PB95-964204
EPA/ROD/R06-95/095
May 1996
EPA Superftmd
Record of Decision:
RSR Corporation Site,
Operable Unit 1, Dallas, TX
5/9/1995
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RECORD OF DECISION
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT NO. 1- RESIDENTIAL PROPERTY
DALLAS, TEXAS
Prepared by:
U. S. Environmental Protection Agency
Region 6
Dallas, Texas
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DECLARATION FOR THE RECORD OF DECISION
RSR CORPORATION SUPERFUND SITE OO
OPERABLE UNIT NO. 1- RESIDENTIAL PROPERTY
DALLAS, TEXAS
Further Action Not Necessary For Protection
And Five-Year Review Is Not Required
SITE NAME AND LOCATION
RSR Corporation Superfund Site, Operable Unit No. 1
Dallas, Dallas County, Texas
STATEMENT OF BASIS AND PURPOSE
The United States Environmental Protection Agency (EPA) presents
its decision in this Record of Decision (ROD) that no further
action will be required at the residential and high risk areas
(such as schools, church play areas, parks, and day care
facilities) of Operable Unit No. 1 (OU No. 1) of the RSR
Corporation Superfund Site (RSR Site). EPA's decision is in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA or Superfund), 42 U.S.C.
§ 9601 et seq., and the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), 40 C.F.R. Part 300. The decision
is based on materials and documents contained in the Administrative
Record for OU No. 1 that is available for public review at three
repositories, one of which is located in west Dallas near the RSR
Site. EPA bases this decision on the results of a remedial
investigation and human health risk assessment conducted at OU No.
1 and the successful completion of the emergency removal action
conducted by EPA at OU No. 1 from October 1991 through June 1994.
DESCRIPTION OF THE SELECTED REMEDY/RATIONALE FOR NO FURTHER ACTION
No further action is necessary at the residential and high risk
areas of OU No. 1 because EPA's emergency removal action
permanently eliminated the principal threats to human health and
the environment from smelter-related lead and arsenic contamination
at OU No. 1 by removal and offsite disposal of contaminated soils
and debris. Lead and arsenic are hazardous substances, as defined
in Section 101(14) of CERCLA, 42 U.S.C. § 9601(14), and further
defined in Section 302.4 of the NCP, 40 C.F.R. § 302.4. High
concentrations of lead and arsenic were found to be present in the
residential and high risk areas of OU No. 1 resulting in potential
exposure by many people living in the area.
In order to avoid substantial delay in responding to these
residential and high risk areas, EPA initiated the emergency
removal action. EPA designed the removal action to provide long-
term protection to persons living in the residential areas and
established conservative health-based soil cleanup levels to be
instituted under the removal action. EPA implemented the removal
action and removed contaminated soils to health-based action levels
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_-•..-.
from reaMenftfa^|^»?a«cfWherevaccessi,wa&tgranteate
Deputy Regional Administrator
U.S. EPA - Region 6
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DECISION SUMMARY
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT NO. 1- RESIDENTIAL PROPERTY
DALLAS, TEXAS
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RSR CORPORATION BDPERFUND SITE
OPERABLE UNIT NO. 1- RESIDENTIAL PROPERTY
DALLAS, TEXAS
TABLE OF CONTENTS
TITLE PAGE
I. Site Name, Location, and Description 1
II. Site History and Enforcement Activities 2
III. Highlights of Community Participation 3
IV. Scope and Role of Response Action 4
V. Site Characteristics 5
VI. Summary of Site Risks 7
VII. Evaluation Criteria 14
VIII. Statutory Authority Findings and Conclusions of Law 17
IX. Documentation of no Significant Change 18
LIST OF TABLES AND FIGURES
FIGURES
Figure 1 Site Location Map/Site Boundaries
APPENDIX
A. Responsiveness Summary
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DECISION SUMMARY
RSR CORPORATION 8UPERFUND SITE
OPERABLE UNIT NO. 1- RESIDENTIAL PROPERTY
RECORD OF DECISION
I. SITE NAME. LOCATION, AND DESCRIPTION
EPA is addressing the release or threat of release of hazardous
substances at the RSR Corporation Superfund Site (RSR Site) under
the authority provided in the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), 42 U.S.C. § 9601 et seq.
(also known as Superfund) and consistent with the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R.
Part 300. The RSR Site is located in west Dallas, Texas and
encompasses an area approximately 13.6 square miles in size. The
RSR Site is very diverse and includes large single and multi-family
residential neighborhoods, multi-family public housing areas and
some industrial, commercial and retail establishments.
Contamination at the RSR Site reportedly originated from the
operation of a secondary lead smelter facility located in the heart
of west Dallas for approximately 50 years. Specifically,
contamination of the RSR Site resulted from the fallout of
historical air emissions from the RSR smelter stack, from the use
by residents of lead slag and battery casing chips as fill material
in residential driveways and yards and from the disposal of smelter
wastes in several disposal areas including two areas operated as
local municipal landfills.
In order to expedite Superfund response actions at this large site,
especially with regard to the residential areas, EPA divided the
RSR Site into five Operable Units (OUs), Figure 1:
OU No. 1 - Residential Property
OU No. 2 - Dallas Housing Authority (DHA) Property
OU No. 3 - Slag Piles
OU No. 4 - Smelter Facility
OU No. 5 - Other Industrial Property Associated with the
Smelter
This Record of Decision (ROD) addresses the private residential
properties and high risk locations such as schools, church play
areas, parks, and day care facilities of OU No. 1. Industrial,
commercial, and retail establishments are not included in the ROD
for OU No. 1. OU No. 1 is bounded on the north and east by the
Trinity River, on the south by Ft. Worth Avenue, and on the west by
State Highway Loop 12 (Walton Walker Blvd.). OU No. 1 includes
primarily single and multi-family housing. Several schools,
churches, parks, recreation facilities, and day care centers also
are present within OU No. l. The population within OU No. 1
numbers approximately 17,000.
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Trinity River
SITE 3
SITE 4
RESIDENTIAL PROPERTY IOU NO. 1)
DALLAS HOUSING AUTHORITY (DHA) PROPERTY IOU NO. 2)
SLAQ PILES IOU NO. 31. SITES 1. 3. AND 4
MUHMUR/RSH SMELTER-TRACT 1 (OU NO. 41
OTHER MUHMER/RSR INDUSTRIAL PROPERTY IOU NO. 51
RSR/OU4-5/65680D50.DGN
FIGURE 1
VICINITY MAP
OPERABLE UNITS (OU) NOS.1,2.3,4 & 5
RSR CORPORATION SUPERFUND SITE n. A4 n
DALLAS, TEXAS 01^19
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EPA has been investigating and studying each OU separately. OU No.
2, the public housing property owned by the Dallas Housing
Authority, will be addressed in a separate ROD that will be
published concurrent with this ROD for OU No. 1. Proposed Plans
outlining recommended Superfund response actions for the other OUs
at the RSR Site will be released in 1995.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The source of contamination at the RSR Site resulted from secondary
lead smelting (lead recycling, primarily automobile batteries)
operations that were conducted from the early 1930s until 1984 at
a facility located near the center of the RSR Site. An extensive
review of available historical information concerning the smelter's
operation indicates that from approximately 1934 until 1971, the
lead smelting facility was owned and/or operated by Murph Metals,
Inc. or its predecessors. In 1971, RSR Corporation acquired the
lead smelting operation and established Murph Metals as an
operating subsidiary. The smelter continued to operate under the
RSR Corporation until March 1984 when a Federal Trade Commission
divestiture order resulted in the acquisition of the smelter in May
1984 by the current owner, Murmur Corporation. In 1983, the City
of Dallas declined to renew the smelter's operating permit. This
decision was based on the smelter's historic operational practices
and changes in the City's zoning ordinance restrictions. As a
result, the smelter closed in 1984 and has not operated since that
time.
The smelter facility currently consists of two properties separated
by Westmoreland Road. The smelter building, stack and other
associated buildings, which are no longer in use, are situated on
one property (OU No. 4), while a disassembled battery wrecking
building and abandoned disposal areas exist on the property across
Westmoreland Road (OU No. 5). Currently, Murmur Corporation is
conducting the only active site operations, which consist of a lead
manufacturing and fabricating facility producing lead shot and lead
sheets for hospital x-ray rooms.
As a result of a lawsuit brought by the City of Dallas and the
Texas Air Control Board against RSR Corporation in 1983, RSR by
court order was required to take corrective measures at the
smelter, which included installation of stack emission controls and
better control of fugitive emissions. RSR Corporation also was
required to fund a cleanup of the residential community within one-
half mile of the smelter. The cleanup funded by RSR from 1984
through 1985 was directed by a court-appointed Special Master and
required the removal of soils in residential areas that exceeded
approximately 1,000 ppm lead concentration. These soils were
removed to a depth of 6 inches, replaced with clean fill, and
covered by sod. Contaminated soils from public play areas and day
care centers were removed to a depth of 12 inches, 18 inches for
gardens, and replaced with washed sand or clean soil. In addition,
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clean soil, was placed on areas without adequate grass cover within
a half mile of the smelter. The cleanup action conducted from 1984
through 1985 ' exceeded recommendations made by the Centers for
Disease Control (CDC) and was considered a protective and
appropriate action at that time. The CDC blood lead level of
concern at that time was 30 micrograms per deciliter (/ig/dL) .
Based on available studies and scientific information, in 1989 EPA
set interim soil cleanup levels for residential properties at 500
to 1,000 ppm lead concentrations. EPA's Office of Emergency and
Remedial Response and Office of Waste Programs Enforcement
considered these levels protective for direct contact in
residential settings. However, in 1991 the CDC lowered the blood
lead level of concern from 30 Mg/dL to 10 M9/dL (CDC, 1991,
Preventing Lead Poisoning in Children).
Concerns about lead contamination in the west Dallas area re-
emerged in 1991 when the Texas Natural Resource Conservation
Commission (TNRCC, formerly the Texas Water Commission) began
receiving complaints from area residents about residual slag piles
and battery chips allegedly originating from the former RSR
Corporation facility. TNRCC requested that EPA re-evaluate the
cleanup activities directed by the Special Master in the mid-1980s
with funds provided by the RSR Corporation.
EPA began soil sampling in west Dallas in 1991 to determine the
presence of soil contamination from the RSR smelter. Results
indicated that areas previously cleaned under the direction of the
Special Master using funds from RSR Corporation (1984-1985) were
not recontaminated and did not require further cleanup, but that
contamination existed in other areas near the smelter and in areas
where battery chips were used as fill. Consequently, EPA initiated
an emergency removal action (discussed in more detail below) in the
residential arid high risk areas consisting of removal and offsite
disposal of soils and debris contaminated in excess of the removal
action cleanup levels.
On May 10, 1993, EPA proposed to add the RSR Site to the National
Priorities List (NPL) of Superfund sites (58 Fed. Reg. 27,507, May
10, 1993) . The proposed listing was based solely on the soil
exposure pathway of the primary chemicals of concern, lead,
arsenic, and cadmium.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Public participation activities for OU No. 1 have been satisfied as
required in CERCLA Section 113(k), 42 U.S.C. § 9613(k), and Section
117, 42 U.S.C. § 9617. The Remedial Investigation Report, Baseline
Human Health Risk Assessment Report and the Proposed Plan for OU
No. 1 of the RSR Site were released to the public on November 18,
1994. These documents as well as other documents and information
EPA relied on or considered in recommending that no further action
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-,
is necessary at OU No. 1 were made part of the Administrative
Record file for the RSR Site on or before November 18, 1994. The
Administrative Record File has been available to the public in
three repositories; the West Dallas Public Library located at the
RSR Site, the EPA Region 6 library in Dallas, and the TNRCC library
in Austin, Texas. The notice of the availability of the Proposed
Plan and the Administrative Record file was published in The Dallas
Morning News on November 14, 1994. The public comment period was
held from November 18, 1994 through January 18, 1995. A Public
meeting was held on December 1, 1994 to receive public comments
from the community. In addition, legal and technical
representatives from EPA participated in a radio talk show on
January 15, 1995, to receive public comments and answer questions
from citizens. Responses to all comments received during the
public comment period are included in the Responsiveness Summary,
which is included as Appendix A to this ROD.
This ROD presents EPA's decision that no further action is required
at OU No. 1 of the RSR Site in Dallas, Texas for protection of
human health and the environment in accordance with CERCLA and
consistent with the NCP. This decision is based on the
Administrative Record for OU No. 1.
IV. SCOPE AND ROLE OF OPERABLE UNITS
To prioritize investigations, enforcement actions, and removal or
remedial actions at the RSR Site, EPA separated the RSR Site into
five (5) OUs as described in Section I. OU No. 1 consists of and
this ROD applies to the private residential properties and high
risk areas of west Dallas that were the subject of EPA's emergency
removal action. The objectives of the removal action were to
protect public health and eliminate the immediate treat to human
health from incidental ingestion, inhalation of airborne
particulates, and direct contact with soils contaminated with
elevated levels of lead, arsenic, and cadmium related to the RSR
smelter.
In addition to the removal action, EPA has conducted a remedial
investigation (RI) and a Human Health Risk Assessment (HHRA) at OU
No. 1 to determine the extent of contamination and long-term
cleanup goals for OU No. 1. This ROD presents EPA's decision that
no further action is necessary for OU No. 1 to protect human health
and the environment based on the results of the studies and the
removal action.
OU No. 2, the public housing area owned by the Dallas Housing
Authority (DHA), has been addressed under a CERCLA Administrative
Order on Consent under which DHA agreed to perform a RI and
extensive removal activities, with EPA oversight, to address
contamination at OU No. 2. EPA performed an HHRA for OU No. 2.
EPA's decision that no further action is necessary at OU No. 2 is
being issued concurrent with this ROD for OU No. 1.
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OUs 4 and 5, the smelter facilities, and OU 3, the smelter waste
disposal areas, are currently being investigated by EPA. EPA
anticipates releasing the results of its RIs as well as Proposed
Plans recommending response actions for these OUs in the near
future.
V. SITE CHARACTERISTICS
Soils
Soils in OU No. 1 provide the most likely exposure pathway of site
contaminants. This is due to soil being contaminated from the RSR
smelting operations and the air deposition of contaminated
particles, primarily lead and arsenic, in the downwind area. Also,
the use of battery chips as fill material in the residential areas
resulted in contamination of the surrounding soils. Although the
smelting operations resulted in soil contamination, the lead and
arsenic fragments bonded to the site alkaline soil particles and
the contamination generally remains at the surface with little to
no movement.
The soil survey of Dallas County, Texas issued by the USDA Soil
Conservation Service (SCS), identified the Trinity-Frio soils as
the major soil type at OU No. 1. Trinity soils are floodplain
soils, poorly drained, clayey, with low permeability and high water
capacity. Because they are primarily found in flat, low-lying
areas, runoff and the potential for these soils to erode is
minimal. Trinity-Frio soils are found over most of the northern
half of OU No. 1.
Two soil types of upland soils are found in the southern portion of
OU No. 1. Ferris-Heiden soils are clayey soils which have
developed extensively on gently sloping to steeply sloping
surfaces. These soils have low permeability and high water
capacity due to their clay content. Eddy-Stephen-Austin soils are
very shallow to moderately deep soils which have developed on
gently sloping to moderately steep surfaces. These soils are more
loamy and therefore have higher permeability and lower water
capacity than the Ferris-Heiden soils.
Houston Black soils, deep clayey soils developed on flat upland
surfaces, are found near the center of OU No. 1. These soils have
low permeability, high water capacity, and average erosion
potential. In addition, deeply developed, loamy to sandy Bastsil
soils are found along old stream terraces on nearly level to
sloping surfaces in a few locations in OU No. 1, primarily along
the Trinity River and its tributaries.
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Geology
The RSR Site (OU No. 1 study area) is located on the margin between
the Blackland Prairie and the Eastern Cross Timbers physiographic
provinces. The study area topography is characterized by low, flat
to gently undulating surfaces. A majority of the RSR Site is
located on a floodplain terrace of the Trinity River. The northern
and western edges of the RSR Site are bounded by the Trinity River
levee. The Trinity River levee system provides protection to the
RSR Site and the city of Dallas from the 100 year flood.
The RSR Site is underlain primarily by Quaternary alluvial
deposits. Below the smelter properties, these deposits vary in
thickness from a few feet in the southeast corner to over 30 feet
in the northwest corner. In addition, fluvial terrace deposits are
located in the southwestern portion of the RSR Site, and the Austin
chalk and Eagle Ford shale are exposed in the uplands on the
southern side of the RSR Site, primarily south of Interstate
Highway 30.
Hydrogeology
In north-central Texas, the two most important water-bearing
stratigraphic units are the Woodbine Group, a minor aquifer, and
the Trinity Group, a major aquifer. Both aquifers provide
municipal, domestic, industrial, and some irrigation supplies to
the north-central portion of the state. However, water for Dallas
residents is provided from the City of Dallas system, which draws
its water from surface reservoirs. Lake Lewisville is the primary
reservoir and is located approximately 20 miles north of RSR Site.
Water from this reservoir is provided via the Bachman Water
Treatment Plant.
The Woodbine Aquifer is composed of sand and sandstone. Ground
water flow within the Woodbine is generally to the east. Within
the RSR site, the depth to the Woodbine from the ground surface is
approximately 200 to 250 feet.
The Trinity Group Aquifer is encountered at greater depths than the
Woodbine and other geologic units present at the RSR site. Within
the RSR site, the depth to the Trinity Aquifer from the ground
surface is approximately 1,300 to 1,500 feet to the Paluxy
formation and approximately 2,500 feet to the Twin Mountain
Formation.
Surface Water
The Trinity River and its tributaries are the only major surface
water bodies in the vicinity of OU No. l. The West Fork flows
east-northeast from Grand Prairie and parallels the study area (500
to 1,000 feet from the western edge) before joining the Elm Fork to
form the main channel. From the confluence of the West and Elm
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Porks, the Trinity River flows east and then south, paralleling OU
No. 1, approximately 1500 feet north of the northern and eastern
boundaries. A surface drainage channel that flows through the
western portion of the site empties into the Old West Fork channel,
which joins the Trinity River at a pumping station between
Westmoreland- and Hampton Roads. An additional surface drainage
channel in the eastern part of OU No. 1 travels along the Missouri
Pacific rail lines and joins the Trinity approximately 1/4 mile
south east of Sylvan Avenue. Fishtrap Lake, Kidd Springs Lake, and
Lake Cliff Lake! also are located within OU No. 1.
Population
Approximately 17,000 people live in the OU No. 1 study area. The
area downwind of the smelter facility, which is also the portion of
OU No. 1 that has been sampled most frequently, lies north of
Singleton Boulevard. This area is comprised primarily of single-
family residential units. There also are public multi-family
residences (DHA property), and commercial service and retail
establishments (including schools, churches, parks, recreation
facilities, day care centers) along Singleton Boulevard and
Westmoreland Road. The remaining land comprising OU No. 1 is zoned
primarily for single-family residential, multi-family residential,
and light and heavy industrial uses and, to a lesser extent,
commercial and retail.
VI. SUMMARY OF SITE RISKS
EPA evaluated specific site risks by conducting a RI and a Baseline
Human Health Risk Assessment (HHRA) for OU No. 1 to determine the
sources and extent of contamination and the cleanup goals for long-
term protection of human health and the environment. Investigations
conducted at the site consisted of:
TNRCC's visual investigation of 6,800 properties to identify
locations where battery chips had been used as fill
material.
EPA home study conducted at 294 residential locations to
determine lead levels in soil, indoor dust, tap water, and
indoor and outdoor paint.
City of Dallas and ATSDR blood study of 463 children to
determine blood lead levels and other potential sources
(questionnaire).
EPA's sampling at approximately 600 residential properties
and 33 high risk locations for removal action activities.
The results of these investigations and studies show that EPA's
emergency removal action conducted at OU No. 1 and the removal
action cleanup levels required under the removal action provide
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long-term protection by eliminating the source of contamination, O5
(soils and fill material) and thus the human and environmental vi
exposure pathways. O
A. Emergency Removal Action
EPA conducted removal activities at 420 residential properties and
high risk areas at OU No. I of the RSR Site from October 1991 to
June 1994. Information concerning the removal action is contained
in the Administrative Record for OU No. 1 which is located in the
Administrative Record document repositories for this site. To
protect the privacy of individuals, names and addresses have been
redacted from documents available in the Administrative Record as
well as in EPA's general RSR Site file.
EPA's determination of the necessity for removal activities was
based on sampling conducted at all residential properties (where
access was permitted by the property owners) and high risk areas in
the air deposition area north of the RSR smelter facility and on a
visual survey conducted at 6,800 properties to identify locations
within OU No. 1 having RSR contamination such as battery chips and
slag. In consultation with the Agency for Toxic Substances and
Disease Registry (ATSDR) and based on the CDC blood lead level of
concern and EPA's interim soil lead cleanup levels of 500 to 1,000
ppm, EPA established the conservative removal action cleanup levels
for residential locations at 500 ppm lead, 20 ppm arsenic, or 30
ppm cadmium for contaminated soils. EPA conducted excavation and
restoration operations at residential properties (where access was
granted) identified by sampling and in the survey where soils or
fill materials exceeded the removal action cleanup levels.
It is EPA's general policy not to conduct Superfund response
activities at private residential properties without first
obtaining voluntary access from the individual property owners. At
OU No. 1, EPA made numerous attempts to obtain such voluntary
access before conducting any sampling or removal action activities
at residential properties. These efforts included: mailing of
various letters containing information about the suspected
contamination in the residential areas and requesting access;
speaking at various churches and public meetings about the need for
access; newspaper notices; and followup personal visits to homes.
Despite EPA's attempts to gain access to properties, several
property owners declined to grant EPA access to conduct sampling
and/or to perform removal action excavation of contaminated soils.
In the case of the property owners who refused access, EPA made
additional numerous efforts to provide information and answer
questions in order to gain voluntary access. However, several
property owners continued to decline to provide EPA access and thus
EPA did not perform sampling and/or removal actions at those
particular properties.
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Phase I Removal Action • . v
EPA's Emergency Response Branch (ERB) initiated site assessment
activities in the west Dallas area in August 1991. The initial
area under investigation, the Phase I Removal Area, covered
approximately 280 acres of residential, 'multi-family housing and
multi-use areas impacted by historical air deposits of contaminants
from the RSR smelter stack. In October 1991, the ERB initiated a
removal action in the Phase I area to address elevated levels of
lead and arsenic. Removal action activities were initiated at
seven high risk areas for children, consisting of two elementary
schools, two church play areas, two community parks, and a
children's recreation facility. In addition to the high risk
areas, removals were conducted on 211 residential properties. The
Phase I Removal Action was completed in June 1993 and resulted in
the removal and of f site disposal at permitted landfills of
approximately 22,900 cubic yards of RCRA non-hazardous soils and
approximately 6,400 cubic yards of RCRA hazardous soils. RCRA
hazardous soils were transported offsite for treatment prior to
disposal at permitted landfills.
Phase II Removal Action
Due to reports of slag/battery chip materials observed within the
13.6 square mile area of OU No. 1, TNRCC initiated a house-to-house
survey of approximately 6,800 properties in July 1992. The TNRCC
survey was completed in February 1993 and identified properties
with contamination resulting primarily from the use of battery chip
materials as fill in driveways. ERB's Phase II Removal Action
commenced in June 1993 and was completed in June 1994 and resulted
in the cleanup of 202 residential properties. These properties
included both TNRCC identified properties and adjacent properties
identified by EPA during the removal action at fill areas where
contamination exceeded 500 ppm lead, 20 ppm arsenic or 30 ppm
cadmium. Approximately 13,800 cubic yards of RCRA non-hazardous
soils and approximately 1,400 cubic yards of RCRA hazardous soils
were excavated and disposed of offsite at permitted landfills.
RCRA hazardous soils were transported offsite for treatment prior
to disposal at permitted landfills.
B. Current and Future Health Risks
To determine current and future risks to human health at OU No. 1
from smelter-related contamination, EPA conducted a human health
risk assessment (HHRA) . Detailed information about the procedures
of the study and the results are contained in the Human Health Risk
Assessment Report for OU No. 1 which is included in the
Administrative Record for OU No. 1.
A human health risk assessment is a procedure which uses a
combination of facts and assumptions to estimate the potential for
adverse effects on human health from exposure to contaminants found
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at a site. Risks are determined by evaluating known chemical ?
exposure limits and actual chemical concentrations at a site. The ,-T
actual concentrations are compared to the exposure to a .
concentration known to have an adverse impact. Conservative IT
assumptions are used in calculating risks that weigh in favor of
protecting human health.
Carcinogenic risks are expressed in terms of the chance of
developing cancer after a lifetime of exposure to the contaminants.
The national risk, or probability, that an individual may develop
some form of cancer from everyday sources, over a 70-year life span
is estimated at one-in-four. This one-in-four probability is
considered the "natural incidence" of cancer in the United States.
To protect human health, the EPA has set the range from one in ten
thousand to one in one million (IxlO'4 to 1x10"*) lifetime excess
cancer incidents as the acceptable risk range. A risk of one in
one million means that one person out of one million people could
develop cancer as a result of a lifetime exposure to the site
contaminants.
Noncarcinogenic risks are determined by calculating the Hazard
Index (HI) which is established by determining the threshold level
of a contaminant that is safe to human health. If the HI equals or
exceeds one (1) , there may be concern for potential non-cancer
effects from lifetime exposure to the site contaminants.
EPA's HHRA for OU No. 1 contains detailed information about the
specific and assumed factors evaluated for the risk assessment at
OU No. 1. EPA commenced the HHRA process for OU No. 1 by
evaluating the current site risk, also called the baseline risk,
posed to human health at OU No. 1. The current site risks at OU
No. 1 were calculated based on the potential exposure to specific
site contaminants. In performing the HHRA, EPA took into account
the characteristics of the population in OU No. 1 as well as the
characteristics of the type of contamination caused by the smelter.
Results of the west Dallas home study were compared to a reference
area where smelter-related contamination was not present.
Due to the historic operations at the RSR smelter facility causing
air deposition of contaminants as well as the residential use of
battery chips and slag as fill material, metals were considered to
be the primary compounds present within OU No. 1. After applying
the exposure and toxicity assessment screening steps, the following
metals were retained as Target Analyte Metals (TAM) for the HHRA:
arsenic, chromium, cobalt, copper, lead, manganese, mercury,
nickel, silver, and zinc. Of these TAMs, lead and arsenic were
detected in soils and fill material in OU No. l at the highest
concentrations.
Based on current populations and land use within OU No. 1, two
exposure scenarios were identified for evaluation in the HHRA;
residential (adults and children) and commercial (adults).
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Residents and commercial workers could be exposed to TAM
contamination in!soil within OU No. 1 through incidental ingestion
of soil, inhalation of airborne soil particulates, and dermal
contact with soil. Two routes of exposure, ingestion and
inhalation, are quantitatively evaluated in this HHRA. Dermal
exposure was hot evaluated quantitatively in the HHRA because human
data is not available to estimate an absorption factor for TAMs
detected at OU No. 1 and the dermal exposure route is not
considered to be significant.
Risks associated with exposure to lead were determined by
evaluating exposure to the most sensitive population in OU No. 1,
children between the ages of 6 months to 6 years. Blood lead data
was collected from a random group of children. In addition, the
exposure scenario for children in OU No. 1 was evaluated using the
Integrated Exposure Uptake Biokinetic (IEUBK) model, (EPA version
0.99d, Feb. 1994), which examined concentrations of lead at
specific exposure points in and around the home, whenever possible,
and default values for other sources of lead exposure. Risks from
exposure to all other TAMs were assessed by calculating His for
noncarcinogenic metals and excess lifetime cancer risks for
carcinogenic metals.
C. Exposure to Metals in Surface Soil - Residential
The residential exposure scenario for OU No. 1 assumed that a
resident would come into contact with contaminated soil containing
site-related TAMs on a daily (350 days) frequency for 30 years.
Potential routes of exposure to soil included incidental ingestion
and inhalation of airborne particulates.
The estimated total noncancer His were less than (<) 1 for children
and adults. A noncancer HI < 1 indicates a low probability of
adverse health effects resulting from exposure to the TAMs,
including lead, under the assumed exposure conditions.
The HHRA revealed that for children in OU No. 1, the estimated
excess lifetime cancer risk for the average exposure to
contaminated soils ranged from 3 x 10~6 to 1 x 10"5. For the
reasonable maximum exposure (RME). the estimated excess lifetime
cancer risk ranged from 9 x 10"6 to 3 x 10"5. For the adult
scenario, the estimated excess lifetime cancer risk for the average
exposure scenario ranged from 2 x 10"6 to 7 x 10"6. For the RME, the
estimated excess lifetime cancer risk ranged from 7 x 10"6 to 3 x
10"5. Arsenic and chromium are the primary compounds contributing
to the total estimated excess lifetime cancer risk for children and
adults living in OU No. 1. However, all of the excess lifetime
cancer risk values fall within EPA's acceptable risk range of 10"4
to 10'6. These values are less than those where analysis for
remedial alternatives would be required under the NCP, 40 C.F.R.
300.430 (e)(2)(i)(A)(2). These values demonstrate that the
emergency removal action has reduced exposure risks below levels of
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concern.
D. Exposure to Metals in Surface Soil - Gamm*ra* «i .
The commercial scenario for OU No. 1. assumed that a worker would
come into contact with contaminated soil containing smelter-related
TAMs at a frequency of 5 days a week (250 days) for 25 years.
Potential routes of exposure to soil included incidental ingestion
and inhalation of airborne particulates.
Results show that for west Dallas, the His are less than 1. Values
ranged from 0.1 to 0.3. A noncancer HI less than 1 indicates a low
probability of adverse health effects resulting from exposure to
the TAMs under the assumed exposure conditions.
The HHRA revealed that the estimated risk of excess lifetime cancer
as a result of worker exposure to contaminated soils ranged from 1
x 10"6 to 9 x 10"6 for ingestion and inhalation exposures. Arsenic
was the only carcinogen considered for ingestion exposures. The
inhalation risk included contributions from arsenic, chromium
(assumed hexavalent), and nickel. Of these, chromium was the
greatest contributor to the inhalation risk values. All of these
values fall within EPA's acceptable risk range of 10"4 to 10'6. As
noted previously, these values are less than those where analysis
for remedial alternatives would be required under the NCP.
idia - Resj
The residential child exposure to lead was evaluated using the
IEUBK model, which uses site-specific or default concentrations of
lead in environmental media to estimate blood lead levels in
children. Worker exposure to lead is addressed qualitatively.
Risk from exposure of children to lead in soil within OU No. 1 was
evaluated by comparing the blood lead distributions estimated using
the IEUBK model to the level of concern of 10 Mg/dL established by
the CDC (CDC, 1991). Graphs of the lognormal frequency
distributions that display the probability density corresponding to
the estimated blood lead levels were generated with the IEUBK
model. The model default geometric standard deviation of 1.60 was
used to generate these graphs.
Results of the IEUBK model predicted mean blood lead levels ranging
from 2.4 to 3.4 M9/dL. The modelled blood lead distributions
(assuming a geometric standard deviation of 1.60) indicated that
less than one percent of the population exposed to lead in soils
are expected to have blood lead levels greater than 10 jxg/dL. The
measured mean blood lead levels were higher than the corresponding
modelled blood lead levels. The measured mean blood lead levels
ranged from 4.5 to 5.7 jxg/dL, with 2 percent to 17 percent of the
population having blood lead levels greater than 10 M9/dL. Many
factors in various areas of the site can contribute to the
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differences between modelled and measured blood lead levels,
including uncertainty associated with environmental and blood lead
data, the IEUBK default parameters, and the full contribution of
leaded paint to the input parameters.
The CDC has identified actions that should be taken when a child's
blood lead content reaches certain levels. For example, medical
evaluation and environmental investigation are recommended for
blood lead levels between 10 and 25 Mg/dL, and medical treatment
is identified for blood lead levels in children exceeding 25 ng/dL.
No children who participated in EPA's study had a blood lead level
in excess of 25 /ig/dL. The highest level found was 22.6 ng/dL in
one child of the sampled population.
Correlation analysis and regression analysis were performed to
determine if there was a correlation between the blood lead levels
measured in the children and the lead concentrations in specific
environmental media in the homes. Results of these analyses
indicated that the measured blood lead levels may correlate with
the combination of bedroom dust and exterior leaded paint (as
measured by X-Ray Fluorescence) concentrations, but are not
correlated to soil lead levels in residential yards.
F. Residential Soil Lead Cleanup Level
The IEUBK model also was used to determine a site-specific cleanup
level for lead in soil for OU No. 1. The IEUBK model considered
the lead concentrations measured in air, drinking water, and dust
in the area to calculate a soil lead cleanup level. The IEUBK
model is designed to provide a soil lead level calculation that
will limit exposure to lead in soil such that no more than 5% of
the children population exceeds the 10 /ig/dL blood lead level (the
CDC blood lead level of concern). The IEUBK model calculated a
soil cleanup level of 540 ppm lead for the residential areas of OU
No. 1. This soil cleanup level further shows that EPA's removal
action level at the private residential areas of OU No. 1 was more
stringent than the soil remedial cleanup level of 540 ppm lead.
G. Exposure to Lead in Environmental Media - Commercial
Adult exposure to lead was not evaluated quantitatively for the
adult commercial worker scenario. The IEUBK model is designed to
estimate blood-lead levels for the most sensitive population
(children between the ages of 6 months and 6 years) and is not
designed to estimate adult exposure to lead. However, exposure to
adult commercial workers is expected to be less than that for
children since intake rates and exposure frequency are less for
adults than children and exposure point concentrations for
commercial workers and residential children are assumed to be
similar. Additionally, the blood lead levels of concern for adults
has been established to be much higher than for children. The
Occupational Safety and Health Administration recommends medical
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O
CM
consultations for workers with blood lead levels above 40 ng/&L and 05
medical removal from the work facility for workers with blood lead r-i
levels above 50 /ig/dL. O
H. Impacts to the Environment
In addition to the human health risk assessment for OU No. 1, an
Ecological Risk Assessment (ERA) was prepared for OU Nos. l and 2,
which is a separate report available in the Administrative Record.
As part of the ERA, a field survey was conducted from March 24,
1994 through April 2, 1994 within OU Nos. 1 and 2 at the RSR Site
to address data needs. The ecological survey was conducted within
the 13.6 square mile study area. The following information was
gathered during this field effort:
Species surveys of terrestrial and aquatic receptors
Identification of critical habitat
Collection of abiotic media (surface water and sediment)
samples
Collection of water quality parameters for characterization
of the aquatic ecosystems
This information, along with data collected from previous
investigations conducted for OU No. 1 and information collected
from various state and local resource agencies (Dallas Nature
Center and Texas Parks and Wildlife Department) were used to
complete the ERA. Threatened and endangered species identified
through the Texas Parks and Wildlife Department have not been
observed or expected within the site boundaries.
The quantitative screening level ERA conducted with this
information indicated potential ecological effects to aquatic and
terrestrial organisms in drainage areas. The Bernal Street
drainage had the highest potential risk to aquatic and terrestrial
organisms. The screening level ERA indicated that further
evaluation in the form of a definitive ERA may be warranted for
surface water and sediment. However, the screening level ERA
indicated no significant ecological risk to target mammal
receptors, terrestrial invertebrates or plants from surface soils.
The screening level ERA indicated that soils did not present a
significant risk to the environment. A definitive ERA of the
drainage areas will be conducted as part of the remedial
investigation for the RSR OU No. 3 site.
VII. EVALUATION CRITERIA
EPA's emergency removal action has addressed the contaminated soil
and battery chip/slag materials that were present at residential
and high risk areas at OU No. 1 by excavation and removal of site
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0
contaminants and off site disposal at permitted landfill facilities. oil
Removal actions were conducted at 413 residential properties and T^
seven high risk areas identified as having RSR-related O
contamination. Therefore, EPA proposes that no further remedial
action is necessary to protect human health and the environment in
the residential and high risk areas at OU No. l. This decision is
based on the results of the investigations and studies summarized
above and presented in detail in documents contained in the
Administrative Record.
Although removal actions do not have to meet all aspects of
remedial actions, the removal action was closely coordinated to
meet long-term remedial goals. Because the removal action met
remedial objectives, EPA is evaluating its decision for no further
action pursuant to the following remedial criteria:
1. Overall Protection of Human Health and the Environment
No further action is warranted because EPA's removal action has
achieved overall protection of human health and the environment at
OU No. 1. EPA's removal action eliminated the ingestion,
inhalation, and direct contact pathways thus providing protection
of human health and the environment by the removal and offsite
disposal of contaminated soils and battery chip materials from
residential and high risk areas in OU No. 1. EPA removed soils
from all properties where access was granted that had greater than
500 ppm lead, 20 ppm arsenic or 30 ppm cadmium. The IEUBK model
results discussed in Section VI and the risk assessment conducted
for OU No. 1 confirm that the removal cleanup levels are protective
of human health and the environment.
Since the lead smelter no longer operates and because the
contaminated soils and materials were removed from the residential
areas of OU No. 1, the potential for future re-contamination above
health-based levels has been minimized. EPA's removal action
provides protection of human health and the environment by
permanently removing contaminants from OU No. 1. Therefore, no
further action is necessary.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
ARARs are federal and state requirements that the selected remedy
must meet. For example, material to be excavated and disposed
offsite must be treated using the best demonstrated available
technology (BOAT) to meet the RCRA Land Disposal Restrictions
(LDRs) prior to landfill disposal. Response actions at OU No. 1
have met ARARs. With regard to the removal action, the removal and
disposal of RCRA hazardous and non-hazardous materials from
residential sites of west Dallas met Federal and State ARARs. RCRA
non-hazardous soils were excavated and transported to the permitted
Republic Waste Industries in Avalon, Texas for disposal. RCRA
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O
hazardous soils were excavated and transported for treatment and v-f
disposal to Peoria Disposal Company in Peoria, Illinois, which is O
a RCRA permitted facility.
3. Long-term Effectiveness and Permanence
Based on the results of the extensive site-specific studies and
investigations at OU No. 1, EPA's removal action has provided long-
term effectiveness and permanence without the need for further
action by permanently removing the contaminated soils and battery
chip materials from residential and high risk properties of OU No.
1. Since the RSR smelter facility ceased operations in 1984 and
contaminated soils have been removed, re-contamination of
remediated areas is not expected and future remedial activity is
not anticipated.
4. Reduction of Toxicity, Mobility or Volume Through Treatment
This criterion has been achieved without the need for further
remedial action because at residential properties where removals
were conducted, EPA's activities reduced the toxicity, mobility,
and volume of the contaminated materials at OU No. 1 by removal and
offsite disposal. Soils classified as RCRA hazardous materials
were treated prior to disposal at permitted facilities to reduce
toxicity and mobility. The removal action did not include
treatment of the non-hazardous materials and therefore no reduction
in toxicity or volume of these materials was achieved. However,
disposal of contaminated soils at permitted facilities will reduce
the mobility of these contaminants at the landfills. Additionally,
the risk of exposure to humans was reduced at the residential and
high risk areas of OU No. 1.
5. Short-Term Effectiveness
Since no further action is necessary, short-terms risks from
exposure are not present. During EPA's removal action, no short-
term risks were encountered at the removal sites. An air
monitoring program was established at each residential removal
location to monitor the potential exposure of residents and site
workers to contaminated materials. No air emissions were detected
above health-based levels.
6. Implementability
Since EPA is recommending no further action, an evaluation of
implementability is not necessary.
7. COSt
Since EPA is recommending no further action, an evaluation of the
cost associated with this choice is not necessary. Costs for EPA's
removal action were approximately $12 million.
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o
8.
State Acceptance . OS
TNRCC has been consulted and has provided technical support
throughout EPA's removal action and remedial investigation and has
participated in site investigations and the home study for the RI.
The TNRCC on behalf of the State of Texas concurs with EPA's
decision that no further action is necessary for the residential
and high risk areas of OU No. 1.
9. Community Acceptance
Comments were received from the community during the public comment
period which opened November 18, 1994, and closed January 18, 1995.
Additional public comments were received at the public meeting held
on December 1, 1994, and during the radio talk show conducted on
January 15, 1995. All comments submitted have been addressed, and
responses are included in the Responsiveness Summary (Attachment A)
to this ROD. EPA carefully considered all comments in making the
final decision for OU No. 1. No new information was received
during the public comment period that resulted in a change to EPA's
recommendation made in the Proposed Plan for OU No. 1.
VIII. STATUTORY AUTHORITY FINDINGS AND CONCLUSIONS OF LAW
Pursuant to CERCLA, studies are conducted at NPL sites to
characterize the nature and extent of contamination associated with
a particular source of contamination and to determine the most
feasible cleanup approaches. At OU No. 1, EPA conducted a removal
action from October 1991 through June 1994 to address contamination
in the residential and high risk areas of OU No. 1. In conducting
this emergency removal action in the residential properties and
high risk areas, long-term remedial cleanup objectives and overall
protection of human health and the environment were achieved.
These objectives consisted of removing contaminated soil and
battery chips/slag materials above health-based levels and
replacement with clean soil and sod. In addition, EPA has
conducted a Remedial Investigation, a baseline Human Health Risk
Assessment (using its own data and data collected by TNRCC and the
City of Dallas) and an Ecological Risk Assessment to fully examine
the nature and extent of contamination and associated risks and to
determine what remedial actions, if any, were needed to address the
contamination. Based on the results of EPA's extensive
investigations and studies, EPA determines that no further action
is necessary to protect human health and the environment in the
residential properties and high risk areas of OU No. 1.
Studies and proposals to address contamination at the other
Operable Units for the RSR Site are being conducted separately.
Studies to fully characterize contamination at other areas of the
site including the slag piles (OU No. 3), former smelter facility
(OU No. 4), and processing area (OU No. 5) are continuing and EPA
will solicit public participation regarding these areas within the
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coming months.
Because EPA's decision is for "no further action," none of the
statutory determinations relating to remedy selection reguired by
Section 121 of CERCLA, 42 U.S.C. § 9621, are necessary in this
Record of Decision. Additionally, because hazardous substances
will not remain on-site above health-based levels, five year
reviews are not necessary at OU No. 1 of the RSR site.
IX. DOCUMENTATION OF NO SIGNIFICANT CHANGE
The Proposed Plan for the RSR Corporation Superfund site, Operable
Unit No. 1 was released for public review and comments from
November 18, 1994, through January 18, 1995. The Proposed Plan
recommended that as a result of EPA's implemented removal action at
the site no further action was necessary. EPA evaluated verbal
comments, reviewed all written comments and information submitted
during the public comment period. Based on this review and
evaluation, it is determined that no significant change to EPA's
proposal, as originally identified in the Proposed Plan, is
necessary.
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APPENDIX A
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•H
RESPONSIVENESS SUMMARY
RSR CORPORATION 8UPERPUND SITE
OPERABLE UNITS NO. 1 AND NO. 2
DALLAS, DALLAS COUNTY, TEXAS
INTRODUCTION
The United States Environmental Protection Agency (EPA) has
prepared this Responsiveness Summary for the RSR Corporation
Superfund Site (RSR Site), as part of the process for making final
remedial action decisions for Operable Unit No. I (OU No. 1) and
No. 2 (OU No. 2) . This Responsiveness Summary documents, for the
Administrative Record, public comments and issues raised during the
public comment period on EPA's recommendations presented in two
Proposed Plans for residential areas of the RSR Site and provides
EPA's responses to those comments. EPA's actual decisions for OU
Nos. 1 and 2 are detailed in the Record of Decision (ROD) for OU
No. 1 and the ROD for OU No. 2. Pursuant to Section 117 of the
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), 42 U.S.C. § 9617, EPA has considered all comments
received during the public comment period in making the final
decisions contained in the RODs for OU No. 1 and OU No. 2.
The comments for both OU No. 1 and OU No. 2 are presented together
in this Responsiveness Summary because the public comment period
and public meetings for EPA's proposals for these OUs were held
concurrently and many comments received may apply to both OUs.
OVERVIEW OF PUBLIC COMMENT PERIOD
EPA issued its Proposed Plans detailing remedial action
recommendations for OU Nos. 1 and 2 for public review and comment
on November 18, 1994. Documents and information EPA relied on in
making its recommendations in the Proposed Plans were made
available to the public on or before November 18, 1994 in three
Administrative Record File locations, including the West Branch of
the Dallas Public Library located at the RSR Site. Initially, EPA
provided thirty days for public comment. However, at the request
of a citizen EPA extended the comment period an additional thirty
days, and the comment period closed on January 18, 1995.
EPA held a public meeting to receive comments and answer questions
on December 1, 1994, at the Thomas Edison Middle School located at
2940 Singleton Boulevard in west Dallas, Texas. In addition, on
January 15, 1995, technical and legal representatives from EPA
participated in a radio talk show public meeting on KGBS Radio in
Dallas, Texas to receive comments and answer questions from Dallas
citizens. All written comments as well as the transcripts of
verbal comments received during the public comment period are
included in the Administrative Records for OU No. 1 and OU No. 2
and are available at the three Administrative Record repositories.
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COMMENTS AND ISSUES RAISED DURING THE COMMENT PERIOD
1. Public Meeting, December 1, 1994, Thomas Edison Junior High
School Auditorium
Ms. Barbara Mailory, Dallas City council
Comment: EPA has not lived up to it's responsibilities if,
after all of the time that has been spent in west Dallas for
a cleanup effort, there is still a chance that children living
near the RSR Site still run the risk of being contaminated at
a rate four times higher than other children throughout the
City.
Response: Lead contamination risks to west Dallas children
are not four times higher than other areas of the City. This
is a common misunderstanding of statistics presented in an
article in the Dallas Morning News. The fact is that children
in west Dallas have average blood lead levels about the same
as children in other parts of Dallas. EPA's actions have
removed all significant RSR Superfund site contamination from
residential soils; remaining sources of lead contamination
come from sources other than the smelter facility.
Mr. Luis Sepulveda, President
West Dallas Coalition for Environmental Justice.
Comment: We can't even talk to the Head Director (Region 6) .
Response: This is not true. Jane Saginaw, the Regional
Administrator for EPA Region 6, has met.with Mr. Sepulveda
regarding other environmental issues. She has recused herself
from RSR matters due to a potential conflict of interest from
her litigation involvement at the site before she was
appointed Regional Administrator. Several offers have been
made to Mr. Sepulveda to meet with the Regional officials who
have been delegated the responsibility for decision-making for
the RSR Site.
Comment: We have tested before you dig and after you dig and
lead is still there.
Response: There is no information to support this claim.
Despite repeated requests by EPA, data has not been submitted
to substantiate this theory. EPA collected thousands of
samples from over 1,000 residential locations both before and
after removal of soils. These data show that lead
concentrations in soils are now at safe levels and that
recontamination of the cleaned areas is not occurring. The
extensive data collected by EPA are available for public
review in the three RSR information repositories.
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.
has held six open house meetings and two public meetings. The £j
West'Dallas Coalition accepted invitations to participate in
the workshops but then failed to attend. EPA has sent every
person on the RSR Site mailing list of almost 1,000 people,
including members of this group, several fact sheets and
notifications about the site. EPA also established a
community outreach field office at the West Dallas Multi-
purpose Center that could be easily accessed by citizens to
obtain site information.
Comment: Despite requests, EPA has yet to make public EPA's
environmental equity report.
Response: EPA is not preparing an "environmental equity
report" specific to the RSR Site. All of EPA's RSR studies,
as well as the studies by the City of Dallas, the Texas
Department of Health, and the Agency for Toxic Substances and
Disease Registry have been made available to the public for
review and comment at three locations, including the West
Branch of the Dallas Public Library located at 2332 Singleton
Blvd.
Citizen's Comments at the Public Meeting
Comment: Why are only the kids tested for lead and not the
grownups? Grown folks need to be tested too.
Response: The reason only children 6 years old and younger
were tested as part of the in-home study is because children
are most sensitive to lead levels in the environment. By
addressing lead contamination in the environment that is
affecting children, then other age groups also would be
protected. Older children not tested and adults can have
their blood tested for lead by their personal physician or at
the City's health clinic located at the West Dallas Multi-
purpose Center at 2828 Fishtrap Road.
Comment: EPA doesn't talk to "poor people".
Response: This perception is not based upon the record of
EPA's actions. EPA has gone to lengths to fully inform and
involve interested members of the community regardless of
their economic status and to provide the residents access to
all other relevant government organizations. Since June 1993,
EPA has held six open house meetings in west Dallas to answer
questions from the community and to provide information
regarding the site and other lead issues. These open house
meetings were attended by EPA, City of Dallas Department of
Health and Human Services, the Texas Natural Resource
Conservation Commission, the Agency for Toxic Substances and
Disease Registry, the Texas Department of Health, and the
Dallas Housing Authority, all making themselves available to
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answer questions from any person in the community. EPA has
also conducted meetings with several community groups to
further listen to their concerns and answer questions. In
addition, EPA has provided to the community telephone numbers
of thexstaff persons on the EPA RSR Team so that people can
call directly to ask questions and obtain information.
Comment: EPA needs to tear down the lead smelter.
Response: A proposal regarding the lead smelter facility will
be released in the spring of 1995 for public comment. One of
the alternatives being considered is to demolish the lead
smelter facilities. EPA chose to give highest priority to
developing proposals for residential areas of west Dallas
since this is where children are most likely to be exposed to
lead.
Comment: I strongly oppose the decision of the Environmental
Protection Agency to remove the Superfund status from the
neighborhoods in west Dallas.
Response: EPA is not proposing to change the Superfund
designation for west Dallas. EPA also is not leaving west
Dallas. EPA is stating that the cleanup in the private
residential locations and public housing area is complete.
However, plans have not been completed for the smelter
facility, former processing area, and slag piles. Plans for
these sites will be released to the public for comment in the
near future.
Comment: EPA's cleanup efforts in west Dallas deserve more
money.
Response: The amount of money that can be spent at a
Superfund site is not a predetermined or arbitrary figure, but
is based on the amount needed to study and correct hazardous
waste problems. At the RSR Site, cleanup efforts and studies
have cost EPA some $16 million dollars to date. Additionally,
the Dallas Housing Authority has spent approximately $10
million in demolition of 167 public buildings and removal of
contaminated soils. Additional funds will be made available
as needed to correct remaining environmental problems
associated with the site.
Comment: The alarming conditions that originally caused the
west Dallas neighborhoods to qualify for emergency Superfund
status have not been fully addressed. That emergency status
was warranted because of extremely high levels of pollution.
Response: The emergency status was addressed by EPA by
conducting removal action cleanups under the Superfund program
at 420 residential and high risk areas with RSR-related
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contamination. Additionally, EPA; TNRCC, and the City of
Dallas conducted comprehensive inspections of 6,800
properties, collected soil samples at over 1,000 homes, and
collected soil, dust, paint, water, and blood samples at 350
residences. Results of these studies indicate that RSR lead
contamination has been addressed. These studies further show
that the removal action cleanup levels for lead provide long-
term protection to the community. There are of course other
health and contamination issues in west Dallas; that is why
EPA and 11 other Federal, State, and local organizations have
joined together to address these issues by forming the Dallas
Area Lead Steering Group. Members of this group collaborated
to write a "Citizen's Guide to Lead Issues". The Guide
provides answers to some of the most commonly asked questions
regarding urban lead contamination and summaries of local
services that are available.
Comment: Even though the government replaced the contaminated
driveway and garage at my mother's house, the cleanup was
incomplete since it did not include cleaning the inside of the
house nor did it include removal of lead that may have washed
under the house.
Response: EPA disagrees. The cleanup removed the RSR lead
contamination to which humans can be impacted by exposure; the
evidence collected in comprehensive household tests showed
that lead contained in indoor dust does not present a public
health risk in west Dallas. When contaminated materials were
removed from residential areas, EPA took protective measures
and monitored air quality to ensure that pollution was not
spread.
Comment: The government is responsible for lowering the value
of my house and making it unsalable.
Response: EPA strongly disagrees; in fact, the Superfund
cleanup has the opposite impact. Residential housing was
placed adjacent to pollution sources before local government
restricted land use and before pollution laws were developed.
EPA's actions have removed the specter of RSR contamination
from all of the residential properties in west Dallas that
were part of the survey, testing, and cleanup effort.
Comment: You said the soil was cleaned. If the soil was
cleaned adequately, why is it being redone?
Response: This rumor is simply incorrect; the soil cleanup is
not being redone. The properties cleaned up in the 1990s are
not the same as the ones cleaned up in the 1980s. When EPA
began its cleanup in the 1990s, all residential properties
previously cleaned were re-sampled. None required additional
cleanup.
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Comment: Is it true that the blood lead level in at least one
of the children participating in the RSR home study dropped
after the child left west Dallas? [Concern that residency in
west Dallas, by itself, increases exposure to lead pollution]
Response: There is no evidence that moving from west Dallas
will reduce blood lead levels. In fact, other parts of Dallas
have higher incidences of elevated blood lead levels due to
the myriad of sources of the substance in the urban
environment. The City of Dallas is conducting follow up
testing of the children that participated in the home study,
had elevated blood lead levels, and continue to reside in the
area. Some of the children were no longer being tracked
because either their blood lead levels were now below the
level of concern of 10 ng/dL or they had moved out of study
area. The blood lead levels have decreased in some of the
children that remain in west Dallas.
Comment: Why did EPA wait until November 1994, to propose the
removal of barrels of contamination from the smelter when
cleanup activities had been going on in residential areas for
two years?
Response: Formal access to all portions of the RSR facility
for sampling and identification of the highly contaminated
wastes was not granted until May 1994. The delay in gaining
access was believed acceptable since EPA's initial priority
was to cleanup the areas where people live. Although these
barrels have high contamination levels, they are located in a
secure location away from public contact.
Comment: Is west Dallas as safe from environmental lead
contamination as suburbs such as Richardson, Carrollton,
Addison and Piano?
Response: Yes, although soil lead contamination data from
these areas is not available as extensive as it is for west
Dallas. EPA's RSR home studies showed that there was no
correlation between soil lead levels and elevated blood lead
levels in west Dallas. Blood lead levels in west Dallas are
comparable to, and are often lower than, other areas of the
City.
Comment: Since EPA only sampled or cleaned up in certain
areas of the community, how can the public be assured that the
total RSR pollution problem has been found and fixed?
Response: All residential areas of west Dallas, approximately
6,800 properties, were inspected by the State to determine if
they had smelter-related contamination. The homes that had
suspected lead contamination or used battery chips as fill
material were tested. In the air deposition area, all homes
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where access was granted also were sampled. This resulted in
over 1,000 residential locations throughout west Dallas being
tested for lead contamination. Therefore, EPA is confident
that all residential properties in west Dallas that
participated in this effort are now free of RSR lead
contamination.
Comment: My children are sick and our doctor does not know
what is wrong with them. They have sudden blackouts, they stay
up for extended periods of time, and they have nose bleeds.
We have lived in west Dallas for 20 years and fear that we
have been exposed to pollution. Could EPA tell us the answer
to the medical situation or where we could get help for them?
Response: In addition to your family doctor, diagnosis of
health problems can be obtained from the City's clinic in west
Dallas and from the Parkland Hospital at the following
addresses:
West Dallas Multipurpose Center
2828 Fishtrap Road, (214) 670-7152
Martin Luther King, Jr. Family Health Center
2922 Martin Luther King Jr. Blvd., (214) 426-2686
Los Barrios Unidos Community Clinic UHI
3316 Sylvan Avenue, (214) 651-8739
Parkland Memorial Hospital
5201 Harry Hines Blvd., (214) 637-1861
Additional information regarding lead contamination and health
services is contained in the "Citizen's Guide to Lead Issues"
available from EPA at:
US Environmental Protection Agency
1445 Ross Avenue, (214) 665-6584
• West Dallas Multipurpose Center
2828 Fishtrap Road, (214) 670-7152
Dallas Public Library- West Branch
2332 Singleton Blvd., (214) 670-6445
Mr. Otis Pagan, Sr., President
Friendship Homeowners Association for Environmental Justice
Comment: Poor health conditions exist in our community
because of the lead-related environmental epidemic; presently
the soil removal base limit, the method and model will not
reduce exposure in the community to a level needed to aid the
community in health recovery.
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Response:. The RSR smelter has been only one of many sources of
lead in the urban environment in west Dallas. EPA's Superfund
cleanup efforts resulted in the removal of the RSR-related
lead from residential areas. Compared to a national average
of 8.9%, 8% of west Dallas children currently have elevated
blood lead levels. Further reductions of lead in residential
areas must be obtained through community education and other
programs.
Comment: We are asking EPA and ATSDR to buy out and relocate
residents in the most polluted area. The area in question is
near the DHA property that is presently granted relocation and
reconstruction.
Response: The Superfund law does not authorize EPA to buy
properties that can be successfully cleaned up. Relocation of
persons and reconstruction of buildings were not required at
the DHA property. These actions were undertaken by DHA based
on the poor conditions of the buildings in the contaminated
areas. Some of buildings had been vacant for as much as 10
years and were structurally unsafe.
Mr. Jim Schermbeck, Jobs and Environment Campaign
Comment: EPA should try to eliminate all sources of lead
exposure one by one in the west Dallas community. This means
cleaning up the soil to 250 ppm instead of 500 ppm, cleaning
the contaminated dust out of homes, sponsoring lead paint
removal programs in the area, address on-going sources of lead
pollution which continue to deposit lead on west Dallas ground
and try to get to the bottom of the mystery of
recontamination.
Response: EPA agrees that broader action than is possible
under the Superfund law or from a single agency like EPA is
needed. Responses to specific suggestions are summarized
below:
cleanup soils below 500 ppm- Comprehensive studies
conducted by EPA, the State of Texas Department of
Health, the ATSDR, and the City of Dallas all conclude
that there is no benefit to cleaning up soils below 500
ppm. Results further show that the average soil lead
levels in west Dallas are less than 120 ppm and that of
the children with elevated blood levels, almost 90% live
in homes with soil lead levels less than 250 ppm.
cleanup house dust- EPA, ATSDR, and the City of Dallas
studies found there was no public health threat from
house dust containing lead. The studies further show
that there is no correlation between the blood lead
levels of children in west Dallas and the actual soil or
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dust lead levels in their homes.
sponsor lead paint removal programs- EPA will endorse
applications by the City of Dallas Housing Department to
obtain lead abatement grants from the Department of
Housing and Urban Development. EPA has already
recommended to HUD that Superfund sites with lead (lead
paint) not related to the source (smelter) should receive
priority in being awarded funds for lead abatement.
• address ongoing sources of lead- Through the use of
grants, EPA provides funds to the City of Dallas and
TNRCC to carry out environmental programs that seek to
control ongoing sources of lead and other contaminants.
EPA has also joined with 11 other federal, state, and
local agencies to form the Dallas Area Steering Group to
provide citizen information about various lead issues.
regarding the "mystery" of lead recontamination- There is
no evidence that a mystery exists:
o all residential areas cleaned up in the 1980s were
resampled and found to be clean.
o soils in front of the Boy's and Girls Club were
found to have lead contamination; it is discussed
below.
Comment: Why did the Boy's and Girl's Club have to be cleaned
up three times?
Response: Different areas of the Boy's and Girl's Club were
cleaned at different times. EPA believes that any
recontamination may have resulted from roofing activities
conducted after the initial cleanup of the 1980s. There are
no indications that recontamination resulted from the smelter
facility since it stopped operations in 1984. High volume air
monitors located on the roof of the Boy's and Girl's Club have
not recorded any ambient air violations since 1984.
Comment: Why are there higher blood lead levels in the
community, even after the cleanups?
Response: The lead levels are not higher. The current blood
lead levels in the community immediately downwind of the
smelter are much lower than in the 1980s when the first
cleanup occurred. In the community immediately downwind of
the smelter, the average blood lead level in the 1980s was
20.1 Mg/dL compared to the current average of 7.0 /ig/dL. In
the 1980s, 91.5% of the children had blood lead levels above
10 Mg/dL compared to the current number of 18.9%; 29.2% had
blood lead levels above 20' /Kj/dL in the 1980s compared to zero
10
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today; and 10.5% had blood lead levels above 30 /ig/dL in the
1980s compared to zero today. Clearly the closing down of the
smelter facility, eliminating lead gasoline, and the soil
cleanups have had a significant effect in lowering the blood
levels in the community. As with urban communities across the
country, many sources contribute to elevated blood lead levels
in children.
Comment: The EPA should not consider declaring success in
west Dallas while there are blood lead levels that are more
than twice as high as the rest of Dallas.
Response: Information available from the City of Dallas and
Texas Department of Health show that some areas of Dallas have
higher blood levels than in west Dallas and several areas have
comparable levels. As indicated in the above response, blood
lead levels in west Dallas have in fact significantly
decreased since the early 1980s.
Comment: The government needs to provide full health care to
residents of west Dallas exposed to lead over the years.
Response: Health care is already provided by a number of
different federal and local agencies. Information about
testing and treatment options related to lead is provided in
the Dallas Area Citizen's Guide to Lead. EPA's role under the
law is to cleanup environmental sources of contamination which
may cause health problems. EPA has fulfilled this role in the
residential areas.
Comment: EPA should raze the smelter and replace, it with
facilities to help the community.
Response: Proposed decisions regarding the smelter will be
separately released for comment; the current Superfund law
authorizes EPA to remove contamination threats but not spend
trust fund monies to redevelop properties.
2. Public Meeting, KGBS Talk Radio (AM 1190), January 15, 1995.
Comment: Why did EPA people wear frightening 'space suits'
when cleaning up properties where residents have lived for
years and wear normal clothing?
Response: EPA cleanup staff are required, at a minimum, to
wear white Tyvek coveralls because they work at a wide variety
of sites around the State and the country. The need to have
these people wear protective dress is similar to the
requirement that firemen wear protective clothing, even if
responding to a false alarm.
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c*
•....-• ' . . o-i
Comaebt? EPA created the Super fund problem in west Dallas and cfl
should pay for its cleanup rather than create more taxes for «r-f
local citizens. O
Response:. EPA neither created the lead contamination in west
Dallas nor are local taxes being imposed to fund the cleanup.
Lead contamination originated from the RSR smelter operations
beginning before there were land use or pollution laws. EPA
has paid for all of the cleanup and studies from a national
trust fund. EPA will seek reimbursement of the money it spent
from responsible parties for the site and not from the
citizens that were affected by RSR contamination.
Comment: What's the cleanup costing?
Response: The total that EPA has spent to date is
approximately $16 million dollars. About $12 million was
spent directly in the cleanup of private residential
properties and about $4 million has been spent in studies. In
addition, the Dallas Housing Authority has spent approximately
$10 riillion in demolition of 167 public buildings and removal
of contaminated soils.
Comment: How many children were actually tested and show lead
in their systems?
Response: Three hundred-thirty three (333) children from west
Dallas were tested in EPA's home sampling program for the RSR
Site; 29 children (8%) had blood lead levels elevated above 10
jig/dL and only one exceeded 20 (j.g/dL. This is about 10% less
than is usually encountered since the national average for
urban areas is 8.9% above the 10 /ig/dL level.
In addition, the City of Dallas has had a lead testing program
in the west Dallas clinic (the West Dallas Multi-Purpose
Center) since the early 1980s. The City has tested thousands
of children not only from west Dallas, but also from other
areas in the City.
Comment: EPA should have cleaned up lead contamination from
under the houses.
Response: EPA disagrees; the cleanup was conducted to remove
RSR lead contamination from probable pathways of exposure.
Comment: What does EPA propose to do about smelter slag
buried on RSR Site property across the railroad tracks west of
Westmoreland Avenue?
Response: EPA is currently conducting studies of this area
and will propose alternatives for public comment to address
this potential problem in the near future.
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Conment: Will EPA dismantle the smelter stack and smelter
buildings? r-f
O
Response: EPA will propose alternatives for public comment for
this potential problem in the Spring of 1995.
Comment: Is EPA doing anything unde? the Superfund program
about the other lead smelters that used to operate in Dallas
(e.g. the 'Dixie Smelter' or 'Dixie Iron'?).
Response: Only the RSR smelter has been proposed for addition
to the Super fund list of hazardous sites. At one time, there
were three secondary lead smelters operating in Dallas: the
Dixie, NL and RSR companies. The Dixie and NL smelters were
located close to each other in east Oak Cliff. These two
smelters were smaller than RSR and created less pollution. In
the early 1980s, when RSR's first cleanup occurred, soils
around these facilities were also cleaned up. Followup
studies are being conducted by the former owners under State
enforcement authority.
Comment: Blood lead levels can indicate recent exposure but
how can you measure buildup of lead in the central nervous
system and body and the health impacts?
Response: When lead enters the body, it is first carried in
the blood. While in the blood, lead can affect the central
nervous system and brain. Children are especially sensitive
to lead because their central nervous systems are still
developing. In the long term, lead is either excreted from
the body or absorbed into the bone.. As long as the lead is
stored in the bone, it produces no adverse health effects such
as damage to the central nervous system. Damage to the
central nervous system from lead can be permanent; however,
lead does not "build up" in the central nervous system.
Comment: It seems to me that many people living in west
Dallas are losing limbs to diabetes. Does exposure to lead
increase susceptibility to diseases like diabetes?
Response: Health scientists are not aware of any data to
connect lead contamination with diabetes. Studies have
documented damage to the central nervous system and kidneys
from exposure to lead.
Comment: Please describe the upcoming lead regulations as
they pertain to real estate.
Response: The real estate lead disclosure rule is scheduled
to be finalized around August or September 1995. Under this
rule, home owners are not required to test their home for
lead-based paint. However, before finalizing a contract to
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sell a pre-1978 home, the seller or their agent would have to
disclose 'all known information regarding lead-based paint and
lead-based paint hazards in the home. In addition, they would
have to afford the purchaser a 10-day period to finance and
conduct an inspection or risk assessment of lead-based paint
hazards. The seller or agent will have to provide the
prospective purchaser an EPA pamphlet on lead hazards. This
pamphlet is scheduled to be available in April or May 1995.
The disclosure portion of the lead rule will also apply to
landlords of multi-housing buildings. However the tenant will
not be afforded the opportunity to test the building for lead-
based paint.
Comment: Why didn't EPA sample the inside of homes that had
yards cleaned up?
Response: During the cleanup of 420 homes, samples were not
collected from inside the homes. However, as part of the
random home study remedial investigation, soil, indoor dust,
tap water, and indoor and outdoor paint samples were collected
from over 300 homes in west Dallas, including some homes where
soil removals had been conducted. The studies showed no
correlation between dust and high blood lead levels showing
that cleanup inside homes was not needed.
Comment: We are surrounded by dump sites, dust, slag and
battery chips three or four blocks from where I'm sitting now.
And on that hill dust is continually blowing, and I know you
got a monitor across the street from my house up there. And
dust is continually blowing. They're wondering where it's
coming from. It's coming from the slag piles. It's the dust
that's still being exposed in this area.
Response: Air quality tests show the air to be free of lead in
west Dallas. Several high volume air pollution monitors have
been located near the smelter for years, and none have shown
elevated lead readings since the smelter ceased operations in
1984. Homes located across the street from the smelter that
were cleaned in 1984-1985 were re-sampled in 1992 to determine
if recontamination was occurring. Results show that
recontamination was not occurring at these homes.
Comment: Why does the Boys Club keep getting contaminated?
Response: It is not clear that any recontamination occurred
at the Boys and Girls Club. Records of the initial cleanup
conducted in the 1980s do not specify if the lawn in front of
this facility was replaced. When EPA sampled the lawn in
1992, high levels of lead were found (and soils were promptly
replaced). One of several air pollution monitors is located
at the Boys and Girls Club. No elevated lead readings have
been recorded at this monitor since the smelter closed in
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1984. EPA believes that the contamination may have been
caused by the replacement of the flat roof after the cleanup
was conducted which could have resulted in recontamination of
previously clean areas. Sampling of flat roofs from DBA
buildings close to the smelter show high lead levels in the
tar and gravel roofing material. EPA therefore believes that
the high lead readings in 1992 were due to either the area
never having been cleaned up in the 1980s or from roofing
materials that were dumped over the side of the building.
Comment: It doesn't make sense that EPA would demolish
abandoned public housing buildings because their roofs are
contaminated with lead but leave standing private residential
homes located across the street the same distance from the
smelter.
Response: EPA is not demolishing public housing buildings
because of lead contamination; evidence shows that tar in the
flat roofs of the public buildings retained lead dust but the
sloped roofs generally did not. The buildings in the Dallas
Housing Authority are being demolished by the Department of
Housing and Urban Development (not EPA) as part of their plans
for renovation of public housing. EPA did oversee this
operation to ensure that lead contamination was properly
corrected when demolition occurred. During demolition, 20 of
167 building's flat tar roofs (nearest the smelter) were found
to have lead contamination. It is evident that dust from the
smelter settled on, and became imbedded in the tar on the flat
roof surfaces. Because of the composition and sloping roofs
of private homes, it appears that lead contaminated dust was
not retained in this type of roof and was probably washed away
by rain.
Comment: How much pollution is being created by the "lead
smelter" located on the former RSR facility.
Response: The Murmur Corporation has an active operation that
is not a smelter and does not create detectable levels of lead
air pollution. Murmur melts lead to manufacture sheets for x--
ray rooms. Air pollution monitors across the street from
Murmur have not detected any lead pollution from the facility. .
In 1993, the company estimated that less than 100 pounds of
lead per year was emitted to the environment (air, water,
soil, etcetera) from its processes. Murmur reported this to
EPA in a "Toxic Release Inventory" report under the category
of environmental losses between 11 and 500 pounds per year,
although the actual amounts are much less than 500 pounds.
Comment: Wouldn't operation of the Murmur facility add to
existing contamination? Could that be a part of the
recontamination of the Boys' Club since it is located across
the street from it?
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•• ... . . .. .
Response t There are no indications that melting operations at
the; Murmur facility are resulting in lead contamination of the
surrounding community.
Comment: Was lead contamination found on the grounds of the
nearby Edison middle school?
Response: No, the grounds of the Thomas Edison school were
sampled but found to have lead concentrations below 500 ppm.
Comment: What health care followup has EPA or U.S.. Public
Health Service provided to children who tested high for lead
in the 1980s?
Response: The City of Dallas Health Department (not the EPA
nor the Public Health Service) is responsible for followup of
west Dallas children with elevated blood lead levels.
Following national guidelines published by the Centers for
Disease Control, the City Health Department:
Recommends followup testing for children with blood lead
levels between 10 /ig/dL and 15
• For children with blood lead levels between 15 jug/dL and
20 /ig/dL, the City conducts home sampling to try and
identify lead sources; and
• For children with blood lead levels over 20 /Ltg/dL, the
City refers children to physicians for medical
evaluation.
Comment: In the early 1980s over 90% of the children in west
Dallas had elevated blood lead levels, what care and treatment
was given to them?
Response: By today's standards, 91.5% of children living near
the smelter in the 1980s had elevated blood lead levels.
However, only 10% exceeded the standards of that time of 30
jig/dL. The Centers for Disease Control lowered the national
guidelines to 10 jig/dL in 1991. Regardless of the guideline
in effect, the City of Dallas has provided testing and health
consultation followups to all children with elevated blood
lead levels.
Comment: The public needs to know that wet mopping with a
high phosphate detergent is effective in control of lead
contaminated dust. Also, more information regarding lead
abatement can be obtained by dialing 1-800-LEADFYI.
Response: EPA agrees and additional information regarding
actions people can take to minimize exposure to lead is
available from various, agencies listed in the "Citizen's Guide
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to Lead Issues" which is available to the public.
Comment: It is now January 15, 1995; why haven't I received
the written response to the questions that I raised at the
December 1, 1994 Public Meeting?
Response: To respond to public requests for more time, EPA
extended the public comment period for 30 days to January 18,
1995. This Responsiveness Summary contains responses to all
questions and comments received during the comment period,
including those of this commentor.
Comment: All of the literature published by EPA is confusing
to me, where can I get straight answers to my questions?
Response: In order to respond to this concern, EPA
established a walk-in information office in the West Dallas
Community Center, held 6 Open House informal meetings with the
community during the study period, and has published names and
telephone numbers of responsible people to respond to
inquiries on a one-to-one basis.
Comment: How can the community be assured that the EPA
cleanup was thorough and complete when some properties were
cleaned while others nearby were not? It seems that cleanup
was done on a random basis.
Response: EPA's cleanups have been conducted based on
contamination levels and not on a random basis. In the air
deposition area, all homes were sampled, and those that
exceeded the removal action cleanup levels were cleaned. In
the rest of west Dallas, the cleanup was based on homes that
had used battery chip materials as fill for driveways and
exceeded the cleanup levels. The battery chip locations were
scattered throughout west Dallas and appeared random. This is
due to the fact that only some of the homeowners in the area
used these materials for fill purposes. TNRCC surveyed 6,800
properties in the west Dallas area to identify battery chip
fill locations. Where battery chip fill locations were
identified, soil samples were collected for laboratory
analyses to verify if the fill areas were contaminated above
the removal action cleanup levels. As a result, EPA conducted
cleanups in 420 homes and play areas in west Dallas. The
facts are that significant actions have been taken in west
Dallas and EPA is continuing its work by next addressing the
smelter facilities and slag piles.
Comment: When the Dallas Housing Authority demolished the
abandoned public housing buildings, pollution drifted across
the street into the inhabited single family residential area.
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QO
Responses Contamination did not spread to the residential
areas during DHA's demolition and removal action. Under EPA
oversight :, the Housing Authority employed pollution control
measures during demolition to prevent off site contamination.
In addition, an extensive air pollution monitoring program was
used to confirm that the control measures were effective and
pollution was not released to the surrounding areas.
Comment: Why didn't EPA just buy out all contaminated houses
instead of cleaning them up?
Response: Buyouts were not authorized under the Super fund law
because the removal of RSR contaminated soils effectively
corrected the environmental problem.
December 14, 1994 Resolution by the Dallas City Council.
Comment: EPA should continue to review all aspects of lead
contamination near the RSR site and implement solutions to
elevated blood lead levels in children, regardless of source.
Response: EPA will continue to do its part under a variety
of statutory authorities to reduce the risks of environmental
lead contamination throughout Dallas and the rest of the
country. However, neither EPA nor other federal agencies have
the authority or responsibility under federal law to act
unilaterally to address all possible sources of lead
contamination. Local authorities, such as the City of Dallas
(which is responsible for zoning, lead testing, and other
measures) , must join with other agencies at County, State and
Federal levels to find and solve remaining lead contamination
problems .
Comment: EPA should continue cleaning up lead contamination
from the residential areas until the causes of, and solutions
to, elevated blood lead levels are found.
Response: Independent studies by the City of Dallas Health
Department and the State Health Department agree with EPA's
assessment that further cleanup of RSR lead in soils will not
benefit public health. Nine out of ten households where
children have elevated blood lead levels also have soil lead
levels from all sources less than 250 ppm, which is half of
EPA's Removal cleanup goal of 500 ppm. Instead, the City's
study points to a wide variety of other causes of elevated
lead levels in children. EPA agrees with, and has
implemented, the idea of cleaning up RSR lead concurrent with
lead contamination studies. The initial Removal Action soil
clean up goal of 500 ppm for smelter related lead
contamination has been achieved in all participating single
and multiple family residential areas of west Dallas.
Concurrent studies by EPA show that the 500 ppm goal exceeded
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O5
the level needed to protect human health. Instead of soil
lead contamination> the City's own studies point to other
potential causes such as leaded house paint and occupational
exposure from .workers to the household.
Comment: EPA should conduct new studies to determine the
causes of continued elevated blood lead levels in children who
live in the high air dispersion and eastern low air dispersion
areas of west Dallas, and then take additional needed actions.
Response: While elevated blood lead levels (> 10 nq/dl) have
dropped dramatically in the past decade (from 91.5% of
children near RSR in 1983 to 8.0% in all of West Dallas in the
1990's) EPA is concerned that elevated blood lead levels
continue to affect many Dallas area children. The studies
already completed show where joint actions, rather than more
studies, between Federal, State, and local authorities can
further reduce lead as a health threat. EPA stands ready to
do all in its authority to work with the City and other
agencies to eliminate lead as a public health threat.
The studies prepared by the City show no relationship between
remaining soil lead concentrations and blood lead levels.
Instead, they point to other potential sources of lead. For
example, in the high air dispersion area near RSR there were
10 children living in 6 households with elevated blood lead
levels (reported as 18.9% of this neighborhood) ; only one of
these homes had soil lead levels exceeding the removal action
cleanup level and a removal action was subsequently conducted.
In Oak Cliff, there were 4 children in 4 households with
elevated blood levels (4% of neighborhood) . The data
collected by the City shows:
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HOUSEHOLDS HOUSEHOLDS
NEAR RSR IN OAK CLIFF POSSIBLE LEAD POLLUTION SOURCE
5 OF 6 1 OF 4 Member of household has
occupational exposure to lead
but does not have/use cleanup
facilities before returning
home.
4 of 6 2 of 4 Eating utensils (glazed
ceramics, pewter, copper).
3 of 6 2 of 4 Live in a house with a wooden
exterior that was repainted,
sanded or chemically stripped
within the last year
Because the numbers of affected households are small, and
because the reason for any one person's elevated lead level
cannot be directly proven, the above associations can only
point to general problems.
Comment: EPA should conduct new studies to determine the
causes of continued elevated blood lead levels in children who
live in east Oak Cliff near the former Dixie Lead Smelter, and
then take additional needed actions.
Response: Causes of elevated blood lead levels at some houses
in Oak Cliff which have not been influenced by smelter
emissions are discussed in the previous response.
Contamination that may be associated with the former Dixie
Lead Smelter is being assessed by the Texas Natural Resource
Conservation Commission through the State of Texas Resource
Conservation and Recovery Act program.
Comment: EPA should pursue all necessary options to require
the cleanup of residential properties in west Dallas where the
owners previously refused access to EPA for testing or
cleanup.
Response: Out of 6,800 properties surveyed by the State for
EPA in west Dallas, owners of 30 did not allow EPA access for
sampling or, if needed, remediation. Those residents that
refused initial requests for sampling were allowed several
opportunities to participate. It is EPA's policy not to force
citizens to allow the government to sample private residential
property or require cleanup even if needed.
Comment: EPA should require the cleanup of the RSR Smelter as
soon as possible .
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CO
.
Response: EPA agrees. Proposed cleanup options will be
released for public review and comment in the near future.
Comment: EPA should decide the best public health solution to
slag piles as soon as possible.
Response: EPA agrees. Proposed cleanup options will be
released for public review and comment in the near future.
Comment: EPA should guarantee funding for the removal of
additional lead contamination that may be discovered in the
future .
Response: Under the Super fund law, EPA has the funds,
authority, and responsibility to protect public health and the
environment from significant hazardous waste threats. To the
extent that Congress continues this statute, EPA will continue
to respond to these problems.
Comment: EPA should provide, or assist in obtaining, funding
for the City of Dallas to address other sources of lead
pollution which may be affecting the health of the City's
children.
Response: EPA currently provides grants to support the City's
air pollution program. EPA does not have statutory authority
to issue grants for programs such as lead paint abatement;
however, EPA is willing to add its endorsement to grant
applications by the City to other agencies that deal with
these programs.
From Yvonne Davis/ State Representative District 111, letter
dated December 21, 1994.
Comment: It is my understanding that tests continue to show
higher than normal lead readings for the citizens of west
Dallas, particularly children under the age of six.
Response: This view is not quite accurate. There is no
"normal" blood lead level for humans. Scientific studies show
that EPA has eliminated RSR-related lead contamination from
the residential areas of west Dallas. However, these same
studies indicate that there are other sources of lead in west
Dallas that may be contributing to the elevated blood lead
levels in children. To address other lead sources, EPA has
joined with 11 other Federal, State, and local organizations
to form the Dallas Area Lead Steering Group. Members of this
group collaborated to write a "Citizen's Guide to Lead
Issues". The Guide provides answers to some of the most
commonly asked questions regarding urban lead contamination
and summaries of local services that are available.
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CO
Commenti I am respectfully requesting your consideration in
continuing your cleanup efforts in the west Dallas area.
Responses EPA will continue to do its part to eliminate lead
as a public health or environmental problem. RSR lead
contamination at the smelter facility, the industrial areas,
in land fills and in the groundwater will be evaluated and
cleaned up by EPA, if necessary. The public will be fully
involved in these decisions. In addition, EPA will join with
other Federal, State, and local agencies to address the other
sources of lead that exist in the urban environment.
5. From Dr. James L. Carter, University of Texas at Dallas- Lead
in West Dallas Soils Study, Letter dated December 8, 1994.
Comment: Preliminary results of an on-going geochemical study
of the vertical distribution of lead in west Dallas, Texas
clay-rich soils reveal that considerable volumes of soil with
lead levels equal to or greater than 500 ppm remain even after
remediation efforts.
Response: EPA does not agree. Samples collected by the UTD
researchers were collected in the Summer of 1992, just as
EPA's Emergency Response Branch was starting its full-scale
removal action in the residential areas of west Dallas and a
full two years before the removal action was completed.
Samples collected by the UTD researchers are not
representative of soil lead levels in the residential areas
and were not collected to determine human health risks but
rather to determine if methods used to track metals through
the natural environment could also be used to track smelter
pollution. On the research study report, four of the most
highly contaminated soil borings are described as: These
cores are not part of the original, undisturbed soil profile
because they contain pieces of nails, concrete, and limestone,
things widely used in construction activities. Thus the lead
content with depth does not indicate systematic behavior as in
the case of the undisturbed soil profiles. Additionally,
nearly all of the soil samples with elevated soil lead levels
were collected along and next to two major roadways, Singleton
Blvd. and Westmoreland Road where soils are most likely
impacted by leaded gasoline. Use of these results to draw
lead concentration isopleths that supposedly represent lead
contamination in the residential areas is unscientific and
presents misleading information to the community.
Comment: Twenty-nine percent of soil cores from previously
remediated areas reveal surface recontamination with ex lead
values exceeding 500 ppm.
Response: This statement is without factual basis. EPA has
learned that the UTD researchers did not know exactly where
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previous cleanup occurred. Instead, UTD researchers
erroneously assumed that any disturbed sample of soil had been
previously remediated. EPA conducted a site visit with Dr.
Carter in January 1995. EPA was shown 26 UTD soil core sites.
Of the 26 soil sample sites, 24 locations were found to have
never been remediated by EPA since they were located along and
next to roadways instead of residential yards, play areas, and
schools. Of the two remaining UTD samples, one had no
significant contamination regardless of depth and the other
had been collected from a location the Dallas Housing
Authority had scheduled but not yet cleaned up.
Comment: The isopleth lead data suggest that as much as
100,000 cubic meters (120,000 cubic yards) of soil, to a depth
exceeding 30 cm (1 foot) nearest the smelter, will have to be
removed to reduce levels to less that 500 ppm, at the cm-
scale.
Response: This statement is without factual basis. UTD's own
reports indicate that the data obtained is not representative
of the residential areas. Most of UTD's samples were
collected next to major roads and 85% of the UTD samples with
lead concentrations above 500 ppm were from "disturbed" soil
borings containing construction debris (e.g. nails, concrete,
limestone) . None of the UTD samples were collected from
residential yards where children could be exposed to lead
contamination. The limited number and locations of the
samples collected for the UTD study are not representative of
the isopleth areas used to estimate the volume of soil
contaminated with lead levels above 500 ppm.
6. From PEACE Environmental, letter dated January 17, 1995.
Comment: Those residential areas where access for initial
sampling were denied should be revisited and sampled.
Response: A small number of property owners refused EPA
access to their properties for sampling or cleanup. Each was
given several opportunities (including letters, and home
visits) . EPA believes that it gave full opportunity for
participation to these homeowners. EPA will not enter and
sample a residential property by force and has pursued all
options to gain voluntary access.
Comment: EPA contractors should conduct a reinspection of the
excavated residential areas to ensure proper maintenance.
Response: It is the homeowner's responsibility to properly
maintain their yards. Prior to backfilling an excavated area
with clean fill, confirmatory sampling was conducted to ensure
that remaining soil lead levels were below 500 ppm.
Therefore, maintenance of excavated residential areas is not
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a requirement for health reasons or to prevent exposure to
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Comment: EPA should inform the residents of the current.
amount of lead emission at the operating Murmur Corporation
lead manufacturing facility.
Response: This information is available to the public through
the Toxic Release Inventory (TRI) System published every year
and available at the public library. Murmur Corporation is
listed as releasing 500 pounds of lead emissions per year in
the TRI because the reporting category is from 11 pounds to
500 pounds and the TRI report lists the maximum amount of 500
pounds. However, Murmur believes that actual lead emissions
are less than 100 pounds per year. Currently emissions occur
mainly at the plant within the Murmur facility. No stacks are
used to release emissions into the environment or surrounding
community. Operations at the facility consist of melting lead
and are not smelting operations as with the former RSR
facility. The melted lead is processed into lead sheets for
x-ray rooms. The lead melting furnaces are equipped with
filters and scrubbers to collect lead air emissions. High
volume air samplers located downwind across the street at the
Boys and Girls Club and six blocks away at the Emila Earhart
Elementary School are monitoring operations at this facility.
In addition, the City of Dallas air monitoring division
conducts random air sampling at the facility on a quarterly
basis. No ambient air emissions standards have been violated
since the RSR smelter closed in 1984.
Comment: EPA should establish within the vicinity of Pinacle
Park, a community based environmental health clinic and
environmental training/ information center for west Dallas
residents who cannot read and understand the currently
available information in the library.
Response: The City of Dallas already operates a health clinic
in west Dallas. Frequent informal public meetings have been
provided and will continue to be provided to inform all
residents, regardless of reading ability, of site progress.
Comment: EPA should declare west Dallas, especially along
Singleton Boulevard, an "Environmental Safe Zone".
Response: EPA has made residential areas of west Dallas
included in Operable Units 1 and 2 environmentally safe.
Plans for the industrial areas will be proposed for public
review and comment in the near future.
8. From Sierra Club, Lone Star Chapter. (Note: Summarized below
are EPA's responses to the Sierra Club in a letter dated
January 19, 1995).
Comment: New scientific evidence suggests unsafe west Dallas
soil levels continue to exist. The Sierra Club expressed
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concern; that "new scientific evidence? from University of
Texas at> Dallasv (UTD) researchers would reveal that EPA has
misled/residents regarding the thoroughness of cleanup.
•;..;•' . • . . •
Response: EPA disagrees. The UTD study does not show
scientific evidence that unsafe levels of soil lead remain in
the residential areas of west Dallas. Soil samples collected
under the UTD study were not located at residential locations.
In the UTD study, soil samples were not collected to determine
the maximum exposure to children or human health risks from
lead exposure as EPA studies did. The UTD samples are not
representative of soil conditions in the residential areas of
west Dallas. They represent conditions along two major
streets (Singleton and Westmoreland) and* other side streets,
most likely impacted by leaded gasoline, where the majority of
the UTD study samples were collected. The UTD study shows
that samples were collected from only 33 locations over a one
mile radius of the smelter facility. Within this same area,
EPA collected thousands of samples from over 1,000 different
locations.
Comment: Averaging of soil samples is not science in the
public interest — produces artifacts! Three concerns were
expressed regarding the accuracy of the EPA sampling approach:
(1) EPA missed "hot spots" of lead contamination by averaging
four composite soil samples per yard; spots with high
lead concentrations would be "diluted" by being averaged
with samples from spots with low lead concentration. The
average concentration found per yard is an "artifact" of
the averaging process.
(2) EPA did not sample deeper than 3 inches and missed deeper
"hot spots" of lead contamination.
(3) EPA's approach was "less refined" than UTD's and grossly
under-reports the amount of lead in west Dallas. A
December 4, 1994, Dallas Morning News article was cited
as support for this assessment. The article reported
that UTD researchers found that 33 percent of their soil
samples exceeded 500 parts per million (ppm) compared to
only 1.5 percent of the EPA samples.
Response: Each of these contentions are inaccurate and
contradicted by the EPA sampling protocols made available for
public review and comment. Responses to each of the above
concerns are:
(1) EPA's composite sampling approach provides a
statistically accurate measure of human exposure to lead
in residential soils. The UTD samples were taken to
determine if mining techniques could track smelter
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pollution— The EPA approach did not hide contamination
nor did> it produce-"artifacts". Separate sets of five to
eight (rather than four) composite samples were taken
from the front yard, from the back yard, and from
children's play area(s). Each set of samples was
combined to more accurately reflact the day to day
accumulated exposure that a resident would encounter.
Any area that exceeded the Removal Action Level was
cleaned up. The Sierra Club's concern that averaging
five samples might miss a "hot spot" or underestimate
exposure was considered by EPA before general sampling
was begun. The Sierra Club does not have an
understanding of how lead contamination was deposited as
a result of air emissions originating from the smelter
stack. An intensive pilot study sampling campaign was
conducted at 7 residential properties in the air
deposition area and other parts of west Dallas to
determine sampling protocols for the comprehensive home
study. Statistical analysis of samples collected and
individually analyzed from 2-foot intervals showed that
the 5 to 8 sample composite approach would not miss any
"hot spot" and that this approach would accurately
reflect residential exposure patterns.
In the contaminated battery chip areas (where sharp
variations in lead concentration were expected and
encountered), initial sampling was conducted at 10 foot
intervals using field portable equipment, krieging
analyses were performed to delineate areas for cleanup,
and laboratory samples were collected in the contaminated
areas. After cleanup, the perimeters of cleaned areas
received intensive confirmatory sampling to ensure that
all contamination had been removed.
Examples of potential problems which may diminish the
accuracy of the UTD study, or its relevance to the
Superfund program, include:
• Small UTD sample size; UTD researchers collected
between 30 to 50 samples (compared to some 7,000
samples by EPA); variations in UTD data have little
significance to residential locations of west
Dallas in general. None of the UTD samples were
collected from inhabited residential areas.
other sources of lead ; UTD researchers may have
measured lead from a variety of sources other than
the RSR smelter. Many of the samples showing high
lead levels were collected from between curbs and
sidewalks of busy City streets and therefore could
reflect leaded gasoline auto exhaust. Other high
lead samples appear to have been collected from
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\: areas of "disturbed" soils or commercial operations
' . (e-.gr a former .gasoline 'station, a bus stop* or
metal fabricating business) . The UTD study even
states that four soil samples taken from, the
vicinity of the smelter that show the highest lead
levels "are not part of the original . undisturbed
soil profile because they contain pieces of nails.
concrete, and limestone, things widely used in
construction activities. Thus the lead content
with depth does not indicate systematic behavior as
in the case of the "undisturbed" soil profiles."
(2) EPA routinely sampled deeper than 3 inches. In the air
deposition area, initial samples for RSR lead
contamination were taken from the top 3 inches of soil to
accurately reflect human exposure. When surface soils
required cleanup, the top 6 inches of soils were removed
and then the next 3 inches were sampled. If
contamination was found at this level, another 6 inches
of soil was removed and the process was repeated. Lead
in residential soils in the air deposition area was
usually confined to the surface of soils. There were
only a few instances where lower sampling indicated that
additional excavation was needed.
In the battery chip areas, contamination usually extended
deeper than 6 inches due to the way that battery chips
had been used for fill. Sampling and excavation often
occurred to depths of 24 inches or more.
(3) EPA/s reports are statistically accurate descriptions of
residential area lead contamination; the UTD results
referenced by the Dallas Morning News are not. In the
same December 4,1994, Dallas Morning News article that
you referenced, UTD professor Dr. Carter indicated that
his studies were not representative of residential area
contamination. A simple comparison between the
percentage of samples exceeding 500 parts per million of
lead is not accurate or meaningful due to the many
differences in scope, sample size, and purposes discussed
above. Moreover, EPA's information received scientific
peer review prior to its release for public comment.
Some of the UTD data has yet to receive peer review or be
published.
Comment: Disproportionate lead cleanups: Cedar Park, Texas vs
west Dallas. The Sierra Club expressed concern that in 1990,
the Texas Air Control Board (now the Texas Natural Resource
Conservation Commission or "TNRCC") had proposed a lead
cleanup goal of 100 ppm for residential soils in this non-
minority community while EPA was proposing levels 5 times
higher in the predominantly minority community of west Dallas.
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... .. . . .. . ... .,.
Responses The .sierra Clubfs; concerns- appear to be based- upon-
a misunderstanding. Disproportionate cleanup goals were^not
proposed by the State at Cedar Park nor EPA at west Dallas!
Lead contamination of soils in Cedar Park resulted^ ftom?
sandblasting of paint from a municipal water supply tank. The
Texas Air Control Board proposed a goal of 500 ppm of leads in
soils based upon the same type of guidelines EPA utilized: to
set 500 ppm as a Removal Action Level in west Dallas. The
City of Cedar Park, which owned the water tower, wanted
cleanup to the 100 ppm level as an extra safety precaution* in
the absence of a human health risk assessment . The State
agreed to allow cleanup below 500 ppm as proposed by the City
on a case by case basis. At the RSR site, a scientific human
health risk assessment has been conducted that shows that the
500 ppm Removal Action level already provides a margin of
safety. The City of Dallas is currently reviewing all federal
reports to formulate their position regarding clean up goals
for the site. It is important to note, however, that
technical studies by the City of Dallas eliminate contaminated
soil as a significant lead source but do identify a host of
other urban 'lead sources other than RSR.
EPA ' is committed to ensuring that poor, and minority
communities such as west Dallas do not suffer disproportionate
environmental insult. For this reason, we have dedicated the
resources to the RSR site necessary to conduct a prompt and
thorough cleanup effort while simultaneously conducting a
world class environmental evaluation. The suggestion that
disadvantaged segments of society would receive lower priority
or less consideration by EPA does not square with the agency's
track record.
9. From Dallas West interdenominational Ministerial Alliance-
letters dated November 17, 1994 and December 9, 1994.
Comment: Concern that EPA is leaving the west Dallas area and
that the lead cleanup is not completed.
Response: The Ministerial Alliance's concerns are based on
incomplete information published in the Dallas Morning News.
EPA is not leaving west Dallas; in addition to a continued
presence under a variety of other authorities, EPA is
continuing its Superfund studies for the RSR smelter and
industrial facilities, slag piles, and groundwater. EPA has
completed the cleanup in the residential areas of west Dallas.
Comment: Concern that elevated lead levels remain in west
Dallas leaving children at risk from remaining lead
contamination .
Response: EPA has eliminated RSR lead contamination as a
public health threat in residential areas of west Dallas.
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Other, sources of lead may continue to contribute to the
elevated blood lead levels in children. To address these
other sources, EPA has joined with 11 other Federal, State,
and local organizations to form the Dallas Area Lead Steering
Group. Members of this group collaborated to write a
"Citizen's Guide to Lead Issues". The Guide provides answers
to some of the most commonly asked questions regarding urban
lead contamination and summaries of local services that are
available.
10. From Disposal Safety Incorporated, letter dated December 19,
1994.
Comment: The model (IEUBK) EPA uses to predict blood-lead
levels in children does not accurately match the measured
blood-lead levels in children from OU 1 and 2.
Response: EPA uses the Integrated Exposure Uptake Biokinetic
Model (IEUBK) as a predictive tool for estimating changes in
blood lead as exposures to lead are modified. The model is
also a tool to make predictions about the levels of lead in
media (soil lead) that might be expected to impact human
health. The model examined site specific data on lead in
children's blood, soil, dust, water and air lead
concentrations. A default value for lead from diet was also
used. If differences exist between predicted and measured
blood lead levels, another source of lead exposure may be
involved. For example, ingestion of lead from paint chips, or
hobbies or lead inadvertently brought into the home from
occupational exposure are not directly reflected in the model.
Comment: Because the IEUBK model significantly underestimates
children's blood-lead levels around the RSR site, it will give
incorrect results when used to calculate "safe" levels of
lead in soil.
Response: EPA disagrees. The safety of the soil cleanup
goals predicted by the model was independently confirmed by
statistical analysis of blood and environmental lead data by
several different health authorities other than EPA. The
IEUBK model simulations for the RSR Site predicted a "safe"
soil lead level for lead from the RSR Site.
Comment: To compensate for the inadequacy of the IEUBK model,
EPA should lower the lead-in-soil cleanup levels in OU 1 and
2.
Response: As discussed in the previous two responses, EPA
disagrees based upon: the intended use of the model, the other
sources of lead that are not fully reflected by IEUBK, and the
statistical validation of the soil lead action level. It
should also be pointed out that an additional margin of safety
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resulted from EPA's cleanup efforts. The calculated lead ^
cleanup level for OU 1 was 540 parts per million (ppm) and 640 ^
ppm for OU 2. The actual cleanup levels implemented at both Q
OUs 1 and 2 was 500 ppm lead. Finally, 9 out of 10 households
having children with elevated blood lead levels also have soil
lead levels of 250 ppm or less.
Comment: Antimony and arsenic concentrations in soil are
correlated to lead levels, indicating that the RSR smelter was
the source of all three.
Response: EPA agrees that in the air deposition area, arsenic
levels can be correlated to the lead levels found.
Comment: If cleanup levels are adjusted in OU 2, the same
cleanup levels would need to be considered for OU 1,
especially in the residential area closest to the smelter
(Subarea 1) . The 500 ppm lead isopleth ( and its 99%
confidence interval) shown in Figure 2-11 of the RI for OU 2
extends into OU 1, so lead levels in the 300 to 400 range
should be expected. Further remediation in OU 1 may therefore
be necessary.
Response: EPA disagrees for the reasons stated in previous
responses. In addition, the 500 ppm lead isopleth in Figure
2-11 of the RI for OU 2 does not extend into the residential
areas of OU 1. The isopleth is correctly terminated within
the OU 2 site because it is based only on samples collected
from OU 2. It cannot be assumed that these concentrations
extend into the residential areas because many of the
residential yards in OU 1 have been cleaned up and significant
concentrations of lead no longer exist in the residential
areas as a result of EPA's cleanup. EPA's home study and
removal action in OU 1 have resulted in sampling being
conducted in nearly every home in the residential air
deposition area and results do not indicate soil lead
concentrations above 500 ppm. In fact, soil concentrations
average less than 120 ppm total lead.
Comment: During the EPA Soil Survey and Removal (Phase II),
which lasted form January 1993 to June 1994, 202 residences
which were contaminated with slag or battery chips were
remediated (RI, OU 1, p.3-16). A total of 301 soil samples
were collected to verify the effectiveness of the removal.
Cleanup standards of 500 ppm lead and 20 ppm arsenic (50 ppm
in the subsurface) were used. The 301 verification samples
ranged from below detection limit (BDL) to 480 lead (average
437), and BDL to 38 ppm arsenic (average 17 ppm).
Given the level of accuracy in the analytical methods used for
lead and arsenic (EPA SW-846 method 6010) which is generally
+ 25%, the levels of lead and arsenic left behind after this
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removal may not meet the criteria of 500 ppm lead and 50 ppm
arsenic. Twenty-five percent below 500 is 375 ppm, and 25%
below 50 is 37.5. Thus the average lead level after
remediation (437 ppm) may in fact be statistically
indistinguishable from 500 ppm. The same is true of the
highest reported arsenic level (38 ppm).
Response: EPA disagrees. EPA's Phase II removal action was
conducted from June 1993 through June 1994. SW846 Method 6010
"Inductively Coupled Plasma Atomic Emission Spectroscopy" has
a quantification limit for lead and arsenic of 10 and 5 mg\kg
or ppm, respectively. These quantification limits are
adequate to determine if the human health criteria are being
met at the site. These are very stringent test methods used
for testing chemical compounds under very high quality
assurance and quality control protocols. The comment did not
suggest that more accurate or better testing methods were
available. The accuracy of the laboratory results are
considered in the test analyses and in the conservative
modeling programs. As stated in the comment, the remaining
lead and arsenic levels, after the removal action, are
statistically lower than the action levels of 500 ppm lead and
50 ppm arsenic. Therefore, the cleanup criteria are being
met.
11. From Madres Del Este De Los Angeles (Mothers from east Los
Angeles), letter dated December 14, 1994.
Comment: This group urges EPA to resume investigations as
well as the cleanup effort on the continuing lead
contamination in west Dallas because the City of Dallas and
the federal Agency for Toxic Substances and Disease Registry
recently released a report showing ongoing lead emissions
still exist, primarily in the downwind neighborhoods.
Response: The EPA and the City of Dallas and ATSDR reports
conclude that additional cleanup of RSR soil lead
contamination is not needed.
Comment: The subject of the report was the neighborhoods'
children. The evidence is there, the high lead levels in
children, the Boy's Club on Singleton, the RSR smelter. Why
isn't the EPA doing something to help these children?
Response: EPA has and will continue to use all of the tools
available to it to eliminate lead as a public health threat
for all children.
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. .. :. . ••• . • .
12. The following public comments vere specifio to the^ RSR
Operabler Unit No. 2- Dallas^Housing Authority property.
.. ...." :" ••'''... ' • '
Petition .from residents of west Dallas.
Comment: We cannot understand why EPA has decided that
hundreds of children in the public housing project should be
exposed to two-and-a-half times more of the poisonous metal
arsenic than those who live in single-family houses. All of
us join in demanding that EPA immediately cleanup arsenic in
all contaminated areas of west Dallas to the same level— 20
parts per million.
Response: The public housing project, Operable Unit No. 2,
has been cleaned by the Dallas Housing Authority under
supervision by EPA, to the same cleanup levels as private
residential areas. Cleanup levels at the public housing
project and private residences consist of; 500 parts per
million (ppm) lead, 20 ppm arsenic, or 30 ppm cadmium.
Comment: We also demand testing of our soil, for other toxic
substances from the smelter, especially antimony.
Response: As part of the in-home study conducted throughout
west Dallas, including the public housing project, EPA also
analyzed soil, dust, and tap water samples for 21 different
metals. These included lead, arsenic, cadmium, and antimony.
Antimony was not detected above 20 ppm and was therefore not
considered a contaminant of concern. EPA confirmation testing
at OU No. 2 has included antimony. Antimony results have not
exceeded the detection limit of 15 ppm.
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