all the red lines you see between here and here
all go the -wrong direction. You can see they all
should be going up. Whatever value you have here
should remain somewhat consistent. As it hits the
plant, it should be added to, but it is not added
to; it ends up lower. We have more going the wrong
direction than we have going in the right direction,
and the sa
-------
So, these irregularities, I did
not have the time to continue with this plot and
continue the four and a half pages. I do not know
what I would have found.
But it appears to me that at least
this first month's effort they looked at it and
said, we cannot stay on this; we are going to keep
going until we get something we can use.
What they finally ended up with was
141, 376, 498 and 155, beautiful, logical. That
is what you would expect, but the underlying data
that goes into it is extremely irregular, and I
think it should be reexamined.
May I have the next slide, please?
It is a little premature, but that is fine, Rick.
This is still on the North Side Plant.
Robert Dean of Copenhagen commented
on the North Side Study. This is at the Cincinnati
*
meeting. "You can get a lot more statistical
Information if you use the law of normal statistics,"
he said. "The law of normal statistics would be
useful in estimating the power. How big a difference
would it have to be before you could see it at all?
59
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Then you could get a little better estimate of the
power of your system,"
Just last Wednesday In a phone con-
versation with Dr. Northrop of the University of
Illinois, we were talking about environmental mon-
itoring equipment that is available today. And he
said:
"The state of the art is so crude
that it is embarrassing." Later on .in the con-
versation he said, and I quote, "The newcomers
are the guinea pigs." And, unfortunately, all
the residents of the Devonshire and Einstein areas
will be the newcomers or the guinea pigs when the
O'Hare plant begins operation.
I have not met Dr. Northrop personally,
but I understand he may be in the audience this
evening, We both share the same objection to finding
answers to the health questions, and he may desire
V
to share his concerns with us later this evening.
Now, Rick,
Let us first — the Egan Plant Study,
let us examine now the Egan Plant Study to find what
60
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57
answers relate to the O'Hare question. Even before
the study was begun, you people In Cincinnati
searched the country for the best study site, a.
new plant being built near an existing population
center. The U.S. EPA could not find one candidate
throughout the country that fit that description.
THey couldnot find one candidate of a new sewage
treatment plant that was being built next to a
populated area.
Therefore, they had to settle on
Egan recognizing, and they recognized this in
writing in the work plan, that the obvious short-
coming, that no one lived within one-third mile
from the plant. -It was an ill-conceived study
and a waste of $280,000,but, more importantly,
time was lost in going through the motions of
doing something.
We do appreciate the professional
»
integrity of Dr. Johnson when he wrote into the
recommendations on page 11, and I quote: "Primary
negative findings were found.relative to adverse
health effects related to the transport of pathogenic
aerosols to exposed populations. These results
61
-------
should not be accepted as conclusive findings."
Another quote from the study reveals
that "The Household Health Survey indicated that
increased incidents of skin disease and the symptoms
of nausea, vomiting, general weaknesses, diarrhea
and pain in the chest on deep breathing occurred
close to the sewage treatment plant and predominantly
in the downwind direction after it was in operation."
You won't find that in that blue book you were
handed out this evening.
One of the study conclusions was
"Results for alpha and gamma hemolytic streptococci
isolations in the throat swabs for the subjects from
the Lexington Green Apartments provide some evidence
that the pattern may relate to exposure to the waste-
water treatment plant aerosols."
Another quote from the conclusions
is that, "The findings obtained in this study,
when considered overall, did not detect a public
health hazard for persons living beyond ^00 meters
from a well-operated wastewater treatment plant,"
But remember Dr. Johnson's caution
62
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that "These results should be accepted as conclu-
sive findings." The U.S. EPA must have overlooked
this advice when writing the draft EIS.
The study states on page 3 that it
is important to the general design to select a
new sewage plant. This is a quote. Sorber, et al,
suggested that treatment plant workers and nearby
residents of an older plant might not show health
effects from exposure to microbiological aerosols
because sporadic inhalation of low concentrations
of pathogens may confer a degree of immunity.
For an epidemiological investigation
of microbiological hazards to have the power to
identify any health hazards that are present,
newly exposed human subjects might be necessary.
With a new sewage treatment site, all the potential
participants are newly exposed. And, of course,
that would be the situation here at O'Hare, but we
*
are not willing to volunteer to be newly-exposed
participants.
[• Next slide, please.
Next, let us examine the Durham
-------
School study In Oregon. Page 2 of the study has
some critical remarks for the previous two studies^
Egan and North Side and I quote, "In general, both
studies found little evidence of detectable health
effects. This may be because both studies lacked
enough participants living very close to the source
of the aerosols who would have had' substantial
exposure from the aerosol. In the study by Johnson,
et al., the requirement for evaluating a new plant
necessitated examining an area that was sparsely
populated.
In the study by Carnow, et al.,
industries occupied much of the area near the
treatment plant, so that few residences were
located near the plant. That was the Skokie
North Side plant."
In the Durham Study, we solved the
problems of not having enough children and of not
•*
being close enough to the aerosol source, but this
study failed by using the 'insensitive measure of
school attendance to determine any adverse health
effects. If the attendance had gotten worse, the
64
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study could have concluded that the plant was. the
contributing factor. And we all rub .our hands here
in Des Plaines and say, "We finally have some good
.hard effort." •
If the attendance remained the same,
then the MSD would have rubbed their hands and then
the plant would have been judged not guilty, but
instead the attendance improved, so they had to
label that measure insensitive.
The analysis of class attendance
data did show some extended periods of elevated
absenteeism among first and second grade students
after operation of the sewage plant started, but
this trend also occurred in many of the base line
years. The study reveals that the students received
a peak dose only one school day a year.
The study concludes that the improve-
ment in attendance may ha^ve been due to a change
of principal when the plant began operation.
Next slide, please.
The next study we will examine was
conducted in Tecumseh, Michigan by the University
65
-------
of Michigan and IIT Research Institute.
The conclusions on page 2 indicated
that, "During the warmer seasons, some respiratory
illnesses within 600 meters, approximately 2000 feet
of the wastewater treatment plant, exceeded those
expected by twenty percent' and twenty-seven percent,
and some gastrointestinal illnesses exceeded those
expected by seventy-eight percent and fifty percent
when specified by income and education, respectively."
The conclusions also revealed that, '
"Higher rates of illness transmission in areas of
higher densities of lower socio-economic families
could have contributed to the findings." And I
might add that the higher illness rate could be
caused by the plant, although there seems to be
a reluctance by the research people to accept this
concept; -and, yet, when pressed f-e-r -an- an-swer, they
will admit that they do not have the dose response
information.
Next slide, please.
Now, let us examine the fifth study
of the seven studies we will look at this evening.
66
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The EIS devotes five pages to a review of this study
but carefully forgets to mention the last paragraph
of the executive summary which is the same as the
last conclusion, which is similar to the first
recommendation. If you have not read the basic
report which has not been distributed yet, then
this will be news to everyone except the Region V
people who apparently dread any reference to So.se
response.
"The overall conclusion of Phase II
of this program is that microbiological wastewater
aerosols are generated by spray irrigation do
survive aerosolization and can be transported to
nearby populations. The most reliable means of
reducing a potential health hazard from pathogenic
aerosols is by disinfecting the wastewater before
spraying. Until the necessary dose response rela-
tionships are developed, neither the level of
•%
aerosolized microorganisms that constitute a hazarc
nor the degree of required disinfection can be
specified,"
I agree with that conclusion, and I
67
-------
detest the apparent cover-up of that important
statement'. Instead, the EIS Is stuffed with useless
field material to make It appear very scientific
and thorough, but it is nothing more than a pure
and simple cover-up of essential information.
Let me give you an example of useless
field material: "This population is located in a
recently completed subdivision of Mission Drive.
, Mission Drive runs east and west, and the street
59 (
begins on Sunol Boulevard opposite the treatment
plant." So what? Is that really more important
than what was emitted?
Let us shift for a moment to some
comments made on this dose response subject by
Dr. Sorber who participated in both the Durham
School study and the Pleasant Town, California
study. These comments were also transcribed by
me from the recording of the Cincinnati symposium
on Wednesday, September 19, 1979.
Dr. Sorber of the University of Texas
shared with us in his introductory remarks : "The
potential for health effects of wastewater aerosols
68
-------
continue to be of some concern. This is based both
on the number of pathogens found' in"wastewater and
on still inadequate infections on minimal infectious
doses of those pathogens, particularly viruses."
Later on he said, and I quote: "As knowledge of
the concentration and extent of the transport of
these organisms has increased, greater emphasis
must now be placed on the more difficult question,
that being the level of risk associated with various
concentrations of these aerosols."
The fact is that — this is another
quote: "The fact is that considerable questions -
remain as to the level of risk to be associated
with microbiological aerosol from wastewater
operations in this country including spray irrigation.'
I thank you.
Next slide, please.
Our sixth study in the draft Environ-
*
mental Impact Statement is another very poor attempt
at hiding information. Region V of the U.S. EPA
is supposed to work for the public. If the individual
responsible for this emission'worked in private
-------
industry and withheld sensitive information from
the owner of that company, he or she would be fired,
but not in the federal bureaucracy.
Please, you won't find these quota-
tions in the biased EIS. These are found on page
7 of your document.
"In the report of medical consulta-
tions with sewer workers, the doctors concluded that
the working environment is responsible for a high
level of acute disorders of the gastrointestinal
tract."
In the report of clinical laboratory
analysis, "The only significant difference was an
elevated level of-gamma globulins among sewer workers
suggesting that they have had more infections than
the other groups."
Another auo_tation> "One can conclude
that workers who have spent more ,than eight years
t
in Copenhagen sewers have about twice the death
rate of all Copenhagen males.," That was withheld
from us.
Next slide, please.
' 70
-------
The last report this evening was
not available to us.
All we have is a six-page explanation
•in the draft EIS of what Region V was willing to
share with the public. This evening we are making
our request again at this time under the Freedom
of Information Act which requires the federal govern-
ment to provide a copy within ten days, and I give
that to you now before I forget.
The EIS does give a general hint
of a problem in the last sentence of the six pages,
in the last sentence of the six pages, "From
preliminary analysis of illness rates, inexperienced
5Z
workers 'exposed to sewage had a higher rate of
gastrointestinal illnesses than experienced sewage
treatment plant workers." That is all they say
about it.
Please remember, too, that 'even
though these workers are nearer to the aerosols
than adjacent residents, they only work there
forty hours out of every hundred and sixty-eight
hour week. They are also generally working age
71
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males, and there are no young children or senior
SO
citizens in their ranks.
The audience is very patient with the
review of the seven studies and my presentation
leads to considerably different conclusions than
the whitewash in the draft EIS. You can turn it
off, please.
I have not mentioned the word odors
this evening until now because I believe that the
MSD can control them with their operational pro-
cedures. If the MSD gets lax and/or tries to save
too much money by reducing the prechlorination,
then I am confident that the many odor cases that
have been ruled on by the Illinois Pollution Control
Board will provide very effective legal remedy.
We can ensure that the Illinois Pollution Control
Board will rule- favorably in our tomplarirrt by
independently — I ask that each of you to do
this, by independently keeping your own records
on your own calendar and do not compare with your
neighbors. Keep your own records. Also recording
your odor complaints with the Des Plaines Environmental
72
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Officer who is here this evening. You want to
raise your hand, Bill? This will add to our case.
And the case history has recognized
that only we can determine if MSD odors are denying
the full- enjoyment of our property. The MSD
judgment has very little weight in our odor complaints.
Now, what are we looking for?
Obviously, you are not capable of moving to a
more remote location. Ue have shown here this
evening that we know you did not have the necessary
dose response data. VJe know that.
We know you are anxious to start
operating your plant, and we expect some temporary
On
cu aeration tank covers channeling the air through a
simple mechanical filter.
If further studies clearly indicate
no health problem, then dismantle the temporary
covers and the expense will be minimal.
»
.If further studies.reveal a health
problem, then replace the temporary covers with
permanent covers and install'whatever type of air
purification equipment that will always keep the
73
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Mr. McCabe's statement, ninety-five' percent. Why
couldn't Mr. McCabe, the man who is responsible
for these studies, communicate these findings to
. Region V EIS staff that concluded the studies and
answered all the questions, and the aerosol suppressio:
requirements should be eliminated.
The U.S. EPA cannot' be construed
\
to- be unbiased because they are a very involved
participant. They have limited funds to solve
poorly defined viater pollution problems, and the
aerosol question just adds uncertainty to'the
relatively easy water decisions. They know they
must eventually determine the infectious dose,
but this O'Hare situation gave them an uncomfortable
deadline. So, they chase after some average situa-
-tions, average situation answers that hopefully
would satisfy the O'Hare residents.
• ' • • Then the U.S.' EPA could begin
^
operation of the O'Hare plant and resume the quest
for some answers without the O'Hare deadline giving
them problems. But we are putting the U.S. EPA
on notice this evening that we will not accept
74
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62
t
aerosols below the dose response of our most
sensitive residents. What we expect need not
be costly. Sears sells a heavy-weight fiberglass
panel, a corrugated panel ten foot by forty inches
for $21. The MSD has the capability of installing
temporary covers of this type in less than five
weeks if the U.S, EPA makes this a high priority
project.
The U.S. EPA has come here this
evening to explain what their studies have
revealed. I listened intently fo.r the rest of
the story of what answers they do not have, but
there was very few explanations on what they
don't" know. By this lack of explanation, the
..'<--.. . ., \ • • • ..
U,S, EPA has clearly demonstrated to us their
lack of objectivity. It should not be my responsi-
bility to point out the unanswered questions.
The U.S. >EPA was formed in 1969 to
protect the public from pollution. They are
supposed to work for us and no-t be an advocate
for chronic air odors such as sewage plants.
In retrospect, I agree a hundred percent with
75
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half answers or volunteer to be the next group of
guinea pigs next to a new air pollution generator.
V/e want the air we breathe to be' as clean as the
.water we drink and the food we eat. V/e feel that
the National Environmental Policy Act of 1969
guarantees us no less.
V/e beg, we warn you not to degrade
our air without knowing how many of us will be
infected. V/e cannot tolerate the undefined
word "insignificant." Give us an estimate; tell
us what your best scientific guess is, but don't
hide behind that word "insignificant" and turn a
handle on the valve that will degrade the air we
breathe.
. Your job is hard. Mine is easier
to criticize your work effort but, really, the
U.S. EPA should be representing tiie people here
this evening. V/e were asking questions and identify-
ing potential, problem areas for several years before
the U.S. EPA or the I-EPA existed. V/hen they were
founded, we were relieved that now some agency
was going to protect our environment. But we
76
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were wrong.
The U,S, EPA and I-EPA have proved
to be no match for the MSD, I thank you.
MR, WOJCIK: Roger Spencer. Are you here?-
Mr, Spencer?
Myrtle Clamer?
MS, CLAMER: I forgot my question.
MR. WOJCIK: Dorothy, Mae Ingram?
MS, INGRAM: I did not say I would make a
statement, but I would like to know, we who live
just, say, about a block or so away from here on
Oakton on Route 83, we are not mentioned. And when
you did start that with the dynamite and everything,
you ruined wells on Oakton Street.
Nov.', what are we to do? I mean,
if that is the case that the bacteria will be so
close, what would we do for our health?
MR. WOJCIK: Is that a comment? We can address
that; we will address that question in the final --
I do not know,
MS, INGRAM: Somebody approached us from the
Environmental to put a black box in my driveway
77
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and monitor, you know, what the pollution count
could be there, the aerosols would be in there.
What the pollution count could be there, the
aerosols would be there. But so far nobody cone.
But the man have come to the house, and I have
got his card at home,
MR, VJOJCIK: Okay. I am sur;e that is part
of some study that you know we are involved in.
So, I'm sure someone was monitoring that. They
won't put it out.
A VOICE: You mean there are questions and
no answers?
MR. WOJCIK: All the questions and comments
at the hearing will be addressed in the final EIS,
They all will be answered.
MR, DEVOREK: My name is Donald Devorek, I
live at 1101 Hewitt Drive. I have lived there for
the last thirteen years. I am currently and have
*
been president of the Wasserman Park Homeowners
Association for the last nine years. However,
my remarks tonight are my own view, although I
believe they reflect the consensus of the area
residents.
78
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What concerns me most Is that the
bacteria that will be emitting from aeration basins
cannot be seen or touched by the average citizens.
•Therefore, we are at the mercy of those who are
operating the plant. 'Is this situation much dif-
ferent than radiation from a nuclear power plant?
Do we have to worry?
Prom the EPA's draft report which
I have for about a month, page 8, the results on
the health implications for the John Egan, Salt
Creek Water Reclamation Plant says, "The study
concluded that the Egan Plant appears to be a
source of indicator bacteria."
Of course', the end conclusion of
this report states that the overall, the bacteria
"is of little practical health concern." If
this is true, then why should I -foorry?
Well, a few years ago, we were
f
advised to spray asbestos on the ceilings of our
schools to protect our students. Today we know
that this has caused cancer in our children. We
used hairsprays for many years, now the FDA has
79
-------
banned the propellant because of danger to upper
atmosphere. Isn't it better to be safe than sorry?
This plant has been planned for
before 1964. Isn't it better to wait just a few
more months and install the aerosol tank covers?
We waited over fifteen years already. If the FDA
feels it should ban saccharine in'soft drinks even
though you would have to drink a huge volume every-
day for years on end to even compare to the amount
administered to a test rat to cause cancer, don't
we, the citizens whc live in a potential dangerous
area have similar rights?
In conclusion, I doubt very much
that _an.y of the information presented tonight will
have any effect. The MSB plans to start operating
its plant in a few short weeks. This hearing is
being held onl-y because it was required by law.
Five years ago I testified before
*
the EPA pertaining to building this plant. I
prepared this lengthy report; in it from the MSD's
own research from outsi.de services it was shown
that it was more economical to have one plant, to
80
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build and to operate it and that plant was the John
Egan Plant. But the die had already been cast. The
federal government had to release the funds by the
end of the year or they would be lost for that year.
So, naturally the federal government employees who
did not want to lower their spending power in future
years chose to spend our taxes rather than making
an intelligent decision. The government's
credibility is at an all-time low. -I hope it does
not slip lower tonight.
MR, MIRRIAM: My name is Gerald Mirriam, and
I live at 431 Dover Drive in Des Plaines. And I
have lived there for the last twelve years. And
I come here with no real' prepared statement except
that of a concerned neighbor.
I haveknown a lot of you folks for
a good many ye-ars, and I have seen the draft of
this thing drawn with concern against what I figure
«
is our rights for a fair and just environment.
All I have to say is, I would like these people to
concern themselves with the health and welfare of
the community, the people who live in it and the
81
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201
children that gets it, inherits it. Thank you,
my fellow neighbors.
MR. WOJCIK: Robert Satnaggari.
MR. SATNAGGARI: I support what Mr. Ward
has said.
MR. WOJCIK: Those are all the people who
indicated they wished to make a statement tonight,
Is. there anyone else who cares to?
MR. LINDAHL: I am Phil Lindahl. I am the
environmental officer for the City of Des Plaines,
The concerns of the residents from
Des Plaines, Illinois have made it necessary for
the U.S. EPA to enlist the help of experts in the
field of viable microbial aerosols to research
their fields of endeavor to attempt to determine
the health effects of building a sanitary sewage
treatment plani- with the edge of the aeration
basin a short distance from the porches of a row
*
of homes that have -been in existence for forty to
fifty years or more.
As a result of these studies, the
U.S. EPA conducted this symposium on water waste
82
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aerosols and disease In Cincinnati, Ohio September
1.9 through the 21st, 1979* Almost every one of the
authors of the various studies that were reported
at this symposium said that their conclusions were
that more research is 'needed to arrive at a positive
proof that a sanitary sewer treatment plant emitting
aerosols would not be harmful to those living in close
proximity of such a plant.
H. L. Longest, associate deputy
assistant administrator for water program operations
for the U.S. EPA in Washington, set the keynote of
the symposium by challenging the scientific com-
munity to conduct studies to determine the health
effects, if any, -of water waste aerosols.
Nothing has been said about those
times when a massive dose of virus or bacteria
might be present rather than tjie few parts per
million or the case in Tigard, Oregon where peak
\
doses of exposure to schoolchildren occur about
one school day per year,
If you take the case of two waiting
rooms, one a lawyer's office and the other at a
83
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pediatrician's office with the same, number of
persons, in each waiting room and the same age
and sex distribution, the lawyer's office waiting
room will be the more healthy place to be, for many
of the pediatrician's office waiting room are
germ carriers or they would not be- there.
A sanitary sewer treating plant is
Just the type of operation where the worst combina-
tion of viable microbial aerosols are just waiting
to happen to those living in close proximity to
the plant.
Conclusions drawn from the papers
given at the wastewater aerosol and disease are
attached.
These conclusions are one, meaning-
ful data interpretation may require consideration
of basic neurological meteorological parameters
as well as the limitations" of methodologies employed,
-. . Two, sampling procedures suitable for
detecting high microbial aerosol concentrations may
not be applicable when very low microbial aerosol
levels are anticipated.
84
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Three, Identification of appropriate
organisms and sampling methods needs to be super-
imposed upon the demographic and socio-economic
nature of a community and meteorological conditions
to obtain a realistic 'evaluation.
Four, chrbnic exposure of wastewater
treating plant and sewer workers deserve continuing
evaluation.
Five, aerosols may not be a very
efficient means of disseminating wastewater-borne
pathogens. However, before it can be proven that
aerosols do not transmit pathogens, more study than
that which has been presented at this symposium
must be made.
Six, future studies "should incorporate
a more precise determination of the exposure situa-
tion and additional clinical tests.
Seven, study population sample size
availability often is the limiting factor in the
design and conduct of epidemlological studies.
Eight, data suggests that the higher
illness rates may be related to higher densities of
85
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lower socio-economic families rather than the waste-
water treatment plant.
Nine, overall findings did not detect
a significant health hazard for persons livi'ng beyond
2.1 400 meters, but what about those persons living 400
feet from the wastewater treatment plant?
Ten, school attendance is a very
Insensitive measure of health effects from sanitary
sewer wastewater treating plants.
Thank you for the opportunity to
present these conclusions.
MR. WOJCIK: George Egan?
MR. EGAN: Good evening. Overall findings
did not attack the significant health hazards for
persons living beyond 400 meters according to the
data I received. But what about those persons living
400 feet from t-he wastewater treatment plant?
Aerosol basins of the treating plant
within 385 feet from the front doors of residents
living on the north side of Oakton Street in Des
Plaines? Identification of appropriate organisms
and sample methods need to be Imposed to obtain a
86
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realistic evaluation of present conditions.
Future studies should incorporate in
more precise determinations of the exposure situation
and additional clinical tests need to be taken.
It has been pointed out tonight that
the methodologies used have been placed in question
which bring about limitations to these studies which
questions the validity of the findings. What is
needed is meaningful data so that a sound decision
can be made which will not-jeopardize your health
or the thousands of people living around the plant,
not only in the 8th Ward.
The City of Des Plaines, Elk Grove,
Mount Prospect, or unincorporated Elk Grove. If
this plant is going to jeopardize thousandsof lives,
I think the question should be raised on a Council
floor to stop the opening of this~planT until the
aerosol suppression devices are in,place. Thank
you.
MR, WOJCIK: Is there anyone else who wished
to make a statement?
A VOICE: When I first came in, I asked if
87
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there were going to be questions and answers. It
was indicated to me there were. I take it there
are not?
MR, WOJCIK: In a sense, we will respond to
your questions on the.final EIS. And if you have
a question to ask, feel free to ask it.
MR, WARD: If you'd like to stay afterwards,
I will answer your questions, I will be perfectly
willing to do it after the meeting. I will answer
your questions.
MR. RATCLIFF: My name is Bill Ratcliff. I
live at 136 West Dover Drive. I do not have any
prepared statement because I came here primarily
because I thought there .would be some questions
and answers, but since there won't be any questions
answered, I would like to make a few comments
here,
First of all, I kind of question
whether studying sewage workers is a valid step.
The reason why I question this is, I work in an
industry which used platinum salts, and just about
everyone is allergic to platinum salts. It is just
88
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a matter of how allergic is he.
Well, what you have is a situation
with so.rt of self get rid of those individuals that
are allergic. The person allergic leaves. So, if
you've got an old person in that type of situation,
the person who is allergic is not around, and I
do not know if that is true in sewage treatment
workers or not, but it might be suspect.
Another thing that bothered me on
page 4 of this draft, there is a list of seven
articles upon which this draft is based, and I
was not able to obtain them thus far, not all of
them. This bothers me, and I object to the fact
that I cannot review the articles upon which a
draft is based.
I personally believe that this
draft or -th-e final d:c.aft ahoul-d -tre iie-td- tmtil— the
i
public has a chance to review every cotton-picking
piece of paper upon which a draft.is based. Now,
also within this draft there is an indication that
• * «
the EPA is not too confident- in their own work and
the fact that there is an indication that there is
89
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biases and.inconclusive -- I'm trying to look for
that right offhand. Somewhere in here it says
some of the data should not be considered because
the public w.oul'd be biased on a question. This
was going around and questioning that there were
field or not.
Well, when you go to a questionnaire,
there is three ways of bias, one is how the
questionnaire is prepared, and I am not an expert
in that. Another one is who analyzes the information
then finally is who prepared the report.
I respectfully request- that a resume
be incorporated into the final draft of the
individual who has prepared this report, and it
should include his age? his education and previous
experience. I thank you,
MR. WOJC-±K: Would you give us your address,
and we will give you a copy of the report mentioned.
Any-one else would like to make a
statement? If not, I would like to remind you we
will still be receiving .written comments on the
draft EIS until November 12th. We will be responding
90
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to all the comments made tonight arid all written
comments in the final EIS, and if you would like
a copy of that, make sure we have your name and
address. Yes, sir?
MR. MURPHY: I did not come prepared for
a statement, but my name is Pete Murphy, and I
am commissioner for the Mount Prospect Park District,
and I am newly elected commissioner. And from what
I understand, the MSD is also going to donate the
land as a park area, and of course, the reason I an
here is I am going to be asked to vote and accept
this land for the people in the area to lay on.
, I woulk make -- I do not want to
sit here and let the question go unanswered. We
I
are thinking of putting a potential park in that
area. I would like to have some answers as to the
safety and validity of having a park in this area
. so that I can make a constructive conclusion from your
report.
91
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B. WRITTEN COMMENTS RECEIVED
Illinois
Department of Conservation
life and land together
605 WM. G. STRATTON BUILDING »400 SOUTH SPRING STREET -SPRINGFIELD 62706
CHICAGO OFFICE - ROOM 100, 160 NO. LASALLE 60601
David Kenney, Director * James C. Helfrich, Assistant Director
September 28, 1979
Mr. Gene Wojcik
EPA, Region 5
230 South Dearborn Street
Chicago, IL 60604
Dear Mr. Wojcik:
RE: DEIS on O'Hare Water
Reclamation Plant at
Elmhurst & Oakton Roads
in Des Plaines, Cook County
This letter is to inform you that we have reviewed the
specifications of your project mentioned above.
Our review of the records indicates that your project will
'have no effect on historic, architectural or archaeological
sites in the area,
This letter of clearance relates only to cultural consid-
erations and should not be viewed as a blanket write-off which
would include natural areas or other concerns of the Department
of Conservation.
If you have further questions
contact me.
this » please
Sincerely,
DK/LSA
//f
cf f I ~C^y^^f-^-^^t,f
David Kenney ' -»^
State Historic Pre«ervatiotv-v
Officer H
PO
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92
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United States
Department of
Agriculture
Soil
Conservation
Service
P. 0. BOX 678
Champaign, IL
61820
October 16, 1979
Mr. Valdas V. Adamkus
Acting Regional Administrator
U.S. Environmental Protection Agency
Region V
230 South Dearborn
Chicago, IL 60604
Dear Mr. Adamkus:
We have reviewed the Draft Supplemental Environmental Impact Statement
regarding O'Hare Water Reclamation Plant.
We have no comments.
Sincerely,
Warren J. Fitzgerald
State Conservationist
H
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CO
CD
C~3 T-«
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CD
93
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Elk
Grove
Villa
Village President
CHARLES J. ZETTEK
Village Clerk
FAY M. BISHOP
Village Manager
CHARLES A. WII.US
Village
LEE D. GARR
EDWARD R. HAUSEB
JAMES P. PETR1
THEODORE J. STADr
MICHAEL A. TOSTO
NANCY L. VAXDhRV
October 19. 1979::,
Mr. Gene Wojcik, Chief
EIS Section, Region V
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Wojcik:
n
^•j
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-------
Mr. Wojcik
- 2 -
October 19, 1979
your consideration of our position on this matter would be
appreciated. Thank you for this opportunity to share our thoughts and
recommendations with you.
Sincerely,
Charles J/.
Village President
CJZ:ms
c: Board of Trustees
Village Manager
Nicholas J. Me las, President
Metropolitan Sanitary District
of Greater Chicago
95
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NICHOLAS J. MELAS
PRESIDENT
-___/11 f-r, r,T; r»
^^Ifil'ljhill
>IETKOB»O],9TAIV SAKITAKY UISTUICT
.! IT Hi ''«MK GiiK
I ! L ---- ' ..
CIIICAUO
BOARD OF COMMISSIONS!
JOANNE H. ALTER
THOMAS S. FULLER
EDWARD W. GJERTS:
WILLIAM A..
NELLIE L. JONES
JAMES C. KIRIE
100 EASTJERIE ST. ; CHICAGO.j lUUINOIS 6O6 1 t( ^.j ]! 7J5l-j56pO CHESTER P. MAJEWS'
,'-'r.~,<-' '~Jr ' !J '—"^-- LJ L_: _^j LZ, I^TJ Lzi L J i_J Lz^ LL id L J irs • M-^-ii NICHOLAS J. MELAS
Hugh H. McMillan
General Superintendent
751-5722
RICHARD J.TROY
October 23, 1979
.-U
~n
Mr. Gene Wojcik
Chief, EIS Section
Environmental Engineering Branch
United States Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
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Subject: Supplemental Draft Environmental Impact Statement
Metropolitan Sanitary District of Greater Chicago
O'Hare Water Reclamation Plant, September, 1979
Dear Mr. Wojcik:
The Metropolitan Sanitary District of Greater Chicago
(District) has received the Supplemental Draft Environmental
Impact Statement (EIS) for the O'Hare Water Reclamation Plant
dated September, 1979. As noted on pages 37 and 38 of the
draft EIS, certain governmental agencies, including the District,
were requested to comment. The District through this letter
will therefore present its position regarding the draft EIS.
The draft EIS contains a brief but complete literature
survey, reviewing the studies which, have boon concluded since
19_75, regarding the health significance of aerosols emitted from
sewage treatment operations, including activated sludge aeration
tanks. These studies, as pointed out in the draft EIS, were
funded by the United States Environmental Protection Agency (EPA)
because of its concern about the effect of sewage treatment plant-
operations on the surrounding community.
Results of studies conducted 'by Dr. Robert Northrop of the
University of Illinois Medical Center (U. of I.) on operations
of the District's North Side Sewage Treatment Plant were presented,
The eight-month environmental health survey conducted by the
U. of I. shows that the District's North Side plant had no effect
upon the health of the surrounding community.
96
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-Mr. Gene Wojcik
USEPA - Chicago, Illinois
October 23, 1979
In a study conducted on the effects of the, operation of the
District's Egan plant, the Southwest Research Institute (SwRl)
concluded that the levels of microbiological and chemical agents
of the air, soil and water in nearby residential areas were
indistinguishable from background levels. Based upon this data,
and an environmental health survey of nearby residents, SwRI
concluded that there was no health hazard for people living
outside the property line of the Egan plant.
Studies conducted by the University of Michigan and the
-Illinois Institute of Technology Research Institute on the
Tecumseh, Michigan Wastewater Treatment Plant led to conclusions
similar to those mentioned previously; namely, the wastewater
treatment plant operations had no effect on the health of citizens
in the surrounding community.
Results of studies conducted by SwRI at a wastewater treat-
ment plant in Durham, North Carolina, involving measuring the
microbiological emissions from a treatment plant, and a health
survey of a nearby school were also presented. These studies
failed to show any connection between the presence of the plant
and the health of the students in the school.
The draft EIS also discusses studies of the health of
sewage treatment workers. Studies noted were those conducted by
the University .of Cincinnati Medical Center. These studies, in
general, do not indicate any significant adverse effect upon
those who work closest to the supposed health risk. They serve
to reinforce the conclusions reached by investigators who have
studied the health of nearby residents.
From the preparation of the Environmental Assessment for
the O'Hare plant, to date, the District has consistently taken
the position that there is no demonstrable adverse effect of
sewage treatment aerosols upon the health of nearby residents.
We recognize, however, that 'the data collected since 1975 is
much more definitive than that gathered previously, and welcome
the update presented in the draft EIS.
97
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-3-
Mr. Gene Wojcik
USEPA .- Chicago, Illinois
October 23, 1979
19
We fully agree with the conclusions of the draft EIS.
Since the studies conducted show that there is no health hazard
associated with sewage treatment plant aerosols, we see no
reason to require the installation of devices to suppress aerosols
•from the O'Hare plant. We, therefore, ask that the draft EIS be
finalized; and its conclusions be implemented. We have no
additions or corrections to the draft -EIS.
The District appreciates the opportunity to submit comments
on this Supplemental Draft EIS.
Very truly yours,
ugh H. McMillan
General Superintendent
HHM:CLH:DRZ:RL:r
93
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THE CITY OF DES PL.A1PV
MINER STREET
October 26, 1979
DES PLAINES, ILLINOiS 6OO16
Mr. John McGuire, Administrator
U.S. EPA Region V .
230$. Dearborn. St.
Chicago, Illinois 60604
Dear Mr. McGuire:
Re: -Environmental Impact Statement
O'Hare Water Reclaimation Plant
Des Plaines, Illinois
33
The repeated concerns from residents of Des Plaines, Illinois made it necessary
for the U. S. EPA to enlist the help of the experts in the field of viable micro
bial aerosols to research their fields of endeavor to attempt to determine the h
effects of building a sanitary sewer treating plant with the edge of the aeratio
basin a short distance from the front porches of a row of homes that have been i
existance for forty to fifty years or more.
As a result of these studies the U.S. EPA conducted a symposium on "Wastewater
Aerosols and Disease" in Cincinnati, Ohio September 19 - 21, 1979. Almost every
one of the authors of the various studies that were reported at this symposium
said that their conclusions were that more research is needed to arrive at a pos
proof that a sanitary sewer treating plant emitting aerosols would not be harmfu
to those living in close proximity of such a plant.
H. L. Longest, Associate Deputy Assistant Administrator for Water Program Operat.
for the U. S. EPA in Washington set the keynote of the Symposium by challenging
the scientific community to conduct studies to determine the health effects, if
any, of waste water aerosols.
Nothing has been said about those times when a massive dose of virus or bacteria
might be present rather than the few parts per million or the case in Tigard, On
where peak doses of exposure to school children occur about one school day per
school year.
If you take the case of two waiting rooms, one a lawyer's office, and the other ;
a pediatrician's office with the same number of persons in each waiting room and
same age and sex distribution, the lawyer's office waiting room will be the more
healthy place to be, for many in the pediatrician's office waiting room are "gerr
carriers" or they would not be there.
A sanitary sewer treating plant is just the type of operation where the worst co;i
bination of viable microbial aerosols are just waiting to happen to those living
close proximity to the plant.
Conclusions drawn from papers given at the "Wasteva-ter Aerosol xtid Disease'^are
attached. / sy ' // •
/•^y y/ ^-> *—'"'
99 / SjiAM/f' CX-
_./ • y
Philip Liddahl, P. E.
-------
66
67
Conclusions: '- .
'Meaningful data interpretation may require consideration of basic meteorological
parameters as well as the limitations of methodologies employed.
Sampling procedures suitable for detecting high microbial aerosol concentrations
may not be applicable when very low microbial aerosol levels are anticipated.
1
Identification of appropriate organisms and sampling methods needs to be super-
imposed upon, the demographic and socioeconomic nature of a community and metrologic
conditions to obtain a realistic evaluation.
Chronic exposure of waste water treating plant and sewer workers deserves continuin
evaluation.
Aerosols may not be a very efficient means for disseminating waste water borne
pathogens. However, before it can be proven that aerosols do not transmit
pathogens, more study than that which has been presented at this symposium must
be made.
Future studies should incorporate a more precise determination of the exposure
situation and additional clinical tests.
Study population sample size availability often is the limiting factor in the
design -and conduct of epidemiological studies.
Data suggest that the higher illness rates may be related to higher densities of
lower socioeconomic families rather than to the wastewater treatment plant.
Overall findings did not detect a significant health hazard for persons living
beyond 400 meters, but what about those persons living 400 feet from the waste
water treatment plant?
School attendance is a very insensitive measure of health effects from sanitary
sewer waste water treating plants.
6'
Philip L^dahl, P. E.
Environmental Control
-------
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
REGION 5
182O9 DIXIE HIGHWAY
HOMEWOOD. ILLINOIS 6O43O
October 31, 1979 J7vj jym/ ,
'WATER
:fl,7
HED-05
Mr. Gene Wojcik
Chief, EIS Section
Environmental Engineering Branch
Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Wojcik:
The draft environmental statement for the Metropolitan Sanitary District
of Greater Chicago, O'Hare Water Reclamation Plant, Chicago, Illinois
has been reviewed. The proposed action has no impact on facilities
within our functional area of responsibility. Therefore, we have no
comments to offer on the statement.
Sincerely yours,
. Donald E. Trull
Regional Administrator
J. Emrich, Director
Office of Environment and Design
101
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136 W. Dover Dr.
Des Plaines, Illinois 60018
November 1, 1979
Mr. Gene Wojcik
Chief, EIS Section (5WEE)
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 6060^
Re; The following contains comments on the Draft Supplemental EIS
for the O'Hare Water Reclamation Plant. It is to be included along
with the specific data requested in the final EIS.
Dear Mr. Wojcik:
On Monday October 29, 1979, I attended the Hearing on the Draft
Environmental Impact Statement for the O'Hare Water Reclamation Plant.
I was disappointed by the EPA Officials. I expected some definitive
statement by the EPA on the aerosol emissions from the O'Hare Water
Reclamation Plant. I expected and was even told at the door that there
would be a question and answer session after the formal statements.
There was none. I did not expect, nor appreciate, the role EPA assumed
as a nonparticipating moderator. Because .of EPA's action, I made a
brief unprepared verbal statement. I am expanding on that statement
in this letter. I am requesting that this letter be included with my
statement. I expect the EPA to make specific, quantitative answers to
all requested information contained in this letter within the final
EIS. Not to do so would leave grievous doubt in the validity of any
operation of the O'Hare Water Reclamation Plant as currently constructed
Background
I am a degreed chemical engineer, registered in the State of Illinois.
I am well experienced in the design and construction of chemical process
plants. My experience includes quantifying waste streams, both air and
water, for operating permits. I appreciate quantified data with clear
definite conclusions.
During one project I had to review literature on specific industrial
chemicals which could cause allergic reactions. When reading on allergle
it was indicated that there is a very wide variation in the sensitivity
of individuals to any specific allergenic agent. Even though'care is •
taken to minimize the exposure of highly sensitive individuals to
specific allergens, s-'frrlie"5 individuals still have "reactions to very
low concentrations. In industry, such individuals when exposed will
.usually seek employment elsewhere. A natural selection process results,,
leaving employees having resistance to the allergen.
Because EPA has not adequately quantified the data, because I do not
have the data or resources for a proper analysis, I am submiting this
letter as a "concerned citizen" whose family resides extremely close
to the water treatment facility.
102
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—ff"
EPA
"I have high regards for the EPA. It is a "watchdog" agency which
usually works hard to assure a quality environment for the public.
Generally EPA forces industry, or assumes the task itself, for the
"burden of proof" that adverse environmental effects will not occur.
This is the first time I had the feeling that EPA ha's forced the
"burden of proof" onto the public, those they are to protect. This
feeling was further heightened by the fact that no EPA Official would
make a definitive statement or answer questions. It leaves grevious
doubt that the EPA is handling this project in "good faith".
Supplemental Environmental Impact Statement
The EIS leaves me with a very uneasy feeling. There is no data,
information or conclusive statement that I can interpet the extent
or complete absence of any health effect that will occur from the
operation of the O'Hare Plant as currently built. There are no solid
conclusions as to what each study means. There are too many qualifying
statements and subjective statements. There is no attempt to correlate
the data from the various studies to each other and the O'Hare Plant.
There is no attempt to statistically verify the validity of the data.
Has EPA adequately performed its task?
a
Request #lt What is the resume of the preparer? Age? Education?
Previous experience?
Data Availability
So that I could better understand the Supplemental EIS, I attempted
to acquire the documents listed on page'IV of the EIS through the
Des Plaines Library. After three weeks, I was informed that none of
the documents were available within any of the local library systems,
and probably none .were available in the local university libraries.
I was informed that I could receive 5of the 7 documents within 10
days of request from the EPA. The remaining 2 documents were made
available just recently. In fact, one document was issued within one
or two days of the Hearing. I commend EPA for using all the data at
its disposal. I object to the short time available to the public for
review of the data before the November 12 deadline for comments.
Validity of the Data Contained in the Seven Studies
Without having the individual study documents available to me, I
have tried to understand specifically what the data from each study
means, and if the data is valid for extrapolation. There appears to
be no contest to the fact that aerosols are generated. There appears
to be no contest that these aerosols contain particulates and
microorganisms (bacteria and viruses are classed within this category)
some of which are pathogens. There appears to be some health effect
from these aerosols. The problem appears to be in determining just
what the extent of the health effect is. As a result, EPA has chose
to employ the statement "no adverse health effect" for incorporation
into the EIS.
Request #2: Specifically what does "no adverse health effect" mean?
Absolutely no increas.ed respiratory, gastrointestinal,
eye, etc. infections/illness?
' • 103
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The key question is if the data from these seven studies is valid
and sufficient to estimate the -health effects to residents bordering
• the O'Hare Plant. The data must be mathematically tested. Statistics,
a procedure employed well by Federal Agencies, should answer this
question.
Request #3; Please answer the following for each' of the seven
studies cited in the EIS on an individual basis.
1. Given all the various parameters; wind, solar radiation
humidity, sampling technique, analytical technique,
potential contamination of sample with active or
sterilizing agent, distribution of samplers, etc. ;
what is the confidence level of the accuracy for
for each data grouping or point?
2. Given the number of participants, the method of data
accumulation, variability of exposure, etc., what is
the confidence level that the data acquired accurately
indicates the health effects for the general puplic?
3. Given the number of participants, etc., what is the
confidence level that the data acquired accurately
indicates the health effects for specific age groups
as follows:
a. 0 to ^ months?
b. ^ months to 2 years?
c. 2 to 6 years?
d. 6 to 18 years?
e. 18 to 59 years?
f. over 59 years?
4. If participants dropped out of the study, can the
EPA make an unqualified statement that a natural
selection process did not occur? This is important
because a natural selection process would result
in data understating the health effects.
5. If a natural selection process could have occurred,
8 using probability, what would be the new confidence
level for Request #3. Items 1,2 and 3?
Correlation of Data to O'Hare Plant
.This topic has been inadequately addressed by the EPA. The Plant has
a design capacity. For this_capacity there are srecific associated
process flows for chemical additions, air for aeration, etc. Using
the correlated data from the various studies and the design parameters
for the O'Kare Plant, the EPA should be able to estimate the total
emissions for particulates and microorganisms. Further the microorgariis
should be able to be estimated-for specific pathogens. Employing a
dispersion modeling technique for degradation estimate of air quality,
the average 2*1 hour exposure rate and the maximum 8 hour exposure rate
for total particulates and the various microorganisms can be developed
for key distances from the plant. Typical distances should be 5° meters
(nearby residents), 150 meters, 300 meters, 500 meters (Friendship Jr,
High), ?00 meters (Devonshire) and 1500 meters (Einstein).
104
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10
11
Request ffi-; I am specifically requesting the following:
1, Prepare a dispersion model "based on the designed
parameters for the O'Hare Plant as built and the
best correlated data available for total particulates,
Prepare a similar model for each key microorganism and
pathogen. It should list the expected average exposure
rate for a 2*4- hour period and the maximum expected
exposure rate for an 8 hour period at distances of 50
meters, 150 meters, 300 meters, 500 meters, ?00 meters
and 1500 meters.
2.Based on the above model, I request that a specific
health statement be made that there will or will not
be any increased infections (eye, respiratory,
gastrointestinal, etc.) as a result of these emissions
for each age group listed in Request #3 Item 3 a,b,c,d,
e,and f at each distance listed in Request #^ Item 1.
3.1 request that both the Water Division and the Air Quali
Divisions of Region V EPA verify and without reservatio:
state that the intent of the law for nondegradation
of the ambient air quality for the region bordering
the O'Hare Plant will be met as the plant is built.
Summary
Since by this date the data requested should have been clearly answered
by the Greater Chicago Metropolitan Sanitary District or the EPA, since
the data requested is critical in making a true assessment of the
adequacy of the Impact Statement, I expect definitive answers to be
incorporated in the final EIS. Since the data requested places serious
doubt in the adequacy of the Impact Statement by a "concerned citizen
directly affected by the action", I would question the legality of
the issuance of an operating permit for the O'Hare Water Reclamation
Plant as built, until all requested information is specifically and
quantitatively answered.
Yours truly,
_
William H. Radclifre
105
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DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
PUBLIC HEALTH SERVICE
CENTER FOR DISEASE CONTROL
-------
Page 2 - Mr. Gene Wojcik
We appreciate the opportunity to review this EIS. Please send us a copy
of the final EIS when it becomes available.
Sincerely yours,
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Bureau of State Services
107
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United States '
,fl Department of
Agriculture
Soil
Conservation
Service
P.O. Box 678
Champaign, IL 61820
217-398-5265
November 5, 1979
Mr. Gene Wojcik
Chief, EIS Section
USEPA Region V
230 South Dearborn" Street
Chicago, Illinois 60604
Dear Mr. Wojcik:
We have reviewed the Supplemental EIS on the Metropolitan Sanitary
District of Greater Chicago O'Hare Water Reclamation Plant dated
September 1979-
The main concerns of this draft EIS is health effects.
constructed and in operation.
We have no comments.
Sincerely,
The plant is
lu
Warren J. Fitzgerald
State Conservationist
cc:
5 copies to: Director, Office of Federal Activities
EPA
Room 537, West Tower
401 M Street, S.W.
Wash (jigton, D.C. 20^60
Berg, Administrator, SCS
Strong, pi rector, MTSC
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112
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6, 1979
30
United dtates Environmental Protection Agencx
Region V "J A'0|'
230 ~~uth Dearborn
Chicago, Illinois 6060'-;-
Attn: SIS Section
Gentlemen:
My. name is Lynn Moskal ano. 1 reside at 1500 Miami Lanv, Jes Plaines.
I attended the Public hearing at Friendship Jr. High School on
October £y, 1979» Having only moved to this arcc-, less tn?.n three
yecirs ago, I have only recently become av/are of th'-; problem concerning
the residents uf this area in regard to the filtration system at the C'nc
Water Reclamation Plant.
I would like to start off by saying hen disappointeu I was in Monday 'c
hearing. I attended this meeting hoping that some of my questions and
those of other concerned neighbors would be ansv/ered. There v/as no
basis for disc^sion or debatw with your representatives, who merely
acknowledged our questions and replied t^at tney v/ould be answered in
your next Draft. I therefore would like to direct my questions at this
time.
In your Environmental Impact Statement Draft you state "There is no
indication that direct or indirect health effects will result j.'ro m
operation of the O'Hare V/RP without aerosol suppression facilities."
.Twenty years ago my mother was doctor-treated for a serious illness.
That treatment cured her but has been proven to have caused her to have
cancer today. My first question is: in twenty years when our .children
are suffering from illnesses due to our air being contaminated, how wil]
you respond then? Y/ill you then acknowledge the fact that aerosol
suppression facilities v/ere indeed needed? How will that realization he
our children who will already suffer the consequences of today's mistake
Another point of interest that I v/ould like to question again comes fror
your Environmental impact Statement Draft, page 8. In discussing «ho
Egan facilities you sta.i,e: "The study concluded that the £gan plant
appears to be a source of indicator bacteria, coliphage, pathogenic
bacteria, enteroviruses, ana mercury in the aerosols emanating from its
aeration oasins." This quote taken from your Draft v/as brought up a;,
the hearing; however, I would like to continue with your next paragra.pl
"From the patterns observed in tue household health survey, the reportcc
incidence of skin disease, and the symptons of nausea, vomiting, genera"
weakness, diarrhea, and pain in chest on deep breathing may be associate
with the nearby operation of the waste.v/ater treatment plant. However,
it v/as considered that this correlation could, be due to people biasing
their responses to the questionnaire because they were aware of the
purpose of the study and consciously or unconsciously recalled a higher
incidence than they night have otherwise." I am shocked that you can
have such evidence of adverse effects on health and claim that people
are "biasing their responses." I v/ould like to ask if every tiuc there
ic a correlation such as this if you will disregard the facts and blame
it on people "exaggerating."
-continued-
113
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United States Environmental Protection Agency
Kovember 6, 1979
Page Two
20
To be born v/ith good health is a blessing; to have it taken av/ay is
an atrocity. There is no price tag that can be put on .one person's
health. Kore consideration and protection should be given to the
residents surrounding the 0' Hare 'plant by installing aerosol suppres-
sion facilities to filter the bacteria and prevent our air from these
pollutants.
Mrs. Lynn lloskal
114
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OFFICE OF THE MAYOR
HERBERT H. VOLBERDING SR
THE CITVOF DES PLAINEE
1<42O MINER STREET ma DES PLAINES, ILLINOIS BOO1G RIB 237-1200
November 16, 1979
Mr, John McGuire, Regional Administrator
Ifeiited States Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. McGuire:
Your letter of November 8, 1979, requests the City's cooperation and
support in a proposed Public Health Study. •
I understand that, at the Regional V meeting with the City of Des Plaines
on October 10, 1979, the U.S.E.P.A. was requested to prepare a list of
alternative study sites. This list is to include an estimate of the
pre-exposed population living within one thousand feet of the predominant
downwind edge of the aeration tanks. Please advise your current best
estimate of the date when this information will be available.
If the O'Hare plant is a unique situation, then we will know that con-
trolling the emissions for our pre-exposed citizens will not be a costly
precedence in many other areas of the United States, And, if several
other potentially unsafe situations are identified, we will have other
candidates to consider for the proposed Health Study. Because our
citizens have lived with the threat of being infected for many years, it
appears to be more acceptable to solicit volunteers adjacent to some
other new sewage plant that has been built in the heart of an existing
residential community.
It appears that the U.S.E.P.A. has prejudged the environmental review
process and has already concluded that aerosol suppression is not safer.
It seems difficult to propose to study our newly exposed citizens unless
you already intend to expose them.
In order to/participate in the proposed Study, we would have to embrace
the conclusions of the previous insensitive studies that could "not find
a significant health hazard". It would- require our citizens to abandon
their belief that suppression of the aerosols containing bacteria and
viruses for newly exposed individuals is safer than uncontrolled release.
1.
t
HI
125
-------
P.age 2
November 16, 1979
I do not believe the officials of the City could convince the citizens
to change their position based on the available evidence.
When the list of alternative study sites is prepared, I will welcome the
opportunity to meet with your staff. Please include this letter in the
final E.I.S. on the O'Hare Plant.
Sincerely,
Herbert H. Volberding, Sr.
Mayor
HHVrcc
126
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November 26, 1979
Mr. Gene Wejik
Chief EIS Section (£WEE)
U.S. Environmental Protection Agency
230 Dearborn Street
Chicago, Illinois 6060L{.
S e,
o
2-0
6
Dear Mr. Wojik:
Kay we suggest posting several signs along the
boundary of the MSD plant stating "DANGER - AEROSAL
EMISSIONS MAY BS DANGEROUS TO YOUR HEALTH." This
will warn the unsuspecting public that the
government recognizes that they don't know how
to Measure what has to be measured.
Our families are important to us, and we do not
want to accept AMY additional risk to their health.
zp
ID
v..,
Mr. & Mrs. Charles Drelicharz
M&3 Marshall Drive
Des Plaines, Illinois 60018
127
-------
RICHARD F. WARD
ALDERMAN EIGHTH WARD
1410 MIAMI LANE
DES PLAINES, ILLINOIS 60(j
.[312] 827-8715
THE CITY OF DES PLAINES
MINER STREET
DES PLAINES . ILLINOIS 6OO16
207-12CX
November 28, 1 979 .
2.2.
]
CO
Mr. Gene Wojcik, Chief, EIS Section (5WEE)
U. S. Environmental Protection Agency
230 South Dearborn Street
Chicago, 11 Iinois 60604
Dear Mr. Wojcik:
c-
<•
CC
o
Fourteen years Is a long time for the citizens living near the proposed plant
site to live In fear of a classic nuisance. Sewage plants have earned their repu-
tation by being notorious air polluters. The odors from sewage plants have not
been the figment of someone's imagination. At best they generate a musty odor —
and with the inevitable upset or poor maintenance, the odors can be quite obnox-
ious. Many of the people near the plant and the federal HUD authorities are
concerned that property values could be affected by the mere existence of the
sewage plant even if it only gives off the musty odor for the next 30 years.
Of course, an upset would echo in every realtor's office.
Most of the other states in Region V have minimum isolation distances that average
IOOO feet from plant boundary to residential boundary. The Chicago HUD office
requires 500 feet. 'The O'Hare plant provides-100 feet — the dedicated width of
Oakton Street. The IEPA and USEPA reluctantly accepted the poor site location
in I975 simply to avoid losing the federal funds allocated to Illinois. There
were no alternate projects that could absorb the $150 million by June 30, 1975,
Since 1965, we have urged isolation or control. Isolation Is Impossible now so
only control remains. Several high odor-generating areas will use ozone for con-
trol. The sludge will not be processed at this site. Adequate pre-chlorina-t ton
has be"eh assured. These concessions will be helpful and our recourse to the
complaint machinery and case history of the Illinois Pollution Control Board
should provide adequate safeguards. But the aesthetic consideration of home
values next to a sewage plant remain as a problem.
Aerosols
From about 1965 through 1973, we were concerned primarily with odors. Then
Region V provided a copy of the Clavey Road Highland Park, Illinois 1971 EIS.
This cast new light on the O'Hare situation and some very hard to shake fears
spread through our community. I was personally responsible for handling a very
delicate situation. I wanted to be honest with the people that trusted my repre-
sentation. And yet I knew that some families would scare easily and a home
selling panic could result. It has been estimated by several sources within
the community that approximately 50 homes were sold based primarily on this fear.
128
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Mr. Gene Wojcik - Page 2
November 28, 1979
2.M
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27
5
1
2.7
t
18
31
2C
Those that remain express varying degrees of confidence that the state and
federal authorities will do what they said they would do in 1975 — control "
the release of the aerosols. No one could argue that it is not safer to con-
trol the aerosols. We believe that the expenditure of $500,000 for safety
covers on a $150,000,000 plant/tunnel system is the minimum tha't can be expected
as an additional cost for the poor site location. The 14 year history of this
project and the concerns of the nearby citizens should be sufficient to tip the
c6st-benefIt evaluation in favor of the safer option.
Studies
It Is Inexcusable that Region V did not advise the citizens near O'Hare that the
1975 promise of evaluating aerosol suppression alternatives would be side-tracked
and a high priority put on eliminating the need. Region V gambled and lost. The
six studies provided JTO_ clear answers — just the hint that no significant health
hazard exists.
Trying to elevate the studies as clear answers, the draft EIS omissions are a
blatant example of building a case for a pre-judged objective. Withholding the
new O'Hare health study proposal until just minutes after the 270 residents left
the public hearing room does not raise our confidence In Region V's objectivity.
We wanted to go out to the parking lot and bring.the people back to the auditorium,
so they could hear the proposal directly that would require them to embrace the
theory that uncontrolled aerosol release is safer than suppressing the bacteria
and viruses. The public hearing attended by 270 potential health study partici-
pants was the perfect opportunity for USEPA to enlist their cooperation. Your
decision was prudent because your chance of success was very slim. The evidence
of "no significant health hazard" falls apart with any close inspection. Your
Mr. McCabe of the USEPA Health Effect Laboratory that helped coordinate the studies
said it very clearly, "We don't have the scientific know-how to address this problem
of sewage treatment 'plant aerosols. We have spent somewhat over 3 million dollars
In the last several years and we have to conclude that we don't know how to measure
what has to be measured." Should we believe Leland McCabe or Rick Beardslee and
Steve Poloncsik who wrote the draft EIS?
Another key area of the draft EIS that exhibits questionable reasoning is the last
paragraph on page 35, "Despite the fact it could be argued that weaknesses in indi-
vldua-l studies may lower their sensitivity, if any significant adverse health effects
result from exposure to activated sludge treatment plant aerosols some substantial
Indications of health effects should have been discovered." This statement infers
that the evidence is cumulative when actually you could not expect to find anything
more significant than from the most sensitive study. And the most sensitive studies
examined the blood of newly exposed individuals. But the Egan subjects were all
beyond 400 meters and the newly exposed Northside subjects were too few. Only 60
C847 x 7.1$) lived within 1/2 of a mile from the aeration tanks for less than I year.
If Immunities are developed in 3 months, then the sample size is down to 15. The
thousands of potentially newly exposed people near the O'Hare plant cannot accept
such weak evidence. How can the federal govenrment possibly reverse their 1975
decision to suppress the aerosols? Please keep the promise that you made to the
people and the federal courts. John McGuire's decision to accept the Beardslee/
Poloncsik recommendation or the McCabe recommendation should not- be difficult.
129
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29
OA
32
3li
69
Mr. Gene Wojclk - Page 3 November 28, 1979
Low cost temporary covering Is the only reasonable alternative based on the 1975
grant conditions and the interim studies. As Mr. McCabe said in September,
"If the suppression can be accomplished at less costs, then -I don't think the
health effects would have to be so unequivocal." We agree.
We also realize that the low cost covering alternative would be very unpopular
with the MSD. However, Mr. McGuire communicates well with Mr. McMillian and the
federal decision selecting the safest option can be effectively explained to the
MSD.
Study Recap
Let me recap the studies using primarily selected quotations from the studies
themselves.
Egan
"Overall findings did not detect a health hazard for persons living beyond 400
meters (1312 feet) from the well operated wastewater treatment plant." "From
patterns observed .in the household health survey, the increased Incidence of skin
disease, and the symptoms of nausea, vomiting, general weakness, diarrhea, and
pain In chest on deep breathing may be associated with the nearby operation of
the v/astewater treatment plant."
Norths Ide
"The overall conclusion that this activated sludge sewage treatment plant had no
obvious adverse health effects on residents potentially exposed to aerosol emis-
sions must be tempered by the recognition that only a very smalI number of people
were exposed to the highest pollution levels. It is important to note that this
plant was not a source of high concentrations of viable particles, gases, or metals
to the study area." The people that prepared the study are telling us that this
plant Is not representative of all plants in the United States.
Durham School
"The Durham students probably received a peak daily dose of about 9 cfu of myco-
bactenJa and 3.5 cfu of feca! streptococci about .one school day per year." "At
this dose and frequency, a rather insensitive measure, school attendance, pro-
vided no evidence of an adverse health response." "In fact attendance at the
nearby school generally improved after sewage treatment commenced." "This change '
In principal may have been responsible for part of the improvement in attendance
at Durham Elementary in the DAWTP- operational years." "The lack of an effect on
school absenteeism does not necessari I y imply the absence of any health hazard."
"Dose-response relationships ^eed to be developed for the pathogenic microorganisms
prevalent in wastewater aerosols so that the health hazards of monitored sources
can be more adequately assessed." We agree.
Pleasanton, California
"Results obtained from the aerosol studies indicate that use of the traditional
Indicator organisms to predict human population exposure results in extreme under-
estimation of pathogen levels." "At sites with aerosol source strengths similar
130
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37
38
Mr. Gene Wojclk - Page 4 November 28, 1979
to the Pleasanton site and with samp I Ing and assay methods currently avaIlable
It Is generally not advisable to conduct microbiological aerosol samp I Ing at
distances beyond 200 meters (656 feet) from a wastewater aerosol source."
"Until the necessary dose-response relationships are developed neither the
level of aerosolized microorganisms that constitute a hazard nor the degree of
required disinfection can be specified." "The available techniques Include
epldemlologlcaI studies of human populations, sentry animal studies, laboratory
animal studies, clinical studies, and/or professional Judgment."
Workers In Copenhagen
"The only significant difference was an elevated level of gamma globulins among
sewer workers, suggesting that they have had more Infections than the other
groups." "In the report of medical consultations with sewer workers, the doctors
conclude that the working environment is responsible for a high level of acute
disorders of the gastro-intestinal tract." "Therefore one can conclude that
workers who have spent more than 8 years in Copenhagen sewers have about twice
the death rate of all Copenhagen males." "It seems probably that biological
and chemical insults, caused in part by lax observance and poor enforcement
of safety regulations and discharge restrictions have all contributed to the
adverse survival expectancy of this group."
Tecumseh, Michigan
"During the warmer seasons, -summed respiratory illnesses within 600 meters
CI968 feet) of the wastewater treatment plant exceeded those expected by 20$
and 27$ and summed gastrointestinal Illnesses exceeded those expected by 7B^
and 50$ when specified for income and education, respectively." "Differences
with respect to totaland gastrointestinal illness were found significant at
the 95$ and 99$ level of confidence respectively." "Higher rates of illness
transmission In areas of higher densities of lower socioeconomic families,
could have contributed to these findings." Or conversly the plant could be
• responsible for the high rate of respiratory Illnesses near the plant.
Cincinnati, Chicago, Memphis Workers
x"From preliminary analyses of illness rates, unexperienced workers exposed to
sewage had a higher rate of gastro-intestinal illnesses than experienced sewage
treatment plant workers."
Many areas of the 156 page study were difficult to evaluate with the resources
available. However, two examples in Tables 44 and 46 seem to be significant and
were classified as "no significant difference". Out of 183 exposed workers, 7 or
3.8$ showed enterovirus isolation and only I out of 77 (1.3$) of the non-exposed
workers were positive. In Table 46 the difference was even greater, 3.4* versus
0.6$.
The above quotations from the seven studies that formed the basis of the draft
EIS certainly do not support the conclusion of np_ health hazard. These excerpts
plus Mr. McCabe^V symposium comments when considered against the history of this
controversy can only lead to the decision to continue some modified, low-cost
- 131
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Mr. Gene WoJc.lk0-.Page 5 November 28, 1979
•(possibly temporary) covering option. If it Is anticipated that the final
EIS may not agree with our conclusions, then I request the opportunity to
meet with Mr. McGuire and any advocate of uncontrolled aerosol release. A
decision maker should have the direct benefit of asking questions and I will
provide that opportunity.
In a letter to USEPA dated November 21, 1977, I reminded Region V of the aerosol
suppression requirement prior to the start-up of the O'Hare plant. I discussed
the apparent delays in the aerosol suppression study and cautioned that "The
MSD must not be allowed to maneuver the USEPA and IEPA into a pre-programmed
decision using the urgency of starting operations at the O'Hare plant before
the finally selected aerosol suppression facilities are constructed."
Then I went on to discuss the faults of using average data to determine the
degree of suppression. I had no idea that six separate studies were quietly
progressing to eliminate the very need of suppression. But my comments two
years ago are valid today:
"Faulty Study of 'Average' Emission Data
While the timing of the study is out of phase with the plant construction time-
table, a more serious problem exists with the average emission data that the
proposed study will provide for a suppression decision. We must all focus our
efforts and attention on the worst case situation. The majority of the study
that the MSD proposes will be useless and completely misses the point of our
concern. We are concerned with the Iimits of our resistance to infection from
bacteria and viruses during adverse conditions of generation, transmission and
intake.
During average conditions, we possibly do not need any aerosol suppression devices
at the O'Hare plant because the die-off rate and dispersion will reduce the
emissions to near the ambient levels. We should not be subjected to building
an immunity with long term low levels of exposure and we are not volunteering.
Let me create a very realistic and probable situation in our community.
An infant is playing in-her crib near an open window on Lincoln Lane. She
has .been suffering with congestion and is just getting over a cold. An elderly
man is walking along the south side of Oakton to the RTA bus stop at Ridge
Lane. He has a history of lung ailments. There has been a heavy rain the
night before and the plant is running at full capacity processing the first
flush concentration from the Elmhurst tunnel. There is a relatively low level
"temperature inversion with fog and a 3 MPH wind from the south. It could also
be presumed that for several days prior to the heavy rain there had been high
levels of ozone which had caused lung irritation and a lowering of the resistance
to respiratory Infections.
Now why Is this situation dangerous to our infant and elderly gentleman. The
activity, of both results In an increased air intake volume per unit time. The
first flush from a tunnel results in a greater concentration of bacteria and
virus In the aerosol generated. The high rain volume that Is stored in the
tunnel requires full plant capacity and Increased aeration tank air flow. The
fog condition greatly reduces the die-off of the viable particles In the aerosols
due to evaporation and the inversion and mild wind channel the air flow and
reduce dispersion.
. I O £-
-------
Mr. Gene Wojc-I !<-•-• Page 6 ' November 28, 1979
The $1,416,000 proposed MSD study does not even approach examining a simflar
situation. And 1 may have omitted other factors that would make a situation
even more dangerous.
Page 30 of the work plan refers to the most cost-effective system will be
recommended by MSD. What health criteria will be used? What concentration
of viral and bacteria pollution is "acceptable" for us to inhale? The burden
of proof of the safety of a_n_y_ degradation of our air quality must be on the
agency approving the degradation. In considering the cost-effectiveness
9
°f each option, it must.be considered that varying degrees of aerosol suppres-
sion could be required depending on certain atmospheric variables. Using . ,..
the covered aeration tank option as an example, it may be energy wasteful
to Incinerate the exhaust air on a windy dry cloudless day. And conversely,
Incineration may be required on a cool foggy evening. Programmed parameters
In a computer could control the degree of necessary air purification. This
could also be varied depending on applicable future medical studies at O'Hare
or elsewhere."
Please comment on. why there was no response or action taken to obtain this
adverse data.
On Friday, September 21, 1979 in Cincinnati, Mr'. Cecil Lue-Hing of the Metro-
politan Sanitary District admitted that his research department misled us In
January, 1975. At the meeting in September, he said, "Five years ago, I could
not comfortably arrive at the conclusions I can today. While it was my gut
feeling that my conclusions were valid then, I couldn't prove them at least
as effectively as I can today. I personally can say that based on what I have
heard in the last two days, I do not see any additional risk to residents around
sewage treatment facilities."
The public and the review agencies relied on the Integrity and professionalism
of -the MSD in 1975 0hen they stated In a 15-page position paper: "Let us
now examine the larger issue of the health implications associated with the
generation of microblal aerosols. The major question to be answered is: Are
xthe assumptions concerning the implications valid? Based purely on the experience
associated with the construction anc[ operation of activated si udge pi ants i n
the United States~ahd the rest of the world since" 1915, th_e_- an-swer must be nol
(emphasis in original on page 1-7 of EIS).
Now we learn this was only a "gut" feeling and that It was "an unfomfortable
conclusion". Will we. learn in 1984 that we were misled in 1979?
Some excerpts from the 1975 EIS may help to keep the "safest option" goal in
focus:
page 3-31: "The possibility here, If any, of aerosol transmission of bacteria
and viruses to the residential area in close proximity to Site I should be
mitigated given the assurances provided under the National Environmental Policy
Act and the concerns of the I EPA and the local residents. Additionally, we feel
that to Introduce a large facility Into an area where none had existed before
and which might possibly pose a potential health hazard in an environment which
Is already severe I y Impacted by the degraded air qual Ity and noise resulting from
133
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Mr. Gene Wojclk - -Page 7
November 28, 1979
6^
18
O'Hare International Airport requires certain mitlgative measures. We believe
that the most unacceptable risks are those taken at the potential expense of
public health. It therefore behooves us to take the conservative approach in
the application of mitigative measures."
page 5-20: "While aerosols will be generated at the WRP, we believe that it
cannot be demonstrated that any health hazard will result from the transmission
of these aerosols. However, since there is also an absence of evidence that a
potential health hazard does not exist, we believe a conservative approach is
required to mitigate any potential risk. We shall therefore require the MSDGC
to design, construct and ma Inta i n such additional facilities as necessary to
adequately suppress aerosol transmission from the aeration tanks, subject to
the approval of I EPA and USEPA including demonstration by MSDGC of the effective-
ness of aerosol suppression." The residents were paclfied'and the federal courts
were Impressed. But with passive encouragement by IEPA and USEPA, the MSD did
not design, construct, demonstrate or maintain the aerosol suppression facilities!
Public disrespect is warranted.
page 5-22: "Should later evidence demonstrate that these measures are not
sufficient, we will require and the MSDGC has Indicated its willingness to
implement, additional necessary mitigative remedies." Note that the "intended"
option of doing nothing (less mitigative remedies) was omitted. "In order to
further assure the implementation of this finding, It will become a speciaI
condition of the grant agreement between USEPA and MSDGC for the proposed
Des Plaines-O'Hare WRP." After effectively assuring the public and the courts,
the parties quietly set out to prove that aerosol suppression-was unnecessary
and thereby not cost-effective. But the studies failed and in September, 1979,
the coordinator of the studies told the audience of scientists in Cincinnati
that: "We have spent somewhat over 3 million dollars in the last several years
and we have to cone Iude that we don't know how to measure what has to be measured.
"We don't have the scientific know-how to address this problem of sewage treat-
ment plant aerosols." "I think we have to have an effect in a micromized
exposed population before we can conclude that the exposure is much lower in
the neighborhoods. I think your problem is the sample size. Each one has been
too small and Inadequate." "We just somehow have to do something that we can
have a measurable effect we can back off from." "We obviously need to be meas-
uring something that relates to—Infectious dose."
accomplished at less costs, then I don't think the
63
be so unequivocal." "I'm sure the public must fee
considered and that something could be done within
tlal or Imagined hazard." I'm sure the USEPA will
'
"If the suppression can be
health effects would have to
I that their interest has been
reason to minimize the poten-
try to get Mr. McCabe to
retract or "clarify" his comments. 'But his original comments to the scientific
community will stand as a pillar of honesty and unusual frankness.
Page 36 of the draft EIS seems to lead the reader to -believe that all factors were
covered by the studies. It talks of a 292 million MGD plant that was studied and
O'Hare will be only 35 MGD initially. But very few people live near the larger
plant. It talked of school children within 40 meters of tanks but the study re-
vealed that the surge basin was a very weak source of aerosols and the absentee
measure was a very insensitive measure. It talked of workers exposed to high
concentrations, but they were all healthy working age males'and did not Include
children or senior citizens. It talked about the "residents" within 117 meters
'134
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Mr. Gene Wojcik - Page 8 November 28, 1979
of the O'Hare tanks but failed to mention children playing on the hills outside
ij^ the fence only 42 meters from many acres of aeration tanks. The entire draft
EIS Is a classic example of trying to fit the evidence to the desired conclusion.
9j The main question remains unanswered. What aerosol dose of 'bacteria and viruses
results in a response In humans? And how frequent Iy wi11 the plant exceed
this dose under adverse conditions? These are the same questions everyone
H3 had in 1971 when the Clavey tanks were covered and in 1975 when the O'Hare tanks
were approved only with aerosol suppression. Until the dose-response question
Is answered., we will expect that new plants built in residential -areas will
only be allowed with aerosol suppression.This conforms to the intent of the
National Environmental Policy Act.
As I prepared my oral testimony and these written comments, I tried to keep
one objective in mind — to insure the safest environment for my community.
I hope I have presented an effective combination of arguments and delivered
them in a tone that will v/ork. Some of the decision makers reading this will
be displeased at my apparent disrespect of the system. Some will feel uncom-
fortable with draft EIS emissions being revealed. Others will know I respect
their intelligence, honesty and objectivity. I have sat at my desk in my base-
ment and used my typewriter and phone for 14 years. I have tried to be honest
in my relationship with all sides of this issue,
I now bring to a close 14 years of my invoIvement'in this controversy. It has
been a frustrating drain on my personal life attempting to steer a consistent
course to achieve the safest environment. There is a basic flaw in the environ-
mental review process that requires my involvement to this extent.
I would like to thank the several thousand people in the Devonshire and Einstein
areas for their trust and support, and I thank my family for their many personal
sacrifices.
Sincerely,
Richard F. Ward
Alderman
135
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2.0
136
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November 29, 1979-
Mr. Gene Wojcik, Chief, EIS Section (5WEE)
U. S. Environmental Protection Agency
230 S. Dearborn Street
Chicago, Illinois 60604
Dear Mr. Wojcik:
Has a study been made on the effect of air pollution on people
who have various deseases or other medical problems? It is my
understanding that persons in the vicinity of a sewage treatment
plant are more subject to bacteria that may cause intestinal
diseases. Obviously, while this may be a minor-problem to most
people, persons who have certain permanent medical ailments may
have serious problems and/or discomfort. For example, there are
persons who have trouble with their digestive system (do not
know the medical terms) and diabetics, who must have food to
offset insulin shots, (in addition to maintaining their system
to protect themselves from other ailments they are more apt to
incur than the ordinary person). I am a diabetic and am interestec
in the amount of risk the MSD is taking with my health and per-
sons with the ailments mentioned above.
From the meeting at Friendship Junior High School, it was my
impression that the MSD representatives are not interested in
minorities like myself. Their attitude is "So what if it only
affects a few people; what is best for the majority is what we
should do, if it saves money." This idea is similar to the
attitude that was used by several countries (Nazi Germany, for
example) and our country fought wars to overcome it.
Please consider the effect the airborne bacteria will have on
the minorities like me, who already have problems with their
health.
Sincerely,
f
Donald F. Argus
495 Courtesy Lane
Des Plaines, Illinois 60018
CQ : I nd G£ AGii 6.1,
Q d A i i J d a v
137
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November 29, 1979
Mr. Gene Wojcik, Chief, EIS Section (5WEE)
U. S. Environmental Protection Agency
230 S. Dearborn Street
Chicago, Illinois 60604
Dear Mr. Wojcik:
Please include the attached petition in the final Supplemental
EIS on the O'Hare Sewage Plant. They represent the active door-
to-door concern of over 25 citizens who circulated the petition
and collected over 800 signatures of others in our community 2.(
*- that will be directly affected by the plant. We gave up a new
park site because of the fear that it would attract our children
closer to the aerosol source.
Donald Dvoral
1101 Hewitt Drive
Des Plaines, Illinois
Vid 0£ K» 6Ll
138
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BOARD OF COMMISSIONERS, MT. PROSPECT PARK DISTRICT:
The attached petition has been circulated among the Mt. Prospect
Park District residents living in the Devonshire and Einstein areas.
Our citizens are far more concerned with meaningful aerosol
suppression devices on the aeration tanks to insure our health than
we are with an additional 5 acres of leased land on the plant site.
With the possible exception of Rand and 83, this corner of
Oakton and Elmhurst has the highest volume of traffic and the highest
speed limits in the park district. It does not seem reasonable to
the people of this area to expend park district funds to attract our
young people to a high risk traffic area. If park district funds are
available, we would appreciate completion of the 1969 Friendship Park
Plan.
We also object to the MSD diverting even part of the federal
funds for the dense vegetation buffer zone to develop a "park"
site. We have information from consultants at the University of
Illinois and Pittsburg that a vegetation zone has absorptive qualities
'that will reduce odors.
The MSD has already proved their irresponsibility by causing
dust, noise and well pollution problems. The MSD has fought for
years to avoid controlling their aerosol emissions. They now have
to reveal the results of their study on the federal aerosol suppres-
sion requirement and their lawyers are still trying to invent evidence
that their aerosol emissions are of no particular concern.
139 Continued
-------
If the community welcomes their park site scheme, then that
will be strong evidence that our health concerns were not serious.
We thank you for your consideration. If you have any questions
a meeting can be arranged with several members of our community.
Sincerely,
X->v
&
Donald Dvorak Heinz'^pkSe
140
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BY 853
• -•• . : PARVC, DIST. dpTiZENS
• . PETITION :
We, the park district residents living near the O'Hare Sewage
Treatment Plant, petition the Mount Prospect Park District Board
of Commissioners to cooperate with the City of Des'Plaines in pur-
suing meaningful aerosol suppression devices to protect our health.
#e do not want to jeopardize covering the aeration tanks "by agreeing
to the use of the plant site for recreation. Also, the traffic
hazards make the plant site unsuitable for a park. If park dovelop-
ment money is available, it should be used to complete Friendship
Park.
Address
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November 29, 1979
Mr. Gene Wojcik, Chief, EIS Section (5WEE) H £2 Tj
U. S. Environmental Protection Agency [^ —^
230 S. Dearborn Street -^ ^ ^
Chicago, Illinois 60604 r. -1
"ta_ *"O ^.^j,
Dear Mr. Wojcik: 2r "^
As a Commissioner of the Mount Prospect Park District^ I Ijaye a—
responsibility to determine if proposals made are in^he best '—'
interest of the park district residents. The MSD has proposed
that certain unused land on the O'Hare sewage plant site could
be used for the recreation of nearby residents. Our initial
review revealed severe access problems for children crossing
Oakton so the Oakton park location was not approved although we
realize that the trees and hills will, attract our citizens after
the MSD moved the fence closer to the aeration tanks.
The site south of Wille Road has been proposed for an adult
baseball location with access primarily by automobile because of
its remoteness. This has been tentatively accepted by the park
district but there are still reservations on the safety due to
the aerosol question. The draft EIS seemed to eliminate this
fear but comments made by USEPA officials recently at a scien-
tific symposium revealed that the USEPA doesn't "have the scien-
tific know-how to address this problem of sewage treatment
plant aerosols." These comments certainly undermine the assurance
in the O'Hare environmental review. When does the USEPA estimate
• that the necessary dose-response data will be generated by
further scientific studies?
Sincerely,
Rosemary S. Argus (Mrs.
Park Commissioner
Mt. Prospect Park District
Home address: 495 Courtesy Lane
Des Plaines, Illinois 60018
144
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'145
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United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
ER 79/944
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»••—
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DEC 41979-^ !=
cr>
CO ^ . » 1
Mr. Gene Wojcik • "p^ '__ :—:
Chief, EIS Section „,, —- ^
USEPA, Region V ^
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Wojcik:
Thank you for the letter -of September 28, 1979, requesting
our views and comments on the draft supplemental EIS,
Metropolitan Sanitary District of -Greater Chicago, O'Hare
Water Reclamation Plant, Illinois. We have reviewed the
document and conclude that it adequately considers those
areas within our jurisdiction and expertise. Because our
review did not reveal any conflicts with existing or pro-
posed projects of this Department, we have no objection to
the proposal.
Sincerely
Jamos H. F.athlesberger
to
•146
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C. RESPONSES
> COMMENT 1
One commenter inquired about the curriculum vitae of the EIS preparer.
RESPONSE
4
The environmental impact statement was the result of input from numerous
individuals. Parts of the EIS were taken directly from scientific
reports prepared by specialists in the field who all have advanced
degrees. The overall assessment regarding the safety of operating
the O'Hare Water Reclamation Plant was made by personnel of USEPA's
Health Effects Research Laboratory in Cincinnati, Ohio. This laboratory
has the responsibility for determining whether or not aerosols generated
from waste treatment processes constitute a public health hazard and
the cognizant personnel have advanced degrees and decades of public
health experience. USEPA Regional personnel, who are experienced
in NSPA requirements, worked with the laboratory personnel most familiar
with the studies, and agreed on the representation and summaries of
the studies. The section listing the EIS preparers has been revised.
COMMENT 2
One commenter was concerned about the alleged unavailability of referenced
reports and short comment period deadline.
RESPONSE
All referenced reports were available at the Des Plaines Public Library
more than 30 days in advance of the October 29, 1979 hearing, except for
a referenced draft report which was available after the hearing. The
commentor was sent copies of some reports. The library was sent addi-
tional copies of all reports so more people could check them out. They
all can still be viewed in the reference library. The cominentor was
notified of this. Notice was g^s/en on November 5, 1979, extending
the comment period through November 30, 1979.
COMMENT 3
One commenter wanted to know specifically what "no adverse health
effect" means.
RESPONSE
No adverse health effect means the absence of clinical symptoms of
disease and the absence of indications of infection as determined
147
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by a rise in antibody titer in blood samples.
COMMENT 4
One commenter wanted to know, if given all the various parameters—
wind, solar radiation, humidity, sampling techniques, analytical
techniques, potential contamination of sample with active or sterilizing
agent, distribution of samplers, etc.—what the confidence level
of the accuracy for each data grouping or point was.
RESPONSE
The environmental factors of wind, solar radation, and humidity do not
influence the accuracy of the data. Quality control was incorporated
into the environmental sampling surveys to assure the accuracy of
the results. In addition upwind samples were generally obtained
as well as downwind so that the net effect of the wastewater treatment
process could be obtained and to equalize the variables. State-of-the-art
technology was used to obtain the most accurate data possible. For
example, the Anderson six-stage sampler, used in the majority of these
studies, is the accepted sampler for measuring viable organisms in
air and provides comparability of these studies with other air pollution
studies. Discussions of the methodology used may be found on the
following pages for each of the seven reports.
Northside Plant: Pages 38 to 58 and 161 to 182.
Egan Plant: Pages 28 to 59.
Tecurnsah Plant: Enviroamental sampling was not conducted because it
is a retrospective study using health data collected
in the past.
Copenhagen Plant: Environmental sampling was not conducted because it
is a retrospective study using health data collected
in the past.
Tigard Plant: Pages 20 to 36 and 86 to 94.
Pleasanton Report: Pages 32 to 44 and 289 to 395.
University of Cincinnati Report; Pages 13 to 19 (samples taken for rela-
tive exp'>r,ure only).
COMMENT 5
One commenter wanted to know, if given the number of participants,
the method of data accumulation, variability of exposure, etc., what
the confidence level is that the data acquired accurately indicates
the health effects for the general public.
148
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RESPONSE
Although the studies were not of equal importance, nor intended to
be, the results, when considered overall, provide a high degree of
confidence in conclusions regarding health effects or lack of health
effects for the general public. All studies used standard statisti-
cal procedures, where appropriate, in design and evaluation of data.
Epidemiological studies must by their nature use existing population
(number, age, sex, race) and the results must be adjusted by ap-
propriate statistical techniques for comparison. There are two types
of health effects to be expected when a person is exposed to an in-
fectious agent in sufficient dose—clinical and subclinical. The
studies were intended to provide indication of such effects, if
present. It is important to recognize that exposure does not necessa-
rily result in a health effect. It is only when exposure is suffi-
ciently high that an infection occurs, and only when a person's immune
response is overcome would clinical symptoms result. For example, it
may take exposure to thousands or even millions of bacteria to cause
an infection.
COMMENT 6
One coalmenter asked, "Given the number of participants, etc., what
is the confidence level that the data acquired accurately indicate
the health effects for specific age groups as follows: 0 to 4 months,
4 months to 2 years, 2 years to 6 years, 6 years to 18 years, 18 to
59 years, over 59 years?"
RESPONSE
The investigators did not use the above age groupings. In the North-
side Plant study, there was no relationship between exposure level
and acute illness at a statistical confidence level of 95 percent
for any of the four age groups tested (0-12, 13-18, 19-59, and over
59). The John Egan Plant study report contains voluminous statistical
data with statistical confidence levels and included data for several
age groupings. The most sensitive health effects tests, measurements
of antibody to 31 viruses which would be expected in wastewater, showed
no infections resulting from living near the plant for any age
group. Data were collected on illness in school children of Tecuinseh,
Michigan, and reported in another report cited. At the 95 percent
confidence level, the children attending the nearest school to the
wastewater treatment plant, located between 600 and 1200 meters away,
had significantly fewer illnesses than expected. Tables 1 through
6 of the Tecumseh report provide a complete breakdown by 9 age groups,
6 distance categories, 2 sexes, and 2 categories of diseases. An ex-
amination of the data for persons living between zero and 600 meters
of the wastewater treatment plant shows no pattern of illness any
different from the control group.
149
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Although the Copenhagen report is not directly applicable to the O'Hare
situation because it involves workers who not only would be exposed to
aerosols but would be in contact with sewage, it does point out that
persons who clean and repair sewers have higher death rates than the
average person in Copenhagen, at the 95 to 99.5 percent confidence
level. This European experience has not been confirmed in a study of
Metropolitan Sanitary District of Greater Chicago workers which is
still in progress.
Even though a new sewage treatment plant was constructed next to an
elementary school at Tigard, Oregon, and the nearest aeration basins
are within 50 meters of the school playground and 400 meters of the
class roans, the illness rates, as reflected by absenteeism, for the
children age 6 to 12 were no different after plant operation than
before nor any different than 8 control schools.
Numerous confidence levels were presented throughout the preliminary
draft report prepared by the University of Cincinnati on sewage-exposed
workers. Workers were generally 21 to 60 years of age.
The study at Pleasanton, California is an environmental monitoring
study and not an epidemiological study so the question is not applicable.
COMMENT 7
One commenter wanted to know, if participants dropped out of the study,
can the EPA make an unqualified statement that a natural selection
process did not occur.
RESPONSE
A natural selection process did not occur. An explanation for attri-
tion was presented in Table 7 of the Northside report. In no case
was the reason given related to the wastewater treatment plant. In
another example, every one of the participants at the Lexington Green
Apartments, the participants closest to the John Egan treatment plant,
continued through the completion of the study. The emphasis in the
sewage treatment plant portion of the Universi ty of Cincinnati study
was on recruitment of inexperienced workers so as to avoid the natural
selection factor. The Tecuraseh plant study used data collected for
an entirely different purpose and was analyzed retrospectively.
COMMENT 8
One commenter wanted to know if a natural selection process occurred,
what would be the new answers for comments 4, 5, and 6 would be.
150
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RESPONSE
A natural selection process did not occur, so this question is not
applicable.
COMMENT 9
One commenter requested that we: (1) prepare a dispersion model based
on the designed parameters for the O'Hare plant as built and the best
correlated data available for total particulates; (2) prepare a similar
model for each key microorganism and pathogen, listing the expected
average exposure rate for a 24-hour period and the maximum expected
exposure rate for an 8-hour period at distances of 50 meters, 150
meters, 300 meters, 500 meters, 700 meters, and 1500 meters.
RESPONSE
An applicable model for an activated sludge plant was developed by
Dr. Paul A. Kenline as part of a Ph.D. thesis at the University of
Cincinnati. The model was developed at a 12 million gallon per day
plant at Hamilton, Ohio. The results at O'Hare are expected to be
the same order of magnitude as those found in Hamilton. However,
even if they are 2 to 3 times Hamilton values, the Des Plaines exposure
would be low.
Bacterial removals are controlled by diffusion, deposition, and
die-off, which operate simultaneously. Under average conditions,
the percent removal for a 24 hour period at varying distances from
the tank would be as follows:
Percent Removal
Mechanism 50_fMI5rn)_ 1QQ ft (30.5m) 150 ft (45.7m)
Diffusion 68 80 85
Deposition 28 28 28
Die-off 61 74 82
Total percent removal 85 91 98
Using this model, the expected average exposure increment from the O'Hare
plant aeration basins for total bacteria at various distances would
be, at 15 meters: 560 cfu per ml (colony forming units per cubic meter
of air); at 50 meters: 106 cfu per m3; at 150 meters: 11 cfu per m3;
at 300 meters: 1 cfu per m3. Over an eight hour period, these densities
could be expected to double. While theoretically one could arrive
at a bacterial density beyond 300 meters, the model is not valid at
these distances. Very few of the total bacteria are pathogens. Total
coliforms (used as indicators) would be approximately 5 percent, while
enterovirus would be 0.003 percent of the above values. Bacterial
pathogens woud be expected to be the same order of magnitude as total
coliforms or lower. Normal background levels of total bacteria without
the treatment plant would be of the order of 100 to 400 cfu per m3. At
151
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50 meters the total coliform value based on Dr. Kenline's model would
be expected to be 5 cfu per m3. Table 25 of the Tigard report confirms
this same level of total coliforras for several other plants of varying
configurations. Enteroviruses are more hardy than the indicator organisms,
but these would have an even lower density.
COMMENT 10
One commenter wanted a specific statement, based on the above model,
that there will or will not be any increased infections as a result of
these emissions.
RESPONSE
Exposure alone does not cause infection or disease. Based on an Okla-
homa study (see reference 9), minimum infective dose for various
pathogenic bacteria is of the order of 100 to 100,000,000, with most
values being in the millions. From correspondence with USEPA's Health
Effects Research Laboratory in Cincinnati, Ohio, based on raw data of two
ongoing studies (see reference 10), the miniimm infective dose for
viruses is about 10 to 200.
There is a distance of approximately 385 feet from the edge of the
nearest aeration basin to the nearest house at Des Plaines. The
incremental total bacteria count at the nearest house would average
about 25 colony forming units per cubic meters of air (cfu per m3)
with the 8 hour maximum double this value. Both values are well
within background levels to which the people are exposed without the
plant being considered. Bacterial pathogens would be a maximum of
about 1 cfu per m3. With a respiration rate of 1 m3 per hour, and with
a large percent of the organisms normally being exhaled, the minimum
infective dose is so high that none of the age groups would be infected.
Enterovirus at the nearest house would be of the order of 0.0008 cfu
per m3. Even with the minimum infective dose of entervirus so much
lower than with bacteria, the exposure is far too low to cause an
infection. Persons living farther away would have even less exposure.
Bahman Sheikh-ol-Eslami ejb al. from Engineering-Science Corporation,
in a paper presented at the Water Reuse Symposium, Washington, D.C.,
March 25-30, 1979 (see reference 11), examined the risk of becoming
ill from inhaling bacterial pathogens from spray irrigation of war.tewater
while standing 50 feet away for 8 hours. The calculated result was
1 chance in 860,000,000.
Knowledge of virus illness is not as complete, but given the low level
of virus in the aerosol expected at the closest home and the estimates
of infectious dose being greater than a single organism, the probability
of an infection caused by the treatment plant is immeasurable, considering
the background levels. The virus shedding rate (indicating infection)
was 17.5 percent in the Northside study, where fecal samples from all ages
were analyzed every two weeks.
152
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Several studies were conducted with USEPA funding to try to measure any
infections which took place as a result of exposure to wastewater. Even
when using the very sensitive procedure of measuring seroconversion
of numerous viral antibodies, no relationship could be found to exposure
to wastewater aerosols.
COMMENT 11
The commenter also requested that both the Water Division and the
"Air Quality" Divisions of Region V EPA verify and without reservation
state that the intent of the law for nondegradation of the ambient
air quality for the region bordering the O'Hare Plant will be met
as the plant is built.
RESPONSE
The USEPA undertook studies to evaluate health implications of aerosols
emitted from wastewater treatment plants. Since no correlation between
health hazards and aerosols has been found and the agency is continuing
to study aerosols, the agency has complied with the intent of the law. Also
no limits have been established for biological aerosols.
COMMENT 12
Another commentor concurred with the conclusions of the EIS and pointed
out that delay in utilizing the O'Hare plant would cause a greater threat
to the health of surrounding residents.
RESPONSE
This point is correct since overloading at existing sewerage systems
is causing back up of raw sewage into the basement of homes. This
is a definite health hazard which must be corrected promptly.
COMMENT 13
A comment was received which recognized the weak association between health
and wastewater aerosols. A recommendation was made to operate the plant
without aerosol suppression while continuing the assessment of potential
health effects.
RESPONSE
Continuing to assess the potential problem is a prudent approach and the Agency
will continue to assess the implications of future research involving waste-
water aerosols and public health.
153
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COMMENT 14
One commentor requested not only the installation of aerosol suppression
facilities, but also took issue with the EIS statement that persons living
near the Egan plant could have biased their answers because they knew the
purpose of the questions about recent disease incidence.
RESPONSE
The Agency agrees that the statement that people may have been biasing their
responses because they knew why the questions in the questionnaire were
asked is inappropriate. The statement has been removed in the final EIS.
COMMENT 15
Another person asked about increased risk of infection from the waste--
water treatment plant for persons that have medical conditions such as
diabetes.
•RESPONSE
In general, a compromised host, such as a diabetic, has an increased risk
when compared to a normal person, when certain infections occur. With a
serious case of diabetes there is decreased leukocyte chemotaxis, so an
infection of a extremity, such as a toe, is more difficult to control.
Various studies have shown the nasal carrier rate for Staphylococcus
aureus to be 1.7 to 3 times higher in diabetics as compared to non-
diabetics. In the John Egan study, isolation rates of S aureus from
people varied in time but were not associated with plant operation.
The people of Des Plaines, including the higher risk groups, are not
expected to be affected by the operation of the treatment plant.
COMMENT 16
One person wanted to know why the permanent fence is closer to the
aeration tanks than the temporary construction fence and requested it be
moved to the MSD property line.
RESPONSE
The fence is in its present location to be away from the heavy street
traffic and for aesthetic reasons since it is behind the landscaped berm.
COMMEOT? 17
One person wanted an estimate of the number of additional sore throats
to be expected in her family as a result of the emission from the plant.
154
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RESPONSE
No additional sore throats are expected. The emissions will be very small
and primarily confined to the MSDGC property. The plant will treat
fecal wastes, and bacteria and viruses that cause respiratory infections
are generally not contained in such wastes. Incidents of sore throats
were specifically checked at the Egan plant and no increase was found.
COMMENT 18
A comrnenter mentioned a statement by Mr. McCabe of the USEPA that we
do not have the complete, scientific know-how to detect minute differences
with the problem of sewage treatment plant aerosols and asked when the' dose-
response data will be generated.
RESPONSE
A number of persons have misconstrued Mr. McCabe"s comment. To clarify
his comments he has provided input and concurred in the following clari-
fication.
He recognizes that scientific procedures exist which can detect infections
with a high degree of accuracy. These procedures, involving antibody
levels in blood, were utilized in three of the USEPA-sponsored studies.
The other approach utilized, the traditional epidemiological approach
looking for increases of disease, is not as sophisticated, and a number
of disease incidents are required to show a difference from normality.
In addition, other variables unrelated to wastewater treatment plants
could result in false positives and give misleading results.
It is common knowledge that, given a sufficient exposure to a microorganism
via the proper mode of entry, a susceptible person will become infected and
possibly become diseased. What is happening neai: wastewater treatment plants
is that the exposure levels are too low to result in an infection or disease.
Other complex points, such as proper receptor site for the organism, minimum
X infective dose, the relatively small number of respiratory-type organisms
in sewage with the principal mode of entry for the host being inhalation r
the rapid decrease in density if the microbes become airborne, etc.,
all tend to reduce the possibility of an infection from wustewater
aerosols.
Environmental monitoring for microorganisms, despite the comments to the
contrary made by a few persons, is relatively good when put in its proper
perspective. The various studies have shown that bacteria and viruses
can be detected in extremely low densities, although heroic measures
were used for viruses in two instances. For example, in the Pleasanton
study enteroviruses were detected at a density of 1 in 71 cubic meters
of air.
Scientists naturally prefer to have positive controls along with the systems
being tested, to assure that the procedure being used is capable of providing
a positive result, if one exists. In animal studies the dose can be
155
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increased until an effect is noted, but in epidemiological studies this
would be unethical and only naturally occurring situations can be studied.
It is possible in some clinical studies to assure that no real adverse
effects will result and exposure can be carefully evaluated. USEPA has spon-
sored two dose/response studies to determine the minimal infective dose of
viruses by ingestion with a range of doses. Here positive results were
obtained and illness producing infections were noted at the higher doses.
The series of USEPA studie's discussed in this EIS was designed to provide
a gradient of exposure. It was expected that sewage treatment plant
workers would have a maximum exposure to the aerosols and would have
demonstrated infection and illness rates that could be compared to the
much lower exposures off site. The results of the study of workers indicate
that even at higher exposures, infections were not noted by the antibody
or clinical chemistry tests used. Without a positive response it is
impossible to know if the correct agents were sought.
The illness inquiry technique (2-week basis) showed that new workers at
wastewater treatment plants have reported an increase in minor gastro-
intestinal symptoms. When similar techniques were used in the Northside
study, the persons living near the plant did not report increased illness.
A three-month recall questionnaire was used in the John Egan Plant study
which does not supply as reliable data on these subjective measurements.
But the John Egan study involved the startup of a new plant with illness
data obtained before and after startup for comparison. Symptoms of
nausea, vomiting, and diarrhea were associated with the initial operation
of the sewage treatment plant and may be related to the same phenomena
note3 in the new plant workers. The rate of these transient symptoms
in the new workers and for neighbors living closest to the plant was
double that reported by the other individuals studied. Because such an
illness increase was not noted in the experienced workers or the residents
around an old plant, the illness would likely not be expected to continue
and may only be associated with a first exposure to contaminated aerosols.
The etiological agent of the illness is not known and is unlikely to be
one of the viral or bacterial agents checked for in the studies. Trie
situation is something like the classic drinking water contamination
problem where, in half of the instances where an illness is reported,
the etiological agent cannot be determined. Methods for sorolcgical
surveys are being developed for several new agents thought to be associated
with waterborne disease, but such techniques are not available at this
time. Lacking these techniques, an objective study of the risk associated
with unknown agents cannot be made, and the only evidence available
is the more subjective measurement of symptom:; in an illness inquiry
survey.
COMMENT 19
Another commenter reviewed the results of the several USEPA-sponsored
health effects studies and agreed with conclusions of the draft EIS.
It was asked that the draft be finalized and its conclusions implemented.
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RESPONSE
The Agency has proceeded as rapidly as practicable and considered all com-
ments before finalizing the conclusion presented in this final EIS.
COMMENT 20
Numerous citizens wrote to request that the O'Hare wastewater treat-
ment plant aeration basins be covered so as to avoid health problems in the
community. Also, some citizens requested that the aeration basins be
covered, no matter what the cost, because of a fear of health
effects.
RESPONSE
The USEPA is sincerely sympathetic with the concerns of the citizens.
These concerns are understandable in view of citizen exposure to partial
information and a fear of the unknown. The Agency has made a substantial
effort over the past several years to obtain the facts and make a scientific
determination of whether or not the citizens living near the O'Hare
treatment plant would be exposed to a health hazard when the plant is
in operation. All evidence indicates that there will be no hazard.
In addition to a responsibility to protect the environment and the
health of people from environmental insults, the Agency has a responsibility
to society to spend government funds wisely. This responsibility includes
withholding the expenditure of funds to correct non-existent problems.
If the Agency had found that serious health effects to the point of a
health hazard would be associated with the operation of the O'Hare plant,
aerosol suppression facilities would have continued to be required.
The quality of the Agency studies has been scientifically sound and
the studies have been lauded by persons in the public health field.
Individual studies do not carry equal weight, nor was this intended.
While each has its strengths and weaknesses, the overall conclusion
remains that when the results are applied to the O'Hare plant, there
will not be a public health hazard for the residents of Des Plaines.
COMMENT 21
Another person, commenting on the referral to limitations of methodo-
logies used in the USSPA-sponsored studies, questioned the validity of
the findings in view of these limitations. This person also referred
to the conclusion of the Egan study that no health hazard existed for
persons living beyond 400 meters of the treatment plant and asked about
persons living 400 feet from a plant.
RESPONSE
Limitations of methodology are relative. While one person may believe a
a procedure provides excellent sensitivity, another may want to improve
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it even more. The procedures used were adequate to detect a health
effect resulting from a wastewater treatment plant, if an effect existed.
The investigator for the Egan study did not want to speculate on health
effects within 400 meters because no one lived less than this distance
from the plant and all of the persons he tested resided beyond 400 meters.
Closer distances were left to other studies.
COMMENT 22
One commenter was concerned that the distance from plant boundary
to residential boundary is only 100 feet.
RESPONSE
The distance from the nearest aeration tank to the nearest house is
about 385 feet, and the aeration tank is back from the plant boundary
about 240 feet. The nearest basin would have been 1300 feet from
these houses if the City of Des Plaines had not refused to vacate
Wille Road.
COMMENT 23
One commenter stated that, in 1975, state and federal authorities
premised to control the release of aerosols.
RESPONSE
The Agency initially required aerosol suppression facilities because
at that time not enough was known about aerosols. (Also see response 46.)
COMMENT 24
One commenter stated that the expenditure of $500,000 for covers
is the minimum that can be expected.
RESPONSE
This Agency looked at various covering schemes. One design scheme uti-
lized corregated fiberglass panels as suggested by the commenter. This
scheme included a 3 foot spacing of 2 X 12's spanning the channel with
transverse 2 X 4's at 4 feet spacing, peripheral closure boards, peripheral
1/2 inch round cinch anchors on 4 foot centers, washable screen filters
per 3 foot section, and the plumbing and hoses necessary to flush the
filters.
We concur with the commenter's findings that covers would exceed $500,000.
We do not, however, agree with their need because all evidence indicates
that there is no health hazard to the public from wastewater aerosols.
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The decision to install covers at the Clavey Road plant was made before
much information was known about aerosols, and these covers increased
the cost of the plant by 24 percent.
COMMENT 25
One commenter stated that "if a waiting room of a lawyer's office is com-
pared to one at a pediatrician's office, the lawyer's office would be
the more healthy place to be. A sewage treatment plant is just the
type of operation where the worth combination of viable microbial aero-
sols are just waiting to affect those living in close proximity."
RESPONSE
The Agency agrees with the scenario that a greater risk is encountered
by a person waiting in the pediatrician's office. On the other hand,
Des Plaines parents send their children to school every day without
fear. The classroom presents a far greater risk to the children of
getting an infection than would be the case with living near the 0'IIare
wastewater treatment plant. Safety may be defined as the acceptability
of a risk. If going to school is considered safe, living near the
plant is even safer.
At times, numerous basements are flooded with raw sewage when sewers
back up. This condition is a health hazard and will be corrected by
the MSD project when operational. The Mayor of the Village of Mount
Prospect, contiguous to Des Plaines, put the situation in perspective
in a letter which is printed on Volume II, page 6-134 of the original
environmental impact statement. Part of his letter is quoted below.
"Inadequacy of the present MSD facilities for removing
sewage from our community have been well documented over
the past ten years and it is the same for our sister
connmunities, Elk Grove Village and Des Plaines. The in-
ability of the MSD interceptors to handle our accumulated
sewage results in raw sewage being overflowed into our
creeks and drainage ditches and backed up into the base-
ments of our residents. For seven years the means to
resolve this major area problem has been at hand, but the
spector of bad environmental impact has been used to delay
the implementation of this most needed facility. No one
can convince me that raw sewage stored in the basements of
residences and spread across the open land is preferable
to storage of such sewage in controlled circumstances.
Unless your Agency can assure our citizens that the storage
of raw sewage in and about our properties is a lesser
health hazard than the storage of such sewage at the O'Hare
treatment facility, I would believe it mandatory that you
approve this facility for immediate construction. I do not
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believe that a project designed via established experts in
the sanitary field can be so patently deficient as to warrant
the attacks being made on this project. If after seven years
the "alleged" deficiences have escaped the notice of the Federal
experts, I would suspect that political pressure is not replacing
reason. We are not considering a beautification project for
the area, but a much needed reclamation plant to treat our own
sewage in a controlled and healthy mannner."
COMMENT 26
One commenter wrote, "It is inexcusable that Region V did not
advise the citizens near O'Hare that the 1975 promise of evaluating
aerosol suppression alternatives would be side-tracked and a high
priority put on eliminating the need."
RESPONSE
Phase 1 of the suppression study is still ongoing and will be completed
in March 1980. Initiation of Phase 2 and 3 for the construction of a pilot
plant and the evaluation of alternate suppression systems is pending the
outcome of this work.
COMMENT 27
One commenter wrote, "The six studies provided no clear answers - just
the hint that no significant health hazard exists."
RESPONSE
This point is discussed in each study. All studies together, though,
indicate that no health hazard exists. (Also, see response nos. 5 and 21.
COMMENT 28
One commenter quoted Mr. McCabe's statement that we don't have the scientific
know-how to address the aerosol problem.
RESPONSE
A discussion of Mr. McCabe's statement is presented in response no. 18.
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COMMENT 29
One commenter quoted the following comment made by Mr. McCabe -and used it
out of context: "If the suppression can be accomplished at less cost,
then I don't think the health effects would have to be so unequivocal."
RESPONSE
' Mr. McCabe's statements reads:
"If we are requested to continue the health effects studies,
it would be well to also research the cost of aerosol suppression?
then more realistic trade offs could be made in the future.
If suppression were very costly, we would need unequivocal health
effects to justify the cost; but if some less costly techniques
are available, health effects data would not need to be as firm.
From what we have heard there would seem to be little justification
for large expenditures to contain aerosols based on a national
policy, or even for a single plant. The designer of sewage treatment
plants must continue to be concerned, however, and do what can
be done to minimize aerosols. Here is where the more than scientific
considerations are involved - the public must feel that their
interests are considered."
COMMENT 30
The following two sentences were quoted by a comenter from the report of
the sero-epidemiological study near the John Egan wastewater treatment
plant.
"Overall findings did not detect a health hazard for persons living
beyond 400 meters (1312 feet) from the well operated wastewater
treatment plant." "From patterns observed in the household health
survey, the increased incidence of skin disease, and the symptoms
of nausea, vomiting, general weakness, diarrhea, and pain in chest
on deep breathing may be associated with the nearby operation of
the wastewater treatment plant."
RESPONSE
The illnesses quoted increased from 1.2 percent to 3.5 percent. Not
mentioned were the number of illnesses shown to decrease during the
same period based on questionnaire results. Examples are colds.
fevers, and sore throats for the people living close in. A more sensitive
testing procedure, checking 31 viral antibodies and attempted isolations
of many pathogenic bacteria, parasites, and virus yielded no evidence
of an adverse wastewater treatment plant effect.
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COMMENT 31
The following is a quote of one commenter. "... you could not expect
to find anything more significant than from the most sensitive study.
And the roost sensitive studies examined the blood of newly exposed indi-
viduals. But the Egan subjects were all beyond 400 meters and the newly
exposed tforthside subjects were too few. Only 60 ... lived within
1/2 mile from the aeration tanks for less than 1 year. If immunities are
developed in 3 months, then the sample size is down to 15. The thousands
of potentially newly exposed people near the o'Hare plant cannot accept
such weak evidence."
RESPONSE
Immunity is conferred when antibody to a microorganism is increased
as a result of sufficient exposure. As stated previously, a rise in
antibody titre related to exposure to wastewater was considered by the
Agency to be an adverse health effect. However, the development of
immunity was not found. The situation at the Norhtside plant is almost
identical to the Des Plaines location. At Northside, the nearest houses
are only 500 feet from the nearest aeration basins and a school is located
1500 feet from the basins. No health effects were found in the nearby
residents. In the Northside study persons were checked for antibody
at the beginning of the observation period as well as at the end. A
rise in antibody to a microorganism for which immunity was not present
at the beginning, even for a person in residence longer than a year,
could be considered equivalent to a similar occurrence in a newly exposed
person. At O'Hare, thousands of potentially newly exposed people do
not live within a few hundred meters of the plant as implied.
COMMENT 32
In summarizing the Northside plant study one commenter wrote, "The people
that prepared the study are telling us that this plant is not representative
of all plants in the United States."
RESPONSE
The investigators had no intention of implying a comparison to all
other plants in the U.S. However, the Northside plant is repre-
sentative of the O'Hare plant because it has essentially the same
aeration basin design. This was the basis for selecting this plant
by the University of Illinois and the USEPA.
COMMENT 33
One commenter wrote, "The Durham students probably received a peak daily
dose of about 9 cfu of mycobacteria and 3.5 cfu of fecal streptocci
about one school day per year."
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RESPONSE
A peak, by definition, is the highest day only. The classroom was
exposed half-time 54 days per year from tha aeration basin and 53 days
per year from the surge basin. The playground was exposed half-time
74 days per year from the aeration basin and 96 days per year
from the surge basin.
COMMENT 34
About the Durham school student exposure one commenter wrote, "At this
dose and frequency, a rather insensitive measure, school attendence, provided
no evidence of an adverse health response.
RESPONSE
Illness, as reflected by school absenteeism is generally considered a rela-
tively insensitive measure of health effects because absenteeism is also
related to socioeconomic factors and teachers. These problems are more
prevalent in lower socioeconomic groups, but Durham elementary school
serves upper middle class children.
COMMENT 35
On the Pleasanton study one commenter wrote, "Until the necessary dose-response
relationships are developed neither the level of aerosolized microorganisms
that constitute a hazard nor the degree of required disinfection can be
specified."
RESPONSE
The Pleasanton study covered a period from May 1976 to April 1977,
prior to the results from the several epidemiological studies being
available. The dose-response relationship was attempted in subsequent
studies.
COMMENT 36
On the workers in Copenhagen, one commenter wrote, "Therefore one can
conclude that workers who have spent more than 8 years in Copenhagen sewers
have about twice the death rate of all Copenhagen males."
RESPONSE
Copenhagen sewer workers have lower sick leave rates than street repairman,
garden and park workers, and workshop and warehouseman. A mortality study
of former employees of the MSDGC has shown no significant departure from
normal expected rates.
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COMMENT 37
On Tecumseh, one commenter wrote, "Higher rates of illness transmission
in areas of higher densities of lower socioeconomic families could have
contributed to these findings. Or conversely the plant could be responsible
for the high rate of respiratory illnesses near the plant."
RESPONSE
The investigator stated, "The larger than expected number of persons
developing illnesses nearest the wastewater treatment plant during
the sunnier may be attributable to reduced levels of sanitation with-
in a lower socioeconcmic group during a period of higher enterovirus
infection incidence." Also see Resoonse No. 58.
COMMENT 38
On the sewage treatment plant workers study, one commenter wrote,
"However, two examples in Tables 44 and 46 seem to be significant and
were classified as "no significant difference." Out of 183 exposed
workers, 7 (or 3.8%) showed enterovirus isolation and only 1 out of 77
(1.3%) of the non-exposed workers were positive. In Table 46 the
difference was even greater, 3.4% versus 0.6%."
RESPONSE
These differences yielded a "p" value of 0.28 and 0.06 respectively.
The "p" value must be less than 0.05 to be stated significant. There-
fore neither was considered significant.
COMMENT 39
One commenter wrote, "I had no idea that six separate studies were quietly
progressing to eliminate the very need of suppression."
RESPONSE
The initial decision to require aerosol suppression devices was made
because not enough was known about aerosols. The Agency went ahead
to further evaluate aerosols, not secretively and riot with the in-
tent to eliminate the need for suppression.
COMMENT 40
After developing a worst case scenario, one commenter asked, "Please comment
on why there was no response or action taken to obtain this adverse data."
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RESPONSE
The EPA Health Effects Research Laboratory conducted a research program
to answer the health questions. Persons were exposed to varying weather
conditions during the study period. All natural occurring health responses
which took place during the study period were investigated. A worst case
situation may have occurred. In Response Nbs. 9 and 10 on dispersion
models, a worst case bacterial count was given. Also, Response No. 15
considers the risk to persons with a medical problem.
OOMMEMT 41
One commenter wrote, "The entire draft EIS is a classic example of trying
to fit the evidence to the desired conclusion."
RESPONSE
The conclusion was based on the evidence obtained since 1975.
COMMENT 42
One commenter asked, "What aerosol dose of bacteria and viruses results
in a response in humans?
RESPONSE
See Response No. 18.
COMMENT 43
One commenter asked, "And how frequently will the plant exceed this dose
under adverse conditions?
RESPONSE
The plant will not cause exposure exceeding that discussed in Response
No. 18.
COMMENT 44
One commenter stated, "Apparently, they just continue to take data until
the averages ended up where they wanted them. The USEPA's staff in Cincinnati
should reconstruct this data to see if the implications or conclusions
are justified."
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RESPONSE
Sampling protocols were developed in advance. It is inappropriate
for the commenter to try to draw conclusions based on only the first
20 percent of the samples. These studies were sponsored, reviewed
and approved by the USSPA staff in Cincinnati.
COMMENT 45
One commenter quoted Dr. Johnson, "Primary negative findings were found
relative to adverse health effects related to the transport of pathogenic
aerosols to exposed populations. These results should not be accepted
as conclusive findings."
RESPONSE
This was the first health study completed and the results of this
one study was not accepted as conclusive findings. Additional
studies were carried out.
COMMENT 46
One cornmenter stated, "Another quote from the study reveals ... that
increased incidents of skin disease and symptoms of nausea, vomiting, general
weaknesses, diarrhea and pain in the chest on deep breathing occurred close
to the sewage treatment plant... You won't find that in the blue book
handed out this evening."
RESPONSE
This statement was included in the draft EIS on Page 8.
COMMENT 47
One commenter made the following statement, "One of the study conclusions
was 'Results for alpha and gamma hemolytic streptococci isolations in
the throat swabs for the subjects from the Lexington Green Apartments
provide some evidence that the pattern may relate to exposure to the
wastewater treatment plant aerosols.1"
RESPONSE
The commenter omitted the next two sentences, which state, "However,
alpha- and gamma-hemolytic streptococcus species are part of man's normal
flora in the intestinal tract, upper respiratory tract and skin, and of his
environment (e.g., vegetation, insects, and animal feces) and do not normally
produce disease. Therefore, their presence in the vicinity of the wastewater
treatment plant or in the throat swabs is of little practical health concern.
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Thirty-one viral antibody tests and attempted isolations of many pathogenic
bacteria, parasites, and viruses yielded no evidence of an adverse waste-
water treatment plant effect.' Streptococcus alpha and gamma isolations
are common in all people as indicated by the high percentage found. Alpha
streptococci colonize the human upper respiratory tract within the first
few hours after birth.
COMMENT 48
One commenter stated, "If you have not read the basic report [Pleasanton
study] which has not been distributed yet, then this will be news to
everyone except the Region V people who apparently dread any reference
to dose response... Until the necessary dose response relationships
are developed, neither the level of aerosolized microorganisms
that constitute a hazard nor the degree of required disinfection
can be specified."
RESPONSE
Since the study developed a model to determine dose and did not evaluate
populations, a response was not determined. A dose response was attempted
in the several other studies which found the exposure did not cause a
response. The low exposure was apparently below the minimum infection
dose. Also, see Response No. 18.
COMMENT 49
One commenter quoted Dr. Sorber, "The fact is that considerable questions
remain as to the level of risk to be associated with microbiological aerosol
from wastewater operations in this country including spray irrigation."
RESPONSE
Dr. Sorber did not say that the risk is high. He was asking £ibout a
numerical value. Such a value is presented in another response as calcu-
lated by Bahman Sheikh-ol-Eslami. Also, see Response No. 10.
COMMENT 50
One commenter concluded by saying, "The audience is very patient with the
review of the seven studies and my presentation leads to considerably dif-
ferent condlusions than the whitewash in the draft EIS."
RESPONSE
The EIS presented relevant information from reports by scientists outside
of USEPA and tried to be objective. The conclusions of the outside
scientists and USEPA scientists differ from those of the commentor.
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The following responses are listed without listing~the specific comment.
RESPONSE 51
The closest homes to the O'Hare aeration basins are 385 feet away, not
150 feet as stated.
RESPONSE 52
The one effect reported by the workers studied was an increase in gastro-
intestinal illness for new workers exposed to sewage when compared to
experienced workers with similar exposure. These workers are chronically
exposed to much higher levels of aerosols than nearby residents and have
direct contact with sewage.
RESPONSE 53
Exposure levels at Tigard were estimated using 4 wind direction measure-
ments per day, and therefore variable exposure levels could have
resulted from wind direction variations between the wind direction
measurements made.
RESPONSE 54
This statement seems to be in error, since Mr. McCabe's written text
of his speech states that "there seems to be little justification as
far as expenditures for aerosol suppression at this time...."
Also see Response No. 18.
RESPONSE 55
This statement is included in the final EIS,
RESPONSE 56
This information is discussed on Pages 36 through 38 of the final EIS.
RESPONSE 57
People moved into the Lexington Green Apartments while the study was in
progress, and these residents were 400 ra (1312 feet) from the plant.
This study was designed as an exploratory study to see if further
study was necessary. It indicated possible effects, so more research
was initiated.
RESPONSE 58
The researchers reached this conclusion since, "In general persons
living in the WWTP 600 m boundary concentric circle had less education
and lower income than in either the comparable control group or other
WWTP rings." Also, significant differences in illness incidence between
the control and WWTP groups were found only in the least educated group,
and not intermediate and higher educated families. Also, no significant
differences in illness incidence were found for individuals dwelling at
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specified distances from the control location, or WWTP group when
specified for education. Furthermore, significant illness incidence
differences were seen in both the WWTP and control location concentric
rings when income was specified, the most significant being for the lowest
income level in the WWTP and control group.
Therefore, these differences indicate that "Higher rates of illness
transmission in areas of higher densities of lower socioeconomic
families could have contributed to the findings."
RESPONSE 59
We concur and have removed this information.
RESPONSE 60
A statement which is similar to the claimed omission was included in the
draft and final EIS: "Sewer workers experienced a high rate of gastro-
intestinal tract disorders which the workers associate with chemical odors
and infectious agents."
RESPONSE 61
This statement was not withheld and has been included. The report in which
it was made was available as a reference document.
RESPONSE 62
See Response 63 and 18.
RESPONSE 63
While additional information and further research is always desirable to
have in a decision making process, it is also necessary at times to make
decisions based on the best available information. It is our determination
that sufficient information has been developed since May 1975 to allow us
to review the decision originally reached in the May 1975 EIS.
RESPONSE 64
Organisms and sampling methods considered appropriate were used in the studies
which evaluated possible demographic and socioeconomic effects before drawing
conclusions about possible health effects.
RESPONSE 65
We agree that it is important to continue to examine research related to
the health effects of wastewater aerosols.
RESPONSE 66
In the Tecumseh, Michigan study the data suggests that the higher illness
rates detected may be related to higher densities of lower socioeconomic
families near the WWTP. Also see Response No. 58.
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RESPONSE 67
The Egan study did not detect a significant health hazard for persons
living beyond 400 meters of the WWTP. Other studies referenced in the
draft EIS evaluated potential health effects of residents as close as
152 meters, elementary school children as close as 40 meters from
the aerosol source, and STP workers who are exposed to the highest
aerosol levels and have direct contact with sewage.
RESPONSE 68
We agree that the basement flooding resulting from the existing over-
loaded sewerage system is a known hazard. This situation presents the
hazard of direct contact and transmission of pathogens from wastewater
accumulated in basements.
RESPONSE 69
The Northside, Egan, and University of Cincinnati studies attempted to
develop more sensitive clinical dose-response relationships for the
pathogenic microorganisms prevalent in wastewater.
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VI. LIST OF PREPARERS
Richard Beardslee, Environmental Engineer, USEPA, Region V.
Gene Wojcik, Chief, EIS Section, USEPA, Region V.
Stephen Poloncsik, Chief, Technology Section, USEPA, Region V.
James Novak., Environmental Engineer, USEPA, Region V.
VII. LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THIS
STATEMENT WERE SENT:
The following Federal, State, and local agencies were requested to
comment on the Draft Supplement Environmental Impact Statement:
Council on Environmental Quality
Department of Agriculture
Soil Conservation Service
U.S. Army Corps of Engineers
North Central Division
Chicago District
Department of Energy
Argonne National Laboratory
Department of Health, Education and Welfare
Department of Housing and Urban Development
Department of the Interior
Heritage Conservation and Recreation Service
Fish and Wildlife Service
Geological Survey
Department of Transportation
Federal Aviation Administration
Governor of Illinois
Illinois Sanitary District Observer
Illinois Institute for Environmental Quality
Illinois Environmental Protection Agency
Illinois Division of Waterways
Illinois Department of Conservation
x Illinois Department of Public Health
Northeastern Illinois Planning Commission
Cook County Department of Environmental Control
Metropolitan Sanitary District of Greater Chicago
City of Des Plaines
Village of Elk Grove
Village of Arlington Heights
Village of Mount Prospect
Village of Palatine
Village of Wheeling
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VIII. SELECTED REFERENCES
i 1. Camann, D. E., H. J. Harding, D. E. Johnson, C. A. Sorber, 1979.
Environmental Monitoring of a Wastewater Treatment Plant. Southwest
Research Institute.
2. Camann, D. E., M. N. Guentzel, H. J. Harding, D. E. Johnson, J. W. Register,
C. A. Sorber, J. M. Taylor, R. E. Thomas, 1977. The Evaluation of Micro-
biological Aerosols Associated With the Application of Wastewater to
Land: Pleasonton, California. Southwest Research Institute.
3. Camann, D. E., J. M. Hosenfeld, D. E. Johnson, R. J. Prevost, J. W. Register,
J. M. Taylor, R. E. Thomas, J. B. Tillery, 1978. Health Implications of
Sewage Treatment FAcilities. Southwest Research Institute.
4. Carnow, B., J. Holden, S. Meyer, A. Neal, R. Northrop, S. Rosenberg,
P. Scheff, L. Sheaff, R. Wadden, 1979. Health Effects of Aerosols Emitted
From an Activated Sludge Plant. University of Illinois School of Public
Health.
5. Clark, C. S. Health Risks of Human Exposure to Wastewater. University
of Cincinnati Medical Center.
6. Cochran, K. W., K. F. Fannin*, A. S. Monto, H. Ross, 1978, Health
Effects of a Wastewater Treatment System. University of Michigan and
*IIT Research Institute.
7. Lun Dean Environmental Company, 1978. Assessment of Disease Rates Among
Sewer Workers in Copenhagen, Denmark. Health Effects Research Laboratory,
Office of Research and Development, U.S. Environmental Protection Agency.
8. U.S. Environmental Protection Agency, 1975. Metropolitan Sanitary District.
of Greater Chicago O'Hare Water Reclamation Plant and Solids Pipeline
Environmental Impact Statement.
9. Bryan, Frank L. Diseases Transmitted by Foods Contaminated by Wastewater,
Wastewater Use in the Production of Food and Fiber—Proceedings, June 1974,
pp. 14-16.
10. Personal communication between USEPA's Health Effects Research Laboratory
personnel in Cincinnati, Ohio and USEPA Region V personnel on preliminary
data from an ongoing University of Cincinnati study and an ongoing Univer-
sity of Wisconsin study.
11. Bahlman Sheikh-ol-Eslami, et al., Aerosol Generation in Sprinkler
Irrigation, Water Reuse Symposium—Proceedings, Vol. 3, March 25-30, 1979,
Washington, D.C., pp. 2248-2250.
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IX. GLOSSARY OF TERMS
acquired immunity—specific immunity attributable to the presence of antibody
and to a heightened reactivity of antibody-forming (and phagocyte) cells
after exposure to an infective agent or its antigens.
activated sludge sewage treatment plant—a biological wastewater treatment
, system in which a mixture of wastewater and biological sludge (microorganisms)
is agitated and aerated. The solids are separated from the treated waste-
water and returned to the aeration process, as needed.
adenovirus—a group of thirty-one viral sero-types that cause diseases of
upper respiratory tract.
aerosol—colloidal-size droplets dispersed in the atmosphere (air).
alpha and gamma hemolytic streptococci—aerobic, facultative/anaerobic
Streptococcus genus of bacteria; gram positive spheric (or oval) cells
occurring in pairs or chains. Beta hemolytic group include human and animal
pathogenic; alpha hemolytic occur as normal flora in upper respiratory and
. intestinal tract.
antibody—an inmunoglobulin molecule of specific amino acid sequence which
interacts only with the antigen that initiates its synthesis in lymphoid
tissues or with antigen closely related to it.
antigen—any substance which is capable, under appropriate conditions, of
inducing formation of antibodies and of reacting specifically, in some
detectable manner, with the antibodies so induced.
bacteria—typically one-celled microorganisms containing no chlorophyll—
some cause diseases and others are necessary, e.g., for nitrogen transforma-
tions, fermentation and organic matter decomposition.
Biochemical Oxygen Demand (BOD)—a standard test, used in assessing waste-
water composition, which measures the oxygen required to oxidize the
organic matter in a sample under standard conditions,
"N
cfu—colony forming units.
cfu/m3—colony forming units per cubic meter.
Chemical Oxygen Demand (COD)—the amount of molecular oxygen required to
oxidize all compounds in water, organic and inorganic.
Clpstridium perfrigens—a gas-producing species of bacteria that produce
several toxins and are the principal cause of gas gangrene in humans.
Also known as Clostridium welchii.
coefficient of variation—the statistical ratio of the standard deviation
of a distribution to its arithmetic mean.
173
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coliform—an organism found in the intestinal tract of humans and animals.
Its presence in water indicates pollution and potentially dangerous
bacterial comtarnination.
coliphage;—any bacteriophage able to infect Escherichia coli.
composite sample—a combination of individual samples taken at selected
intervals that represents the total, material (population) being sampled.
coxsackievirus—one of the enteroviruses producing a disease resembling
poliomyelitis but with no paralysis.
echo virus—one of a subgroup of the picornoviruses infecting the gastroin-
testinal tract and discharged in the excreta; includes polioviruses,
coxsackieviruses and echoviruses.
enterovirus—a subgroup of human viruses including the coxsackieviruses
and the echoviruses.
epidemiology—a field of medicine concerned with the determination of
specific causes of local outbreaks of infection, e.g., hepatitis and
toxic disorders such as lead poisoning and other diseases of recognized
etiology.
flora—plant life in a specific location.
free chlorine—the free elemental form of chlorine from a chemical used
for the disinfection or ixidation of drinking water, sewage, or industrial
waste.
gamma globulin—any of the serum proteins with antibody activity. Also
known as immune globulin.
gastrointestinal—pertaining to that portion of the digestive system
including the stomach, intestine, and all accessory organs.
health hazard—a health effect which represents an increased risk of
exposure to danger, harm, injury, or loss which has distinct medical
concern in comparison with the risks of infection otherwise encountered
in normal daily life.
intestinal flora—bacteria normally residing in the lumen of the intestine.
Klebsiella—a genus of nontnotile, rod-shaped bacteria in the family of
Enterobacteriaceae; species are human pathogens.
liter—a unit of metric volume or capacity equal to 1000 cubic centimeters.
mfc—membrane filter count.
mixed liquor—a mixture of activated sludge and water containing organic
matter undergoing activated sludge treatment in the aeration tank.
micrometer C«m)—a unit of metric length equal to one-millionth of a meter.
174
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mucoid type—pertaining to large colonies of bacteria characterized by
being moist and sticky.
parasitic worms—worm-like organisms that live in or on another organism
of different species from which it derives nutrients and shelter.
^articulates—fine solid particles which remain individually dispersed
in gases and stack emissions.
'pathogen—disease-producing organism.
pfu—plaque forming unit.
pH—a term used to describe the hydrogen ion activity of a system,
or how acid or alkaline a material is presently.
Proteus—a genus of Enterobacteriaceae that occurs in the motile and
non-motile forms.
Protozoa—a diverse phylum of microorganisms; the structure varies from a
simple uninucleate protoplast to colonial forms.
Pseudomonas—a genus of the Pseudomonadaceae family; most species are
aerobic and include cellulose decomposers and human, animal, and plant
pathogens.
regression analysis—analysis which measures the mean expectation one
variable to another, given two dependent random variables.
Salmonella—a genus of rod-shaped pathogenic bacteria of the family
Enterobacteriaceae that are usually motile by flagella.
scatter diagrams—statistical diagrams involving the plotting of the
pairs of values of two variates in rectangular coordinates.
Shigella—the dysentery bacilli, a genus of the family Enterobacteriaceae.
serological—pertaining to the branch of science dealing with the properties
and reactions of blood sera.
sero survey—a survey involving the properties and reactions of blood sera.
sputum—matter discharged from the surface of the respiratory passages,
mouth, or throat; may contain saliva, microorganisms, blood, or inhaled
particulate matter in any combination.
Streptococcus—a genus of the tribe Streptococceae including many patho-
genic strains; the cells are round and occurring characteristic chains.
titer—the concentration in a solution of a dissolved substance as shown
by titration.
total organic carbon (TOG)—a measure of the amount of organic material in
a water sample expressed in milligrams of carbon per liter of solution.
175
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total suspended solids (TSS)—the total number of small particles of solid
pollutants in sewage that contribute to turbidity and that resist separa-
tion by conventional means.
viable—capable of living, e.g., a pathogen capable of infecting.
virus—a large group of infectious agents capable of infecting animals,
plants, and bacteria; characterized by total dependence on living cells.
windrose pattern—a diagram in which statistical information concerning
direction and speed of the wind at a location may be summarized.
176
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X. Index
activated sludge - pg. 1, 2, 3, 5, 9, 14, 17, 19,
21, 22, 27, 28 32, 34, 35, 36
adenovirus - pg. 7, 40
aeration tanks - pg. 3, 17, 18, 21, 35,
aerosol suppression - pg. 1, 2, 3, 36, 37
aerosols - pg. 1, 2, 3, 4, 6, ,7, 8, 9, 10, 11, 12,
13, 17, 18, 19, 21, 22, 23, 24, 28, 29,
33, 34, 35, 36, 37
ambient - pg. 6, 11, 18, 22, 34, 35
Anderson 2000 six stage (A6S) - pg. 18, 29, 33
antibody - pg. 8, 20, 27, 30, 31, 32, 33
barminutors - pg. 21
Biological Oxygen Demand (BOD) - pg. 5, 9, 10
Chemical Oxygen Demand (COD) - pg. 9, 10,
Clostridium perfringens - pg. 9, 11, 12, 13, 34
coliphage - pg. 7, 8, 9, 10, 11, 12, 13, 18, 23, 24, 34
collection system - pg. 3
coxsackievirus - pg. 7, 19
combined sewer overflow (CSO) - pg. 2, 37,
cytomegalovirus - pg. 29
Echovirus - pg. 7, 10, 19
enteric - pg. 7, 10, 22
enteroviruses - pg. 8, 9, 11, 12, 23, 24, 34
epidemiological - pg. 5, 6, 9, 24, 25, 27, 34
fecal coliform - pg. 7, 11, 12, 18, 34
fecal streptococci - pg. 9, 11, 12, 13, 23, 24
flora - pg. 8
free chlorine - pg. 9
gamma globulin - pg. 26
gastrointestinal - pg. 15, 19, 20, 26, 30, 32, 35
Hepatitis A or B -- pg. 31
iirmunoglobulin - pg. 27, 28, 30, 32
Klebsiella - pg. 9, 12, 13, 23, 34
land application - 9
Legionella pneumophilia - pg, 32
Leptospira - pg. 32
lime addition - pg. 9
Litton Large Volume Air Sampler (LVAS) - pg. 18, 33, 34
- 177 -
-------
microbiological - pg. 6, 7, 8, 9, 10, 11, 12,
13, 18, 19, 23, 34, 35
microorganisms - pg. 3, 7, 9, 10, 11, 13, 22,
23, 24, 29, 33, 34, 25
mixed liquor - pg. 7
mucoid type - pg. 12
mycobacteria - pg. 11, 12, 13, 23, 24, 25, 34
nitrates - pg. 9, 18
parasites - pg. 8, 29, 30, 32, 33
pathogens - pg. 6, 8, 9, 10, 11, 12, 13, 23, 24
Proteus - pg. 7
Protozoa - pg. 7
Pseudomonas - pg. 7, 9, 11, 12, 13, 23, 24
Salmonella - pg. 23, 32
seroconversion - pg. 31
serological - pg. 20, 27, 29, 30, 31
shigella - pg. 7, 23
solar radiation - pg. 11, 22, 23
sputum - pg. 7, 8
Staphylococcus - pg. 34
stormwater - pg. 2, 34
streptococcus pg. 7, 8
sulfates - pg. 18
titer - pg. 31, 33
total coliform - pg. 11, 12, 13, 17, 18, 20, 23,
24, 34, 35
total organic carbon - pg. 9, 10
total suspended solids (TSS) - pg. 5, 9, 18, 20
total viable particles (TVP) - pg. 7, 9, 17, 18, 19,
20, 32, 34, 35
viruses - pg. 7, 8, 10, 18, 22, 27, 29, 30, 31, 32, 33
windrose pattern - pg. 7
MS:gw:Tape tlO:12-27-79
- 178 -
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