PB95-964205
EPA/ROD/R06-95/096
March 1996
EPA Superfund
Record of Decision:
RSR Corporation Superfund Site,
Operable Unit 2, Dallas, TX
5/09/1995
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RECORD OF DECISION
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT NO. 2- DMA 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 8UPERFUND SITE
OPERABLE UNIT NO. 2- DBA PROPERTY
DALLAS, TEXAS
Further Action Not Necessary For Protection
And Five-Year Reviev Is Not Required
SITE NAME AND LOCATION
RSR Corporation Superfund Site, Operable Unit No. 2
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 Operable Unit No. 2 (OU No. 2) 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 cased on materials and documents contained in the Administrative
Record for OU No. 2 that is available for public review at three
repositories, one of which is located near the RSR Site.
Specifically, EPA bases this decision on the results of a human
health risk assessment conducted by EPA for OU No. 2 and the
results of a remedial investigation and the successful completion
of certain removal and demolition activities performed by the
Dallas Housing Authority (DHA) at OU No. 2 from July 1994 through
March 10, 1995.
DESCRIPTION OF THE SELECTED REMEDY/RATIONALE FOR NO FURTHER ACTION
No further action is necessary at OU No. 2 because the demolition
and removal activities performed by DHA have permanently eliminated
the principle threats to human health and the environment from
contamination caused by the historic operation of a lead smelter
located adjacent to OU No. 2. DHA conducted these activities as
well as the remedial investigation for OU No. 2 under a CERCLA
Administrative Order on Consent signed and effective on August 9,
1993. All DHA activities were performed with EPA oversight and
approval.
DHA's demolition and removal action activities at OU No. 2
consisted of removal and offsite disposal of approximately 24,000
cubic yards of lead or arsenic contaminated soils, demolition of
167 buildings and offsite disposal of the demolition debris, and
removal and offsite disposal of lead contaminated roofs. All
contaminated soils and building debris removed from the site were
disposed of at permitted offsite facilities authorized to receive
such wastes. The demolition and removal action conducted by DHA
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met the same cleanup standards as EPA used in its emergency removal
action performed in the residential and high risk areas of OU No.
1. Therefore, the demolition and removal action conducted by DHA
at Operable Unit No. 2 meets EPA's cleanup standards for
unrestricted residential use. Detailed information regarding DHA's
removal activities is contained in the Administrative Record for OU
No. 2.
DECLARATION STATEMENT
The remedial investigation and human health risk assessment show
that the removal and demolition activities conducted by DHA at OU
No. 2 of the RSR Site provide overall protection of human health
and the environment and compliance with Federal and State
requirements that are legally applicable or relevant and
appropriate for sites contaminated with lead and arsenic. The
removal and demolition action has addressed all concerns associated
with the high concentrations of lead and arsenic at OU No. 2 and
has provided for unrestricted residential use. The removal of
contaminants to health-based levels has negated the need for a
feasibility "study of remedial action alternatives for OU No. 2.
Therefore, consistent with CERCLA and the NCP, I have determined
that based on the results of the investigations a^d studies and the
successful completion of the demolition and removal action, no
further action will be necessary at OU No. 2 of the RSR Site to
ensure protection of human health and the environment.
Because hazardous substances will not remain onsite above health-
based levels, five-year reviews are not necessary for OU No. 2 of
the RSR Site.
SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY
The State of Texas, through the Texas Natural Resource Conservation
Commission (TNRCC), concurs with EPA's decision that no lurrher
action is necessary at OU No. 2 of the RSR Site.
EPA has determined that DHA's response action at OU No. 2 of the
RSR Site is complete.
A/ S^anrey Meiburg^T /) Date
Deputy Regional Administrator
U.S. EPA - Region 6
^ »
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DECISION SUMMARY
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT NO. 2- DMA PROPERTY
DALLAS, TEXAS
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RSR CORPORATION SUPBRFUND SITE
OPERABLE UNIT MO. 2- DBA 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 4
IV. Scope and Role of Operable Units 5
V. Site Characteristics 5
VI. ^uiiunary of Site Risks 7
VII. Evaluation Criteria 13
VIII. Statutory Authority Findings and Conclusions of Law 15
IX. Documentation of no Significant Change ....... 17
LIST OF FIGURES AND APPENDICES
FIGURES
Figure 1 Site Location Map/Site Boundaries
APPENDIX
A. Responsiveness Summary
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DECISION SUMMARY
R8R CORPORATION SUPERFUND SITE, OPERABLE UNIT NO. 2
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 (Figure
1) . 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 R2P Cite report -dly 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,
sspecially with regard to the residential areas, ZPA divided the
?>SR Site into five Operable Units (OUs) , Figure 1:
OU No. 1 - Residential Property
OU No. 2 - Dallas Housing Authority (DHA) Property
OU No. : - Slag Piles
OU No. -t - Smelter Facility
OU No. 5 - Other Industrial Property Associated with the
Smelter
\
Operable Unit No. 2 (OU No. 2) is an area owned and operated by the
Dallas Housing Authority (DHA) which encompasses approximately 460
acres within the RSR Site. The OU No. 2 site is oounded by
"Jestmoreland Road to the west, Hampton Road to the east, Canada
Drive and the West Fork of the Trinity River to the north and
Singleton Boulevard to the south. OU No. 2 includes primarily
puolic multi-family housing, schools, parks, recreation facilities,
ind a day care center.
This Record of Decision (ROD) addresses only OU No. 2 (DHA
Property) . Since OU No. 1 and OU No. 2 involve residential and
.ligh risk areas, RODs for OU No. 1 and OU No. 2 are being issued
concurrently. However, the RODs will be published as separate
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thinly
Silt 4
SlIL 3-
MLSlDtNllAl I'HOI'IHIY IOU NO II
DAI I AS HOUSING AUIHDHIIY (DtlAI PHOPLRIY lOl) NO J\
SLAQ PllES IOU NO 31. SlTtS. 1. 3. ANO 4
MUHMUR/RSH SMCLTtH-THACl 1 IOU NO 41
OIHER MUHMLR/HSH INDUS1HIAI 1'HOPtRIY IOU NO il
HSR/OU4 b/bbbUOI)50.DGN
FIGURE 1
VICINITY MAP
OPERABLE UNITS (OU) NOS. 1,2,3,4 & 5
RSR CORPORATION SUPERFUND SITE
DALLAS, TEXAS
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LTi
reports. Proposed Plans outlining recommended Superfund response
actions for the other OUs at the RSR Site will be released in 1995.
Because OU Nos. 1 and 2 are residential and high risk areas with
similar characteristics, EPA performed some of its investigation
activities concurrently for OU No. 1 and OU No. 2. In addition,
some of the information generated for both OUs during the
concurrent studies have been compiled and presented in documents
applicable to both OUs. These materials are included in the
Administrative Record for OU No. 2.
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 Feder-I 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 snelter ouilding, 3tacK and" other
associated buildings, which are no longer in use, are situated on
one property ;ou No. 4), vnile a disassembled oattery .recking
building and anandoned 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
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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,
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 (/zg/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 Mg/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
.nere battery _hip_ were used as fill. Consequently, EPA initiated
an emergency removal action from October 1991 through June 1994
'discussed in more detail below) in the residential and high risk
areas consisting of removal and offsite disposal of soils and
debris contaminated in excess of the removal action cleanup levels.
Likewise, DHA conducted a demolition and removal action from July
1994 through March 10, 1995, using the same cleanup levels as were
used for OU No. 1.
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.
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ADMINISTRATIVE ORDER ON CONSENT
On August 9,, 1993, EPA entered into a Superfund Administrative
Order on Consent (AOC), Docket No. 6-21-93, with DHA, under which
DHA agreed to conduct a remedial investigation and feasibility
study (RI/FS) and, in addition, to conduct demolition and removal
actions at OU No. 2. DHA has completed the remedial investigation
and the demolition and removal activities required under the AOC.
The demolition and removal activities were performed in an
uninhabited residential area of OU No. 2 known as George Loving
Place.
Under the AOC, DHA was required to perform the removal action in
the same manner and in accordance with the removal action performed
by EPA at the residential areas in OU No. 1 (completed by EPA in
June 1994) . In accordance with this requirement DHA excavated and
removed all contaminated soils with concentrations equal to or in
excess of 500 parts per million (ppm) lead, 20 ppm arsenic or 30
ppm cadmium, and disposed of those soils in appropriate and
perm-^t^d offsite landfills. In addition, DHA demolished ""67
buildings using methods approved by EPA to prevent public exposure
to contaminants that may have been contained in the building
materials. DHA's demolition and removal actions were performed
with the oversight and approval of EPA. TNRCC also provided
oversight support, and DHA coordinated and received approval from
TNRCC for the disposal of materials to offsite facilities.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Public participation activities for OU No. 2 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. 2 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 in recommending that no further action is necessary
at OU No. 2 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.
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This ROD presents EPA's decision that no further action is required
at OU No. 2 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. 2.
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. 2 is the public
housing area owned by DHA, which has been addressed under the
CERCLA AOC. Based on the results of the remedial investigation
(RI) conducted by DHA, the home study and human health risk
assessment (HHRA) conducted by EPA, and DHA's demolition and
removal action, EPA has determined that long-term remedial
objectives have been achieved for OU No. 2. Therefore, no further
action is necessary at OU No. 2 of the RSR Site to protect human
health and the environment. The demolition and removal action
implemented by DHA to artdf^ss smelter-r0"1 ated contamination will be
the final response action for OU No. 2.
OU No. 1 consists of the private residential areas of west Dallas
that were the subject of EPA's emergency removal action. In
addition to the removal action, EPA conducted a RI and an HHRA at
OU No. 1 to determine the extent of contamination and long-term
cleanup goals for OU No. 1. EPA's decision that no further action
is necessary at OU No. 1 is being issued concurrent with this ROD
for OU No. 2.
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. 2 provide the nost likely exposure pathway of site
contaminants. This is due to soil contamination from the RSR
smelting operations and air deposition of netal particles,
primarily lead and arsenic, in the downwind area. Although the
smelting operations resulted in soil contamination, the lead and
arsenic materials bonded to the alkaline site soil particles and
the contamination generally remained at the surface with little to
no rovement due to the type of soils present.
The soil survey of Dallas County, Texas issued by the USDA Soil
Conservation Service (SCS), identified the Trinity-Frio soils as
the najor soil type at the RSR Site. Trinity soils are floodplain
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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 the RSR Site.
Two soil types of upland soils are found in the southern portion of
the RSR Site. 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 the RSR Site. These soils
have low permeability, high water capacity, and average erosion
p'jtential. Ir addition, deeply developed, .jic.uiy to sandy Bastsil
soils are found along old stream terraces, on nearly level to
sloping surfaces in a few locations at the RSR Site, primarily
along the Trinity River and its tributaries.
Geology
The RSR Site is located on the margin between the Blackland Prairie
and the Eastern Cross Timbers physiographic provinces. The RSR
Site 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 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 ~y Quaternary ailuvia_
deposits. Below the RSR smelter facility (located in the center cr
the RSR Site), these deposits vary in thickness from a few feet in
the southeast corner to over 20 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 snaie
are exposed in the uplands on the southern side of the RSR Site,
primarily south of Interstate 30.
Hydrogeology
In north-central Texas, the two nost important water-bearing
stratigraphic units are the Woodbine Group, a minor aquifer, ana
the Trinity Group, a najor 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
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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. ;-5
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The Woodbine Aquifer is of Upper Cretaceous age and is composed of O
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 in 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 surf- r
water bodies in the vicinity of OU No. 2. The West Fork flows
east-northeast from Grand Prairie and parallels the RSR Site (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
Forks, the Trinity River flows east and then south, paralleling the
RSR Site, approximately 1500 feet north of the northern and eastern
boundaries. A surface drainage channel that flows through the
western portion of the RSR 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
cnannel in the eastern part of OU No. 1 travels along the Missouri
Pacific rail lines and joins the Trinity River approximately 1/4
r.ile south east of Sylvan Avenue. Fishtrap Lake, Kidd Springs
Lake, and Lake Cliff Lake also are located within the RSR Site.
71. SUMMARY OF SITE RISKS
To evaluate the nature and extent of contamination at OU Mo. 2 a RI
.fas conducted by DHA pursuant to the terms of the AOC and with EPA
oversight and approval. In addition, EPA conducted a baseline
r.uman health risk assessment (HHRA) using data collected in EPA's
home study of environmental media in homes in OU No. 1 as well as
homes in the inhabited portion of OU No. 2. The home investigation
consisted of sampling of several media inside and outside of each
nome. The home investigation consisted of collecting samples of;
indoor dust, tap water, indoor and outdoor paint, and soil. This
information was used in the HHRA process to determine the potential
risks to human health from smelter contamination. The results of
the RI and the HHRA show that the demolition and removal activities
performed by DHA at OU No. 2 and the cleanup levels implemented in
these activities achieve overall long-term protection of human
nealth and the environment at OU No. 2.
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DHA's Demolition and Removal Action
Pursuant to the AOC, DHA submitted and EPA approved demolition and
removal action workplans, sampling and analyses, and quality
assurance and quality control plans. DHA's demolition and removal
action was conducted from July 1994 through rfarch 10, 1995 at the
George Loving Place area of the OU No. 2 site. DHA established a
50 by 50-foot sampling grid throughout the demolition and removal
area to determine the in-place concentration levels for lead,
arsenic, and cadmium. This was done do determine which soil areas
(soil grids) would require removals based on the soil cleanup
action levels of 500 ppm lead, 20 ppm arsenic, or 30 ppm cadmium
that EPA established in the residential areas of OU No. 1. Once
the demolition of building, sidewalks, and streets had been
completed, DHA conducted sampling in this same grid to determine if
additional areas required soil removals because of contamination
caused by or during the demolition activities. As part of EPA's
oversight of DHA's demolition and removal action, EPA collected
split confirmation soil samples which were analyzed at the Corps of
Engineer Southwestern Division Laboratory for independent results.
Pursuant to the AOC, DHA completed demolition of 167 buildings and
excavation of approximately 24,000 cubic yards of site soils
contaminated above the removal action levels of 500 ppm lead, 20
ppm arsenic, or 30 ppm cadmium. Demolition debris and excavated
materials were then disposed of offsite at hazardous and non-
hazardous permitted landfill facilities.
To monitor air emissions and prevent releases of site contaminants
to the surrounding areas and provide protection to site workers
during the demolition and removal action, DHA established an air
monitoring and air sampling program to determine short-term
releases. Most of the soil materials excavated consisted of clays
and grass/clay mixture and no air emissions above health-based
levels were recorded. During the demolition and removal action,
engineering controls (such as wetting) were used to minimize any
potential releases of air emissions at elevated levels. Storm water
control measures were also used to prevent offsite runoff of
contaminated material.
EPA conducted regular oversight activities to ensure that the
demolition and removal action was conducted in accordance with the
AOC and the workplans approved by EPA. Additionally, EPA collected
random confirmation soil samples from excavated areas to ensure
that no contamination remained above removal cleanup levels before
the areas were backfilled with clean soil.
DHA completed the demolition and removal action on March 10, 1995.
EPA has reviewed DHA's Supplementary Report to the Final Closure
Report for George Loving Place of the DHA site and has evaluated
the final confirmation sampling. Based on DHA's results and EPA's
own confirmation sampling, EPA has determined that DHA has
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successfully completed the demolition and removal action activities
to address RSR Site contamination as required under the AOC.
The only remaining field activities include final grading
activities, hydroseeding to promote grass growth for erosion
control, and demobilization of construction and support equipment
from the site. DHA's demolition and removal action activities and
EPA's oversight and confirmation sampling results are presented in
documents included in the Administrative Record for OU No. 2.
Current and Future Health Risks
To determine current and future risks to human health from smelter-
related contamination, EPA conducted an HHRA for OU No. 2.
Detailed information about the procedures of the study and the
results are contained in the Baseline Human Health Risk Assessment
Report for OU No. 2 which is included in the Administrative Record
for OU No. 2.
A numan 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
at a site. Risks are determined by evaluating known chemical
exposure limits and actual chemical concentrations at a site. The
actual concentrations are compared to the exposure to a
concentration known to have an adverse impact. Conservative
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 IxlO'6) lifetime excess
cancer incidents as the acceptable risk range. A risk
of one in one million means that one person out of one nillion
people could develop cancer as a result of a lifetime exposure to
the site contaminants. However, since risk is a probability, the
actual risk could also be zero.
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 commenced the HHRA process for OU No. 2 by evaluating the
current site risk, also called the baseline risk, posed to human
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health. The current site risks for OU No. 2 were calculated based
on the potential exposure to site contaminants based on the
characteristics of the population and type of contamination at OU
No. 2. OU No. 2 is currently zoned primarily for multi-family
residential uses, and the probable future land use for the site was
considered to be residential.
Because historical operations of the RSR smelter facility resulted
in stack emissions causing the deposit of smelter-related
contaminants within OU No. 2, EPA considered metals to be the
primary contaminants of concern in OU No. 2. After applying the
exposure and toxicity assessment screening steps, the following
metals were retained as Target Analyte Metals (TAMs) for the HHRA:
lead, cobalt, copper, manganese, and zinc. Of these TAMs, lead and
arsenic were detected in the highest concentrations in OU No. 2.
The TAMs associated with the inhabited area of OU No. 2, other than
lead, are not classified by EPA as carcinogens. Therefore, excess
lifetime cancer risks cannot be quantified as a result of exposure
at CU No. 2, and potential cancer effects for these metals are not
discussed further. Because the TAMs are noncarcinogenic, risks
from exposure to the TAMs, other than lead, were assessed by
calculating the His.
Based on the current population and land use within OU No. 2, one
exposure scenario, residential (adults and children), was
identified for evaluation in the HHRA. Residents could be exposed
to TAMs in soil within OU No. 2 through incidental ingestion of
soil, inhalation of airborne soil particulates, and dermal contact
with soil. Two routes of exposure, ingestion and inhalation, were
quantitatively evaluated in the HHRA. Dermal exposure was not
evaluated quantitatively in the HHRA because no metals with
available human data to estimate an absorption factor were
identified as primary contaminants and the dermal exposure route is
not considered to be a significant exposure pathway.
Risks associated with exposure to lead vere determined cy
evaluating exposure to the most sensitive population in OU No. 2,
children between the ages of 6 r.onths to 6 years. Slood lead data
'fas collected from a random group of children. In addition, the
exposure scenario for children in OU No. 2 was evaluated using the
Integrated Exposure Uptake Biokinetic (IEUBK) nodel, (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.
Occupied Portion Of OU 2
Exposure to Metals other than Lead in Surface Soil - Residential
The residential exposure scenario fcr OU No. 2 assumed that a
resident would come into contact with contaminated soil containing
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^3
site-related TAMs on a daily (350 days) frequency for 30 years.
Potential routes of exposure to soil include inadvertent ingestion
and inhalation of airborne particulates. O
The estimated total noncancer His for the TAMs, other than lead,
were significantly less than one (< 1) for children and adults in
OU No. 2. A noncancer HI less than 1 indicates a low probability
of adverse health effects resulting from exposure to the site TAMs
under.the assumed exposure conditions.
Exposure to Lead in Environmental Media - Residential
Residential exposure to lead was evaluated using the IEUBK model,
which uses site-specific or default concentrations of lead in
environmental media (such as soil, dust, water, air, paint, and
diet) to estimate blood lead levels in children. Adult exposure to
lead is addressed based on exposure in the workplace.
Risk to children from exposure to lead in «-^i] within OU No. 2 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) . Results of the IEUBK model predict a mean
blood " ead level of 1.7 fj.g/dL for children living within OU No. 2
based on the random sample population. The model did not predict
any blood lead values greater than 10 Mg/dL for any child in OU No.
2. The modelled mean blood level of 1.7 ^g/dL was lower than the
measured mean blood level of 4.3 ug/dL. The model predicted no
(0%) children with blood lead values greater than 10 Mg/dL while
the measured value was 5 percent (5%). Many factors contribute to
the 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.
T.ie CDC has li-ntified actions that snould be taken wnen a child's
;Iood lead content reacnes certain levels. Based on the olood leaa
results, none cf the children from OU No. Z would be recommended
:or medical evaluation and/or intervention under the CDC standards.
The results of this evaluation snow that no further soil removal
action is necessary in OU No. 2 based on residential risk of
exposure to RSR-related contaminants.
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. 2. The IEUBK model considered
zhe 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
/ill limit exposure to lead in soil such that no more than 5% of
the children population exceeds the 10 ug/dL blood lead level (the
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CDC blood lead level of concern) . The IEUBK model calculated a
soil cleanup level of 640 ppm lead for the residential areas of OU
No. 2. DHA completed a demolition and removal action at OU No. 2
pursuant to the AOC and workplans approved by EPA. Even though the
EPA's HHRA found that 640 ppm is a safe soil lead level, DHA
conducted the removal action based on the more stringent 500 ppm
lead level applied by EPA at the private residential areas of OU
No. 1. The 500 ppm lead action level was applied at all
residential areas of OU No. 2, including the uninhabited areas of
George Loving Place designated for future residential use after
completion of the demolition and removal action.
DHA Human Health Evaluation
DHA also conducted a supplemental health evaluation for OU No. 2 in
order to address specific contaminants identified in the RI at OU
No. 2. This assessment included arsenic, cadmium and lead, in the
demolition and removal area of George Loving Place and the VOCs and
semi-TTolatile organic compounds identified in a former disposal
("fill") area at OU No. 2. Although materials in the fill area ao
not appear to be related to the RSR smelter, DHA conducted a human
health assessment to evaluate the potential risks to human health
and the environment from the contaminants found in the fill
materials. One metal and seven of the organic compounds were
present at reasonable maximum exposure (RME) concentrations that
could pose a threat to human health. Cleanup levels for soils were
developed for the range of acceptable cancer target risks of 1 x
10"6 to 1 x 10'4. The levels for the eight carcinogenic constituents
ranged up to 13 ppm for the semi-volatile organic compounds and up
to 52 ppm for arsenic. The actual concentration of these
contaminants present in the fill area do not exceed the health-
based cleanup levels and therefore do not pose a threat to human
health. DHA's supplemental human health assessment did not
identify organic constituents of concern in the fill areas.
Although DHA's health evaluation indicates that an arsenic cleanup
level higher than the removal action level of 20 ppm would be
protective of human health, DHA implemented its' demolition and
removal action using the 20 ppm arsenic standard.
Impacts to the Environment
In addition to the assessment of risks to humans, EPA performed an
Ecological Risk Assessment (ERA) for OUs No. 1 and 2, which is a
separate report available in the Administrative Record for OU No.
2. As part of the ERA, a field survey was conducted from March 24,
1994 through April 2, 1994, within OUs No. 1 and 2 at the RSR Site
to address data needs. Samples were collected from the 13.6 square
nile RSR Site study area as well as from a reference area where no
smelter-related contamination was present. The following
information was gathered during this field effort:
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Species surveys of terrestrial and aquatic receptors 73
«-O
Identification of critical habitat 7M
C^>
Collection of abiotic media (surface water and sediment) T-*
samples O
Collection of water quality parameters for characterization
of the aquatic ecosystems
This information, along with data collected from previous
investigations conducted at OU No. 1 and OU No. 2, 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 the above
information indicated putwutial ecological effects to aquatic and
terrestrial"organisms in the drainage areas. The Bernal Street
drainage area had the highest potential risk to aquatic and
terrestrial organisms. The source of the contsr.inants identified
in the surface water and sediments could not be determined. This
drainage area receives runoff from numerous sources, both
commercial and residential, that could be contributing to the
elevated levels of contaminants. The screening level ERA indicated
that further evaluation in the form of a definitive ERA may be
warranted for surface water and sediments in the drainage areas.
However, the screening level ERA indicated no significant
ecological risk to target nammal 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 vill be
conducted as part of the remedial investigation for the r.S«. ~U No.
2 site.
VII. EVALUATION CRITERIA
EPA's decision is that no further action is necessary to protect
numan nealth and the environment at OU No. 2. This cecision is
based on the results of the investigations and studies summarized
in Section VI and presented in detail in documents contained in the
Administrative Record.
EPA determines that DHA's demolition and removal activities have
addressed the contaminated soil and building materials that were
present at OU No. 2 by the removal of site contaminants and off site
disposal at permitted landfill facilities. Althougn removal
actions do not have to achieve all of the goals of remedial
actions, EPA finds that DHA's demolition and removal action has met
long-tern remedial goals for OU No. 2. EPA evaluates its decision
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for no further action pursuant to the following remedial criteria: ^
1. overall Protection of Human Health and the Environment ""*
^2
No further action is necessary at OU No. 2 because DHA's demolition
and removal action achieved overall protection of human health and
the environment. DHA's demolition and removal action eliminated
the ingestion, inhalation, and direct contact pathways and provided
permanent protection of human health and the environment by the
removal and offsite disposal of contaminated soils and building
materials from OU No. 2. Because the site contamination was
removed and the smelter is no longer in operation, the potential
for future releases of or exposure to contaminants, re-
contamination at hazardous levels, and future air emissions from
contaminated soils and building materials have been eliminated.
DHA's demolition and removal action offers protection of human
health and the environment by permanently removing contaminants
from OU No. 2 to levels demonstrated to be protective of human
heath and the environment.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
ARARs are federal and state requirements that should be considered
or complied with in the performance of a selected response action.
For example, hazardous material to be excavated and disposed off-
site would have to be treated using the best demonstrated available
technology (BOAT) to meet the RCRA Land Disposal Restrictions
(LDRs) prior to landfill disposal. Since EPA's decision is that no
further action is necessary, this criterion is not applicable
except in regard to the demolition and removal action. DHA's
demolition, removal, and disposal of RCRA hazardous and non-
hazardous materials from OU No. 2 'DHA) met Federal and State
ARARs. RCRA non-hazardous soils were excavated and transported tc
State permitted disposal facilities. RCRA hazardous materials were
removed offsite for treatment prior to disposal at pemittea
facilities.
2. Long-term Effectiveness and Permanence
Further action is not warranted cecause DHA's demolition ana
removal action has provided long-term effectiveness and permanence
oy permanently removing the contaminated soils and buildina
materials from OU No. 2 to a level demonstrated as protective of
human health and the environment. Since the RSR smelter facility
ceased operations in 1984, re-contamination of remediated areas is
not expected to occur. Therefore, based on the results of the
extensive site-specific studies and investigations at OU Mo. 2,
long-term effectiveness and permanence has been achieved through
the demolition and removal action without the need for additional
response actions.
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4. Reduction of Toxicity, Mobility or Volume Through Treatment CT|
DHA's demolition and removal action has reduced the toxicity, O
mobility and volume of contaminants at OU No. 2 to a level that is
protective of human health and the environment and further action
is not necessary. At remediated locations, DHA's demolition and
removal action reduced the toxicity, mobility, and volume of the
contaminated materials at OU No. 2 by removal and offsite disposal
eliminating the inhalation and ingestion exposure pathways for
children and adults in OU No. 2. In addition, RCRA hazardous
materials were treated prior to disposal, which reduced the
toxicity and mobility of these materials at the disposal site.
Non-hazardous materials did not require treatment prior to
disposal. However, this action reduced the mobility of these
materials by disposal at offsite facilities permitted to handle
this type of wastes.
5. Short-Term Effectiveness
Since no further action is necessary, short-term risks are not
present. During DHA's demolition and removal activities no short-
term risks were encountered. An air monitoring program was
implemented at the site to monitor potential exposure of the
surrounding community and site workers to contaminated materials,
and no air emissions above health-based levels were recorded.
During the demolition and removal action, engineering controls
(such as wetting) were used to minimize any potential for air
emissions at elevated levels. Windrows were constructed around the
site to maintain rain runoff with the site boundaries. Water
runoff within the site was then diverted to holding ponds located
at the site to prevent potential contamination from moving offsite.
There were no adverse impacts from transporting excavated material
to offsite landfill facilities.
S. Implementability
This criterion is not applicable to the no further action decision.
/
7. Cost
This criterion is not applicable to the no further action decision.
3. State Acceptance
The TNRCC has been consulted and has provided technical support
throughout the RI process and demolition and removal action. TNRCC
has reviewed and commented on the Proposed Plans for OU No. 2.
Disposal of site materials to offsite permitted facilities was
coordinated through TNRCC. The State of Texas concurs with EPA's
decision for no further action at OU No. 2.
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^
9. Community Acceptance ^
Community comments are an important consideration in the final
decision for the site and EPA has carefully considered all public
comments in making this decision. The public comment period for
EPA's recommendations concerning OU No. 2 was from November 18,
1995 to January 18, 1995. During the comment period, EPA held a
public meeting on December 1, 1994, and participated in a radio
call-in talk show to answer questions and to receive verbal and
written public comments. Other written comments were received
during the comment period.
Generally, the public approved of the demolition and removal action
conducted at OU No. 2. The main criticism centered around the
cleanup action level for lead of 500 ppm established for the
removal action. The public wanted to lower the residential cleanup
level for lead to 250 ppm, but did not provide a rationale or any
scientific reasons for this number. No risk analyses were
presented to justify love- Ir.g of the cleanup level for lead.
On the contrary, all of the studies conducted by or under the
direction of EPA at OU No. 2 show that 640 ppm lead in soil is a
cleanup level that is fully protective of human health and the
environment assuming residential use of the site and frequent
exposure to soils. Nevertheless, DHA removed all soils found to
contain more than 500 ppm lead. The studies show that the average
soil lead concentration in the residential areas at OU No. 2 is 50
ppm and that elevated blood lead levels in children do not
correlate to the residual amounts of lead in soils in OU No. 2.
Therefore, there are no indications that lowering the soil lead
levels further would result in a decrease in blood lead levels.
Additional public comments and responses are included in the
Responsiveness Summary which accompanies this ROD.
VIII. STATUTORY AUTHORITY BINDINGS AND CONCLUSIONS OF LAW
Pursuant to CERCLA, studies are conducted it :IPL sites ~o
characterize the nature and extent of contamination associated with
-he source and to determine the most feasible cleanup approaches.
At OU No. 2 of the RSR Site, EPA and DHA have conducted site
investigations to determine the nature and extent of RSR
contamination. EPA conducted a human health risk assessment to
determine safe cleanup levels for smelter contaminants cased on the
characteristics and circumstances unique to OU No. 2. In addition,
under a CERCLA AOC, DHA conducted a demolition and removal action
to address contaminated soils and buildings within OU No. 2.
Based on the results of the extensive site-specific investigations
and studies, and EPA's finding that the demolition and removal
action has been successfully completed, EPA determines that no
further response action is necessary at OU No. 2 to protect human
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health and the environment. Because hazardous substances will not ^
remain onsite above health-based levels, five year reviews are not
necessary for OU No. 2 of the RSR Site.
The no further action decision presented in this ROD applies only
to OU No. 2. The ROD documenting EPA's decision for OU No. 2 will
be presented to the public at the same time as the ROD for OU No.
1. Studies and proposals to address contamination at the other OUs
at the RSR Site are being conducted separately and results and
recommendations for response actions will be issued within the
coming months.
IX. DOCUMENTATION OF NO 8]
The Proposed Plan for OU No. 2 of the RSR Site was released for
public review and comments from November 18, 1994, through January
18, 1995. The Proposed Plan recommended, that once DHA completed
the demolition and removal action at OU No. 2, no further action
wculd be required at OU No. 2 to address smelter contamination.
DHA completed the demolition and removal action on March 10, 1995,
which EPA "has subsequently reviewed and approved. EPA has
carefully considered all written comments submitted during the
public comment period. Based on consideration of these comments
and the successful completion of DHA's demolition and removal
action, EPA has determined that no significant change to its
original proposal of no further action is necessary.
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T-l
APPENDIX A
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RESPONSIVENESS SUMMARY
RSR CORPORATION SUPERFUND 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. 1 (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
Comprahensive Environmental Response, Compensation, and Liability
Act (CERCLA), 42 U.S.C. § 9617, EPA has cuusidered 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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SO
COMMENTS AND ISSUES RAISED DURING THE COMMENT PERIOD
l. Public Meeting, December i, 1994, Thomas Edison Junior High
School Auditorium
Ms. Barbara Mallory, 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 sane
as children in other parts of Dallas. EPA's actions h
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Comment: EPA should have temporarily relocated people while
residential properties were being cleaned up.
Response: EPA disagrees. When cleaning up a private
residential property, it is best for the owner to be nearby to
ensure that the job was done to their full satisfaction.
Precautions, including wetting down of excavated soils, were
taken to ensure that lead contaminated dust was not 'kicked
up' and air pollution monitors were continuously operated to
verify that no problem was being created during the
activities.
Comment: EPA should have cleaned up the inside of homes.
Response: EPA disagrees. The studies conducted by EPA and
reviewed by health authorities at the Federal, State, and
local levels showed that household dust presented no
significant risk of lead contamination.
Comment: EPA let i_h*- Dallas Hous^^g Authority cleanup their
properties without supervision; the dust from their demolition
work is ".. everywhere...".
Response: This is not true. The Dallas Housing Authority
(DHA) conducted its cleanup under EPA oversight through an
Administrative Order on Consent. Actions were taken to
prevent air pollution. Several layers of oversight were in
place to ensure that the cleanup was conducted according to
the approved workplans. Oversight of the construction
contractors was conducted by EPA, EPA's contractor, TNRCC,
DHA, and DHA's contractor. Extensive engineering controls
were used to control dust emissions like wetting of the
buildings prior to and during demolition to prevent dispersion
of dust. Air monitors were placed around the construction
area to verify that contaminated dust was not being generated
during the demolition activities. No air violations were
recorded during these activities.
Comment: My parents are concerned that they are being exposed
to high levels of lead in their home.
Response: EPA has not been allowed to confirm if there is a
problem. EPA has requested, but has been refused access to
sample this property. However, sampling of properties in the
vicinity of this home have not indicated elevated lead levels.
Comment: EPA has not kept the West Dallas Coalition informed
about what's been going on.
Response: This opinion is without basis; EPA has conducted a
vigorous outreach effort. Since the proposed addition of the
RSR site to the National Priorities List in May, 1993, EPA
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has held six open house meetings and two public meetings. The
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 locatic -, including the West
Branch .of i_he 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 the staff 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
"Detection Agency to remote the Superfund status fro^ ^-«?
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 ^t 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 r.y house and r.aking it unsalable.
Response: ~PA strongly disagrees; in fact, tr.e Superfunri
cleanup nas the opposite impact. Residential housing was
placed adjacent to pollution sources before local government
restricted land use and before pollution laws -,;ere developed.
ZPA's actions have removed the specter of HSR contamination
from all of the residential properties in vest Dallas that
;ere part of the survey, testing, and cleanup effort.
Comment: You said the soil './as cleaned. If the soil was
cleaned adequately, why is it being redone?
Response: This runor is simply incorrect; the soil cleanup is
r.ot 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 Mg/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: tfhy did EPA wait until November 1994, to propose the
remova-1 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 Hay 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 vest Dallas as safe from environmental lead
contamination as suburbs sucn as Ricnardson, Tarrollton,
Addison and Piano?
Response: Ves, althougn icil _aaa contamination _ata frcm
these areas is not availaole as extensive as it _s for vest
Dallas. IPA's RSR home studies snowea that ~nere vas r.o
correlation between soil lead levels and eievatea ricod leaa
levels in vest Dallas. 31ood lead levels in vest Zailas are
comparable to, and are often lower tnan, other areas or tne
City.
Comment: Since EPA only sampled cr cleaned up in certain
areas of the community, how can the public be assured that tne
total ?SR pollution problem nas ceen found and fi::ed?
Response: All residential areas of vest Dallas, -pproximately
5,800 properties, were inspected by the State to determine if
they had smelter-related contamination. The nomes that had
suspected lead contamination or used battery chips as fill
natenal vere 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., ul4) 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.
8
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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 buildinas in the contaminated
areas. . Some of buildings had been \a< /ii_ 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 che r.ystery of
recontamination.
Response: I PA agrees tnat -roader action than is possible
.inder the Superfund law ~r from a single agency like EPA _5
-.eeded. Responses to specific suggestions are summarized
oelow:
cleanup soils celcw fOO oom- Ccmprenensive studies
conducted by ZPA, the State of Texas Department
Health, the ATSDR, and the City of Dallas all conclude
that there is no cenefit to cleaning up soils oelow 500
ppm. Results further show that the average soil lead
levels in west Dallas are less than 120 ppm and that of
the cnildren with elevated blood levels, almost 90% live
in nomes with soil lead levels less than 250 ppm.
cleanup nouse dust- EPA, ATSDR, and the City of Dallas
studies found there vas 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 Super fund 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 /^g/dL compared to the current average of 7.0 /Ltg/dL. In
the 1980s, 91.5% of the children had blood lead levels above
10 jig/dL compared to the current number of 18.9%; 29.2% had
blood lead levels above 20 fig/dL in the 1980s compared to zero
10
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today; and 10.5% had blood lead levels above 30 /ng/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 receding the smelter ill ze.
separately released for comment; the current Junerfund law
authorizes EPA to remove contamination threats out not spend
trust fund monies to redevelop properties.
Public Meeting, XGBS Talk Radio (AM 1190), January 15, 1995.
Comment: Why aid EPA people wear fricrntening -'space suits'
;nen cleaning up properties wnere residents nave lived for
years and wear normal clothing?
Response: EPA cleanup staff are required, at a minimum, to
./ear white Tyvek coveralls oecause they work at a wide variety
of sites around the State and the country. The need to have
these people '/ear protective dress is similar to the
requirement that firemen wear protective clothing, even if
responding to a false alarm.
11
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Comment: EPA created the Superfund problem in west Dallas and
should pay for its cleanup rather than create more taxes for
local citizens.
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 oe«n spent in studies. In
addition, the Dallas Housing Authority has spent approximately
$10 million 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
jjg/dL and only one exceeded 20 ^g/dL. This is about 10% less
than is usually encountered since the national average for
urban areas is 8.9% above the 10 /jg/dL level.
In addi^^on ""he City of Dallas has had a lead testing program
in the vest Dallas clinic (the West Dallas Multi-Purpose
Center) since the early 1980s. The City has tested thousands
of children not only from vest Dallas, but also from other
areas in the City.
Comment: EPA should have cleaned up lead contamination iron
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.
12
i
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Comment: will EPA dismantle the smelter stack and smelter
buildings?
Response: EPA will propose alternatives for public comment for
this potential problem in the Spring of 1995.
Comment: Is EPA doing anything under 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 Superfund 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
ocudies are being conducted by the former owners under S_^i_e
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 nor "build up" in the central nervous system.
Comment: It seems to :ae that many people living in vest
Dallas are losing linns 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
13
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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 IJ
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
14
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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 DHA
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 nousing. 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 vas probaoly wasned away
oy rain.
Comment: Hew nucn pollution is csing created cy in a ''lead
smelter" located en the fcrrer 3SR facility.
Response: The Mumur Corporation r.as an active operation that
is not a smelter ana does r.ot create detectable levels of lead
air pollution. Murmur neits lead to manufacture sneers for x-
ray rooms. Air pollution r.onitors 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
I PA in a "Toxic Release Inventory" report under the category
of environmental losses cetween 11 and 500 pounds per year,
althougn the actual amounts are rvach less than 500 pounds.
Comment: Wouldn't operation of the Murmur facility add to
existing contamination? rould that be a part of the
recontamination of the Boys' Club since it is located across
the street from it?
15
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00
Response: There are no indications that melting operations at C^
the Murmur facility are resulting in lead contamination of the C5'
surrounding community. T-<
O
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 Mg/dL and 15
For children with blood lead levels between 15 ^g/dL and
20 /xg/dL, the City conducts home sampling to try and
identify lead sources; and
For children with blood lead levels over 20 /ig/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
jug/dL. The Centers for Disease Control lowered the national
guidelines to 10 /ig/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
16
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oo
7*
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 t-.hroxiahout 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.
17
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Response: 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 offsite 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 Superfund law
because the removal of RSR contaminated soils effectively
corrected the environmental problem.
3. 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 1"
elevat-.ed 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. ana solutions
to, elevated olcod lead levels are found.
Response: Independent studies oy the City of Dallas Health
Department and tr.e State Health Department agree with EPA's
assessment that further cleanup of RSR lead in soils will not
benefit public nealth. Nine out of ten nousenolds where
children have elevated blood lead levels also have soil lead
levels from all sources less than 250 ppm, wnich 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 acnieved in all participating single
and multiple family residential areas of west Dallas.
Concurrent studies by EPA show that the 500 ppn goal exceeded
18
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oo
the level needed to protect human health. Instead of soil 7$
lead contamination, the City's own studies point to other ^
potential causes such as leaded house paint and occupational T-4
exposure from workers to the household. O
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 /ig/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 olood 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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s.'-
oo
HOUSEHOLDS
NEAR RSR
5 OF 6
HOUSEHOLDS
IN OAK CLIFF
1 OF 4
POSSIBLE LEAD POLLUTION SOURCE
Member of household has O
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 thp 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
Conserve-ion -nd 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 .
20
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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 Superfund 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 ill, letter
dated December 21, 1994.
Comment: It is ny understanding tnat 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 vest Dallas. However, these same
studies indicate that there are other sources of lead in west
Dallas that nay 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.
21
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Comment: I am respectfully requesting your consideration in
continuing your cleanup efforts in the west Dallas area.
Response: 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 cc or greater t..^n 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 na^or roadways, Singleton
Blvd. and Westmoreland Road where soils are nost 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
22
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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
23
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a requirement for health reasons or to prevent exposure to r-l
lead at unsafe levels. C|
Comment: EPA should make funds available for training west
Dallas residents on current environmental awareness issues.
Response: EPA is working with other Federal, State, and local
agencies to provide information to residents of west Dallas
and has published a booklet outlining the roles and
responsibilities of these agencies related to lead issues.
EPA will continue to work with these agencies to provide
information to residents throughout Dallas on lead and
environmental issues. EPA conducted several open house
meetings this past year where EPA and other agencies were
available to answer environmental questions on a one-to-one
basis. EPA will continue to conduct these meetings to keep
the citizens informed about site activities and answer
questions related to overall environmental issues. Also, one
of the purposes of the Technical Assistance Grant, awarded to
PEACE.. Environmental, is to inform the citizens of issues
related to the Superfund site.
7. From Reverend Conley, New Waverly Baptist Church, letter dated
January 17, 1995.
Comment: The soil lead action levels should be lowered to 250
ppm to ensure the safety of west Dallas residents.
Response: There is no increased safety or health benefit from
a 250 ppm cleanup level. Extensive studies by EPA, ATSDR,
City of Dallas, and TDH show that 500 ppm is fully protective
for humans at residential areas where frequent exposure to
soils occurs. This conclusion was based on information
specific to the RSR Site residential areas. The current
average residential soil lead level= in west Dallas ai-o less
than 120 ppm. Ninety percent (90%) of the children with
elevated blood lead levels already reside in homes where soil
lead levels are below 250 ppm. Finally, EPA and the City of
Dallas risk assessments show no connection between blood lead
levels and soil lead levels under 500 ppm. Lowering the soil
lead levels will not provide additional benefit in lowering
the blood lead levels in children.
Comment: EPA should give people the option of being bought
out.
Response: Buyouts are not authorized under the Superfund law
because EPA has successfully cleaned up RSR-related
contamination at residential properties.
24
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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 *i-«- 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.
i
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.
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
25
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concern that "new scientific evidence" from University of
Texas at Dallas (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" cf lead contamination.
;3) ZPA's approacn vas "less refined" than UTD's and grossly
under-reports the amount of lead in vest 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 nade 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
26
-------
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 reflect 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 1 residential properties in the air
deposition area and otner parts of west Dallas to
determine sampling protocols for the comprehensive home
study. Statistical analysis of samples collected and
individually analyzed from 2-root 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 -..-nich nay diminish the
accuracy of rhe 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. Hone 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
27
-------
areas of "disturbed" soils or commercial operations 7^
(e.g. a former gasoline station, a bus stop, or Jj
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 tnis. 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
s?ne December 4,1994, Dallas Morning News article that
you referenced, 'JTD professor Dr. Carter indicated that
.iis studies were not representative of residential area
contamination. .\ simple comparison between the
percentage of samples exceeding 500 parts per million of
lead is not accurate or meaningful due to the nany
differences in scope, sample size, and purposes discussed
above. Moreover, ZPA'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
puolished.
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-
ninority community while EPA was proposing levels 5 times
higher in the predominantly minority community of west Dallas.
28
-------
Response: The sierra Club's 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 from
sandblasting of paint from a municipal water supply tank. The
Texas Air Control Board proposed a goal of 500 ppm of lead 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.
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 cased on
incomplete information puolished 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.
29
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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 ^edictive cc^j. 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 vhen used to calculate ''safe" levels of
lead in soil.
Response: IPA 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
30
-------
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
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 nave 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 l, 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 430 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
31
-------
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.
32
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12. The following public comments were specific to the RSR
Operable 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 " ° ~pm 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.
33
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