United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-90/121
March 1990
&EPA
Superfund
Record of Decision:
NL Industries/Taracorp Lead
Smelting, IL
-------
50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R05-90/121
3. Recipient's Accession No.
Title and Subtitle '•
SUPERFUND RECORD OF DECISION
NL Industries/Taracorp Lead Smelting, IL
First Remedial Action
5. Report Date
03/30/90
7. Auttiof(s)
8. Performing Organization Rept No.
9. Performing Organization Name and Address
10. Projecl/T«sk/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Umlt: 200 words)
The NL Industries/Taracorp Lead Smelting site is an inactive secondary lead smelting
facility in a heavily industrialized section of Granite City, Madison County, Illinois.
Land in the site vicinity is primarily industrial, but includes adjacent residential
communities, including Eagle Park Acres and Venice Township. Prior to 1903, the site
was used for metal refining, fabricating, and other associated activities. From 1903 to
1983, the site was used for secondary lead smelting activities. These operations
generated an onsite pile of blast furnace slag and battery casing debris waste (the
Taracorp pile). From 1981 to 1983, St. Louis Lead Recyclers, Inc. (SLLR) used equipment
on an adjacent property to recycle lead-bearing materials from the Taracorp waste pile
for use in the furnaces at Taracorp. Hard rubber was the end waste product of this
recycling process. In 1983, both operations were discontinued and the equipment
dismantled. In 1983, a State study of the Granite City lead attainment air emissions
problem linked emissions from the onsite lead smelter and reclamation operations at the
NL Industries/Taracorp site to the air pollution problem. Onsite contaminated areas
identified during the study included the 85,000 cubic yard Taracorp pile, smaller
adjacent waste piles associated with the SLLR recycling operation that total 2,450 cubic
(See Attached Page)
17. Document Analysis a Descriptors
Record of Decision - NL Industries/Taracorp Lead Smelting,
First Remedial Action
Contaminated Media: soil, debris
Key Contaminants: metals (lead)
b. Identifiers/Open-Ended Terms
IL
c. COSATI Reid/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
199
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
-------
EPA/ROD/R05-90/121
flndustries/Taracorp Lead Smelting, IL
rst Remedial Action
Abstract (Continued)
yards, and 25 to 35 drums containing solid waste from onsite smelting operations.
Additionally, the adjacent property contained a 4,000 cubic yard pile of battery casing
debris from the SLLR operation, and another large contaminated unpaved area was
identified south and west of the site, other contamination associated with the site
included 2,700 cubic yards of battery casing material in Eagle Park Acres and an
additional 670 cubic yards of similar material in Venice Township. In 1984, the State
required the implementation of remedial actions to improve air quality. This Record of
Decision (ROD) addresses the Taracorp pile, the SLLR piles, and residential soil, alleys,
and driveways that are contaminated by airborne lead and/or hard rubber battery casing
material. The primary contaminant of concern affecting the soil and debris is lead.
The selected remedial action for this site includes excavating a total of 94,820 cubic
yards of lead-contaminated soil and debris from the SLLR piles, the unpaved area, and
adjacent residential areas, and hard rubber battery casing material from Venice, Eagle
Park Acres, and other nearby communities; consolidating the soil and debris within the
Taracorp pile; covering the Taracorp pile with a RCRA multi-media cap, and lining the
newly-expanded Taracorp pile with a clay liner; removing all onsite drums to an offsite
secondary lead smelter facility for recovery; monitoring nearby communities to determine
if additional areas need remediation or lead exposures need mitigation; performing blood
lead sampling to determine potential acute site-associated health effects; monitoring air
and ground water during remedial activities; developing a contingency plan to provide
remedial action if any nearby soil lead levels exceed 500 mg/kg or ground water or air
jexceed applicable standards; and implementing institutional controls, including deed
^restrictions, and site access restrictions such as fencing. The estimated present worth
cost for this remedial action is $30,000,000, which includes an annual O&M cost of
$35,300 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Soil cleanup levels for lead are based on the "Interim
Guidance on Establishing Soil Lead Cleanup Levels at Superfund Sites" (1989). All
contaminated soil in the unpaved area adjacent to the site will be excavated to achieve a
lead cleanup level of 1,000 mg/kg. All contaminated soil in adjacent residential areas
will be excavated to achieve a cleanup level of lead 500 mg/kg.
-------
DECLARATION FOR THE MEUJM) GF i»«r*r
SHE NAME AND LOCA33CN
NL Indiistries/Taracorp
Granite City, Illinois
STMSHENT Of B&SIS AND KKPOSE
This decision document represents the selected remedial action for the NL
Industries/Taracorp (NL) site developed in accordance with the Comprehensive
Environmental Response, Canpensation and Liability Act (CEPCXA), as amended
by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
This decision is based upon the contents of the administrative record for the
NL site. The attached index identifies the items which comprise the
administrative record upon which the selection of a remedial action is based.
The State of Illinois has concurred on the selected remedy. The letter of
concurrence is attached.
ASSESSMENT OF THE SHE
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this ROD, may
present an imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
This final remedy includes treatment of the principal threats posed by the
site by (l) removing crushed hard rubber battsry casings and lead
contaminated soil from residential areas, 2) consolidating the soils, crushed
casings and lead-contaminated materials from an adjacent waste pile into the
existing Taracorp slag pile and 3) providing the expanded Taracorp pile with
a RCRA-conpliant, ff^l^jina^ia cap.
The major components of the selected remedy include:
' Installation of an upgraded security fence around the expanded Taracorp
pile.
* Deed Restrictions and other institutional controls to ensure protection
of the Taracorp pile.
* Performance of soil lead sampling to determine which areas must be
excavated and the extent of the excavation.
* Inspection of alleys and driveways and areas containing wrficial
battery case material in Venice, Eagle Park Acres, Granita City,
fiadison and any other nearby communities to determine whether
additional areas not identified in the Feasibility Study oust be
remediated as described below.
-------
-2-
Perfonnanoc of blood lead sanpling to provide the ocntunity with
current data on potential acute health effects associated with site
contamination.
Installation of a minium of one upgradient and three downgradient
deep wells, monitoring of groundwater and air, and inspection and
maintenance of the cap.
Removal and recovery of all drums on the Taracorp pile at a secondary
lead smelter.
Consolidation of waste contained in an adjacent St. Louis Lnad
Recyclers piles with the Taracorp pile.
Excavation and consolidation with the Taracorp pile or off -site
of battery case material from all applicable alleys and
driveways in Venice, Illinois, Eagle Park Acres, and any other nearby
Cdmunities.
Excavation and consolidation with the laracorp pile of all unpaved
portions of adjacent Area 1 (see Figure) with lead concentrations
greater than 1000 ppm.
Excavation and consolidation with laracorp pile or off-site di«yncai of
all residential soils and battery case »»twtaig around the site and in
Venice, Eagle Park Acres, and any other nearby cconunities with lead
Ttrations greater than 500 ppm.
Inspection of the interiors of homes on property to be excavated to
identify possible additional sources of lead exposure and recommend
appropriate actions to minimize exposure.
Implementation of dust control measures during all remedial
construction activities.
Construction of a RCRA-ocnpliant, Multi-media cap over the expanded
Taracorp pile and a clay liner under all newly-created portions of the
expanded Taracorp pile.
Development of contingency plans to provide remedial action in the
event that the concentration of contaminants in groundwater or lead or
PM10 (particulate matter greater than 10 microns) in air cxouod
applicable standards or established action levels, or that waste
materials or soils have become releasable to the air in the future.
Development of contingency measures to provide for sampling and
removal of any soils within the zone of contamination cVwrlbnrl by the
soil lead sanpling to be implemented above with lead concentrations
above 500 ppm which are presently capped by asphalt or other barriers
but become exposed in the future due to land use changes or
deterioration of the existing use.
-------
-3-
The selected remedy ia protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant and
appropriate, and is cost-effective. This remedy satisfies the statutory
preference for remedies that employ treatment that reduces tcodcity,
•ability, or volume as a principal element and utilizes permanent solutions
and alternative treatment technologies to the lavinum extent practicable for
this site.
However, because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted every five
years after commencement of remedial action to ensure that the remedy
continues to provide adequate protection of human health and the environmer
Date fj Waldas V. Adamkus
Regional Administrator
Region V
-------
AREA 1
NL INDUSTRIES
GRANITE CITY SITE
GRANITE CITY, ILLINOIS
LOCATION MAP
N
i«?\u 8 •/ «j///t/^/vrav
sTLila /^Y&sW$^M*>A
-------
ML INCQ91KIES/IARAGQRP SEES
GRMQXB Cm, TTJJMrrTS
I. SITE BACR3OHD
The NL Industries/Tferacorp Site ("the NL Site" or "the Sit*") im located
within a heavily industrialized section of Granite City, Illinois, a
ocmnunity of approximately 40,000 people located across the Mississippi River
from St. Louis, Missouri. Although the site is located within the
Mississippi River Valley, it is not within the 100-year flood plain of any
surface water. The location of the site is shown on Figure 1. Figure 2
presents the site plan, and Figure 3 shows the 100-year flood plain in the
vicinity of the site.
II. SHE HISTCRt AND ENFORCEMENT ACTIVITIES
Die NL Site is the location of a former secondary lead smelting facility.
Metal refining, fabricating, and associated activities have been conducted at
the site since before the turn of the century. Prior to 1903, the facilities
at the site included a shot tower, machine shop, factory for the manufacture
of blackbird targets, sealing wax, manufacture of mixBd metals, refining of
drosses, and the rolling of sheet lead. From 1903 to 1983 secondary lead
smelting occurred en-site. Secondary smelting facilities included a blast
furnace, a rotary furnace, several lead melting Kettles, a battery breaking
operation, a natural gas-fired boiler, several baghouses, cyclones and an
afterburner. Secondary lead smelting operations were discontinued during
1983 and equipment dismantled.
In July of 1981, St. Tnuis Lead Recyclers, Inc. (SLLR) began using equipment
on adjacent property owned by Trust 454 to separate components of the
Taracorp waste pile. The objective was to recycle lead bearing materials to
the furnaces at Taracorp and send hard rubber and plastic of f -site for
recycling. SLLR continued operations until March 1983 when it shut down its
equipment. Rpsidivtls from the operation remain on Trust 454 property as does
some flfjui|iiitaiL.
A State Implementation Plan for Granite City was published in September 1983
by the Illinois Environmental Protection Agency (IEPA) . The lEPA's Report
indicated that the lead ncnattainment problem for air emissions in Granite
City was in large part attributable to emissions associated with the
operation of the secondary lead smelter operated by Taracorp and lead
reclamation activities onrrtirtfld by SLLR. The IEPA procured Administrative
Orders by Consent with Taracorp, St. Touts Lead Recyclers Inc. , Stackorp,
Inc., Tri-City Truck Plaza, Inc., and Trust 454 during March 1984. The
Orders required the implementation of remedial activities relative to the air
quality.
NL Industries (NL) , as former owner of the site, voluntarily entered into an
Agreement and Administrative Order by Consent with the U.S. Envdronmental
Protection Agency (U.S. EPA) and IEPA in May 1985 to implement a
Investigation and Feasibility Study (RI/FS)
-------
for the site and other potentially affected areas. Taracorp was not a party
to the doiutamait due to the fact that it filed for bankruptcy. The U.S. EPA
determined that the site was a CCRCXA facility and it was placed on the
National Priorities List en June 10, 1986.
IU. OCMCKTIY RELATIONS HISTORY
U.S. EPA published the Proposed Plan in accordance with CEROA Section 117.
This document and the draft Feasibility Study (FS) Report and associated FS
Addendum were made available to the public on January 10, 1990, at the
beginning of a 45 day public cxjuuait period. The comment period was extended
an additional 15 days to March 12, 1990, due to extensive community interest
and response to the proposed remedy for the site. Availability sessions were
held on January 23-25, 1990, and March 5, 1990, and a public meeting was held
on February 8, 1990. Approximately 240 people attended the public meeting
and expressed their concerns. Comments received during the public commit.
period and the responses to those comments are contained in the
Responsiveness Summary (Appendix A).
IV. SCOPE AND POLE GF THE KESKN5E ACTION
ML Industries, a Potentially Responsible Party (PRP) and former site
owner/operator, under the direction of U.S. EPA and UPA, initiated a RI/FS
at this site. Activities performed under the May 1985, RI/FS Administrative
Order by Consent included determining the nature and extent of contamination
at the site and evaluating the feasibility of various remedial alternatives
to clean up the site.
This Record of Decision (ROD) addresses contaminated soil and waste materials
on the site, in adjacent residential areas, and in nearby alleys, driveways
and residential areas. These areas were determined to be a principal threat
at the site due to the potential risk from direct contact, ingestion, and
inhalation of contaminated soils, dust, and waste materials. The surface
water and air exposure pathways did not present an unacceptable risk to human
health and the environment, and groundwater was not contaminated immediately
downgradient (200-300 feet) from the site; however, the deeper portion of the
upper aquifer was not sampled. This is the first and only planned response
action at the site.
V. SITE CHARACDKISZICS
The RI was conducted by NL under the direction of U.S. EPA and IEPA to
determine the nature and extent of contamination at the NL Site. Field
activities were conducted from Dfnmbpr 1986 through November 1987. Field
aspects of the investigation included excavating test pits in the Taracorp
pile, constructing monitoring wells, collecting representative samples of
waste materials, soils, surface water, sediment, groundwater, and air, and
conducting aquifer tests.
-------
-3-
The NL Site is located in the Southwestern portion of Madison County,
Illinois within the Mississippi River Valley. The site is approximately
eight to ten miles gcuth of the confluence of the Mississippi and Missouri
Rivers. The site la underlain by recent alluvium and glaciofluvial and
glaciolacustrine deposits. Bedrock beneath the alluvium is Carboniferous age
rocks consisting of limestone, sandstone and shale. Die alluvial and glacial
deposits which fill the valley range in thickness from less than one foot
adjacent to the bluff boundary and the Chain of Rocks reach of the
Mississippi River to greater than 170 feet near the City of Mood River. The
fill thickness across the entire area averages approximately 120 feet. The
estimated thickness of the valley deposits beneath the site is approximately
100 to 120 feet. Investigations conducted by the Illinois State Hater Survey
have revealed the valley deposits become progressively coarser with depth.
Generally, groundwater in the Granite City area occurs within the
unccnsolidated valley deposits under unconfined and leaky confined
conditions. Recharge of groundwater within the area is from precipitation
and inducted infiltration of surface water from the Mississippi River and
smaller surface water bodies in the area.
A search of available hydrogeologic data, door-to-door surveys in areas
inmediately downgradient of the site, and hydrogeologic field investigations
conducted during the RI indicated the following:
- residents of Granite City drink water provided by the city which is
obtained from the Mississippi River.
- only one well in the downgradient vicinity of the site was in use; it was
used for lawn watering.
- the water table was encountered at an average depth of 24 feet below ground
surface.
- the horizontal hydraulic conductivity of the site ranged from 5.3X1CT4
cm/sec to 2.0X10*2 cm/sec within the shallow portion jfapproximately 20 feet
deep) of the aquifer and 4.3XHT4 cat/sec to 6.1 X 10~2 en/sec in the
"deeper" zone (approximately 35 feet deep).
- groundwater flow is in a south-southwesterly direction across the site,
toward the Mississippi River.
- the linear groundwater flow velocity has been calculated as ranging from
3XLO-3 ft/day to 0.5 ft/day in the shallow portion of the aquifer and
2x10-3 ft/day to 0.5 ft/day in the "deeper" zone.
- a downward verticle gradient was identified in some of the well nests at
the site.
Results of the RI, which was finalized on February 1, 1989, with Addendum
dated January 10, 1989, are summarized below:
-------
Areas of contamination (Refer to Figure 4):
Located on the site is a pile nrrfrinort primarily of blast furnace
slag and battery case material. "Die volume of the pile is approximately
85,000 cubic yards. In addition, smaller piles immediately adjacent to the
Taracoxp pile, which were associated with the adjacent SLLR recycling
operation, nmprisft approximately 2450 cubic yards. Tests conducted on the
materials in the Taracorp pile and small SLLR piles demonstrate lead con-
centrations in the range of 1-28%. n» toxicity test results demonstrate that
the waste pile tna^r**"** are a characteristic ha^anlnns waste under 40 CTO
Part 261. In addition, on the surface of the pile are 25-35 drums and con-
tainers holding solid wastes from the smelting operations which normally
would be recycled. These containers remained after the smelting operations
ceased in 1983.
• Ar
-------
Eagle fork Acres
Eagle fork Acres Includes acne vacant land to which battery case naterial was
previously hauled. The battery case naterial was uood to fill a ditcii on the
property and a portion has been uncovered during subsequent excavation. The
approximate volume of material and surrounding soil at Eagle fork Acres is
2700 cubic yards. Testing of the soil in this area indicated surface lead
Ttrations ranging from 63 mg/kg to 3280 mg/kg. Refer to Figure 6 for the
estimated areas of contamination in Eagle
Venice Township Alleys
According to residents in the area, Venice Township hauled hard rubber case
material to unpaved alleys in Venice Township. Tests conducted on these
alleys resulted in a vide range of lead concentrations. Surface lead
concentrations ranged from 200 mg/kg to 126,000 mg/kg. The estimated volume
of battery case material and associated soil in these alleys is 670 cubic
yards. Refer to Figure 7 for estimated areas of contamination in Venice.
Background water quality at the site is characterized by elevated
ocnoentrations of dissolved solids, sulfates, and manganese. Collectively,
a shallow and adjacent deep well located on the site demonstrated elevated
ocnoentrations (as compared to background) of sulfates, dissolved solids,
arsenic, cadmium, manganese, nickel, and zinc. However, data from the shallow
and deep wells located hydraulically downgradient demonstrated water quality
similar to that in the background monitoring well. The possibility of a straiy
downward hydraulic gradient was identified during the RI.
Surface Wa+^f flnfl f£f
No surface water is pioocnt at the site; runoff away from the area of the
Taracorp pile is limited to the property of Tri-City Trucking, Trust 454, and
Taracorp.
Results of air monitoring for lead conducted by IEPA have indicated that
emissions from the site are well within the National Ambient Air Quality
Standard for lead since Taracorp ceased smelting operations in 1983.
Post RT information and InsumjLions
An inspection conducted with residents of Eagle fork Acres indicated that
battery case material was uood for fill much more extensively than indicated in
the draft FS Report. Many former driveways and parking lots throughout the
area contain battery case material at the surface; others have been covered
with an undetermined depth of fill material. The estimated volume of
contaminated material in the draft FS Report is low.
-------
During the public cuimnt period, many residents indicated areas in Granite
City which contained battery case material as fill. These area are currently
being investigated. It should be noted that Figures 5, 6 and 7 were generated
based on information available at the flme of the Feasibility Study, and
therefore, represent only estimated areas of contamination/remediation.
VI. SOMARSf OP SITE RISK?
The Risk Assessment included in the RI Report identified two complete exposure
pathways that exist at the site: direct contact with contaminated waste
materials and soils, and inhalation of contaminated airborne dust. Lead was
identified as the primary contaminant of concern at the site, and all remedial
activities included in alternatives in the FS are based on lead contamination
levels.
Based on the above information, it was determined that remedial alternatives
considered should address the Taracorp pile, Area 1 battery case materials and
soils, nearby residential surface soils, battery case materials at Eagle Park
Acres and in Venice Township Alleys, and the potential data gap presented by
the possible strong downward hydraulic gradient near the site.
U.S. ERA and IEPA did not agree with the portions of the Risk Assessment
conducted by NL Industries which selected soil cleanup levels for lead. This
dispute led to the drafting of an FS Addendum by U.S. EPA and IEPA which added
an eighth alternative, Alternative H, to the list of alternatives to be
evaluated for the site. Among other things, Alternative H utilized a 500 ppm
soil lead cleanup level for residential areas around the site. Documentation
for the selection of this cleanup level is included in Appendix B.
VH. DESCRIPTION OF AUCEfNKCCVES
The alternatives that underwent detailed analysis are briefly described below.
Alternative A - No Action
Monitoring: Air Quality Monitoring; Ground Water
Monitoring, Additional Deep Nells.
Institutional Controls: Site Access Restrictions; Land Use
Restrictions; Deed Restrictions; Sale
Restrictions.
Estimated Total Remedial Costs: $475,110 Present North
BgfriTnafrat^ Months to Implement: 6—12
The no action alternative (A) includes a group of activities that can
be used to monitor contaminant transport. The auuiuea considered potentially
viable include air, surface soils, and groundwater. It includes institutional
controls on the Taracorp property and other properties where residual
concentrations do not meet TTnmnrtlnl Objectives. In addition, • •*< •*<•»• of one
upgradient and three downgradient deep wells would be installed to nonitor
water quality in the lower portion of the aquifer; well nests or clusters would
be employed wherever possible.
-------
-7-
Alternative B
Taracorp Pile: Multimedia Cap, Institutional Controls .
Taracorp Drums: Off-Site Recovery at Secondary
Laad Smelter.
SUP. Piles: Excavate and Consolidate with Taraoorp Pile.
Venice Alleys: Asphalt oar Sod Cover Based on Usage.
Eagle Park Acres: Vegetated Clay Cap, Institutional Controls.
Area 1 Uhpaved
Surfaces: Asphalt or Sod Cover Based on Usage.
Area 2 Unpaved
Surfaces: Asphalt or Sod Cover Based on Usage.
Area 3 Unpaved
Surfaces: Asphalt or Sod Cover Based on Usage.
Monitoring: Air and Groundwater Monitoring, Additional
Deep Wells, Contingency Plans.
Estimated Total Pancrfi*! Cost: $5,685,020 Present Worth
Estimated Months to Implement: 12-24
To implement Alternative B, drums containing lead drosses and other production
by-products would be removed to an off-site secondary lead smelter for lead
recovery. Wastes contained in the SIIR piles would be consolidated into the
Taraoorp pile; the consolidated pile would be graded and capped with a
multimedia cap. Institutional controls such as site acness restrictions,
restrictive covenants, donrl restrictions, and property transfer restrictions
would »igft be implemented.
Eagle Park Acres would be purchased and a vegetated clay cap in compliance with
ARARs would be installed over the battery case material (refer to Figure 6) .
Institutional controls such as site access restrictions, restrictive covenants,
deed restrictions, and property transfer restrictions would also be
Venice Alleys would be covered in accordance with present usage (refer to
Figure 7) . Asphalt would be applied to the portions subject to vehicular or
pedestrian use; the remaining areas would be covered with 3 inches of topsoil
followed by sod.
Unpaved portions of Areas 1, 2, and 3 (refer to Figure 4) would be covered in
accordance with present usage. Asphalt would be applied to unpaved driveways
and alleys; grassed or open areas would be covered with three inches of topsoil
followed by sod. Removal of existing soils would be limited to driveway
subgradc preparation; therefore, surface elevations would change somewhat
depending on surface treatment. Any soil excavated would be transported to the
Taraoorp pile for use in grading prior to cap installation.
-------
-e-
The air and grcundwater monitoring included in the no action alternative would
also be implemented as part of Alternative B.
Alternative C in the FS Report is nearly identical to Alternative D;
therefore. Alternative C has been excluded from further consideration.
Taracorp Pile: Multimedia Cap, Institutional Controls.
Taracorp Drums: Off-Site Recovery at Secondary
l#*4 Smelter.
SLUR Piles: Excavate and Consolidate with Taracorp Pile.
Venice Alleys: Excavate Case Material and Consolidate with
Taracorp Pile. Restore Surfaces.
Eagle Park Acres: Excavate Case Material and Consolidate with
Taracorp Pile. Restore Surfaces.
Area 1 Unpaved
Surfaces: Excavate Soil and Consolidate with Taracorp
Pile. Restore Surfaces.
Area 2 Unpaved
Surfaces: Excavate Soil and Consolidate with Taracorp
Pile. Restore Surfaces.
Area 3 Unpaved
Surfaces: Excavate Soil and Consolidate with Taracorp
Pile. Restore Surfaces.
Monitoring: Air and Grcundwater Monitoring, Additional
Deep Nells, Contingency Plans.
Estimated Total Remedial Cost: $6,835,450 Present Worth
Estimated Months to Implement: 12-24
To implement Alternative D, drums containing lead drosses and other production
by-products would be removed to an off-site secondary lead smelter for lead
cy. Wastes contained in the SUP. piles would be consolidated into the
Taracorp pile; the consolidated pile would be graded and capped with a
multimedia cap. Institutional controls such as site access restrictions,
restrictive covenants, deed restrictions, and property transfer restrictions
would be implemented.
Battery case material would be excavated from both Venice Alleys and Eagle Park
Acres and transferred to the Taracorp pile. After preliminary sampling is
conducted, any portion of the case material that is EP Toxic for lead will be
removed to an off-site, RCRA compliant landfill or treated prior to placement
in the Taracorp pile. These areas would be restored with either asphalt or
sod, in accordance with current usage.
-------
Unpaved portions of Areas 1, 2, and 3 would be excavated to a depth of three
inches and restored with either asphalt or sod, in accordance with present
usage. Excavated soil would be transported to the Taraoorp pile for use in
grading prior to cap installation.
The air and groundwater monitoring included in the no action alternative would
also be implemented as part of Alternative D.
Alternative E
Taraoorp Pile: Multimedia Cap, Supplemental Liner,
Institutional Controls.
Taracorp Drums: Off-Site Recovery at Secondary
Toad Smelter.
SLLR Piles: Excavate and Consolidate with Taracorp Pile.
Venice Alleys: Excavate Case Material and Consolidate
with Taracorp Pile. Restore Surfaces.
Eagle Park Acres: Excavate Case Material and Consolidate
with Taracorp Pile. Restore Surfaces.
Area 1 Unpaved
Surfaces: Excavate Soil and Consolidate with Taracorp
Pile. Restore Surfaces.
Area 2 through 8
Residential Surfaces: Excavate Soil and Consolidate with Taracorp Pile
Taracorp Pile. Restore Surfaces.
Monitoring: Air and Groundwater Monitoring, Additional
Poop Wells, Contingency Plans.
Estimated Total Remedial Cost: $31,000,000 Present Worth
Estimator! Months to Implement: 42-54
To implement Alternative E, drums containing lead drosses and other production
by-products would be removed to an off-site secondary lead smelter for lead
recovery. An impermeable liner would then be installed on a section of Area 1
adjacent to the Taracorp pile. All soils in Area 1 with lead concentrations
greater than 1000 ppm would be excavated prior to liner installation, with the
excavated soil staged with the Taracorp pile. The liner would consist of 2
feet of clay, 1 foot of sand (secondary drainage layer), a 60 mil synthetic
membrane, and 1 foot of sand (primary drainage layer). A primary and secondary
leachate collection system (perforated PVC piping) would also be provided.
Excavated soils from Areas 1 through 8 would be placed over the primary
drainage layer as a base' to protect the liner from damage. Following liner
construction, waste materials from the Taracorp pile, SLLR pile, Eagle Park
Acres, and Venice Alleys would be excavated, transported to, and placed on the
liner. These wastes would be covered and graded with soils excavated from the
base of the former Taracorp pile. A multimedia cap would then be installed
ever the consolidated pile. All construction activities in Area l mentioned
above would comply with any applicable flood plain construction permit
-------
-10-
requirements. Institutional controls such as site access restrictions,
restrictive covenants, dead restrictions, and property transfer restrictions
would also be implemented.
As *Harnecad above, battery case material would be excavated from both Venice
Alleys and Eagle Park Acres and transferred to the newly constructed liner.
These areas would be restored with either asphalt or sod, in accordance with
current usage.
Residential soils in Areas 2 through 8 (see Figure 5) with lead concentrations
greater than 500 ppm would be excavated and restored with either asphalt or
sod, in accordance with present usage. As stated above, excavated soil would
be transported to the newly constructed liner and placed directly over the
primary drainage layer, to protect the synthetic membrane from damage from
heavy slag and debris.
Air and groundwater monitoring included in the no action alternative would be
implemented as part of Alternative E.
Al Amative F
Taracorp Pile: Multimedia Cap, Supplemental T.
-------
-11-
aegragaticn unit. The commercially available unit would utilize flotation as a
recovery mechanism. Recovered plastic would be shipped off-site for use as a
raw material. Recovered lead and lead oxide would be shipped to a secondary
smelter after drying. Residuals, including slag and rubber case Material,
would be transported to the liner.
Taracorp Pile: Recovery of Plastic Battery Case Material
and Lead, Disposal of Residuals in RCRA
landfill.
Taraoorp Drums: Off-Site Raoovery at a Secondary Lead
Smelter.
SLLR Piles: Disposal in RCRA landfill.
Venice Alleys: Excavate Case Material, Disposal in RCRA
landfill. Restore Surfaces.
Eagle Park Acres: Excavate Case Material, Disposal in RCRA
landfill. Restore Surfaces.
Area 1 Unpaved
Surfaces: Excavate and Restore. Disposal in
RCRA landfill.
Area 2 through 8
Residential Surfaces: Excavate and Restore. Disposal in
RCRA or Non-RCRA landfill.
Monitoring: Grcundwater Monitoring, Additional Deep
Wells, Contingency Plan.
Estimated Total P*»«*^»I Cost: $67,000,000 Present North
Estimated Months to Implement: 66-78
To implement Alternative G, drums containing lead drosses and other production
by-products would be removed to an off-site secondary lead mpltfir for lead
recovery. The remaining waste materials in the Taracorp pile would be
excavated, processed to recover recyclable plastic, and Hinprwri of in a RCRA
landfill.
Processing would consist of visual segregation during initial excavations to
separate non-plastic bearing wastes from wastes containing plastics. Non-
plastic bearing waste would be transported directly to the RCRA landfill; those
containing significant amounts of plastic battery case material and smeltable
lead would be transported to an en-site segregation unit. The commercially
available unit would utilize flotation as a recovery mechanism. Recovered
plastic would be shipped off-site for use as a raw material. Recovered lead
and lead oxide would be shipped to a secondary smftlter after drying.
Residuals, including slag and rubber case material, would be transported to the
RCRA landfill.
Battery case material would be excavated from both Venice Alleys and Eagle Park
Acres and transported directly to the RCRA landfill. It is thought that these
casings are primarily rubber and, therefore, not likely suitable for recycling.
If significant amounts of plastic casings were excavated, however, they would
be proceased in the sane fashion as the Taracorp pile casings. Venice Alleys
-------
-12-
and Eagle Park Acres surface areas would be restored with either asphalt or
sod, in accordance with currant usage.
Unpaved portions of Areas 1 through 8 would be excavated and restored with
either asphalt or sod, in accordance with present usage. Excavated soil from
Area 1 would be transported to a RCRA landfill; excavated soil from.Areas 2
through 8 would be transported to a RCRA or non-RCRA landfill, based on the
results of preliminary EP Toocicity tests for lead.
The groundwater monitoring included in the no action alternative would also be
implemented as part of Alternative G. Long term air monitoring would not be
required.
Alternative H
Taracorp Pile: Multimedia Cap, Institutional Controls.
Taraoorp Drums: Off-Site Recovery at a Secondary lead
Smelter.
SLLR Piles: Excavate and Consolidate with Taracorp
Pile.
Venice Alleys: Excavate Case Material and Consolidate
with Taraoorp Pile. Restore Surfaces.
Eagle Park Acres: Excavate Case Material and Consolidate
with Taracorp Pile. Restore Surfaces.
Area 1 Unpaved
Surfaces: Excavate Soil and Consolidate with Taracorp
Pile. Restore Surfaces.
Areas 2 through 8
Residential Surfaces: Excavate Soil and Consolidate with Taracorp
Pile. Restore Surfaces.
Monitoring: Air and Groundwater Monitoring, Additional
Deep Wells, Contingency Plans.
Estimated Total Remedial Cost: $25,000,000 Present Worth
Estimated Months to Implement: 18-30 (construction)
Alternative H, which was added by U.S. EPA and IEPA in an addendum to the
draft FS Report, is identical to Alternative D, with the exception that the
scope of off-site soil and waste materials excavation is increased
significantly as described below. NL Industries has indicated to U.S. EPA its
objections to the increased scope of soil excavation in this alternative.
All soils in Area 1 with lead concentrations greater than 1000 ppm and
residential soils in Areas 2 through 8 with lead ooncentraticns greater than
500 ppm would be excavated and consolidated with the Taracorp pile. Surfaces
would be restored with either asphalt or sod, in accordance with present usage.
Vm. SUMMARY OF OCMPARATIVE ANAUCSXS OF AlOBMKEIVES
The nine criteria used for evaluating the remedial alternative* listed above
include: overall protection of human health and the environment; oompliar
with ARARs; long-ten effectiveness; reduction of toxicity, mobility, or
-------
-13-
acceptance; volume; short-term effectiveness; implementability; cost; state of
Illinois acceptance and cconunities of Granite City, Madison, and Venice,
Illinois acceptance. Based on these nine criteria, the U.S. EPA and ZEPA have
selected Alternative H, as modified with five additional elements added due to
public cooments received, as the preferred alternative for remedial action at
the NL site. The preferred alternative includes: Blood Lead Sampling in the
Neighboring Oonnunities/Remcval and Recovery of Taracorp Druns/Cbnsolidation of
SLLR Piles Into Taracorp Pile/Excavation and Restoration Of Unpaved Portions Of
Area 1 With Lead Ooncentration Greater than 1000 ppm and Residential Areas
Around The Site and in Venice, Eagle Park Acres, and Other Nearby dcnraunities
with Lead Concentration Greater Than 500 ppm, and Consolidation of These Soils
and Battery rase Materials with the Taracorp Pile or Off-Site Disposal/
Excavation, Restoration and Consolidation With Taracorp Pile or Off-Site
Disposal of Battery Case Material in Alleys and Driveways in Venice, Eagle Park
Acres, and Other Nearby Canaruties/Oonstruction of a RCRA-Conpliance Cap Over
the Expanded Taracorp pile and a Clay Liner Under All Newly-Created Portion of
the Expanded Taracorp Pile/Construction of a RCRA-Ccnpliant Cap Over the
Expanded Taracorp Pile/Inspection of Home Interiors/Establishment of Contingency
Measures To Properly Dispose of Contaminated Soil Generated Through Changes In
Land Use/Installation of Deep Monitoring Wells/Cap, Air and Groundwater
Monitoring And Contingency Plans/Fencing and Institutional Controls. Refer to
Figure 8 for a diagram of the RCRA-compliant, multijnpriia cap to be placed over
the Taracorp pile, after consolidation. This section discusses the performance
of the preferred alternative against the nine criteria, noting how it ccopares
to the other options under consideration.
It oust be noted that the conparisons made below are for the alternatives as
discussed in the Proposed Plan. Due to comments received during the public
eminent period, five elements were added to Alternative H, namely blood lead
sampling in the surrounding community, home interior inspections on properties
to be excavated, provisions to remediate additional areas in Eagle Park Acres,
Venice, Granite City, Madison and other nearby communities where battery case
materials are located at or near the surface and which were not identified in
the draft FS Report, construction of a clay liner under the new newly-created
portions of the expanded Taracorp pile, and establishment of contingency
measures to provide for proper dif^ofial of contaminated soil due to land use
changes within the zone of contamination. The selected remedy, or preferred
alternative, is Alternative H as modified by the addition of these five
elements. These elements are not diisra gyred in the analysis below since, with the
exception of Alternative A and Alternative B and G, for which a liner would not
be required, they would be included in each of the alternatives. Additionally,
cost estimates have not been provided for these elements; however, it is
expected that, excluding the contingency measures, these activities will not
cost more than 15% of the cost estimates for the alternatives provided in this
ROD. It is difficult to provide a cost estimate for the contingency measures;
however, it is expected that the cost of these measures would be the same for
each alternative which rpmnrtlntp*; residential soils. Finally, it oust, be noted
that Figures 5, 6, and 7 represent only estimated areas of remediation and that
the extensive soil sampling and inspections provided as part of the preferred
alternative will result in the accurate delineation of areas of remediation
during the upcoming ftanmdi*! Design phase of the Super-fund process.
-------
-14-
Overall Protection - With the exception of the no action alternative, the
treatment of Areas 4 through 8 in Alternative B, and the treatment of Areas 1
through 8 in Alternative D, all of the alternatives, as amended by the addendum
to the Feasibility Study, would provide adequate protection of human health and
the environment. Each of the alternatives found adequately protective of human
health and the environment includes a residential soil lead cleanup standard of
500 ppn and a soil lead cleanup standard of 1000 ppm in Area 1. Levels of
protectiveness are based on interim guidance and site specific analysis of
Granite City and the surrounding oonaunities (see Appendix B) . The preferred
alternative includes the elimination of direct contact with and inhalation of
soils and waste •aterials contaminated with lead at concentrations above levels
which may present a risk to public health by: removal of Taracorp drums and
off-site recovery at a secondary lead smelter; excavation, restoration, and
consolidation with the Taracorp pile of the SILR piles, soils and battery case
materials with lead concentrations greater than 500 ppa in residential areas in
Areas 2 through 8, and battery case material in Venice Alleys and Eagle Park
Acres; excavation, restoration, and consolidation of soils and waste
in Area 1 with lead concentrations greater than 1000 ppn; and providing a
multimedia cap over the Taracorp pile and providing institutional controls.
The preferred alternative also includes installation of additional deep wells,
air and groundwater monitoring plans, and contingency plans to be developed
implemented in the event that site-related contaminant levels in the air or
groundwater exceed applicable standards or that »»«w<»ig in the expanded
Taracorp pile banomp exposed or releasable to the air in the future.
Compliance with ARARs - Alternatives B through H would meet all Applicable
or Relevant and Appropriate Requirements (ARARs) of Federal and State
Environmental laws except for State of Illinois General Use Water Quality
Standards (35 IAC 302.208). Ihese standards are applicable to groundwater
beneath the site and are exnrwtarl for sulfates, total dissolved solids, iron,
manganese and zinc. The standards for these parameters were developed to
ensure the aesthetic quality of water and concentrations in excess of the
General Use standards for these parameters would not present a health concern.
Cadmium was also pnaanit above the General Use standard during three rounds of
sampling but not during the most recent sampling. The groundwater monitoring
and additional deep well installation included in an alternatives win verify
cadmium concentrations and monitor concentrations of all other parameters of
concern. Care would have to be exercised with Alternatives E, F, and G to
ensure that Taracorp pile excavation activities do not create exceedances of
air ARARs.
Additionally, the consolidation of excavated contaminated soils from the
residential areas around the site is included in Alternatives D and H due to
the fact that these areas are within a zone of continuous contamination created
by the airborne deposition of lead from the smelter stack throughout its years
of operation. Lead contamination is highest next to the smelter stack (cn-
site) and gradually decreases with increasing radial distance from the stack,
and the .nearest residential areas to be excavated are physically separated free
the site boundary by one roadway, 16th Avenue.
-------
-15-
Effectiveness - Alternatives E, F, and G would provide good long-term
effectiveness against direct contact with and inhalation of soils and waste
materials containing lead concentrations above levels which may pruouat a risk
to public health, as wall as an additional barrier against leaching of lead and
other metals into the groundwater. The preferred alternative (i.e.,
Alternative H) would provide similar long-term effectiveness but would not
provide the additional barrier (bottom clay liner) against leaching metals
under the present Taracorp pile; however, the groundwater does not represent a
complete risk pathway at this site. With the exception of Areas 4 through 8,
for which no remediation is provided, Alternative B would eliminate the risk of
human exposure in off-site areas upon completion of remediation but would not
provide long-term effectiveness in these areas due to maintenance requirements
and the potential for uncontrolled excavation. With the exception of Areas 4
through 8, for which no remediation is provided, Alternative D would provide
good long-term effectiveness with respect to materials consolidated with the
Taracorp pile; however, at Areas 1, 2, and 3, lead concentrations at 3 inches
beneath the ground surface would remain at levels which may present a risk to
public health. The no action alternative allows waste iM+wiais to remain in
place and, thus, has poor long-term effectiveness.
Reduction of Toxicity. Utility» or Volurns — With the exception of the no
action alternative, all alternatives provide a reduction of mobility of
contaminants; the degree of mobility reduction provided, from least to
greatest, is Alternative B, D, H, E, F, then G. The no action alternative does
not provide any reduction of toxicity or volume, Alternatives B, 0, H, and E
provide a slight reduction of toxicity and volume by removal and recovery of
Taracorp drums, and Alternatives F and G provide a slightly greater reduction
of toxicity and volume by recycling some waste materials. The reduction of
volume effected by Alternatives F and G has been calculated to be less than
10%, based on the quantity, nature and physical condition of recyclable
materials in the Taracorp pile. A recycling effort on the Taracorp pile was
conducted in the early 1980's by St. T""° laad Recyclers. The effort was
unsuccessful in that anticipated volume reductions were not achieved and the
material remaining after recycling was more contaminated than that which
entered the piuoaus. The nature of the materials in the Taracorp pile is not
conducive to a successful recycling effort, and will potentially create a
greater adverse health impact to workers and the public than would exist if
the materials remain in place. Treataent/stabilizaticn has been applied to
contaminated soils at other sites, but has not been successfully applied to
waste materials such as exist in the Taracorp pile. Additionally, Alternatives
F and G would produce a contaminated sludge as a result of precipitation of
rinse waters used for recycling.
Short-Term Effectiveness - Implementation of Alternatives A and B would
produce mlmmnl short-term impacts to the community, workers, or the
environment, as contaminated material would be left in place. Implemen-
tation of Alternatives D, E, F, G, and H could generate dust in residential and
commercial areas, which would require monitoring and control. Alternative D
would be of shorter duration and would involve the movement of less materials
than Alternative H, Which would in turn involve less materials movment than
Alternatives E, F, and G. Alternatives-E, F, and G include significant
excavation at the Taracorp pile; the generated dust could impact the
-------
-16-
oommunity, workers, and the environment. Control measures would be required.
Alternatives F and G also include extensive manual handling of waste materials
at the Taracorp pile; worker health and safety oould be jeopardized through
ingestion of and direct contact with lead containing materials.
The following periods of time are required to implement the
construction activities for each alternative:
Alternative
A 6-12 Months
B, D 1-2 Years
H Approximately 2 1/2 Years
E 3 1/2 - 4 1/2 Years
F, G 5 1/2 - 6 1/2 Years
Unplementability - Alternatives A, B, D, and H would utilize standard
monitoring and construction techniques which would be readily implementable.
The excavation of the Taracorp pile and other soils and waste
incorporated in Alternatives D, E, F, G, and H would require dust control
measures. The segregation and recovery utilized by Alternatives F and G,
however, would utilize equipment designed to handle batteries, not the slag and
waste materials present at the Tferaoorp pile. In addition, the recovered
products may not be suitable for recycling: the recovered plastic may not
the TCLP test for lead, and the lead content of the recovered slag/dirt/lead
mixture may not be high enough to be acceptable to a secondary smelter.
cost - Ihe costs of each alternative are presented below. It must be noted
that these are estimated costs. More detailed cost estimates will be prepared
during the Remedial Design phase of the
O&M Present Worth
A $143,840 $21,550 $475,110
B $5,142,390 $35,300 $5,685,020
D $6,292,820 $35,300 $6,835,450
E $30,500,000 $35,300 $31,000,000
F $44,500,000 $35,300 $45,000,000
G $66,500,000 $5,300 $67,000,000
H $24,500,000 $35,300 $25,000,000
gfrat** jypceptanoe - The State of Illinois supports the preferred alternative.
OrHTMnity Ar'rer'fflnoe - Community acceptance of the preferred alternative has
been evaluated and it has been determined that the following five elements
should be added to the preferred alternative: 1) blood lead sampling in the
surrounding community, 2) home interior inspections on properties to be
excavated, 3) provisions to remediate additional areas in Eagle Park Acres,
Venice, Granite City, Madison, and other nearby communities where battery case
materials are located at or near the surface and which were not identified in
the draft FS Report, 4) construction of a clay liner under the newly-created
portions of the expanded Taracorp pile and 5) establishment of contingency
-------
-17-
to provide for proper disposal of contaminated soil due to land use
Changes within the zone of contamination. The Responsiveness Senary is
included in Appendix A of this Record of Decision and addresses all comments
received during the 60 day public omimnt period.
IX. THE SMKL'IH) REMEDY
The preferred alternative (selected remedy) for cleaning up the HL Site is
Alternative H, as amended by the addition of the five elements listed above:
Blood Lead Sampling In the Neighboring Carnalities/Removal and Recovery of
Taracorp Drums/Consolidation of SLLR Piles Into Taraoorp Pile/Excavation and
Restoration Of Uhpaved Portions Of Area 1 With lead Concentration Greater than
1000 ppm and Residential Areas Around The Site and in Venice, Eagle Park
Acres, and Other Nearby Ccnnunities With laad Concentration Greater than 500
ppm, and Consolidation of These Soils and Battery Case Materials with the
Taraoorp Pile/Excavation, Restoration and Consolidation With Taracorp Pile,
or Off-site Disposal, of Battery Case Material in Alleys and Driveways in Eagle
Park Acres, Venice, and Other Nearby Ciomnunities/Construction of a RCRA-
Compliant Cap Over the Expanded Taracorp Pile and Clay T.JTW under all Newly-
Created Portions of the Expanded Taraoorp Pile/Inspection of Home Interiors/
Establishment of Contingency Measures To Properly Dispose of Contaminated Soil
Generated Through Changes In land Use/Installation of Poop Monitoring
Wells/Cap, Air and Grounduater Monitoring and Contingency Plans/Fencing and
Institutional Controls. Based on current information, this alternative
provides the best balance of trade-offs among the alternatives with respect to
U.S. EPA's nine evaluation criteria.
Samling/Insection
Soil lead sampling shall be oorrincted in Area 1 and all residential portions of
Areas 2-6 (Figure 5) and immediately adjacent properties to determine the depth
to which each individual residential yard must be excavated to achieve a 500
ppm soil lead cleanup level and the depth to which Area 1 must be excavated to
achieve a 1000 ppm cleanup level.
Inspections of alleys and driveways and areas containing surf icial battery case
materials in Eagle Park Acres, Venice, Granite City, Madison, and other nearby
communities shall be rnrrtiv^rf to determine which specific areas not already
identified in Figures 5, 6 and 7 need remediation. EP tcodcity sampling for
lead shall be conducted for all identified areas, and lead sampling of all
identified areas which are not alleys or driveways shall be conducted to
determine the depth to which such areas must be excavated to achieve a 500 ppm
cleanup level.
tensive blood lead study shall be conducted on a representative number
and distribution of residents nearby the site. Results shall be provided to
the ccniunity as soon as possible. The study will be coordinated with and/or
conducted by the Agency for Toxic Substances and Disease Registry and/or
Illinois Department of Public Health and shall be mnrtiirtfld during optimum
exposure tlmp (i.e. numm 1990).
-------
-18-
All drums en the Taracorp pile shall be removed and transported to an of f-cite
secondary lead smelter for lead recovery.
All wastes contained in the SLLR pile shall be consolidated into the Taracorp
pile.
Based upon the FS and the inspections outlined above, battery case material
shall be excavated £rco all alleys and driveways in Venice, Eagle Park Acres,
and other nearby ooanunities in which it has come to be located at or near the
surface. Sampling for EP toxicity for lead shall be conducted in all affected
areas prior to removal of the case material. All excavated material which is
not EP toxic for lead shall be transported to the Taracorp pile for
consolidation. All excavated material which is EP toxic for lead shall be
transported to an off-site RCRA-ocnpliant landfill or treated prior to
placement in the Taracorp pile. Excavated areas shall be backfilled, if
necessary, and paved.
Based on the sampling outlined in the Soil Sampling/Inspection paragraph above,
all unpaved portions of Area 1, including the material which is beneath the
SLLR pile, with lead concentrations greater than 1000 ppm shall be excavated
and consolidated with the Taracorp pile. The surfaces shall be restored with
asphalt or sod, in accordance with present usage.
Based on the sampling outlined in the Soil Sampling/Inspection paragraph above,
an accurate mapping of all residential areas around the site and in Eagle Park
Acres, Venice, and other nearby communities with a lead concentration greater
than 500 ppm shall be provided. All soils and battery case materials with lead
itrations greater than 500 ppm in the residential areas indicated on the
map shall be excavated and consolidated with the Taracorp pile, with the
. exception of soils and battery case materials in Eagle Park Acres, Venice, and
other nearby communities which are EP toxic for lead, which shall be
transported to an off-site R3*A-compliant landfill or treated prior to
placement in the Taracorp pile. The surfaces shall be restored in accordance
with present usage. Every effort shall be made to remediate sensitive areas
(school yards, playgrounds, areas with highest lead concentrations, etc) first,
and no trees or structures or large vegetation shall be removed.
During the excavation of each residential yard, an inspection of the interior
of each home shall be omrtuctad to identify possible sources of lead expos*
4£e.
-------
-19-
The results and rnucuinei riations of each inspection shall be presided to the
appropriate residents.
Dust Control Mpv*g»
During all excavation, transportation, and consolidation activities conducted
as part of the remedy, dust control measures shall be implemented as necessary
to prevent the generation of visible emissions during these activities.
After all Materials have been transported to and consolidated with the Taracorp
pile, the consolidated pile shall be graded and capped with a RO?A-compliant,
multimedia cap. The cap shall be constructed as indicated in Figure 8 and
shall meet or exceed the requirements of RCRA Subtitle C, and Illinois State
lav. The proposed construction does not lie within any flcoduay in the area.
With the exception of the existing Taracorp pile, a clay bottom liner shall be
constructed on all areas upon which consolidated materials are to be placed as
part of this remedy. Portions of this liner on Area 1 shall be constructed
after Area 1 has been excavated to a 1000 ppm lead cleanup level.
OpTtrls/Fencincf
Institutional controls, such as site access restrictions, restrictive
covenants, dood restrictions, and property transfer restrictions, shall be
implemented for the properties which contain the expanded Taracorp pile to
prohibit future development of the site and any activities that would in any
way reduce the effectiveness of the cap in achieving remedial action goals.
The facility shall be fenced in a manner sufficient to prevent access to the
fixpnnrtad Taracorp pile. Warning signs shall be posed at 200-foot intervals
along the fence advising that the BTM is hazardous due to chemicals in the
waste materials and soils beneath the cap which may pose a risk to public
health.
of one upgradlent and three downgradient deep wells shall be
installed to monitor water quality in the lower portion of the upper aquifer.
Monitoring of these wells and the 14 existing site wells shall be conducted
semi-annually for a •Inlmm of 30 years and analyses shall be performed for the
full scan Hazardous Substance List organics and inorganics. After four
sampling events, consideration shall be given to deleting parameters from the
list which are below detection limits for all four events.
Air monitoring for lead and PM10 (partlculate matter less than 10 microns)
shall be performed annually at a minimm of two locations adjacent to the site
for a mlmmm) of 30 years.
-------
-20-
pcac a minimum of 30 years, annual inspections of the cap shall be conducted to
identify areas requiring repair. Appropriate maintenance shall be conducted
immediately following the inspections.
CPU**1 TFRTKy Plans
Contingency Plans for air, grounduater and the cap/soil cover shall be
developed to provide remedial action in the event that concentrations of
contaminants in grounduater or lead or Rf^0 *** a*r c*P°od applicable standards
or established action levels or that waste materials have migrated to the
surface or Hor»-mo releasable to the air in the future.
Oth°TT Contingency
Contingency measures shall be established to provide for sampling and removal
of any soils located within the zone of contamination established pursuant to
the Soils Sampling/Inspection paragraph above with lead concentrations above
500 ppm which are presently capped by asphalt or other barriers but become
exposed in the future due to land use changes or deterioration of the existing
use.
X. STATUIURy DEn39QKKFXCN5
Based on the information available at this tine, U.S. EPA and IEPA believe this
alternative will satisfy statutory requirements to: protect human health and
the environment, attain ARARs, be cost-effective, utilize permanent solutions
and alternative treatment technologies or resource recovery technologies to the
mnyinim extent practicable.
Protecti
The selected remedy will be adequately protective of human health and the
environment. Removal of soils and battery case materials in residential areas
above 500 ppm lead, soils and taste materials in Area 1 above 1000 ppm, and
battery case materials in alleys and driveways, and restoration through
applications of sod, paving, etc. will eliminate direct contact with and
inhalation of dust and lead contaminated soils and waste materials which may
create a risk to human health and the environment. Inspection of the interiors
of homes and providing residents with reccmnendations to «
-------
-21-
and ether nearby ocmunitles to a RCRA-ccnpliant i*rH*
-------
-22-
specifying sloping and topaoil requirements. Closure of the expanded Taracorp
pile ahall be conducted in accordance with 35 IAC Part 724, subpart N;
landfills. These requirements are ARARs for the capping of the expanded
Ttaracoxp pile.
• Lead, BJ^, and Fugitive Dust Emissions During and After Construction and
Past-Construction Ncnitoring/COntingency Plan
The State of Illinois has jurisdiction for Ambient Air Quality Standards and
Measurement Methods for Lead and PMi Q and requirements for fugitive
particulate matter. This is covered by 35 ZAC Part 212, Subpart B for lead and
IM10 and 35 IAC Part 212, subpart K for fugitive particulate Batter.
Construction activities and post-construction monitoring shall be conducted in
a manner that will achieve ocnplianoe with these requirements, which are ARARs
for these activities.
• Grcundwater Contingency Plan Action Levels
The State Of Illinois General Use Water Quality Standards which are covered by
35 IAC Part 302, Subpart. B, also apply to the groundwater at the NL site.
Action lewis for the Grcundwater Contingency Plan shall be adopted from the
Maximum Contaminant Levels (MCLs) and the General Use Water Quality Standards.
Groundwater contingency plans will be triggered if concentrations of
contaminants in the groundwater exceed action levels at the points of
compliance.
• Soil Lead Cleanup Level
Due to the fact that there is no promulgated soil lead cleanup standard and
that a complete quantitative risk mmr 'ihmnrit. cannot be performed at this
(see Appendix B for detailed explanation) , the September 7, 1989 "Interim
Guidance on Establishing Soil Lead Cleanup Levels at Superfund Sites" is a TBC
criteria for this site. This guidance basically recommends a residential soil
total lead cleanup level at 500 to 1000 ppm. The selected remedy, which
utilizes a 500 ppm residential soil cleanup level, ocmpHfis with this guidance.
The selected remedy is implementable and provides the elimination of direct
contact with and inhalation of soils and waste materials contaminated with lead
at concentrations above levels which may present a risk to public health in a
comparable or smaller time frame and cost than other alternatives which
achieve this goal.
The selected remedy utilizes permanent solutions and alternative treatment
technologies to the wnriinm extent practicable, in that it would remove
contaminated soils and waste Mt-4""!*!* from areas where »**<••• human exposure
would occur and provide recycling of the Taracorp drums. Due to the nature of
contaminated waste materials in the Taracorp pile and SLLR piles, the
-------
-23-
relatively low concentrations of lead in the contaminated soils, and the
of downgradient groundwater contamination at the site, this remedy represents
the lavlinBn extent to which pernanent solutions and treatment can be
practicably utilized.
for Tr**** inciple
The selected remedy satisfies the statutory preference for remedies that eoploy
treatment that achieves substantial risk reduction through recycling of the
Taracorp drums and by providing safe management of waste materials and soils
that will be consolidated and remain at the site.
No treatment is provided for the Taracorp pile and SLLR piles because, although
treatment has been provided for lead contaminated soils and certain lead waste
materials at other Superfund sites, the quantity, nature, and physical
orrriitim of waste materials in the Taracorp pile create a situation where very
little volume reduction can be achieved, stabilization is not feasible, and
treatment will create a significant potential risk to workers and the ccflmunity
during implementation but will not achieve an appreciable volume reduction or
reduction in mobility. The soils and battery case materials from residential
areas and alleys and driveways to be consolidated with the Taracorp pile will
not be EP toxic for lead. This, in conjunction with the fact that no
downgradient groundwater contamination has been detected at the site, make
treatment of these materials unnecessary and impractical. Soils and battery
case materials which are EP toxic for lead will be treated prior to
consolidation with the Taracorp pile or will be difipnrpnd off-site. However,
because this remedy will result in hazarrtnus substances remaining on-site above
health-based levels (the expanded Taracorp pile) , a review will be conducted
every five years after coonencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and the
environment. The monitoring and contingency plans provided in the remedy will
help to achieve this goal.
-------
FIGURE
NL INDUSTRIES
GRANITE CITY SITE
GRANITE CITY, ILLINOIS
LOCATION MAP
-------
« p;|t
I nr c r
er
Trust
Si. Uo«
Truck,'
-------
NL INDUSTRIES
GRANITE CITY SITE
GRANITE CITY, ILLINOIS
VU.r, in ihe
of Ihe S;
PROJECT SITE
FLOOD
-------
i o o rg _H _
,J ~ ~~
GRANITE CITY SITE
GRANITE CITY, ILLINOIS
Areas 1.2..
$\\l I
»* i_ ii v
r^tetu
n S*! */
-------
F;
r ,
apt.
NL INDUS! HltS
GRANITE CITY SITE
RANITE CITY, ILLINOI
jW Artoi
Above
-------
REMOTE nt-L AREA
ZAGLK PARK ACRES
LEGEND
SOIL SAMPLE LOCATION
APPROXIMATE LOCATION OF DITCH
''
-------
MERCHANTS
REMQ
LEGEND
SOIL SAMPLE LOCATION
PROPOSED REMEDIATION SITES
-------
ft
C
ap
u
^ rr r
^ — r r-1 ^
• • • 11 I • ' I , t I 11 11 I , I I / / / , II /,,,./ ( /
/'•••••••• I '• t I t > ' I I 11 I 11 , I • •. , . .,,
'' •'' ' *'•••''/ < /1,1 1111, 1. 1111 > ' .,,
x x *
* * x
A X *
X
X
X x
A
x •
ravel
x
>.
D
P;[
-------
NL INXJSTRIES\TARACOKP
GRANITE CITY, HUNDIS
RESPONSIVENESS SWINE!
I. RESPONSIVENESS SUWftRY OVERVIEW
In accordance with CKRCTA Section 117, a public conment period was held
from January 10, 1990 to March 12, 1990, to allow interested parties to
cement on the United States Environmental Protection Agency's (U.S.
EPA's) Feasibility Study (FS), FS Addendum, and Proposed Plan for a final
remedy at the NL Industries\Taracorp Superfund Site. At a February 8,
1990 public meeting U.S. EPA presented the Proposed Plan for the site,
answered questions and accepted cements from the public.
II. BACKGROUND ON COMJNITY INVOLVEMENT
The NL\Taracorp Superfund site occupies almost 16 acres at 16th Street
and Cleveland Boulevard in Granite City. There are areas near the site
that are mostly residential and these areas were found to contain lead
levels which could be a health threat to the community. An estimated
55 city blocks could be included in the area to be remediated.
ISSUE # 1: Some of the local officials and homeowners are not convinced
that a health threat really exists. There is no current standard set for
lead in soil. These local officials and homeowners are questioning the
recommendations set by ATSDR and adopted as guidance by U.S. EPA. There
is a request for blood lead testing to be conducted on the residents in
the site area to determine if any actual health effects exist. The
officials and homeowners say this would be a way to determine the course
of action.
ISSUE # 2: Local officials and some homeowners are concerned with an
adverse impact on economic development and property values. This
contingent says that too stringent of a cleanup value is being placed on
the site and that this is exaggerating the situation out of proportion.
ISSUE t 3: Some residents living directly adjacent to the site are
anxious for U.S. EPA to take action. They say that some officials and
property owners are more concerned with economic issues than people's
health.
ISSUE # 4: Some residents Object to collecting the contaminated material
and leaving it in a pile with the already existing pile on site.
ISSUE #5: As stated in a previous issue, there is no current standard
for lead in soil. Potentially Responsible Parties for the site are
arguing against the 500 ppm residential cleanup recommendation of U.S.
EPA's Proposed Plan, saying hard data backing up this reccntnentetion is
lacking.
-------
These issues were identified during a February 8, 1990 public cement
meeting and are reflected in the transcript of the meeting. Public
Garments received orally during the meeting and in writing during the
cement period also reflect these issues.
The following categories include the sunmarized responses to the above
issues.
1. GENERAL
2. TECTNICM,
3. HEZVLTH
4. LEX3\L
The Garments are paraphrased in order effectively sunmarize them in this
document. The reader is referred to the public meeting transcript and
written Garments which are available at the public information
repository.
-------
Gl. A handful of comments received asked that the contaminated areas be
cleaned up with no specific reference to an alternative. These
Garments were supportive of nan specific action and seme asked that
the residents be kept informed of the process and work progress.
The U.S. Environmental Protectional Agency (U.S. EPA) Region 5, acknowledges
the cements and support of action at the site. As the project progresses,
U.S. EPA will distribute information to the community through a variety of
ways, such as press releases, newspaper advertisements, direct mailings and
informational meetings, either formal, or informs], depending on the need.
U.S. EPA has established an information repository where documents and
information about the site can be found. It is located in the Granite City
Public Library, 2001 npima-r Avenue, Granite City, IL.
-------
HEALTH-BASED COMMENTS
EPA has received six public comments on the proposed Record of Decision
which address the risk assessment and/or health Impact to the residents of
Granite City posed by the NL/Taracorp Superfund site at Granite City,
Illinois. These comments and the EPA response follows.
HI: We received an extensive comment (49 pages plus exhibits A-0) from NL
Industries on the proposed clean-up plan for the NL/Taracorp Superfund site.
Their comment is attached to this responsiveness summary. The U.S. EPA
response Is presented in two sections. The health-based portions of the
comments are addressed below, and the technical portions comprise comment T6
on page 10 of this responsiveness summary. In summary, NL Industries
maintains that their recoomended remedial action, alternative D, fully
complies with EPA's Interia guidance on establishing soil clean-up levels at
Superfund sites, and moreover, that it supports a clean-up of areas with soil
lead levels above the 1,000 ppm level as being fully protective of public
health. They identify children as the group which has been shown to be the
most sensitive to lead. They document their conclusions with a three-prong
"risk assessment" approach: a review of the blood lead survey data collected
by the Illinois Department of Public Health (IDPH) in April 1983, a risk
assessment prepared by O'Brien and Gere Engineers, Inc. using a modification
of the outdated Acceptable Daily Intake (ADI) approach, and an abbreviated
review of post-1980 literature on lead exposure which they used to identify
the slope of the relationship between soil lead and blood lead levels in
children.
Secondly, NL Industries refutes the selection of the remedial action
alternative H (a clean-up of soil to the 500 ppm level) proposed by EPA and
the Illinois Environmental Protection Agency (IEPA) on the following grounds:
in support of this clean-up level, EPA used irrelevant vegetable consumption
data, the pre-1975 Madhaven et al. study data on lead exposure to derive the
relationship between soil/dust lead levels and blood lead levels, the work
plan for the Cincinnati Soil Lead Abatement project which has no bearing on
Granite City conditions, and Superfund Records of Decision (RODs) prepared
for other, disslmiliar sites.
U.S. EPA Response: A careful reading of the public comment prepared by NL
Industries and of the Risk Assessment prepared by O'Brien and Gere as part of
the Remedial Investigation report for the NL/Taracorp Superfund site is
necessary to comprehend the concerns presented. It is understandable that NL
Industries objects to the 500 ppm lead in soil clean-up level, given the
Information presented. NL offers three "risk assessments" 1n defense of their
proposed 1,000 ppm soil clean-up level.
The first approach, the use of blood lead survey data collected by
IDPH 1n 1983 to justify a sojl lead clean-up level is flawed In many respects:
a final report of this survey was never prepared by IDPH and the conclusions
reached by the contractors for NL Industries using this data^re therefore
suspect; the coramenters use a combination of elevated blootf~1ead levels and |
elevated levels of free erythrocyte protoporphyrin (FEP) 1n blood to delineate'
an adverse health outcome In children while a literature review indicates that
-------
-2-
FEP, which is an Indicator of deranged heme synthesis. Is a poor indicator of
bloo'd lead levels and other adverse health effects; Rabonowitz et al. (Arch.
Environ Health 1984) have shown that blood lead levels are not stable and
caution against the use of a single measurement to evaluate lead exposures.
The second approach, the risk assessment prepared by the NL
Industries' contractors is also flawed. It uses a modification of the
outdated Acceptable Daily Intake (AOI) approach, citing the new Risk
Assessment Guidance for Superfund, Volume 1, Human Health Evaluation Manual
(Part A), December 1989 and the approval of EPA's Environmental Criteria and
Assessment Office (ECAO) as justification for this approach. O'Brien and Gere
has misunderstood that toxicity values derived in such a manner must be
approved on a case by case basis before being used. The use of the derived
modified dose in this risk assessment is erroneous. A major flaw in this risk
assessment is that it fails to identify the critical population at risk, the
child under the age of six years, and instead presents the chronic risk to the
adult population using a lifetime exposure to lead in soil. While the soil
lead exposure does continue over a lifetime, the most sensitive endpoint is
the subchronic effects seen in developing children. To dilute this effect
over a lifetime exposure of 70 years greatly underestimates the risk to
children and is completely unacceptable to EPA. If the risk assessment were
to be done using the derived toxicity values as applied to the most sensitive
population, children under the age of six, a clean-up level below 500 ppm lead
in soil would be warranted, as has been demonstrated in risk assessments
prepared for other lead smelter sites. EPA rejects this approach in favor of
other site-specific approaches presented in Appendix B.
The last approach to justify the soil clean-up alternative D, the use
of three of the lowest slope factors abstracted from the literature to derive
the relationship between soil lead levels and blood lead levels appears to be
a conserted effort to obscure the issue. A literature review quickly shows
that a myriad of slope factors for the soil/blood lead relationship have been
proposed, ranging from 1.1 to 7.6 micrograms per deciliter blood lead per
1.000 ppm soil lead. In general, the slope factors from mining sites can be
shown to average approximately 2.0, which is about half the average slope from
smelter sites (the median slope factor is approximately 4.0). The slope
relationship, at best, emphasizes correlations. These estimates make no
assumptions about exposure, bioavailability, the age range of the population
studied, and so on, which makes the derived slope factor relationship
tenuous. Ongoing studies supported by EPA are presently underway to further
delineate this relationship. Until more conclusive data is available to
support a blood/soil lead relationship, EPA rejects a risk assessment
approach which relies on slope factors.
In conclusion, the three "risk assessment" approaches proposed by the
contractors for NL Industries fail to identify a risk at all to children
living in the area of the NL/Taracorp Superfund site, and are fundamentally
flawed and unacceptable for use to establish a soil lead clean-up level for
the NL/Taracorp site.
The second set of comments address the EPA selection of remedial
action alternative H. NL Industries misunderstands the criteria which were
used by EPA to determine the need for a 500 ppm lead in soil clean-up-level at
the NL/Taracorp Superfund site. This goes to the basis for rejecting the 500
ppm soil clean-up level. For a discussion of the factors used to determine
the proposed clean-up level, this commentor is referred to the position paper
presented in Appendix B. Comment is required on two issues that will not be
-------
-3-
addressed In the position paper. The first is the suggestion that the work j
plan for the Cincinnati Soil Lead Abatement project was used by EPA as support1
for alternate H. This 1s totally erroneous as results from the Cincinnati
project are not expected to be available until June 1992, long after
remediation at the NL/Taracorp site Is underway. Data from the Cincinnati
project, as well as the Baltlnore and Boston projects, have been used to test
the Integrated Lead Uptake/Bloklnetic Model which is expected to replace the
Reference Dose for evaluation of the toxic effects of lead. Secondly, other
RODs have not been used to select the clean-up level for the NL/Taracorp
', Superfund site, although the conditions at several other sites across the
'-•* country s-uggest that the use of similiar risk assessment methodology would a
•*£' advocate a similiar clean-up level. Other RODs have been consulted to
demonstrate a trend of more stringent soil lead clean-up levels across the
country.
In general, we disagree with the conclusion that the CDC blood lead
level of 25 micrograms per deciliter or the proposed 15 micrograms per
deciliter can be considered as a threshold effect level for lead. Health
effects at the 10-15 micrograms per deciliter level have been well documented
in numerous publications by Needleman et al. A report by Schwartz and Otto in
1986 suggests that blood lead levels as low as 5 micrograms per deciliter may
be associated with minor hearing problems. EPA does agree with the comment
from NL Industries that the incorporation of the Biokinetic Model and other
generic and site-specific data into the development of clean-up levels for
lead are appropriate.
H2: We recieved a comment from the Tri-Cities Area Chamber of Commerce '
stressing that the issue of what the proper clean-up level at the NL/Taracorp
Superfund site must be resolved. They maintain that only a site-specific risk
assessment can properly address this question. They have requested that only
areas that have been proven to pose a health hazard be cleaned-up, and that
the clean-up begin at once and be completed as soon as possible.
U.S. EPA Response: EPA agrees that the clean-up level for lead at
Superfund sites should be carefully chosen and suggests a range of values
(from 500 to 1,000 ppm lead in soil), with the choice within that range to be
dictated by the site-specific characteristics of the site (OSWER Directive #
9355.4-02). Traditional risk assessments have been difficult to carry out for
sites containing lead as a contaminant due to the Inability to determine a
safe level for lead in soil under all conditions. Where risk assessments have
been used for this purpose, the calculations are sometimes suspect and have
resulted in soil clean-up levels down to 200-250 ppm lead in soil In some
cases. EPA used site-specific considerations in the setting of the 500 ppm
soil cleasn-up level at the NL/Taracorp site. However, EPA believes that a
better approach for determining the proper clean-up level at Superfund sites
Is through the use of models, which are discussed in the position paper in
Appendix B. The use of a favored model, the Lead Uptake/Bioklnetic Model,
demonstrates that approximately 34X of the Granite City children under the age
of six will have blood lead levels greater than 15 micrograms per deciliter if
the 1,000 ppm clean-up level for lead in soil is allowed. This would put 34%
of the children above a level that may represent a risk of adverse health
effects.
-------
-4-
H3: He received one comment from a Granite City resident who is extremely
concerned over the health hazards presented by the lead in the soil in the
a-anite City, Madison and Venice area. He has made and effort to read the
Material deposited by the the EPA in the reading file and has consulted with
four professors at major universities regarding the problem. He accepts that
recent studies show a Multitude of adverse health effects In children
associated with blood lead levels greater than 10 micrograms per deciliter.
He Is aware that the clean-up proposed by the EPA Is not aimed at reducing
soil lead levels to those thought to be necessary to reduce the blood lead
levels of~ch1ldren below 10 micrograms per deciliter, and he questions whether
the EPA proposed clean-up will be fully protective or leave large number? of
children at risk to lead poisoning. He urges EPA to begin an Immediate testing
of all locations in the area where children play and inform parents as to the
dangers that exist there.
U.S. EPA Response: This resident has also learned of a report being
prepared by the Society for Environmental Geochemistry and Health (SEGH) Task
Force on Lead in Soil and believes that the report to be released this summer
will give further input on this problem. He requests that EPA refrain from
making a decision on the soil clean-up level until that report is released.
At present, the National Centers for Disease Control (CDC) has
determined that blood lead levels equal to or greater than 25 micrograms per
deciliter represent a reason for concern. CDC is now considering a level of
15 micrograms per deciliter to protect for the health effects seen at lower
blood lead levels. EPA has also adopted this "action level" for the purpose
of the clean-up at Granite City because the significance of changes seen in
children at blood lead levels below 15 micrograms per deciliter are not yet
understood. The EPA is the funding agency for the SEGH Task Force on Lead in
Soil, whose report will probably be made public at the SEGH Meetings to be
held in Cincinnati in July. However, the study by the the SEGH Task Force is
just one of many efforts currently underway to delineate the impact of lead in
various media on the health of young children. The SEGH Task Force on Lead
has recommended the use of a lead soil matrix formula, which will allow a
variety of environmental factors to be considered in the development of a
site-specific evaluation of lead hazards. Another tool, the Lead
Uptake/Biokinetic Model, is also under evaluation and is expected to be
released to the EPA Regions in April 1990. The Biokinetic Model is expected
to fill the deficit caused by the withdrawal of a reference dose to assess the
health effects of lead. The model is more fully described in the position
paper on lead presented in Appendix B. When site-specific data collected in
Granite City and a soil lead level of 500 ppm is input into the Biokinetic
Model, a mean blood lead level of 8.37 micrograms per deciliter is predicted,
with approximately 8.5 percent of the children predicted to attain blood lead
levels greater than 15 micrograms per deciliter. EPA believes that the clean-
up level of 500 ppm lead in soil 1s appropriate because further reductions in
food lead levels are anticipated due to the removal of lead-containing soils
and to the reductions 1n allowable releases of lead to the air and in the
water expected from changes to the National Ambient Air Quality Standard and
the National Primary Drinking Water Regulations later this year.
H4: We also received a comment from Bobby G. Wixson, Dean of the College
of Sciences, Clemson University, South Carolina; He 1s one of the professor*
-------
I
solicited by the above Granite City resident and the Chairman of the SEGH TasR'
Force*on Lead In Soil. He stressed that the task force remains convinced that
a matrix approach to a site-specific location and population at. risk be used
rather than a single number or abatement approach applied to all sites, and he
provided a copy of the May 1989 presentation on the status of the SEGH Task
Force In which the matrix approach was presented. He voiced a concern that
Region V not adopt a 500 ppm lead 1n soil level as an Interim guideline
without knowledge of the target blood lead soil matrix model. He advised that
the clean-up level Bight actually be higher or lower than 500 ppm 1f based on
the health criteria used to derive the SEGH model.
U.S.EPA Response: While the Interim Guidance on Establishing Soil Lead
Cleanup Levels at Superfund Sites (OSWER Directive f 9355.4-02) sets forth an
interim soil clean-up guideline for total lead in soil at 500 to 1,000 ppm, it
also allows that "site-specific conditions may warrant the use of soil clean-
up levels below the 500 ppm level or somewhat above the 1000 ppm level". This
latter clause has recently been used to set a residential soil clean-up level
at 250 ppm in another region. The use of the SEGH Task Force matrix model is
one method for achieving a site-specific guidance level for clean-up.
However, recent and frequent conversations with the EPA Office of Research and
Development concerning this matter indicate that the model favored by that
office is the Lead Uptake/Biokinetic Model, which has already been largely
validated. When site-specific data from the NL/Taracorp Superfund site are
used in that model, a cut-off soil lead level of 500 ppm can be shown to be
appropriate for the Granite City site clean-up. Actual parameter values used _
in the model can be found in Appendix B.
H5: We received one comment from a Granite City resident who had
chronicled a history of multiple deaths due to cancer and heart disease in her
family and in her husband's family. She expressed a concern that this history
of disease was directly tied to the lead and other foreign particles in the
air and in the ground in the area. She believes that "there is a clear and
present danger" due to the lead in the soil and urges that the EPA clean-up
project begin immediately.
U.S. EPA Response: This resident's concern that this history of family
Illness is related to the lead and other foreign chemicals in the air and in
the ground is probably warranted. One of the primary concerns of the EPA is
that residents of highly industrialized areas are exposed to a complex mixture
of toxic chemicals, which can enter their bodies from the air, water, contact
with soil and food products. In addition, personal habits such as smoking and
over-eating, genetic factors, and exposures received in the workplace further
predispose the body to diseases such as cancer. With so many factors
operating to cause some types of cancer, it is difficult to trace any
particular Incidence of cancer 1n this resident's family to a single cause
without careful documentation. However, the concentration of toxic pollutants
in the air, water and soil have sometimes reached very high levels In the
past. The EPA has strived in recent years to reduce the levels of such
pollutants and their related health effects. In Granite City, we will
continue to pursue whatever clean-up is necessary to reduce the danger to
these residents from exposure to lead in the soil, and we will make every
effort to move forward with this clean-up with expediency.
-------
-6-
H6: -We received a comment from the Illinois Department of Public Health,
which offered four point? for consideration. Their primary concern is that
they have been told that a risk assessment could not be performed at the
NL/Taracorp Superfund site because an EPA verified Reference Dose for lead is
unavailable, and they object to that premise. Secondly, they question the use
of a generic clean-up level 1n the range of 500-1,000 ppm lead in soil ,
arguing that this is a CDC generated level and CDC itself has often not
recommended soil removal until the lead level reaches levels as high as 5,000
ppm. They argue that the use of a generic clean-up level sets a dangerous
precedent which allows IDPH to propose multiple other sites in the area for
inclusion on the Superfund list. They go on to suggest that biomonltoring of
the population in the form of repeated blood lead level testing of area
children, testing of domestic animals (dogs and cats) residing in the area,
and such could be used to resolve the issues of risk assessment and clean-up
objectives, and they urge that a carefully designed and implemented
biomonitoring program be instituted in Granite City. Their final comment
addresses the perceived need for an educational effort to answer questions
raised by citizens and urges that an integrated joint effort between agencies
be used to answer citizen concerns.
U.S. EPA Response: The concern that a traditional Superfund structured
risk assessment cannot be prepared for the NL/Taracorp site has already been
discussed in the response to the comments from ML Industries (HI) and the Tri-
Cities Chamber of Commerce (H2). Region V agrees with the rationale that a
generic clean-up level should not be used at any Superfund site, and that
site-specific factors such as populations at risk, bioavailability, etc.
should be considered in setting such clean-up levels. The comments and
responses presented in H3-H5 and in Appendix B suggest the approach that EPA
believes is reasonable to address this concern. EPA strongly disagrees with
the premise that the clean-up at hazardous waste sites should be limited
because such a clean-up may set a precedent for the potential clean-up of
other areas which have become contaminated through other routes. EPA
recognizes that there may be other lead contamination problems in Illinois,
and encourages that other such sites be identified and assessed for inclusion
on the NPL. This, however, is not a comment that is specific to the
NL/Taracorp site. Clean-up levels below 500 ppm have been accepted at other
sites. In response to the third comment set forth by IDPH, EPA Is not adverse
to the biomonitoring of sensitive populations exposed to soil lead in the
Granite City area and suggests that women of child-bearing age as well as
children under the age of six be especially targeted for a biomonitoring
program. A blood lead study has been added to the selected remedy in response
to public comments. However, EPA believes that the soil lead levels at the
NL/Taracorp site represent an present and on-going hazard to these segments
of the population and is reluctant to postpone any remedial activities in
favor of a data-gathering endeavor. IDPH's suggestion that an educational
effort 1s needed to address dtized concerns is a good one. EPA has already
delivered, door-to-door, one Lead Guidance Fact Sheet to residents in the area
and has begun the preparation of more complete guidance to be distributed
before the summer season when children face the greatest exposure to lead in
soil. EPA would welcome input for inclusion in this latest flyer. By
distributing this Information early, EPA hopes to keep soil Ingestion and
thus, blood lead levels at a minimum during the period required for further
soil'sampling and the development of the soil removal activities.
-------
-7-
Technical
Ti. Two oconenterB sent U.S. EPA information regarding the locations of
other areas around the site where battery case material
potentially came to be located.
- U.S. EPA Response: U.S. EPA thanks these ccranenters for providing very
..^.useful information. Appropriate follow-up will be taken in these areas.
T2. One ccnmenter requested that material submitted to U.S. EPA be
included in the Administrative Record for the site.
U.S. EPA Response: The material was placed in the Administrative Record for
the NL site, and where appropriate, background information regarding Trust
454 was corrected, as stated in the material submitted.
T3. Four commenters stated that Alternative A (No Action) is the only
alternative having any merit and that further studies are needed before
any action is taken.
U.S. EPA Response: Alternative A-No Action is inappropriate due to the fact
that waste materials and soils which may pose a risk to human health and the
environment would be left in place without any treatment and that it does
not comply with all applicable federal and state laws. U.S. EPA feels that a
cleanup level of 500 parts per million (ppm) will be protective of the
public health in the area of the NL site. Lead levels in residential areas,
the Taracorp pile, and St. Toms lead Recyclers piles range from 1% to 30%,
which is 10,000 ppm to 300,000 ppm lead. It is unacceptable to take no
action when people nay be exposed directly to lead concentrations of this
magnitude. Additionally, allowing the Taracorp pile and St. Tniis Trt
Recyclers (SLLR) pile, both of which contain characteristic hazardous waste,
to remain uncovered is not in compliance with the Resource conservation and
Recovery Act (RCRA). It is not necessary to conduct further studies before a
remedial action is selected for this site. Data gathered during the Remedial
Investigation are sufficient to indicate that a lead contamination problem
exists at and around the NL site, and available guidance and national and
site-specific lead data are sufficient to select a residential lead cleanup
level for the site. However, further studies, including a blood lead study
and extensive soil sampling will be undertaken during the design of the
selected remedial action to provide residents with current blood-lead
information and to determine exactly which areas must be excavated and to
what depth.
T4. One commenter supported the selection of Alternative H and questioned
whether residents would be made aware of the results of soil sampling
conducted on their properties.
-------
-8-
U.S. EPA. Response; U.S. EPA acknowledges and appreciates the support for
Alternative H. The selected remedy is Alternative H, with five elements
added as listed in response to ccuuient T9. Results of soil sampling to be
conducted as part of the selected remedy will be made available to the
specific residents as well as the community at large.
T5. Three commenters recommended that Alternative G be selected to
remediate the NL Site.
U.S. EPA Response: There are advantages to Alternative G, namely the
complete removal of all contaminated areas from the Granite City area, which
also would remove the vast majority of waste ma
-------
-9-
indicating a recent national trend toward more stringent soil lead cleanup
levels. The ccmnenter is cai'imjt in stating that each site for which a ROD
was reviewed has a unique set of conditions and that a direct nrnrarigri of
these sites to the NL Site was not possible.
T6b. Section V of the ooanent letter is entitled "Alternative H is neither
Cost Effective Nor Technically Feasible11. Paragraph A comnents on the
cost estimate.
The <» """"uter is correct in stating that U.S. EPA's $25 »
-------
-10-
range of tine (1 1/2 - 2 1/2 years) presented in the Propoood Plan. The
elements added to Alternative H as a result of public oconents will not
change this tine estimate tor construction.
T6d. Paragraph C of Section V ccoments on the technical infeasibility of
implementing Alternative H.
As part of the selected renaady, additional yrmaezty must be acquired, or the
material must be H*»^pnnnrt Of off-site Trust 454 property is better suited far
the expanded Taracoxp Pile since only a snail portion of Trust 454 that would
be needed for the pile would be at the outer edge of the 100 year flood
plain. The affected area on Trust 454 is not in the "flcodway", so no
additional permits would be required; it is, however, at the very edge of the
portion of the 100 year flood plain which is narked as "minimal flooding*1.
From the nap, it appears that during a 100-year flood event the water would
come right up to the edge of the expanded Taracorp pile, as it would to the
existing Taracorp pile and the SUR piles. If necessary, barriers could be
built around the south and west sides of the expanded pile; however, even
without barriers it does not appear that a 100 year flood event would harm
the integrity of the cap or result in any threat of releases into the
environment.
The Commenter is correct in stating that the soil lead sampling done to date
is not sufficient to delineate all areas around the site requiring
remediation. Additional sampling will be performed during Remedial Design to
provide this information. The figure identifying areas 4 through 8 in the
Proposed Plan represents only a best estimate of areas requiring remediation
based on data gathered to date.
T6e. Section V is entitled "Alternative H's Increased Risk to Residents and
Adverse Impacts on the OcBBunity and the Environment Are Not Justified
by the Minimal Protection it Provides."
U.S. EPA disagrees with this statement and the conclusions drawn in this
section, with the exception that truck traffic involved in implementing
Alternative H increases the risk of traffic accidents, as compared to
implementing Alternative D. U.S. EPA has analyzed the short-term impacts
involved with implementing Alternative H (i.e. removing approximately 112,000
cubic yards of contaminated soils from an estimated 58 city blocks) as part
of the analysis of the nine criteria. Proper wetting of soils and
construction and transportation procedures can be employed such that visible
dust emissions will be prevented and adverse impact to the community will be
minimal. The technology, equipment, and procedures exist to do this
effectively. U.S. EPA recognizes the short-term impacts involved in
implementing Alternative H and feels that the benefits resulting from the
removal of soil contaminated with lead above 500 ppm outweighs these
potential impacts. U.S. EPA also feels that implementing Alternative D is
..inappropriate since Alternative D allows large quantities of lead
contaminated soil with concentrations above that tfoich nay cause an adverse
public health impact (i.e. above 500 ppm) to remain in place. -The elements
added to Alternative H as a result of pjblic oconents will not significantly
impact the above response. Oily the potential additional excavation in
Venice, Eagle Park Acres, and other nearby communities will increase truck
traffic, however, this increase is estimated to be
-------
-11-
T7. One ocnmenter was concerned about future blood lead testing and past
IDPH blood lead testing, emissions during construction, the length of
tj"«* it took to get: information to the public about the contamination
problem at the site, and further soil testing prior to excavations.
U.S. EPA Response: The results of soil lead testing were released to area
residents in 1988, prior to the release of the RI Report. The RI Report was
released in early 1989. An availability session was held in October 1988 to
the results of soil lead testing with residents. Although several
local politicians attended, no residents cane. During this public cximieitL
period U.S. ERA discovered that using the local newspaper and other mpriia
does not effectively disseminate information in the affected communities
around the NL/Taracarp Site. Information was provided effectively by handing
out fact sheets door-tc-door, and this practice will continue in the future.
So, although the information provided in January 1990 nay seen relatively
new, U.S. ERA has been providing information through the mpriia as it has
available.
U.S. EPA cannot provide a response for the Illinois Department of Public
Health (IDPH) regarding its conduct of a blood lead study in 1982; however,
in response to public comments received, U.S. EPA has added the requirement
for a blood lead study to the selected remedy. The study will be performed
by or in consultation with IDPH during the summer of 1990 and will be
designed to provide current information on potential health effects
associated with site contamination. Blood lead testing is the most effective
means available to determine whether acute effects due to lead contamination
may exist in the community.
Dust control measures included in the selected remedy will be implemented
during construction activities. These measures, which will primarily consist
of applying water to soil to be excavated, will be employed to prevent
visible emissions of dust and will minimize any adverse health effects
arising during construction.
Regarding aHHi«-irrai soil sampling, the selected remedy includes extensive
sampling of each yard in the suspected zone of contamination and all
applicable alleys, driveways, and yards in Venice and Eagle Park Acres to
determine exactly which areas must be excavated and the extent of excavation.
This will be performed before excavation begins.
T8. one Commenter expressed support for Alternative H and asked if any or
all houses will be demolished as part of the selected remedy.
U.S. EPA Response; U.S. EPA acknowledges and appreciates the support for
Alternative H. No demolition of houses will be performed as part of
Alternative H, the selected remedy.
T9. Three commenters expressed concern over the negative economic impact
the selected remedy will have on the surrounding areas, including
. problems with the resale of property in the zone which has been
"contaminated11.
-------
-12-
U.S. EPA Response; U.S. EPA can understand the concern citizens have for the
resale value of property in the "contaminated zone," as well as the economic
impact the selected remedy could have on the surrounding areas. The U.S.
EPA must, however, consider risks to human health and the environment from
the contamination to be our top priority in addressing this Superfund Site.
Bear in mind that the contamination exists no matter what remedy is selected;
it is, in fact, the contamination, not the cleanup, that is the true culprit
in terns of any real or perceived stigma resulting in lowered property
values or "negative fmmnaric impacts. The selected remedy will result in a
cleaner, healthier living environment in the affected areas, particularly in
light of the fact that there will not be a continuing source of airborne
contamination, and the residential properties will be left with the same or
better appearance than they currently have. This should ultimately result in
increased property values. Although the Taracorp pile will remain in place
and be expanded, after the cap is completed, it will be less of an eyesore
and less of a threat to human health and the environment than it has been all
the years it has been part of the Granite City landscape.
T10. Two conmenters expressed concern about whether public comments would
have any bearing on U.S. EPA's final decision on the selected remedy.
U.S. EPA Response: U.S. EPA appreciates the comments it has received
regarding its Proposed Plan for cleanup of the NL/Taracorp Site. Five
elements have been added to Alternative H as a result of public comments
(Alternative H, as amended by the addition of these five elements, is U.S.
EPA's selected remedy):
1. Blood lead sampling to provide the comunity with current data on
potential acute health effects associated with site contamination, to
be conducted in summer, 1990,
2. Inspection of the interiors of homes on property to be excavated, to
identify possible additional sources of lead exposure and recommend
~ Doprxate actions to pininn*^ exposure,
3. Inspection and remediation of additional areas of contamination in
Eagle Park Acres, Venice, Granite City, and Madison which were not
identified in the draft FS Report, and
4. Development of contingency measures to provide for sampling and proper
disposal of any soils within the zone of contamination with lead
Ttraticns above 500 ppm which are presently capped by asphalt or
other barriers but become exposed in the future due to land use
changes or deterioration of the existing use.
5. Construction of a bottom clay liner under newly constructed portions
of the expanded Taracorp pile.
Til. One commenter listed a series of questions which are answered below.
Qt- What level of lead is in site area 18 and how much direct
contact would it take to become dangerous to my health?
-------
-13-
R: The lead levels in site area §8 range from just over 500 ppm to
approximately 2500 ppm. It is not possible to determine how much
direct contact it would take to become dangerous to the ocnmenter's
health.' Each individual has a different reaction to lead exposure.
U.S. EPA has selected the 500 ppn cleanup level to be protective of
sensitive individuals.
Q: Can I send a sample of my yard and have it tested?
R: Each yard which nay require cleanup will be tested to determine the
depth of excavation required. This test is anticipated to begin in
early 1991, so the commenter's yard will be tested then. It may be
possible to arrange for sens limited testing prior to that tHm» for
persons who want to have information prior to 1991; however, nothing
has been planned at this time.
Q: Would the residents be allowed to stay in their hones during
rtruction?
R: Yes
Q: Would U.S. EPA have to tear up fences to remove the soil?
R: No, shovels would be used for excavating tight spots, such as fences
and along driveways and foundations.
Q: Would tmes be damaged by this soil removal?
R: We do not expect any trees to be damaged; however, some shallow roots
may be slightly damaged. The excavation would be implemented in a
manner tO
Q: After work completion, would realtors have to mention anything to
potential buyers in the area?
R: Yes, under the Illinois property transfer laws, the prior
contamination of the property will be documented; however, the cleanup
will be also be documented, and this will indicate to potential buyers
that the property has been cleaned up to levels which are considered
protective of public health.
Q: When would the work start?
R: It is projected that actual excavation activities would begin in
later 1991 or early 1992.
T12. One cconenter expressed criticism of Alternative H.
U.S. EPA Response: No response is really necessary since no reasons
for the criticism were outlined. U.S. EPA appreciates the comment.
T13. One cconenter stated that an independent firm should conduct testing to
determine the scope of soil contamination before any more hysteria is
created without facts.
-------
-14-
U.S. EPA response: Testing conducted to date clearly Indicated that there
is a soil lead contamination problem at and around the Nl/Iferaaarp Site.
Further soil testing will be required to determine which yards must be
excavated and to what depth. U.S. KE& regrets any hysteria that Bay have
been created during the remedy selection process. Throughout the ptvrmuu,
47.S. EFA has clearly stated that the situation at the NL site is not an
•faiinjmry situation but that cleanup is required to prevent potential chronic
-health effects that Bay arise from exposure to contamination at and around
the site.
T14. One commenter supported Alternative D, propoood that residence located
within the 10004- ppm zone be purchased, razed, excavated, and that the
areas be rezoned as ormmRrcIn]; stated that work should < > im^'i ie as
soon as possible; and supported the conduct of a blood lead study prior
to the ocDDenoement of any work at the site. Another oommenter
supported Alternative D and submitted a petition with approximately
300 signatures.
U.S. EPA Response: Alternative D is not acceptable because soils and battery
case material B containing lead concentrations above levels which may present
a risk to public health are allowed to mm in in place under Alternative D.
This is not an acceptable situation.
Razing and excavating homes is not appropriate. The area can be cleaned up
to levels which will be protective of the public health without creating such
a major disruption to the residents who live there and without such a high
cost. The idea of rezoning certain areas as «i««ii»»»ivM«i is interesting but is
not within the realm of U.S. EEA's authority, and problems exist with this
due to potential disruption of residents who prudently live there and the
fact that the areas will be cleaned up to protective levels under the
selected remedy, Baking rezoning potentially moot.
U.S. EEA will expend every effort to onimmp work as soon as possible.
A blood lead study has been added to Alternative H as part of the selected
remedy; however, set Ling soil lead cleanup standards from a blood lead study
is not appropriate, for I****>
-------
-15-
residential areas are present around the site, to select the 5OO pom cleanup
level.
Capping, as outlined in Alternative B, is not appropriate for residential
areas around the site because soil with lead concentrations above levels
which may present a risk to public health are allowed to regain in place and
can easily become expoood in the future due to gardening, excavation, etc.
It is impossible to ensure the integrity of the cap in each residential yard,
and removal of the contaminated soil is more protective and appropriate.
Capping will also raise the elevation of all capped areas, which nay present
runoff/erosion problems. Along with monitoring and institutional controls,
capping is appropriate for remediation of the expanded Taracorp pile and
included in the selected remedy for that reason.
T16. Cne ccnmenter stated that: 1) all actions on 'the NL site cleanup
proposals be put on hold until blood lead testing is conducted on
residents in the designated areas, 2) U.S. EPA has caused severe
economic problems for landowners and the City of Granite City,
Illinois through inadequate studies and their subsequent release to
the public, and 3) the IDFH blood lead study of 1982 did not indicate
elevated blood levels in the residents tested.
U.S. EPA Response; Statements 1) and 2) of this comment have been addressed
in the response to comments T14 and T9, respectively. The IDPH blood lead
study of 1982 did indicate elevated levels in the residents tested and, by
the present standards used by toxicologists to evaluate health risks,
indicated that some of the residents tested had blood lead levels which would
present a health risk. U.S. EPA has questioned the usefulness of the IDPH study.
-------
Ll. Comment: Several questions were raised concerning the
impact of the clean up on A t K Railroad. The railroad is
located near the Site. The commenter believes alternative H
should be chosen, with modifications to include industrial areas
such as A & K Railroad. The commenter asks (1) who is liable for
contamination placed on a site before its present ownership, (2)
whether-U.S. EPA has jurisdiction over industrial areas located
within a Superfund Site, (3) what government agency regulates the
health and safety of a company's employees, and (4) what federal
government agency should address concerns about toxic levels in
the soil, water, and air found at an industrial plant site.
Response: The scope of liable persons under the Superfund
law is discussed at 42 U.S.C. §9607(a)(CERCLA §107(a)). Persons
liable include but are not limited to the present owner of a
facility, the owner or operator of a facility at the time of
disposal of a hazardous substance, any person who arranges for
the disposal or treatment of hazardous substances owned or
possessed by such person, and any person who accepts hazardous
substances for transport to disposal or treatment facilities.
CERCLA Section 107(b) lists three exceptions to the scope of
liability discussed in Section 107(a). The exceptions include
(1) an act of God, (2) an act of war, and (3) acts or omissions
of a third party. The third defense, however, requires that due
care was taken by the party using the defense with respect to
the hazardous substance concerned. The party using this defense
must have also taken precautions against foreseeable acts or
omissions of any such third party and the foreseeable
consequences from such acts or omissions.
A Superfund site may include any area, industrial or
otherwise where a hazardous substance has been deposited, stored,
disposed of, placed, or otherwise come to be located. 42 U.S.c.
{9606 (CERCLA §106) grants authority to the Attorney General of
the United States to secure such relief as may be necessary to
abate the danger of an actual or threatened release of a
hazardous substance from a Superfund site.
The Department of Labor is the federal government department
which regulates the health and safety of employees. The U.S.
EPA, in cooperation with the State Environmental Protection
Agency, is the federal agency which addresses concerns about
toxic levels of substances in the soil, water and air.
L2. Comment: One commenter challenged both U.S. EPA's selection
of alternative H as the appropriate remedy and also U.S. EPA's
selection process. The commenter raised concerns that the remedy
will cost more than U.S. EPA initially estimated, the remedy will
require additional property to dispose of residential soils,
short term dangers of choosing alternative H may outweigh the
-------
-17-
advantages of alternative D and were not properly considered, and
the potential disruption of the community was not properly
evaluated by U.S. EPA. The commenter estimates the cleanup may
cost $40 Billion. The estimate is based on the belief that U.S.
EPA underestimated the need for either the purchase of additional
property or off site disposal of wastes.
Concerns were also raised regarding U.S. EPA's selection
process. The commenter believes U.S. EPA did not properly notify
affected-parties of the public comment period and U.S. EPA's
increased cost estimates for the site, relied on general guidance
to determine cleanup levels rather than site specific
information, and has failed to offer a better alternative to the
risk assessment conducted during the remedial investigation by NL
Industries which was rejected by U.S. EPA.- The commenter
recommends a new, binding risk assessment, raises the possibility
of conducting blood lead studies in the affected area, and
requests an extended public comment period to evaluate revised
proposals.
Response: The commenter's concerns regarding the additional
public benefits of choosing alternative H over other alternatives
and the cost estimates for alternative H are addressed in
response to comment T6.
Affected parties have been properly notified of U.S. EPA's
actions throughout the remedy selection process. On December 18,
1989, U.S. EPA conducted an informational meeting to inform
potentially responsible parties of available site information.
All identified FRPs were notified of the meeting. Information
discussed at the meeting included the proposed cleanup standards
being considered by U.S. EPA. The meeting informed the PRPs of
where U.S. EPA was in the selection process and gave all parties
an anticipated time frame for the public comment period, a public
meeting to be held in Granite City, Illinois, and the scheduled
date for this Record of Decision. Public notice was subsequently
given for both the public comment period and the public meeting
held in Granite City. U.S. EPA agreed to meet with all parties
who requested meetings with U.S. EPA during the selection
process. In addition, four availability sessions were conducted
in Granite City to further inform the public about the site and
respond to any concerns. U.S. EPA extended the final date of the
public comment period from February 24, 1990, to March 12, 1990,
in response to the strong public interest in the site. The
extension was made.without any formal requests for an extended
public comment. Little interest has been shown for an
additional extension to the public comment period. U.S. EPA does
not believe an additional extension is appropriate at this time.
U.S. EPA revised its cost estimate for site cleanup after release
of the proposed plan for the site. An addendum was added to the
proposed plan with an updated cost estimate. The addendum was
placed with the proposed plan in the public repository for site
documents and was send with the proposed plan in all freedom of
-------
-18-
infomation request responses. U.S. EPA has shared its revised
cost estimates as soon as they were available with all parties.
The revised cost estimates were given at the public meeting in
Granite City, in meetings with local officials, at availability
sessions in Granite City, and were reported in the press. Cost
estimates were also shared in numerous phone calls both before
and after the public meeting.
The commenter's recommendation for a blood lead study has been
incorporated into this Record of Decision. However, a second
risk assessment would not add additional, useful information to
the remedy selection process for the same reasons U.S. EPA
rejected the initial risk assessment. The validity of a risk
assessment depends on the reference dose used to evaluate risk.
At this time, the selection of any reference dose would be
arbitrary for the reasons discussed in Appendix B.
-------
ADMINISTRATIVE RECORD INDEX
ML 1NDUSTR1ES/TARACORP
GRANITE CITY, ILLINOIS SITE
1.
DATE
3/11/65
TITLE 7 DOCUMENT TYPE
tl/FS
Concent Order
CONTENTS
Sane as Title
PA;;;
2.
Vari ous
Access File
N/A
RI Access Agreements
and Summaries
7S.
3.
Vari ous
Access file
N/A
Rl-Phase I! Access
Agreement s
4 .
May 1986
"Rl/FS
Uork Plan"
O'Brien I Cere
RI/Fs Work Plan/
OAPP/Safety Plan
5.
7.
5/6/87
5/20/87
5/26/87
Memo to
Jerri Carl, U.S. EPA
R 1 Pre I i mi nary
Results
Letter to
Brad Bradley
Brad Bradley,
U.S. EPA
0'Bri en i Cere
Ken Mi I ler.
IEPA
Request for review
of we I I Ioc at i ons
Same as Title
IEPA Comments on
RI/FS Work Plan
Addendum
6.
6/16/87
Letter to
Stephen Holt.
NL Industries
Brad Bradley
U.S. EPA request for
and comments on
Work Plan Addendum
9.
7/10/87
Revised Work
Plan Addendum
Stephen Holt,
NL Industries
Same as Title
10.
September
1988
"RI Report*
O'Brien i Cere
Same as Title
405
11.
1/10/89
12.
13.
2/8/89
April 1989
RI Report
Addendum
Meeting Notes
"Alternat ives
Development Report"
Brad Bradley
•rad Bradley/
O'Brien I Cere
O'Brien I Gere
Letter approving
and stat i ng
necessary changes
to R! Report
NL Presentation
of leaedial Response
Objectives at aieeting
Alternatives Array
for the cite
-------
u.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
DATE
7/15/85
7/24/85
7/30/85
8/19/85
8/23/85
10/21/85
10/24/85
11/25/85
12/11/85
12/17/85
12/20/85
1/14/86
2/4/85
5/6/86
TITLE / DOCUMENT TYPE
Letter to W.K.
Weddendorf, ML
Industries
Letter to W.K.
Weddendorf. ML
1ndustr ies
Letter to W.K.
Weddendorf. NL
Industri es
Letter to W.K.
Weddendorf. NL
Indus tries
Letter to
Frank Hale,
OB i C
Letter to U.S. EPA
•nd IEPA
Letter to Frank Hale
Letter to W.K.
Weddendorf
Letter to W.K.
Weddendorf
Letter to W.K.
Weddendorf
Letter to Brad Bradley
Letter to U.S. EPA and
IEPA
Letter to U.S. EPA and
IEPA
Meaio to file
2
AUTHOR
John Hooker,
IEPA
John Hooker,
IEPA
Neil Meldgin,
U.S. EPA
Neil Meldgin,
U.S. EPA
W.K. Weddendorf
W.K. Weddendorf
W.K. Weddendorf
John Hooker
Brad Bradley
Brad Bradley
John Hooker
w.K. Weddendorf
W.K. Weddendorf
Brad Bradley
CONTENTS
Comments on RI/FS
Work Plan, Safety
Plan
Consents on OAPP
Comments on RI/FS
Work Plan
Comments on QAPP
Transmittal letter of 13
U.S. EPA and IEPA
RI/FS Work Plan and
QAPP Comments
Response to U.S. EPA
and IEPA RI/FS Work
Plan and QAPP comments
RI Soil Sampling 4
Program Discussion
RI/FS Work Plan, QAPP 2
Safety Plan Comments.
RI/FS Work Plan 2
Safety Plan Comments
RI/FS Work Plan 4
Safety Plan Comments
RI Sampling Parameters 2
RI/FS Work Plan Comment 2
Timeframes
Re»pon»e to U.S. EPA and 23
IEPA coMents on RI/FS
Work Plan
Summary of 2/27/86 3
meeting between U.S.
EPA/IEPA/NL Industries
-------
28.
29.
30.
31.
32.
33.
35.
36.
37.
38.
39.
40.
41.
PATE
3/4/86
3/24/86
5/12/86
15/86
6/26/86
7/30/86
8/29/86
11/4/86
12/15/86
4/9/87
4/24/87
10/30/87
12/30/86
3/11/88
TITLE / DOCUMENT TYPE
Letter to Bred Bradley
Letter to frank Hale
Memo to file
Letter to w.K.
Weddendorf
Letter to Stephen
Not t, NL Indust r i es
Letter to Stephen Molt
Letter to Oavid
Hill. O'Brien I Cere
Letter to U.S. EPA
•nd 1EPA
Letter responding to
Holt's 11/4/86 letter
Letter to Stephen Holt
Letter to Stephen Holt
Letter to Stephen Holt
Memo to Norman
Miedergang, U.S. EPA
Letter to Stephen Holt
U.K. Ueddendorf
Brad Bradley
Brad Bradley
Ken Miller
Brad Bradley
David Payne,
U.S. EPA
Stephen Holt
Brad Bradley
Brad Bradley
Ken Miller
Brad Bradley
Cavid Payne,
U.S. EPA
Brad Bradley
CONTENTS
••vised RI/FS Work
Plan Comments
Summary of changes
necessitated by 2/27/86
•eeting
Summary of U.S. EPA/
IEPA/NL Industries
4/9/86 QAPP Conference
Call
Approval to commence
RI Tasks 1 and 2
Comment on May 1986
RI/FS Work Plan
Approval of May 1986
RI/FS Work Plan
Requirements for OA
Performance Evaluation
Samples
RI Field Work Time
Frames
Same as Title
Parameters to be
analyzed for in
groundwater in 2nd
Quarter for RI
Oat* Reporting
Requirements
for RI Samples
Approval for RI/FS
Work Plan Addendum
Performance Evaluation
Sample Analysis
Comments en Draft
RI Report
19
43
-------
42.
43.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.
55.
PATE
5/20/86
5/27/88
6/6/88
8/18/88
8/18/88
8/24/88
9/7/88
11/4/86
11/30/88
12/U/88
12/16/88
12/16/86
2/1/89
6/23/89
TITLE / DOCUMENT TYPE
Letter to Stephen Holt
Letter to Stephen Molt
Letter to U.S. EPA and
IEPA
Letter to U.S. EPA and
IEPA
Letter to U.S. EPA and
IEPA
Letter to Stephen Molt
Letter to Frank Hale
Letter to Stephen Holt
Letter to U.S. EPA
IEPA
Letter to Irad Bradley
Letter to U.S. EPA and
IEPA
Letter to irad Bradley
Letter to Stephen Holt
Lttttr to Stephen Holt
AUTHOR
•rad Bradley
frank Hale
Stephen Holt
frank Male
Frank Hale
Brad Bradley
Brad Bradley
Brad Bradley
Stephen Holt
Bonni Kaufman
Donovan, Leisure,
Newton t I rvine
Bonni Kaufman
Donovan, Leisure
Newton ( Irvine
Ken Hi Her
•rad Bradley
•rad Bradley
CONTENTj p>GES
Timeframes for 3
additional
II Soil Analyses
Analysis of Additional 2
Soil Sasiples
Soil Analysis and Final 2
RI leport Tine Frames
Draft HI Report 5
Risk Assessment Defense
RI QA Data Review 3
Comments
Final RI Report
Submission Schedule
Approve I
Risk Assessment
Criticism Letter
Necessary Changes to
Final RI Report
Time Frame for NL
Industries Response
to 11/4/88 Bradley
letter
Time Frames for NL
Industries Response
to 11/4/88 Bradley letter
NL Industries Response 23
to 11/4/86 Bradley letter
IEPA Comments on U.S. 2
EPA Procedures for
Finaliiing RI Report
Final Agency Action on 6
Final II Report •
Comments on Alternatives' 4
Array Document I
-------
•5-
DATE
TITLE/DOCUMENT TYPE
CONTENTS
PACES
56. 10/26/89
Letter to Stephen Holt
Frank Hale
Areas Targeted for
Remediation
57. Various Bi-Monthly Progress
Reports
Stephen Holt
Same at Title
66
58. 5/28/85
Letter to U.S. EPA
and 1EPA
U.K. Weddendorf
Statement of NL
Industries Project
Coordinator
59. 4/13/89
"Cincinnati Soil Lead
Demonstration Project"
University of
Cincinnat i
Same as Title
60. April 1983 "Study of Lead Pollution
in Granite City, Madison
and Venice, Illinois"
IEPA
Same as Title
61. September "A Land Pollution Assessment IEPA
1984 of Granite City/Taracorp
Industries"
Same as Title
62. 7/16/86
Letter to Frank Hale
Robert Crawford,
Galena Industries
Lead Recovery
Method
63. 2/10/87
64. 2/24/87
65. 6/12/86
Letter to Steve Holt
Letter to Sue Doubet,
IEPA
Marble Lead Works
Preliminary Assessment
Ken Mi Her
John Coniglio,
Envi rodyne
Engineers
Richard Lange,
IEPA
Monitoring We I I 25
Boring Logs
RI grounduater 12
Duplicate Sample Date
Same as Title
18
66. 4/26/88
67. 4/25/88
Letter to Stephen Holt
Letter to Brad Bradley
Ken Miller
Ken Miller
Transmittal of Illinois 160
Dept. of Public Health
Soil Sampling Results
and Lead health effects
papers
Transmittal of Illinois 12
Water Survey Data on
Wei Is near the site
-------
•6-
DATF TITLE/DOCUMENT TYPE
68. 1/18/89 "Preliminary Health
Assessment for ML
Industries/Taracorp
lead Site"
CONTEXTS
Agency for
Toxic Substances
and Disease Registry
Same as Title
PACES
6
69.
70.
71.
72.
9/7/89 "Interim Guidance
on Establishing coil
Lead Cleanup levels
at Super fund Sites"
October 1989 "Internalionl Lead
Zinc Research Organization
Environmental Report"
5/13/85 Letter to Stanton Sobel,
Taracorp, Inc.
3/5/87 Letter to Stephen Holt
Henry Longest
U.S. EPA
Sames as Title
U.K. ueddendorf
Same as Title
Same as Title
File Request
Basil Constantelos, SARA Summary
73. 8/24/88
74. 8/30/89
75. Various
76. April 1988
77. 3/27/84
78. Various
79. Various
U.S. EPA
Letter to Stephen Holt Brad Bradley
Letter to Stephen Holt Ken Miller
OA Data Review File Various
"Title 35: Environmental I EPA
Protection Subtitle C:
Water Pollution"
MRS Scoring Package U.S. EPA
Community Relations Various
File
RCRA File Various
Letter .
RI/FS Guidance
Transmi ttal
letter
Well Survey
Transmittal
Letter
Same as Title
1 1 1 inois
Regulations
Same as Title
Community
Relations
Plan, Fact
Sheet, etc.
Part A Pernit,
•SLLR Closure
Plan. etc.
1
1
43
106
22
59
82
-------
PATE
TITLE/DOCUMENT TYPE
AUTHOR
CONTENTS
PAGES
80. S/28/B5 Taracorp Access Agreement U.K. Weddendorf
81. 10/24/89 Letter to Brad Bradley Bonni Kaufman
82.
83.
84.
10/3/89
none
2/1/84
Letter to Stephen Holt
Pamphlet on Galena
Industries
"Lead Exposure and the
Health Effects on Children"
85. July 1988 "The Nature and extent of
Lead Poisoning in Children
in the United States"
Brad Bradley
Calene, Ind
Minnesota
Department
of Health
ATSDR
Same as Title
Schedule for
Response
Under Bl/fS
order
U.S. EPA and
1EPA comments on
draft Preliminary
FS Report
Lead Recycling
System
Same as Title
Same as Title
13
99
561
86.
87.
88.
Various
5/1/86
7/26/89
89. None
Notice Letter/PRP File
Trip Report
Door-to-Ooor
private well survey
Packet
Various
Brad Bradley
Dave Webb,
Illinois
Oept. of
Health and
Ken Mi Her
Various
Notice Letters
and PRP
Informal ion
Summary of
findings
during a
site visit
Survey forms of
welis in area of
site
Packet of
Residential
'Are* clean-up
Issues at
several Superfund
Sites
123
2+photos
11
-------
TIUE/DOCUMEMT TYPE
AUTHOR
CONTENTS
PAGES
90. Various
Other ROOs Fi I*
Various
91. 1/16/90
92. 1/5/90
Letter to Valdas
Adamkus, EPA
"Evaluation of Studies
on Human Exposure
to SoiI Lead Residues"
Steven
Ttsher,
Wilkie
farr
t Caltagher
O'Brien &
Cere
Copies of other
•00* and tOO
abstracts
involving soil
Lead cleanup
Letter
regarding
Dispute
Resolution
Sane as Title
138
93. 2/8/?C
Public Meeting Handout
94. 10/26/89
95. 11/10/89
96. 2/8/90
97. 1/3/89
98. 2/H/90
Letter to Stephen Holt
Letter to U.S. EPA
and IEPA
Public Meeting Transcript
Letter to Ken Milter
Letter to Brad Bradley
NL
Industries
Ken Miller
Stephen Holt
Jo Elaine
foster t
Associates
Dennis Kennedy
111inois Dept.
Transportation
Ken Miller
Handout
presented
at 2/8/90
Public
Meeting in
Granite City,IL
Articles on
Lead Uptake
NL Industries
Response to
10/3/89
draft
Preliminary
FS Coonent
Letter
Same as
Title
Floodway
and Proposed
Construction
at NL Site
Alternative
N ARARs
Concerns
10
16
91
-------
DATE
TITLE/DOCUMENT TYPE
AUTHOR
CONTENTS
99.
10/27/89
Article
100. 3/12/90
Public Comment
101. August 1989 Draft Feasibility
Study Report
102. 1/10/90
103. 1/10/90
104. None
105. Nay 1987
FS Report Addendum
Proposed Plan
Cost Calculations
"The U.S. EPA
Weekly Report"
Dames t Moore
O'Brien I Cere
U.S. EPA
U.S. EPA
U.S. EPA
Lead-in- 2
Soil
Clean-up
• Ian
comments
Comment 16
Regarding
St. Louis
Lead
Recyclers
Same as 142 *
Title Tables t
f igures
Same as 24
Title
Same as 26
Title
Cost 3
Calculations
for
Alternatives
"Review and Recommendations Hazardous
on a Lead in Soil Guidance" Contaminants
Branch
Report to the
Minister of
the Environment
56
106. 5/7-9/88
107. 10/23/89
•Lead in Soil Issues and
Stridelines"
•Health Hazard and Risk
Assessment from Exposure
to Heavy Metals in ore in
Skagway, Alaska"
M.U. Mielke
J.P. Middaugh
etal
Proceedings
from a
Conference
held in
Chapel Hill.
N.C.
Same as Title
10
20
-10-
-------
• lo-
TITLE/DOCUMENT TYPE
AUTHOR
CONTENTS
PAGES
108.
2/1/90
"Acidity of Stomach Secretion* lufuc
in Humans, Hate and Pigs, and Chancey,
the Potential Importance of USDA
stomach pM in lioavailabiIity
of Pb in Soil* and Nine Wastes"
Saate as Title
11
109.
1987
•Toxic Effect* of Lead in the 8. J. Hoffer
Developing Nervous system: In ttat
Oculo Experimental Models"
Article from
•Environmental
Health
Perspectives"
110.
None
Abstracts from "Hedline/Lead"
Various
Listing of
Ltad studies
10
111.
112.
Various Excerpt from Integrated Risk
Information system
None
January 1985 "Preventing Lead Poisoning in Centers for
Young Children"
Disease
Control
Lead data
Same as
Title
10
82
113. May 1988 "Fact Sheet-Drinking
Water and Lead"
U.S. EPA
Lead Data
114. 4/23/87 "Longitudinal Analyses of
Prenatal and Postnatal
Lead Exposure and
Early Cognitive Development"
D. Bellinger
etal
Article in
•New England
Journal
of Medicine"
Same as Title
115.
Various
116.
1982
Articles
Various
•Lead-Laden Freeway Parks
Hazardous to Kids"
Louis
Freedberg
Three Articles
Entitled "Sources
of Lead in the Urban
Environment," "The
Potential for Heavy
Metal Exposure from
Urban Gardens
and SoiIs,"
and "Lead
Concentrations in
Inner-City
Soils as a Factor
in the Child
Lead Problem"
Saaw •• Title
27
-------
-11-
PATE
TITLE/DOCUMENT TYPE
AUTHOR
CONTENTS
PUCES
117. 7/11/84 -Condition end Type of
Housing as an Indicator
of Potential Environmental
Lead Exposure and Pediatric
Blood Lead Levels"
C.S. Clark
Article in
•Environmental
••search'
Saa» •• Title
118. 3/13/85 "Evolution of Efficient
Methods to Sample Lead
Sources, *uch mt Mouse
Oust and Hand Dust, in the
Homes of Children
S.S. Quettee
etat
Same as Above
10
119.
3/1/88
"Lead and Osteoporosis:
Mobilization of Lead from
Bone in Postmenopaustl Women"
E.K. Silbergeld
Same as Above
13
120.
December 1984
"Separating the Effects
of Lead and Social Factors
on 10"
S.R. Schroeder
Same as Above
11
121. 1/11/90 "The Long-Term Effects of Needleman
Exposure to Low Doses etat
of Lead in Childhood"
Article in
•The Hey
England
Journal of
Medicine"
Same as
Title
122.
8/25/88
123.
124.
6/8/84
5/30/87
•Port Pirie Cohort Study McNichael
Enviroaentat Exposure in etal
Lead and Children's Abilities
at Age of four Tears"
•The Relationship between Needleman
Prenatal Exposure to Lead etal
and a congenital Anomalies"
•Influence of Blood Lead on Fulton
the Ability and Attainment etal
of Children in Edinburgh"
Same as above
Article in "JAMA1
-Same as Title
Articile in -The
Lancet" -Same as
Title
125. None "Neurobehavioral Effects *.L.
of Lead" BornscHein
126. April 1985 "Hoaw ••finishing. Lead labinowitz
Paint, and Infant Blood eta I
Lead Levels"
Same •• Title
Article in
"AJPM- • Sa
•s Title
15
-------
•12-
TITLE/DOCUMENT TYPE
AUTHOR
CONTENTS
PACES
127. June 1986 "Exterior Surface Duct
Lead, Interior Mouse Outt
Lead and Childhood Lead
Exposure in an Urban
Envi ronment"
•ornachein
etal
Saae at Title
13
128.
1988
"Port Pirie Cohort Study:
Childhood Blood Lead
and Neurophsychological
Development at age 2 years"
Wigg
etal
Article in
•Journal
of Epidemiology
and Community Health"
-Same as Title
129.
3/12/90
Public Comment
Bradley
O'Brien,
Gardner
Carter,
i Douglas
Comment regarding ML
Industries Public
Comment
130.
None
131.
None
Drawing
"Assessing the
Contribution
from Lead in Mining
Wastes to Blood Lead"
U.S. EPA
Steele
etal
Sketch of possible
Final contours for
Expanded Taracorp
pi le
Same as Title
40
132.
None
•Low-Level Lead Exposure Bellinger
and Infant Development etal
in the First Tear*
Article in
•Neurobehavioral
Toxicology and
Teratology"
•Same as Title
11
133.
134.
Various
3/30/90
Public C
nts
Conversation Record
Various
Milt Clark
U.S. EPA
Public Coanents
received on NL
Proposed Plan
Record of
conversation
with ATSDR
regarding
•oil lead clean
up levels
269
-------
•13-
Oraft Documents
DOTE
135.
136.
September
1984
October
1989
TlTLE/POCUHtUT TYPE
"Health Effects Assessment
for Lead
•Technical Support
Document on Lead"
OUTHOB
Environmental
Criteria and
Assessment
Office,
U.S. EPA
Environmental
Criteria and
Assessment
Office,
U.S. EPA
COMTENTS
Sam* as Title
Same as Title
PACES
45
78
Attached is a Compendium of CERCLA Response Selection Guidance Documents, which is part of this Index.
-------
1V-V
•r«:
NO. 1
>/!«/*•
»OILM OF CBKXA acsFoec stifCTicM OLxcwKX
OK
rule
die
JUIui PIgei Tie' Allicmcnli
oooo i IMXX ID OVDCILM OF
OCOXNTJ
SUECTICN auitwa
ot/oi/19 - OPE
II OAtA IlEXTNT «KNI1IO6
1) ORONiZAnoKMi *eeHr
AOlCNn6 IDCNTIflCD IN
oooi i DCP»«D sue ir«P(CTirx
000) I nKli«iM4|
ICB (t-es
10/01/6' • ODD)
Ol'Ol'ta • OCRSA6O)
lirul 7< }
finii 1) )
r»J«J i 01
«)H7M]IX.S 01/0 I/O • *iyil. HI n Al /V3
ioo) i CxrvcDcr RCsrTNsf rocoiuirs rrp oxrun nr HS/^TXXS sjisi-^a 31/01/1} • XI^OLD. a
•CirASCS • .06/ei • ctxs
1 1
i»4 I
CEMOI «)H 0-05
)(iO O I )
ion) } CUiO^Cf OM KON-^PI Bl»CV»l
SICMlflOMT CK WICTDOJt Jinr^C IS3JS
100) i iMOUwflCM ON OIIKKIK: lulO) oCtiOM llvtlS
M»HO*y ir o«/0)/e* • 10/TSt. HI /onto
0'/>9/>t • Mlui. |« . I /QEMOt/BD
100* i s-pmroo orxVAi raoarutts. RCVISIQN «j
too; i n< Roif OF CXPIDITDRCTOCE ACTION LK» SABA
«
o«/oi/e«
> BfO REUASCJ mo*
PtSTlCIIJfS
71 MOOOOCP OHIAMUVHTIOKI
II OJIOrCt fO)
DUKiKCHTO
Flnil HI I
flnil ) ]
rnui « >
APPIKD
QSMfl «)6O 0-OS
Q5KR ««16O 0-15
iO)u> I -01
o-om
-------
1VIJ/M
-IKXX-
CBXiA RCSPO«I sEifcnCH ONCWKZ
IXC
MI vol II Me
Dilt AUIhoit
Slilui P»pei llei Allictncnli
OK«61/(P« MJItWI
Ri/rs
jooo i CASE SUDUS i-ir
Rl<7«n«xiiDMAi»«Daj8-«AsrE sins
1001 ) QJION3 fCR ONXCIIKCRIMIDIAL IM>tSIICATlO« <*Q MASIBMinr 10/OI/BB • ifMU'OOM
sitons ucw ana A
MO) 1 IOIMI ODPS/EPA OJION2 ' M/)4/l) ORB/PAS
joo« 4 mxu>c R(MU»AI ACTICKK A? on>»oniiD MO/ncas ovsii sms OA/OI/BS nan^iii JH
ntj»*< 11 |R
1006 < RIMIOM P(VT>/i{ Al HMAROXfi "«
>OOI 4 OI/(S IM-VCMXH1S
1009 4 RI/IS IMIKVIMCHIS
1010 < SLrrerun fctxRAi-iEAO RtxCDiAt reoiia
1011 J SLTOia/O RIXDIAl KSICN AK3 RlMCDlAl ACTICN OJICVK3
ion j 9^^^u^o suit -ifAt> RIMOIAI raoitci
•• Rl/rs • Rl Uli (Xulllv'SHc » tatle
jioo s A aM'tK)ii* nr SLTwroo riELD CTWAIIO*
JIOI 4 OtA QJX.ITV OBIECTIVtS fCR REXGDIAl R(SK>«E «CTIVITI(S.
raoccss
i
ID . w 6 • CIWI
U/OI/BJ • OH«
• Ol'l
oi/oi/a; • ox iicetAi WOCR«*« ODP
- am/art
FIIUl «» I
Mn»l IX) J
(MUl }90 I
flrul 4| 1
)0 )
nrai II J l| Bl/rs
• in.ll 16 > IIRI/fS IKSCVIKWIS KXlO LP
Jl BIXDIAl iMOtMAtlCN TOw«IO>
ACIIVIIItS
OlM l>« I
Hnil loo I
rnul i )o i
riiul
rirwl tto I
[PA J40/1-I4/OOK)
/1 es/oos
CWUl «35S )-OI
j-oj
QS*1B «)15 0 OB
ro)Ao n-o)
tPA S<0/|-8
-------
i/it/it
-IKJOC-
CBK3.A *E9O«E SELECTION OJIOttt DOOMMS
OK
N3 Vol Idle
die
Slilui Ptget Tlet AlUctmenli
OSXBI/EPA
jioj t DAIA otMirr GB|(crivfS rot (EMSIAL IESTO«E ACTIVITIES: CXMFK oj/oi/u • o» roots *i mcoxMS OSP
JCD*AIO: ii/is ACiivilits AI A Sin •/ oxiAMiMiiED sons wo • am/tx*(
OHUOiATDI
not * asicN *n i»vtm««NT a HM/WOUS »*sit BKCIIVIIY KMIKC
Hiotaa
]IO4 4 rillO KD|^i»C KM CKOflL OMMilNiNIS IN SM*>UJ HKX
HM/MZLfl HASH Mill
Miul I JO I
. co . n AI /Aancx (TUP rhvii 110 i
110) 4 M(IO SCBtOJIfC » run) si*o««)croiAiircniaciELiiEs MNM M-XDIC SMS
not > finn »i»o*o (rpun*c mamjiis «ONJ«I «i AH
nu« i nun
mo ? acnirsiCAi
mi i aoxrsiCM
MIOIAllOX
mi
r«-ni(
in>nrc ABWJXMD «ius
101 io«i«:n«iit>»ASns
OI/OI/BS • OIRRAfXZ) Fll\ll }4 ]
04/01/4) • HTDR/IRiD fliul It } IISoM'HSlM S«ri IV PI MM GO H
iCM oaxs
>CNIIO)
it Bisroet SAIIT* o-Kx-af
01/01/84 • nHSO-KMCT. I » . ft AI /U S
aarcioi SLBVTV
>n i
ot/oi/>« • BOCCH o c . n *i /KOKOS uc iiiui
• v
ir»/» 01
CK««J1 r?J«5 I OS
IPA-«aO/4-«4-06)
(PA-60O/r->4/O«<
-------
PACI m. •
OJ/U/BI
ox
MD VDl IIIIC
•IWXX-
EK>ILM OF CBK1A RESKKKI SEIEC1ICN CUD-MI OQOte«S
Calf lirC O*l I TV ASSURA»«3 CBWS OJ1EX
in? * son SJWTLIK; OJV.ITY ASSLRWCE tsEjrs OJIDE
>lll *• KST wTTKDi KD fVAllMTlKC SatOHASIE. lABCPAIDIr MWOU
MfTKDS. THIBD ODlllCN (VQIXS IA. 18. 1C.
II)
lilt II LEER'S OIIOE TO IK COXTRACT l/OCRATOIv PRODAM
i
•• Bi/IS • linODMootil Ficllllv Tectnolojf
1100 I] OTV1IIS FCR UCOTROiltO »«£MtCCLE "ASTI SUES
INI I) DESIO4. OXTRlXtlCN. AtO EVA1O1KN CT QAT UsCRS roi
DOi i) EVAUMIifc ocvfR srsiix; FCR saio
JJOJ I] OJION3 MKNJM. FO) MINIHI2IKC PdlL/IICN n«> HASH OIVOSM
SITES
JJ04 1) IWO OISFOBAI RESTRiai(>«
o«/oi/e) • BWCUCNA. « ).. n Ai./iuitois ST. nnii in i
"Arm smvrv
• SCA1F. MR./OO/Rl
01/01/85 • BWTH D.S • S1*X.S I.S.AXIV OF Hrul 110 I
KV. IAJ VKAS
• RON. * H /I/WD
04/Ol/»< - 0«IH OS.* iwJOW D | AJ Of fitul 104 I
. IAS VtOS
/DO/IMC
II/OI/B6 • OWW Mrvll XXXI I
ii/oi/ei • cnm/ar
ona
EPA 600/<-BE OUIfdMIA IIST PRO-IIBIIlOe
D on-et AHAOC CUED «NE AVAIIABIE IN
IPA/J40/J-B5/OO)
EPA/Ijo/sw-fli/oo/
«<76 00 I
-------
OX>»OIUM OF ORCIA RIJPOXC sfitcnoH ojicxrct
IDC
Ml VDl IIMC
Mjlhori
Slilui P*gei llei AlUciwenli
CEXB/fPA MJlMI
rro src.
>X» 14 IIK»COr mill OMTAIM4NI WOOD!* HfOOOfl r/CIUUtS 09/Ol/U • tumiOM. INC.
. R./o»/«i9i SHXCIICN
IM* it UNUCOF «wif UTOXXNT AVODISTOSAI r«cninti oi/oi/n • IJKDCTII. * /
ix» i» woarmij rm KMII^MCX n noun a AY IIMRS n>cxinun»€ oi/oi/« • CK»
IHIOVCSS
anxwi i»criii asicv u*« srsiuo »o HM*I ai/oi/e? • ir*
avn
JIM it sfmtxNi ANoavri ajisiooo a iw/wius »*su I*no ij a-wii>efl«i» ouio»c( (»ocirRMiM>ciiKOi/iiAOMif CHUCIICH ot/o>/>6 • "mxi a s
sntlM QOTAiiBiiirr n)CD)
»*SII l»ODISr\BAl lACIlllllS OVma Oi v
Miul tX> 1
tlntl 4io )
Dull 14} ]
Dull JO I
cnul < I
»in»l 40 >
uorrtro i
cx/wro ramfmc
sic
or RCAOIVT »».Mt^ AI
IMS
ItOMCI
• 9 mire n n »i / n unir
ire
a /wrai
30OO ]) APPIICABIIITY Or TK MXA MINIMJJ
•CSPICTIN: IIKTRJ »o itAonif axitciKM rrsiiMS
(eleitnccl
0
riiul j |
INI i*r. nr
>no
CEMII r»««o 00-4
OEMS) «<«0 00- W
|r»-tOO/S) OVOJ5
r»cK>iL« or iiotoocus UECD IH in IRCATMCNI or nn>onis 09/01/1; • oo/cnii
•ASUS
49 1
-------
PACT to. t
OVU/H
one
K> VOl IIIK
OMTHMIM Or C8ICLA *[9>a>«[ JfUCtlOM OADWCt
Oilf AulhOM
SUIui P«gei lltr Alliclranli
HJItKI
JJOI
1301
I30J
)»<
u CMUIN «08UiPi i(N mnoua ro» nnic OIONICS
l» oCicrriMM: fwrnODC fOI HAMCOU "ASH IKCIKOUIICN
IT CPA ojioc rot loeffiFvitc O.HHJ> AiiB»«Tivf j AT
sun SPIIIS: iiaociCAi
04/oi/ao - ixrns. • A /MOU iiml
• CDfN. | M /MTBI
OT/OI/II • BO*« T.A.. Cl. At./KXXWIO Hnil
RCSCDOIODV.
• CBOKXW. o A /an
•ASIC - • PACIFIC Ks»««£$f feaaAioiv rimi
. I.C./CDIVAUIS
II (rAONDf KK
ii
tot
f(X
a SSITJ
OF SLP«<1
irOCRLH SIMS
>xr ii IHMTOTX rat
mi
RCMDIAI ACIICM AI HASIC Disrnrm snrs mrvismi
M u/OMii nix >w«>a«rNi
10 tOIUI mfAIUfNt HOKXCCUJ rd) nrfBCUO "ASUS
Ji re/ciioi ojioc-niAi ojthf. rat iw/mnae HA.MC
II RKCTICAl QJIDC-raiAl ItOKK KM HMVACQLE "ASIC
woua
a>»/»cn>«««D-a>w/B(Jir
n«nt (.AXIS)
a>tncn>"No-a >a /nor r «i$io*c c
jn i
44) 1
I JO 1
M 1
Mi 1
• BMltl. I.
[PA/}4O/]-|J/00<
(PA/}40/]->6-OO]f
fPV600/)-86/0»
' |PA/tao/si-(>/oy>
-------
A""'
. ^PO)/U/I*
MJ. »
-IKW-
CBtCLA RfSFOeC SIlfCTICN OLNDWCE OXLM94IS
DOC
M> VOl Illlt
Oile Aulhoci
Slilut r«get llci AtUctacnli
DM 11 iw«m<>40ki n« PiACDOfl OF HJUC u(X*DMu/«rjjs "ASIC IN M/n/a6 • CB«w/as»»
KKJMIIJ-JIAIUTORY IMTBMCTIVE OJICVK2
mi it irvip* of IN-PI/CE miAiKM ieo««Qj(s rcn ONIAMINAICD 9Ji"a n«n/«4 - SIMS. * c . n M. /I«B ASSOCIATES
mis-va. i: BAaunoLK) IWOUMIKNKX IM-SIIU niAne^r • e««iirr. N./HOII
1)14 IIICVIFMGF iH-riACf wiAiuen noNicxts ia> animimitD son«a o«/i«/«< • axs/aow
mis-xx. i: IEO+JICAI. rvAitKTioi . • oo/xni
iiu n iiwwr latKji a>«niuniCH to) raiuniCM MICRAIICM axrea ot/oi/x • cnw
rimi
js i u uooac SAHC SLBIECT FRCM WIUIAMS.
M C./tKM
JM i
itj i
os"Bi ««i.oo-i»
»ii i) SVSIIMS to AOCUPUU IN siiu
ni'CEiis
1)10
11 tmhacrT SOUCMIK; ama rra IKI»IKNI a ova* sous »-n
siuxzs
11 niAMMI ItOMXQCY WIHS A1ID»«IIV>S TDItvMBXljK "ASH
>»<• IUJ
nn>i
o«/oi'tt • AMmre H . n AI /o*isosno)( CD rimi
- Oitfif . n
o«/oi/as •
IKI i
)J 1
[PA/S«/I 14 oou
iPA/>40/i-t<-ooi
(p* v«o/]-«t/ooi
IP* iw/j ae/oo«
' fP*/6OO/» 8«,/OI >
li/rs • Oouid-iQlef *o>i la ing » moled 101
n o»iirei« io> iDnjiirrihc 6ivf cHQK)-»»ire
QJlOfd
>H/oi/«6
lirul «v> 1
n/i«/«t • iixrna c
HO) i< a»CLN)-»»liu KNIIUIIKC AI
"*Jtl nil LNIIS
i«o) 14 ota/o-MATCR PBOiictiCN sra Aitor
1404 i4 anaiiNis rrn CDCLIO-HAIO) aASsmoiKxiNm ni IPA
nnKT-nUO) rUOIICIICN SIBATtCr
140J 14 crotAtioj »o MAiMiD«ra>o»«iiii
ton im IK;
oi/oi/K • ana a o»a>o ««rw
u/oi/e6 • ana a CRCLND »«iw
CMCROXNI
5! 1 I) OIIAIICN9IIP (f UONICA1
IH««XHCIES ro csauK) "«in<
raraiMwO SKNXBX
i i
rintl 6} 1
Dull tOO )
so j u
wo RE
suiun
CBHR ««J) 00-IA
CEK1I «?«) J
CEXD ««76 CO it
fPA/<«O/6-B4 OO]
CEMII
I
-------
CBKLA RiaoeE sutciiox ojiowct
Cnc
H3 VOl Idle
Dile Aultai
Slilui Ptget Her AlUchtcnli
KOI
i« mtnaxx FCS OMXK>-«AIOI
is HOI* OKUO-MAIIR Kxnmtc UONIOM ivrcscuon
it sou cna/o-tuiin «o«ioiirc HO+WCAL WOPOXNI ajio*a
COOXNf. HCD: BKUllVf
O4/OI/I6
roia
CM/OI/»6 • IP*
MASK CRCLK)
tucoio. c » /o*>f
IA91
ritul >OO 1
Clful J»0 1
riial I I
rr»io i
MMI
xno
xxii
X»I
XX»
x»t
)ti«K2 WITH on o< CKWIROMHIHIAI SIAIUKS
04/01/85 •
io/oi/ei • rcpiED. i M
) )
oi/oa/ie •
ol/)i/e) •
01/01/86
• Or*<
It COlaA ODCIKKX HITHOnOI l«
It IP* $ IM>l(>ICHIAllONOr IK S-TWrV-K) w«NXNIS
RIALnVORIZATICN ACT CF I9M
» ojtowo MMHI (X IK BCRA RiatAiioN or atoacD »w«coz
•ASUS
li irnoi lutes A/ana A aurwa CM MV CCNIIOIXS sms l>m 07/01/86 • (KMIRfCKM
SCR* JlAimWr IMIWPIHTIVI GUI OKI Iveccreuir «eltimccl
j< FIMM. «OIA oM^BDCivt oiauo-MAioi KNIKDIK: (VAUMHON icxci n/w/ee • lucato. c A
OJICXK2 OOOLMNI ISeCCnOllY Rcltrencel
14 OPRAllOM «rO HAINIFNvO lr«PICIICN OLMCX IRCRA CRQX)-"»IO<
•OnitBiKC SVSIIMt) Isccondiir Relcitncel
1J RWA OKXrO-KAlO! tCNITOIIX: IIO-NIOl CMOtOKHI OJICMCI
OQOX&flllKD) ISccortUiv Reltitnccl
;j «OIA atax>-HATOi KNIIWIK; HONICAL FMCROXXI ajicvto
. HOD: EKCO/IIVI SLM**Y IsccadiiY Rcleienccl
H3KMK3 I'C
I II POICNTIAiiY APPiioeit OP Rlllv»
(mil
CHlll
llrxll
lm>l 6 1 1) OMIlMl
SfM AOICN
(in.il «%o 1
XK80 01(85)
M))4 0 )
"AMF. SlUS ICP OG"0> «)«) o-l
Oj/)o/6B • QK*^j»/tM'F./BOIA (MCPQXHi DIVISION rirul
09/01/86 • IPA (Inil J70 1
0/01/87 • IUBIO. C A./O»Pt Fliul | |
llMl 55 1 II HUMIOe-IIP OF l(Oto RI SAX suiitci
OSMR W91O-J
-------
P*3 NO.
Oi/U/lt
•IMXX-
CWtKMLM OF CBK1A RE7O6E SELECTION OJDWCE
trx
N> VDl Idle
Ule Aulhori
Slilui Ptgei Tlei Allicmenlt
OSMdl/lPA MJIWI
JTOI is ROuancvfCf anxxT: i»nriii asicN LIMJI yvjitxs »o MN*I o>/oi/e> - IPA
ovB) iscomiir MI M wee I
«ooi JJ •OlA/CBICLA OCCI JIO* «MO€ O4REXSW SELECTION ISeantoiy 06/H/«) • «IIP»THICX. M
•elcimcl
nail 10 j
8R»O<. CM'f rinil 1 I
•• mle)
4000 H
OX»JTS»tlCN IIUI1 QJICMK3 >*O) PSCVIOIK: Mio»Mn KAIOI SLTPIICS oi/oi/te • cast
toot it IMIBIIM nun ancxrct CMBI>OV*I ACIICNKVIIS AI O>/I*MIN*IH) lo/ot/tr
CRINdK: "AID) SIT(S
400) )6 OMiinr aniniA res n*ira im o^/ol/» • ana or HAIBI HICUAHO*
)MI U &WOCN AOSO1PIICM I son DIMS Id) IDIICCNONICS iMcadiiy 04/oi/to • OTBS. R A /«H[
Rflticncel • CDCN | M /Km
loot I IMOUMIICH CN CPCMIIK; »»in> ACTIOJ ifvtlS IStxcrctirv ««l(>mccl 04/i9/e« • »KLDS It I
rinil 64 l
linjl 1 )
riiui in i
Iliul 111 I
HlMl. l> J I) **O RUIAMS I»O4 tAMUIV
PESTICIDES
11 Mf>O CBQT* OIWIAHl^MTIO4
ji cuiivrcx roi rrMn»« OIRROHOC
r94Il OO-tC
CEMR rt)S) ) 0)
MJ60 I -01
(PA/440/J-66-OOI
IPA/600/>-tO-0))
Ml .« AttCltflClll
XXX) J7 A1SLH HAini AiSfSSKN'S CN Wl SUCS
06/16/tt
i »O H>kB)rvK> REMEDIAL FW23SS • AIStA
jooj ]> anociiNES ran CMCINXENRIX ASSCSSUCNT (fEDOny. BECISKR 09/i4/«6 • (PA
14. !««». p. JJWJI
t
Oil I 14
Hrul )IO >
linil II I
tins. D*irt> 4/u/ar
CEMO) r)J85 4-01
-------
P«X K>. 10
OJ/U/19
•IKXX-
C8X3A *c9o«t SCIECTICN 0*0*0. GOIXNTS
Doc
N> VOl Till*
Oile Aiilhon
Stilut Pipei llei AtUctncnlt
CEXR/IPA
*(cism. sinoow o«/i«/66
VXH » ouiociiKes rot otposmi ASSISSWCNT
14. I«M. P. J4041I
jooi >; OJDEIIKS roi KAIIH Aisuve* OF SLBPICT
lexicons IHECHAI Rtcism. SEPTCMR K. itu. p. KOHI
MM !> OJUXUtCS KS MJI/CB«CirY «I9C ASSES!»«XT (rOWM HICISIOI.
jfpiuea. 14. p. )4oo4>
MO; i! cmocuxs KM TK KAITHBIX MjtSiMtM OF o-txiou MUIUIES
(FBXRAl •ICISIBI. SCPIIMBI 14, IfM. p. J4OUI .
• :e >i< KAIIH ifftcis ASsissM»n tm>ejrj 01 OCMICAI paaius)
VOL ie: Aarot. WSENIC. ASDCSUX. BMILM. BB^DIAIPXKM.
OOUILM. CWKN HIHAOICRIM OHOICDCKCCKC. o-too»<
CKOTOFORM. am. IMS. CTPPW. axsas. cv»not. an.
i.j-oicno>otn*»< va. )«
I. J-OICK(3>CFn-M.O-t.
o«/i«/g6 • IPA
01/H/tt • IPA
o«/>-€N»ni«fM va x>
IPCDS). ra«o>ciic «o*nc
MiCROOWBOS (P»6>. P\«e<. S(l»"» I^OCCMKXKK). UDlLM
OrMlH. SUfVRIC ACID. J. ). J .1- IfTOOiOlCDIBeXD C Oit>iM
i.i.i.i-iEiRAOtoianH*c. TrnxoiatanncK
t.l.l-WICH.OROriVt»4;. I . I . l-TPIO-tCROEIMwC .
> <.VTOIOlCRCW-efHX. TRIVAIENT
viwrt CXCRia. XntfC. Zl»C (>K)OD*Q>OSI
rinil 14 1
rim) 14 1
llral I )
Mrvil I) }
rinil i;jo I
5009 )l INTIOtAIO) RISC IKfORMAlltN MIEM (IRIS) (A OMVIDI-BASa)
ICAIIHRISK IMOUUIICN SYSItM AVAIIADlt nOOJCH I-M»ll •-fFOl t«e
O4AO2SS IS
OCA
Flnil - >
I
-------
PACf K>. II
kns/u/tf
CBKIA *csro«f stifcncN CUICXKZ
ooc
Wl flllt
0»lt AUlhOfl
SUlut pjpel flei Allichnenll
O9IV i A . n «i /rA5l| JllfS i4U>Aioir
• MI I ID) M| /OCPVA11IS
tOIJ II SLPWfUO CXPCOUII AISCSSMMT
SOU JI SLPCRfXX) f\-8UC UAIIH tVAlLHIIOM MWO*t
lO'Oi/es • cow
• CB»<
oB/oi/»i • (in
. i>c
. i i
rtRICR I »
IO/OI/B) • IBB Aisa;iAns/ociM MIII
• OiD/KRL
sots Ji rexicacc* i
OOOO JJ 1H>*~ntunnt ASS(SWNI OJIOrcI IScCmdiiy I
•• cm I Antlyili
MOO » DiHDiAi ACTION axiirc recarmis H«K>I
6001 )) KEKVAt OBT MW*d>f*ooo j> O>HXInr KiAiic^e IN suwuo: AIKTCBOX (INIOIIM vtxsiCNi o6/oi/ii • cow
rlrul SO 1 I) INIOIIM rRCOELflES «»
•isxs AssociAia> WITH txposmcs TO
DIXTLACS: to/at
llntl - I
Mrul IO6 I
rinil I6O I
nnjl soo I
Of
-------
-Ad *O. II
os/u/tt .
-IWO-
COKXA ms"occ SIHCTICN QJICVKI
ox
»O vol Hilt
Alt MJlhoii
Slilui Ptget Iltf Alliclnmli
OSMIB/IC* MIU-I
•• inlotcoienl
*ooo j>
1001 II IMIOIi
OJity»cz II/JI/M • ftxiR. i *.taoa>
«Awa» nosioc
JIUCTICN
1J/H/B6 • KPIW | « A1SXV
cx>/)
3 i
CE»W «J51 P
-------
IEPA Record of Jec ii'I-..- u;claration For the NL Industries/Taracorp
NPL Site in Granite City, Illinois
Th* selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant
and appropriate for this remedial action, and is cost-effective. This
remedy satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a principal
element and utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining en-
sile, U.S. EPA is expected to conduct a review no less than five years
af>:er commencement of remedial action to ensure that the remedy continues
to provide adequate protection of human and health and environment.
Based on the information described above, the IEPA adopts and concurs
wii;h the decision the U.S. EPA has made in selecting this remedy.
Date ffernard P. Killian
Director
-------
»»« M
PUBLIC COMMENTS OF NL INDUSTRIES ON THE
PROPOSED PLAN FOR THE TARACORP SUPERFUND
SITE, GRANITE CITY, ILLINOIS
Prepared by:
Janet D. Smith,
Associate General Counsel
Stephen w. Holt,
Senior Environmental Engineer
NL Industries, Inc.
Frank Hale, P.E.
Swiatoslav Kaczmar, Ph.D., C.I.H
O'Brien 6 Gere Engineers, Inc.
Henry T. Appleton, Ph.D.
Jeffrey P. Robinson, Ph.D.
Paladin Associates, Inc.
Steven A. Tasher, Esquire
Bonni Fine Kaufman, Esquire
Willkie Farr 6 Gallagher
-------
TABLE OF CONTENTS
I. INTRODUCTION 1
II. THE BACKGROUND AND HISTORY OF NL'S CONDUCT OF
THE RI/FS AND PROPOSED REMEDIAL ALTERNATIVE 3
III. NL'S RECOMMENDED ALTERNATIVE D FULLY COMPLIES
WITH EPA'S INTERIM GUIDANCE ON ESTABLISHING
SOIL LEAD CLEAN-UP LEVELS 5
A. NL's Risk Assessment Complies With The
Guidance By Taking Into Account
Site-Specific Conditions 7
1. The Illinois Department of Health
Blood Lead Survey Provides the Best
Information on Lead Exposure in
the Granite City Community 8
2. The ADI Approach is an Acceptable
Approach Given O'Brien & Gere's
Development of a Modified
Reference Dose 11
3. The Soil/Blood Lead Slope Proposed
in NL's Risk Assessment is
Consistent with Recent Studies of
Lead Exposures As Well As Recent
EPA Air Policy 13
IV. THE INFORMATION CITED BY EPA TO SUPPORT A
500 PPM CLEAN-UP LEVEL IS IRRELEVANT TO
GRANITE CITY CONDITIONS AND RELIES ON
OUTDATED INFORMATION * 17
A. The Results Of The Vegetable Uptake
Studies Are Not Appropriately
Applied To Granite City 18
1. The Bassuk Study 19
2. The Spittler and Feder Study 21
-------
a. Application of the Spittler
and Feder results to Granite
City shows DO increase in lead
exposure 24
B. The Madhavan Study Is Drawn From A Biased
Sample Of Outdated Studies And Does Not
Support EPA's Clean-Up Standard 26
1. A correct analysis of the Madhaven
data supports the 1,000 ppm clean-up
standard 30
C. The Cincinnati Work Plan Cited By EPA
As Support For Its 500 pprr, Level Also
Has No Bearing On Granite City Conditions.. 32
D. EPA's Reliance On Other Records Of
Decision To Select A Cleanup Level'
For The Taracorp Site Contravenes
The Interim Guidance And Is
Scientifically Inappropriate 34
V. ALTERNATIVE H IS NEITHER COST EFFECTIVE
NOR TECHNICALLY FEASIBLE 35
A. Cost Estimate . 36
B. Implementation Time 38
1. Design 38
2. Excavation/Transport 39
3. Installation of the Cap 41
C. EPA Failed To Consider The Technical
Znfeasibility Of Implementing
Alternative H 42
VI. ALTERNATIVE H'S IHCREASED RISK TO
RESIDENTS AND ADVERSE IMPACTS ON THE
COMMUNITY AND THE ENVIRONMENT ARE NOT
JUSTIFIED BY THE MINIMAL PROTECTION
IT PROVIDES 44
VII. CONCLUSION 46
- ii -
-------
I. INTRODUCTION
NL Industries (NL) submits these comnents for the
public record for the Taracorp Site, Granite City, Illinois in
support of the implementation of Remedial Alternative D. For
the reasons set forth in this public comment, Alternative D is
the most cost-effective remedy which will protect human health
and the environment in accordance with CERCLA. NL will
demonstrate that EPA's selection of recommended Remedial
Alternative H violates EPA Interim Guidance on Establishing
Soil Lead Cleanup Levels at Superfund sites and ignores site
specific data and risk assessments which support the
implementation of the 1,000 ppm clean-up level proposed in
Alternative D. Furthermore, it is not justified by available
scientific studies relevant to lead exposure and is technically
infeasible. Finally, implementation of Alternative H will
disrupt the Granite City community, and expose it to
unnecessary adverse health, safety and environmental impacts.
Alternative H involves the removal and resodding of
lead-bearing soils from a ninety-seven block area in Granite
City, one of the largest projects undertaken by the Superfund
program. Supporting technical and scientific data for this
incredible proposal were not developed during the five-year
remedial investigation/feasibility study conducted by NL with
IEPA and EPA oversight. Instead, they were released less than
two months ago, without review by the Illinois Department of
Health or O'Brien & Gere, the engineering firm approved by EPA
-------
and IEPA to investigate the site and propose selected remedial
alternatives.
The essential difference between Alternative H and
KL's preferred Alternative D is the clean up level for
lead-in-soil in residential areas. In general, Alternative H
would clean up residential areas with soil lead above 500 ppm,
while Alternative D cleans up areas with soil lead above 1,000
ppm. As these comments will demonstrate, the 1,000 ppm level
proposed by NL is not only supported by EPA guidance and site
specific risk assessment data, it will be fully protective of
public health, particularly the health of children, who as a
group have been shown to be more sensitive to lead.
Alternative D fully complies with EPA's Interim
Guidance on Establishing Soil Lead Clean-up Levels at Superfund
sites by employing three valid risk assessment approaches,
including a site specific local blood lead study, a modified
ADI approach for lead and a soil/blood lead correlation
incorporating recent data on lead exposure. In contrast, EPA's
Alternative H does not rely on site specific data, but instead
on limited vegetable uptake studies irrelevant to Granite City
conditions and outdated information on lead exposures.
Moreover, the cost and implementation time of Alternative H has
been underestimated by EPA and community impacts and technical
feasibility concerns have been ignored. EPA's recommendation
of Alternative H and arbitrary and capricious rejection of
Alternative D without scientific or technical justification
- 2 -
-------
violates the letter and spirit of CERCLA, wasting precious
Superfund monies with no additional benefit to the public or
environment.
II. THE BACKGROUND AND HISTORY OF NL' S CONDUCT OF
THE RI/FS AND PROPOSED REMEDIAL ALTERNATIVE.
NL voluntarily entered into an Administrative Consent
Order ("ACO") for conduct of a remedial investigation
feasibility study (RI/FS) with EPA and the Illinois
Environmental Protection Agency (IEPA) in May, 1985. The ACO
scope of work negotiated and agreed to by the parties required
NL to undertake a site-specific risk assessment, incorporating
previous sampling, blood tests and health studies undertaken at
the site.1
During the next five years, NL fully complied with the
terms of the order, conducting three separate site-specific
risk assessments, supervised by U.S. EPA and subjected to peer
The ACO also required compliance with the EPA Guidance
for Conducting Remedial Investigations and Feasibility
Studies under CERCLA. This Guidance provides that:
a. the RI must be tailored to meet
site-specific needs;
b. data generated must be evaluated in
context of individual nature of the
site; and
c. where ARAR's are unavailable, toxicity
assessment should be based on reference
doses. The weight of the evidence
associated with toxicity information is
a key element of this risk
characterization.
- 3 -
-------
review scrutiny. NL submitted the preliminary feasibility
study report in August, 1989. It concluded that a 1510 ppm
soil lead level for residential areas was protective of public
health and the environment and conservatively used a 1,000 ppm
soil lead level to select residential neighborhoods targeted
for remediation.
NL received comments from U.S. EPA and IEPA on
October 4, 1989, arbitrarily rejecting the previously approved
and legally required risk-based approach to remediation of the
site. The agencies instead proposed a 500 ppm level for
residential soils and a 1,000 ppm level for industrial areas
based on their interpretation of U.S. EPA Interim Guidance on
Establishing Soil Lead Clean-up Levels at Superfund Sites
issued in September, 1989. NL responded to these comments in
compliance with the Consent Order on November 10, 1989, but
U.S. EPA, without explanation, has refused to enter into
dispute resolution to resolve the differences in the two
approaches, in direct contravention of Paragraph 17 of the
Consent Order.2
On January 10, 1990 U.S. EPA further breached the
Consent Order by releasing NL's August, 1989 study, with an
Paragraph 17 of the Consent Order required EPA to respond
to NL's submittal within thirty days. EPA was further
required to enter dispute resolution procedures if it did
not approve NL's submittal. As of this date no response
has been received and EPA has refused to enter into
dispute resolution.
- 4 -
-------
addendum prepared by EPA selecting Remedial Alternative H. As
the following comments will show, this arbitrary and capricious
rejection of Alternative D is not supported by the evidence.
III. NL'S RECOMMENDED ALTERNATIVE D FULLY COMPLIES
WITH EPA'S INTERIM GUIDANCE ON ESTABLISHING
SOIL LEAD CLEAN-UP LEVELS.
In September, 1989, after the preliminary feasibility
study for the Taracorp site had been completed, EPA
Headquarters issued Interim Guidance on Establishing Soil Lead
Clean-up Levels at Superfund sites.3 The Guidance sets forth
an interim soil clean up level for total lead in residential
areas at 500 to 1,000 ppm, which is adopted from a 1985 Center
for Disease Control (CDC) Publication "Preventing Lead
Poisoning in Young Children."
The CDC Publication itself does not recommend a
clean-up level for lead in soil, however. Based on its review
of lead exposure studies, it suggested that "lead in soil and
dust appears to be responsible for blood levels in children
increasing above background levels when the concentration in
soil or dust exceeds 500 to 1,000 ppm." No indication is
provided of the background level used or of any potential
EPA's issuance of the Interim Guidance has been
challenged by the Atlantic Richfield Company in a suit
filed in the United States Court of Appeals for the
District of Columbia, on the grounds that EPA failed to
'comply with notice and comment procedures for rulemaking
when it issued the guidance.
- 5 -
-------
occurrence of adverse effects following exposure to soil or
dust levels in this range.4
Within this framework, the Interim Guidance explicitly
provides that "site specific conditions may warrant the use of
soil clean-up levels below the 500 pptn level or somewhat above
the 1,000 ppm level," providing flexibility on either end of
the range. It emphasizes that the Administrative Record
supporting the clear.-up level should include background
documents on the toxicology of lead and information related to
site-specific conditions.
EPA has ignored this flexibility inherent in the
guidance, however, failing to recognize that a range of
clean-up levels from 500 to 1,000 was provided so that
site-specific factors may be taken into account. Instead of
examining these factors and incorporating them into a proposed
clean-up level, EPA seemed to randomly pick a 500 ppm level
with no relation to site conditions. It has struggled to
articulate the scientific reasons for selecting the 500 ppm
level ever since. When compared to the laborious process
undertaken by NL to support its 1,000 ppm level, this effort
falls far short of EPA's legal responsibilities under CERCLA to
Review of the CDC document makes clear that it never
intended the 500 to 1,000 ppm level to be considered as a
"recommendation" and adopted as a soil cleanup level. As
the attached comments submitted to Jonathan Z. Cannon by
ARCO demonstrate, there is no scientific documentation in
the CDC document to support the interim cleanup level.
See Exhibit A.
- 6 -
-------
choose a cost-effective remedy which is sufficiently protective
of human health and the environment.5 EPA has provided
no scientific justification whatsoever for its arbitrary
rejection of NL's risk assessment which complies with the
Guidance, the Consent Order and EPA policy.
A. NL's Risk Assessment Complies With The Guidance
By Takino; Into Account Site-Specific Conditions.
NL's risk assessment included an analysis and review
of a local blood/lead study conducted by the Illinois
Department of Health, a toxicology assessment based on a
modified reference dose developed pursuant to EPA policy and a
Soil Lead Blood Lead Correlation Approach. The risk assessment
addressed site-specific conditions including ambient air
concentrations in Granite City, dietary intake of Granite City
residents and soil lead intake. All three approaches were
arbitrarily rejected by EPA.
Moreover, EPA asserted at the February 8, 1990 public
hearing that it chose the lower end of the 500-1000 ppm
range presented in the guidance in part because Granite
City is an urban, industrial area, and therefore, the
population may be exposed to other contaminants. This
approach is unorthodox, unscientific and unsupported by
the facts. First, there is no evidence in the record to
indicate that there are other pollutants that threaten
the health of the Granite City population, nor was any
risk assessment conducted to evaluate the effects of
other pollutants alone, or in combination with lead.
Second, the literature is devoid of any reference to
recommending a lower cleanup level of lead in soil where
other pollutants are present, nor has EPA cit«d any
scientific support for this synergistic approach. Thus,
'this statement, like much of what EPA relies on as
support for its decision, does not withstand scrutiny.
- 7 -
-------
1. The Illinois Department of Health Blood Lead
Survey Provides the Best Information on Lead
Exposure in the Granite City Community.
As part of its risk assessment, NL reviewed the data
from the Illinois Department of Health (DOH) Blood Lead Surveys
conducted during 1979 and 1982 summarized in the IEPA report
"Study of Lead Pollution in Granite City, Madison and Venice,
Illinois, April, 1983." This study, conducted while the
Taracorp Smelter facility6 was stall in operation, found that
"high absorption of lead is not occurring" in Granite City and
.there was no "unusual incidence of elevated blood levels."
The DOH blood-lead study provides the best and most
relevant information to understand the relationship between
lead-bearing soils surrounding the Taracorp site and any health
risk to nearby residents from.elevated blood-lead levels. EPA
summarily rejected the data from this study, however, because
it was conducted in November and December, when it believed
residents were less likely to be outdoors. Using unreferenced
values for blood lead declines, the Agency estimated the peak
blood lead might have been 15 to 20% higher if the survey had
been conducted in the summer or late fall. The U.S. EPA Review
of the National Ambient Air Quality Standards for Lead (1989)
cites data indicating that the half-life for clearance of lead
from the blood of children is 10 months, however, with a rate
The Smelter facility was identified by IEPA as a major
source of lead. It was shut down in 1983 and is no
longer operational.
- 8 -
-------
constant of 0.072 per month. Thus, in the absence of any
external uptake of lead over the period in question (an
obviously theoretical assumption in Granite City or elsewhere
in the U.S.), blood lead should decline by only 7.2% per month.
In other words, the mean blood lead level of 10 ug/dl reported
in the IDPH report for November might have been 12.3 ug/dl in
September, if no lead exposure had occurred in the three month
period.
The IDPH report also contains data on the levels of
free erythrocyte protoporphyrin (FEP) in blood. FEP is formed
when zinc is incorporated into heme instead of iron during
erthrocyte formation, due to the inhibitory effect of lead on
the enzyme ferrochelatase (U.S. EPA 1986). It is a longer term
indicator of lead exposure than blood lead, because the life of
an erythrocyte is approximately 120 days. Thus, if lead
exposure had actually been higher during the summer and early
fall months as EPA alleges, FEP concentration should have been
elevated during the November/December sampling period. It was
not elevated, however, according to the IDPH survey, indicating
that the results of the study were a valid indicator of blood
lead, even for summer months when outdoor activity may be more
frequent.7
As IDPH points out in its report, one or two cases of
elevated FEP should have been found in a sample of 46
urban children.
- 9 -
-------
Therefore, the Agency's position that sunnier blood
lead values may have been elevated relative to the time of the
ZDPH survey is incorrect, both because it uses an assumption of
no significant exposure to lead over the period between summer
and late fall (ignoring ambient exposure sources such as diet,
house dust and air), and because FEP levels were not elevated.
Moreover, the blood lead and FEP testing conducted by
IDPH indicate that soil lead concentrations in Alternative H's
proposed remedial Areas 4-8 were not causing public health
risks at that time. Therefore, the need to remediate these
areas as proposed under Alternative H is not supported by the
public health data.
Although a final report of the 1982 Granite City blood
lead survey was never prepared by IDPH, summary tables of the
survey were provided by IDPH, which break down data by age,
sex, and location for both blood lead and FEP. Data for
children aged 1 to 6 in Granite City were extracted for
analysis (Exhibit B). Table 1 presents these data for the
total 33 childrens' samples provided as a function of sectors
of the study area EPA (Figure 4-5). The data show a decreasing
trend in lead exposure with increasing distance from the
Taracorp site, with mean blood and FEP levels of 17.1 to 33.5
mg/dl and 16.8 to 16.1 mg/dl for Sectors 2 and 3 respectively.
Using the most recent guidance available for blood lead
exposure parameter of concern (ATSDR 1988) with consideration
of a proposed revision for blood lead of 15 mg/dl, none of the
•/•
- 10 -
-------
33 children analyzed shoved a combination of blood lead
exceeding the current or proposed action level for lead
exposure.
Furthermore, two predominant sources of lead in the
study area - active smelting operations and use of the leaded
automobile fuels were present at the time of the IDPH study,
but are not present now. As discussed in Section III.A.3. of
these comments, U.S. EPA (1989) has reported that the average
blood lead levels of children have decreased from 14.9 ug/dl in
1978 to a projected 4.2 to 5.2 ug/dl in 1990. Therefore, blood
lead levels of Granite City residents should have substantially
decreased since 1982, meaning the values in the study are
likely overstated.
2. The ADI Approach is an Acceptable Approach
Given O'Brien & Gere's Development of a
Modified Reference Dose.
In its comments, EPA criticized the Acceptable Daily
Intake (ADI) Approach proposed in NL's risk assessment because
the Agency has withdrawn its ADI for chronic exposure (ADIC)
for lead. The new Risk Assessment Guidance for the Superfund
Human Health Evaluation Manual (HHEM, 1989), however, provides
guidance on the derivation of toxicity values even in the
absence of EPA-verified values. It is possible to
independently generate such values with the approval of the
U.S. EPA's Environmental Criteria and Assessment Office (ECAO).
As documented in previous correspondence submitted to"this
- 11 -
-------
record,8 sucb an approach was taken with the Granite City risk
assessment, whereby the previous AIC was reduced by 40% in
proportion to the anticipated lowering of the CDC level of
concern for blood lead from 25 to 15 ug/dl. Dr. Michael
Dourson of ECAO concurred that such an approach might be a
reasonable alternative until additional guidance is forthcoming
from the Agency.
The Agencies rejected the ADI approach, however, for
Granite City, presumably because it assures thresholds for
lead. Such rejection may be based on the implied conclusion
that there is co threshold effect level for lead in children, a
position that is unsupported by the record or scientific
principles. For example, a lowest observed adverse effect
level (blood concentration) for lead in humans is cited by
Madhavan et al. (1989) as 10 ug/dl (p. 137) because this level
was the lowest associated with the inhibition of the enzyme
ALAD (delta-aminolevulinic acid dehydrase), a key enzyme in the
biosynthesis of beme. However, this inhibition is translated
into decreased hemoglobin levels and anemia only at
substantially higher blood lead levels — 40 to 80 ug/dl —
based on a number of investigations reviewed in the ATSDR
See December 16, 1988 letter .to Mr. Brad Bradley,and Mr
'Ken M. Miller from Bonni Fine Kauftnan, with attachments
- 12 -
-------
Toxicological Profile for Lead (draft 1988).9 Thus, ALAD
inhibition at 10 ug/dl should be viewed as a biological
indicator of lead exposure, rather than an overt adverse
effect. Given the existence of an appropriate threshold effect
level of 25 ug/dl for lead or a proposed level of 15 ug/dl, the
ADI approach is a valid method of risk assessment, supporting
NL's proposed 1,000 ppm clean-up standard.
3. The Soil/Blood Lead Slope Proposed in NL's
Risk Assessment is Consistent with Recent
Studies of Lead Exposures As Well As Recent
EPA Air Policy.
A critical review of post-1980 information on lead
exposure indicates substantial decreases in baseline lead
exposure, due primarily to the phasedovn in leaded fuels and
other lead uses. Since this phasedovn beginning in the
mid-1970's, there has been a dramatic decrease in the blood
lead content of the United States population, as well as an
apparently lower contribution of soil lead residues to blood
lead content. As explained below, these contemporary data are
more relevant to the remediation of the Taracorp site than the
older studies relied upon by EPA and provide ample basis for
the risk assessment's soil/blood lead slope.
This would appear to be due at least in part to the
observation that approximately 90% or more of ALAD
activity can be lost without, measurable effect on the
rate of heme synthesis (0'Flaherty 1981, p. 28T).
- 13 -
-------
The original risk assessment for Granite City uses a
soil/blood lead slope of 2 ug/dl lead per 1,000 ppm increase in
blood lead. This slope was based on the analysis presented in
EPA'S Air Quality Criteria for Lead (1986), which suggested
that a slope of 2.0 ug/dl per 1,000 ppm soil lead may represent
a reasonable median estimate for a soil/blood lead slope.
Three recent empirical studies. Stark et al. (1982), Rabinowitz
and Bellinger (1988), and Johnson and Wijnberg (1988) indicate
that the relationship between blood lead concentrations and
soil lead ranges from 0.6 to 1.8 ug/dl per 1000 ppm, indicating
that 1,000 pm will be protective of public health at the
Taracorp site.
First, Stark et al. (1982), conducted a study of the
exposure of urban children to soil lead from 1974 to 1979 in
New Haven, Connecticut using 153 children of age 0 to 1 year,
and 334 children of 2 to 3 years, and soil ranging in lead
content from 30 to over 7,000 ppm. An analysis in U.S. EPA's
Air Quality Criteria For Lead (1986) of the data in this study
gave a slope estimate of 1.8 ug/dl blood lead per 1,000 ppm
soil lead. U.S. EPA identified this slope as a good median
estimate of the relationship between soil and children's blood
lead. It has been incorporated into the Granite City/Taracorp
risk assessment slope of 2 ug/dl blood level per 1,000 ppcn soil
lead.
Second, Rabinovitz and Bellinger (1988) conducted a
•
study similar to Stark et al. of a population of children in
- 14 -
-------
Boston during 1981. The study used a sample size of 195
children aged 6 months to 24 months and a range of coil lead of
7 to 13,240 ppm. The population was divided approximately
evenly into populations of children with more mouthing activity
and those who were said to finger and hand mouth less, which
was determined by a statistical analysis of psychologists'
judgments on the frequency with which the children placed their
fingers, hands, or foreign objects in their mouths. (This
distinction is important as high hand to mouth activity may
lead to relatively higher exposure to soil and dust lead
residues.) The slope estimate for the less mouthing group was
0.57 ug/dl per 1,000 ppm (standard error of 0.2), and 1.6 ug/dl
per 1,000 ppm of lead (standard error of 0.5) for the greater
mouthing group,10 once again less conservative than the 2 ug/dl
per 1,000 ppm slope in the NL risk assessment.
Third, Johnson and Wijnberg (1988) conducted a study
commissioned by the Centers for Disease Control in 1983 of
children living in the vicinity of the ASARCO lead smelter in
East Helena, Idaho. These investigators derived a slope
10 Because the study population did not live in crowded
conditions which might enhance exposure to leaded paint
residues in soil near houses,, the authors caution that
•the slope might be steeper 'under more crowded, urban
environmental conditions.
- 15 -
-------
estimate of 1.4 ug/dl per 1,000 ppm lead, with a coil range of
158 to 1,549 ppm studied.11
These recent studies, taken as a whole, show that the
contribution of soil lead to children's blood lead may be
substantially less than originally thought, validating the
2 ug/dl per 1,000 ppm slope used in NL's risk assessment.
Koreover, as reviewed and documented in the U.S. EPA
Review of the National Ambient Air Quality Standards for Lead
(1989), general lead exposures have been declining rapidly, not
only because of the phasedown of leaded gasoline, but also due
to the elimination of the use of leaded solders in metal food
containers and the replacement of water distribution systems
containing leaded solders. For example, estimates of mean
dietary lead exposure in children was reported to have
decreased from 52 ug/day to 8.8 ug/day between 1978 and 1990
(p. C-9). The U.S. EPA Review of the NAAQS for Lead (1989) was
reviewed and approved by the U.S. EPA Clean Air Scientific
Advisory Committee which estimated, through the use of a
validated biokinetic lead exposure model and the 1978 NHANES II
blood lead data, decreases in children's blood lead due to
*
phasedown of leaded gasoline of 8.6 ug/dl, decreases in blood
11 The data of Johnson and Wijnberg (1988) were also used by
U.S. EPA (1989) to successfully validate its mathematical
biokinetic model predicting blood lead levels in various
age groups based on uptake, absorption and elimination
... rates via several physiological compartments and exposure
routes. *
- 16 -
-------
lead due to decreased dietary lead exposure of 0.9 to 1.8
ug/dl, and decreases in maternal lead exposure producing
decreased blood lead of 0.2 to 0.3 ug/dl. As a result, blood
lead levels of 2 year old children in 1990 should average
(geometric mean) from 4.2 to 5.2 ug/dl (compared with the
average 1978 value of 14.9 ug/dl), and also from 3.5 to 5.8
ug/dl in adults (down from average values of 10.8 to 17.7
ug/dl) (see Table C-5, U.S. EPA 1989). These values, combined
with the lover contribution from soil lead, and the fact that
the IDOH blood lead study shoved that residents of Granite City
do not have elevated blood lead levels, indicate that the 1,000
ppm clean-up standard in Granite City vill be fully protective
of public health.
IV. THE INFORMATION CITED BY EPA TO SUPPORT A 500 PPM
CLEAN-UP LEVEL IS IRRELEVANT TO GRANITE CITY
CONDITIONS AND RELIES ON OUTDATED INFORMATION.
To support its preferred Alternative D, NL developed a
three-pronged site specific risk assessment which has been
updated by detailed information presented in these comments.
In contrast, to justify its selection of Alternative H, EPA has
relied on two generic vegetable uptake studies, an analysis of
an outdated data set on lead exposure and a Super fund Record of
Decision.12 Upon review, it is readily apparent that these
12 EPA has also referenced a draft ATSDR risk assessment of
..; the Taracorp site. The ATSDR did not undertake a site-
specific risk assessment for lead1, however, it 'simply
referenced the CDC guidance.
- 17 -
-------
studies and the United Lead Scrap Record of Decision are
completely irrelevant to conditions at the Taracorp site and do
not provide a basis for a 500 ppcn clean-up level. In fact, if
the data in these studies are applied correctly, they support
the 1,000 ppm level proposed in Alternative D.
A. The Results Of The Vegetable Uptake Studies Are
Not Appropriately Applied To Granite City.
The first two studies relied upon by EPA, (Spittler
and Feder 1979) and (Bassuk, 1986) examine vegetable uptake of
'lead and the methods to reduce such uptake. The Study of Lead
Pollution in Granite City, Madison and Venice, Illinois
conducted by IEPA in 1983, however, concluded that garden
vegetables grown in the vicinity of the smelter do not appear
to pose a significant risk. This site specific data should
clearly take precedence over two generic vegetable studies .that
have no relation to Granite City soil conditions.
The IEPA study (1983) surveyed a variety a vegetables
grown in Granite City gardens. As reported on page 37 of the
study, vegetables grown in soils containing 53 to 97 ppm lead
showed mean wet weight concentrations of 0.009 ppm, compared
with 0.17 ppm for crops grown in soils of 1,100 to 1,500 ppm
lead, in contrast, lettuce raised under greenhouse conditions
by Spittler and Feder (1979) in 1,000 ppm soil lead contained
approximately 3.1 ppm total lead (wet weight), almost 20-fold
higher than the measured Granite City samples. Combining these
data with an analysis of the dietary contribution of home-grown
•f
- 18 -
-------
vegetables, and consideration of the limited extent of
vegetable gardening in Granite City, IEPA (1983, pp. 38 and 48)
concluded that vegetables did "... not appear to pose a
significant risk as long as they are thoroughly washed before
eating."(p. 48). Therefore, as will be shown below, the
results of the Bassuk and Spittler and Feder studies are
completely irrelevant to the derivation of soil lead remedial
objectives for the Taracorp site.
1. The Bassuk Study.
The purpose of the Bassuk Study was to determine the
effect of the phosphorus content in soil on lead uptake in
plants as a function of soil lead concentration. The study
used a soluble lead compound, PbCl2, to determine lead uptake
by lettuce.13 In contrast, as stated on page 54 of the RI
report, due to their smelting operation origin, the soil lead
compounds at the Granite City site are likely to be oxides,
sulfides, and mixed oxide/sulfates which are insoluble in water
(Budavari 1989). Their insoluability is also indicated by the
negative EP TOX results in the RI/FS from a soil sample with a
total lead concentration of 3110 mg/kg (dry weight) (page 35 of
the Ri report).
Metal uptake by plants is directly proportional to the
solubility of the metals in soil (Logan and Chaney 1983). Due
13 The aqueous solubility of PbCl2 i*s 9.9 g/L at 20/C (Weast
1973), making it a relatively soluble lead compound.
- 19 -
-------
to their relatively low water solubilities, the uptake by
lettuce of the lead compounds at the Granite City site will be
lover than in the Bassuk study where PbCl2 was used. The
extent of lead uptake by lettuce plants determined using the
more soluble PbCl2 cannot therefore be used as a measure of
uptake of the relatively insoluble Granite City site lead
compounds.
Moreover. no data were provided in the Bassuk study on
the simple relationship between soil lead concentration and the
extent of lead uptake by the lettuce. All the data are
concerned with the effect of phosphorus on this relationship.
What would have been more relevant to the site would have been
a determination of the relationship between lead in soil and
lead uptake unconfounded by the added factor of the phosphorus.
To ignore the effect of phosphorus and simply apply the data to
the site as a guide to the relationship between soil lead
concentration and plant uptake is not scientifically valid.
Finally, nowhere in the Bassuk study are there any
data to support selection of 500 ppm lead in soil as an
acceptable remedial level based on agricultural or other land
use. In fact, the data provide no basis for differentiating
between 500 ppm and 1,000 ppm soil lead remedial objectives
based upon lettuce uptake.
- 20 -
-------
2. The Spittler and Feder Study.
The Spittler and Feder (1979) study similarily cannot
be used as a valid basis for setting Granite City site clean-up
objectives. The study was designed to determine the
relationship between lead uptake by various common garden
plants and the concentration of lead in urban soils. While the
results clearly show the dependence of lead uptake on soil lead
concentrations under the study conditions, the design of this
experiment makes it of questionable relevance to the Granite
City site. Moreover, the failure to document study conditions
which would increase the bioavailability of the lead studied
means the results cannot appropriately be applied to Granite
City.
The major problem with the Spittler and Feder study is
that it was conducted in a greenhouse rather than a field
setting. It has been shown that.the uptake of certain metals
such as Zn, Cd, and Mn by plants is up to 5 times higher in
greenhouse studies than in field studies (Logan and Chaney
1983). It is probable that lead is also subject to this
phenomenon and the amount of lead actually observed .in the
field (i.e. garden) would be expected to be lower than observed
in the Spittler and Feder greenhouse study.
This "greenhouse effect" is the result of several
factors. First, the use of NH4-N fertilizers in pots in the
greenhouse has the effect of lowering fhe pH of the soil
directly adjacent to the plant roots. This results in higher
- 21 -
-------
metal solubility, and consequently greater bioavailability
(Logan and Cheney 1983). Abnormal watering patterns and the
relative humidity of a greenhouse contribute to this effect.
In contrast, the naxirmrr growth rates achieved within a
greenhouse cannot be achieved in Granite City because such
conditions do not exist naturally. Therefore, lead uptake in
Granite City vegetables will be lower.
The description of study procedures presented in
Spittler and Feder was clearly inadequate to determine whether
the conditions responsible for the greenhouse effect were
present. Consequently, the study results are not likely
characteristic of growth conditions in a typical urban garden,
but of greenhouse conditions that would result in higher uptake
levels. Without specific details on study conditions, it is
improper to rely on these data to predict garden vegetable lead
uptake levels.
Moreover, several additional factors important for the
determination of the bioavailability of lead in soil were not
addressed in the study. The most important of these factors is
the pH of the soil. As the soil pH decreases, the solubility
of metal compounds typically increases, causing an increase in
bioavailability (Logan and Chaney 1983). No soil pH data were
given in the study. Without such data, it is not possible to
use the study to predict the extent of lead uptake by plants in
other areas, including Granite City.
- 22 -
-------
As the Bassuk (1986) study demonstrated, the
concentration of phosphorus in the soil also has a pronounced
effect on the extent of lead uptake by lettuce. Specifically,
as the concentration of phosphorus in soil rises/ the amount of
lead taken up by lettuce decreases. Since Spittler and Feder
(1979) did not measure the phosphorus concentration of the
soils used to conduct their study, it is not possible to
determine how widely applicable their data are. This is a
particularly critical point, because serious vegetable
gardeners routinely amend their soils with organic and
inorganic fertilizers, mulches, and other additives, the
majority of which would act to reduce lead solubility and plant
uptake.
The study also fails to analyze the nature of the lead
compounds that were accumulated from the soil by the crops.
The lead compounds at the NL Granite City site are relatively
insoluble, having been weathered in the years since their
original release as a result of smelting operations. The lead
compounds contained in the soils used by Spittler and Feder
were-likely derived from lead paints and auto exhaust. In the
case of auto exhaust at least, the lead compounds are likely
halides and mixed lead halide/ammonium halide double salts
(U.S. EPA 1986), which will be much more soluble than the NL
Granite City site lead compounds (Budavari 1989), and therefore
have greater bioavailability.
- 23 -
-------
The final problem with EPA's reliance on this study is
that the study contains absolutely no rationale or support for
selecting the 1000 ppm and 500 ppm advisory soil lead levels.
These guidelines were simply stated to have been recommended to
the Boston Gardening Community. There was no assessment of the
risks that pertain to such soil lead levels and they were
presented without derivation. Based on the lack of
substantiation for the selection of these levels, and the fact
that the experiment conditions under which the study was
conducted were not similar to conditions at the Granite City
site, the use of this study to set lead clean-up levels for
Granite City is clearly not supported by the data presented.
The obvious conclusion is that the IEFA study of the Granite
City garden vegetables is a more appropriate site-specific site
evaluation of lead uptake in Granite City vegetable gardens.
a. Application of the Spittler and Feder
results to Granite City shows no
increase in lead exposure.
Even if one were to accept Spittler and Feder's uptake
calculations for lettuce and other vegetables, which is clearly
not recommended, the following calculations show that the
resultant blood lead increase projected by the study for
Granite City residents is not of concern. Spittler and Feder's
study shows that lettuce grown in greenhouse conditions in
Boston garden soil at 1,000 ppm lead contained 55 pprn dry
weight, and 3.14 ppm wet weight.- Values for 500 ppm were 30
- 24 -
-------
ppm dry weight, and 1.71 ppm vet weight. Values for radish
tops (a possible surrogate for other vegetable types) were
approximately 50% of the lettuce values, and radish root even
less. The EPA Exposure Factors Handbook (EFH 1989) summarizes
adult dietary intakes as 200 g per day of total vegetable
consumption, 40 g of which are lettuce. The handbook also
presents a reasonable worst case, whereby 80 g per day of
vegetables are homegrown over 50% of the year, or 40 g per day
on a yearlong basis (10 g as lettuce). Thus, for a garden plot
containing 1,000 ppm soil lead, the increase in blood lead due
to consumption of the garden vegetables is as follows:
ppm fresh increase
weight ug Pb/inqested/day blood Pb*
lettuce 3.1 31 0.99
other vegetables 1.5 45 1.44
Total 76 2.33
* U.S. EPA (1989): blood lead increases 0.032 ug/dl per
ug lead ingested for adults
The increase at a corresponding 500 ppm soil lead would be
approximately 1.2 ug/dl.
It is not probable that young (ca. 2 year old)
children would consume fresh vegetables at these rates. A 7 kg
child (10% adult weight) who did so proportionally on a body
weight basis would ingest 7.6 ug lead per day, and absorb 3.8
ug approximately. The children's relationship between absorbed
lead and blood lead is 0.38 ug/dl per ug absorbed (alsp from
the U.S. EPA (1989) OAQPS biokinetic model) or 1.4 ug/dl blood
- 25 -
-------
lead increase at 1,000 ppm coil lead and 0.7 ug/dl at 500 ppm.
In the context of projected baseline blood lead of 5 ug/dl and
the exaggeration of lead/plant uptake by the Spittler and Feder
study design, these estimated increases in blood lead are of no
concern. Therefore, neither the study nor its predicted impact
in Granite City provides a basis for a 500 ppm soil lead
clear. -up standard.
B The Madbavan Study Is Drawn From A Biased Sample
Of Outdated Studies And Does Not Support EPA's
Clean-Up S
The third study, (Madhavan, Rosenman & Shehata) cited
by EPA to support Alternative H relies entirely upon older,
pre-1975 data on lead exposures and ignores more recent data
suggesting that the contribution of soil lead to children's
blood lead may be substantially lower than originally thought.
As discussed in the preceding section, downward trends in the
level of lead exposure in the United States render the Madhavan
conclusions of questionable contemporary significance. Zn
addition, the study selection method used by Madhavan et al.
was biased and used an invalid data point.
Madhavan et al. used a compilation of studies on blood
lead and soil exposure conducted primarily before 1975
contained in Duggan (1980). In Duggan's analysis of the
available literature, 21 blood lead/soil and/or dust lead
correlation studies were listed, with correlation slopes for
the contribution of soil and/or house dust lead, ranging from
- 26 -
-------
1.6 to 14 ug/dl per 1000 ppm soil lead (some of which represent
averages of replicate studies within a single cited source).
Duggan (1980) selected 19 of these values which showed a
statistically significant difference in the range of soil lead
concentrations measured; and derived an estimated increase
(both arithmetic mean and median) of the order of 5 ug/dl per
1000 ppm of soil or dust lead (p. 316).
Madhavan et al. selected only 8 of the 21 individual
blood lead/soil lead correlation estimates, ranging from 0.6 to
65.0 ug/dl per 1000 ppm, from the Duggan compilation for their
analysis. The intent was to isolate uptake in children less
than 12 years of age ("... the most susceptible group to lead
toxicity"...) and to eliminate the influence of other sources
of lead exposure (house dust was cited, p. 138). No other
justification was provided for the selection of these eight
values. In fact, Duggan (1980, p. 312) notes that there was no
clear separation of the slope values seen in soil studies vs.
house dust studies. This opinion was confirmed by U.S. EPA
(1989). Thus, the basis for study selection in the Madhavan et
al. analysis is questionable, particularly the exclusion of
house dust studies because these studies would include lead
from the soils as well. This diminishes the statistical
confidence of the resulting estimate of slope.
Kadhavan et al. also determined a geometric mean
(based on an assumption of lognormal blood lead distribution)
•
for the 8 studies taken from Duggan (1980) of 3.41 ug/dl per
- 27 -
-------
1000 pptn soil lead with a geometric error of 1.75 ug/dl. An
upper bound 95% confidence limit of 8.5877 ug/dl per 1000 ppm
is reported. Examination of the table in Duggan (p. 313) from
which the 65.0 ug/dl per 1000 ppm value (from the Angle et al.
reference) was selected by Madhavan indicates that the soil
lead residue range was considerably less than 1000 ppm (97 to
219 ppm), and that the variation was not considered
statistically significant. Thus, this value cannot be
considered a "slope" describing the incremental contribution of
increasing levels of soil lead to blood lead, as mistakenly
represented by Madhavan et al'. (p. 139, Table 1). It
represents only an estimate of blood lead obtained by
extrapolation from a single soil lead level typical of urban
background levels, and measured blood lead levels of 14 to 22
ug/dl, to a hypothetical soil lead level of 1000 ppm.
Derivation of a valid correlation slope requires that
the independent variable(s) be measured over a statistically
significant range of values, encompassing the entire range of
interest. It is therefore inappropriate to include the value
of 65.0 ug/dl per 1000 ppm in the statistical treatment of
estimated slopes, because it is not a slope. Neither Duggan
(1980, p. 316) nor U.S. EPA (1986) included this value in their
analyses of soil lead uptake in children. Furthermore, 65
ug/dl of children's blood lead represents a potential effect
level for lead toxicity in children for effects including
« •
anemia and neurotoxicity (ATSDR 1988, CDC 1985). Such readily
- 28 -
-------
observed toxicity indicated in Madhavan et al. to be associated
with soil lead levels of 1000 ppcn is not consistent with public
health investigations conducted in Granite City (as reviewed in
the Granite City RI report), which did not reveal elevated lead
exposure. Nor is it consistent with clinical manifestations of
toxicity noted in other reviews, including CDC (1985) and EPA
Air Quality Criteria for Lead (1986).
Excluding the highest value in the Madhavan et al.
(1989) data set from the calculation (65.0 ug/dl per 1,000
ppm), reduces the 95% upper confidence estimate of the slope to
4.52 ug/dl (Madhavan et al. 1989, p. 140)). This would
correspondingly increase the maximum permissible soil lead
level derived by the Madhavan et al. (1989, p. 140) approach to
1200 ppm, rather than the 600 ppm level proposed in the study.
This soil lead level is clearly inconsistent with the 500 ppm
level proposed by EPA.
The Madhavan study has also erroneously assumed that
lead uptake is linear with concentration to reach their
proposed 600 ppm level. Madhavan et al. presents a table which
assumes a linear relationship between blood lead and soil lead
down to a slope of 1 ug/dl per 116 ppm soil lead. The basis
for this assumption of linearity, however, is not provided. In
fact, in citing the Centers for Disease Control (CDC, 1985)
review of some of the sane information utilized by Duggan
(1980), Madhavan et al. appear to contradict their own
assumption of linear uptake. Specifically, CDC concludes: "In
- 29 -
-------
general, lead in soil and dust appears to be responsible for
blood lead levels in children increasing above background level
when the concentration in the soil or dust exceeds 500-1000
ppm." This statement clearly suggests that soil lead of less
than the 500 to 1000 ppm range does not result in observable
blood lead increases.
Choosing 5 ug/dl as a "tolerable" level of blood lead
to be added to baseline blood lead, Madhavan et al.(1989,
p. 140) present the associated value of 600 ppm of soil lead
from their linear analysis as a protective level, adding the 5
ug/dl incremental blood lead increase to 1976 - 1980 baseline
blood lead medians of 16 and 20 ug/dl. Since the U.S. EPA
Review of the NAAQS for Lead (1989) determined that 1990 blood
lead values in children should be of the order of 5 ug/dl
(p. C-14) the 600 ppm level is obviously significantly
overprotective.
1. A correct analysis of the Kadhaven data
supports the 1,000 ppir clean-up standard.
Utilizing data from Stark et al. (1982) and Rabinowitz
and Bellinger (1989), further supported by the CDC's ASARCO
study (Johnson and Wijnberg 1988), as well as estimates of
current base-line lead exposure, it is possible to utilize the
approach of Madhavan et al. to derive an alternative clean-up
objective for soil lead in Granite City based on more
contemporary data.
- 30 -
-------
Rounding the slope of the Stark et al. (1982) and the
Rabinovitz and Bellinger (1988) high mouthing behavior study
group to 2.0 ug/dl per 1,000 ppm lead, and adding 1.0 ug/dl
(two standard errors on the geometric mean of the Rabinovitz
and Bellinger (1988) study), it appears that exposure of a
child with high hand to mouth behavior to soil lead levels of
the order of 1,000 ppm will add approximately 3.0 ug/dl to
baseline blood lead &s an upper bound estimate using
contemporary data.H In view of recent projections (U.S. EPA
1989) that the national mean baseline blood lead concentration
in young children may be up to 5.2 ug/dl (geometric mean), an
upper bound estimate of childrens' blood lead resulting from
exposure to 1,000 ppm soil lead appears of the order of 8.2
ug/dl. This level is below the blood lead level of 10 ug/dl
incorrectly cited by Madhavan et al. (1989) as a lowest
observed adverse effect level based on ALAD inhibition, and
14 Madhavan states that data on estimates of the amount of
soil ingested by children show a 100-fold variation and
thus are not useful in deriving a "safe" soil level for
lead. Therefore, Madhavan et al. use information only on
the relationship between blood lead concentration and
soil concentration to derive their criterion. However,
the sources cited by Madhavan et al. (1989) show good
consistency in estimated soil ingestion rates (EFH,
1989). Both the Binder et al. (1986) and Clausing et al.
(1987) studies directly measured children's coil
ingestion in controlled experiments, and show less than a
two-fold variation in mean daily soil ingestion rate (127
- 230 mg/day). Thus, an additional approach to lead
-• exposure analysis was rejected incorrectly, even though
U.S. EPA (1989) successfully used such an approach in
developing its validated biokinetic lead exposure model.
- 31 -
-------
considerably less than the 25 ug/dl represented by these
authors to result from exposure to the 600 ppm maximum
permissible soil lead level under the worst case conditions
presented in that study.
A margin of uncertainty of approximately 2 ug/dl or
more thus exists between the upper bound blood lead estimate of
8.2 ug/dl for exposure to 1,000 ppm soil lead and the Madhaven
et al. 10 ug/dl lowest observed effect level for ALAD
inhibition. This will allow for protection of site-exposed
individuals who are at the upper end of both the 1990 baseline
blood lead distribution (estimates of the geometric standard
deviation were not available for the current mean estimate but
are most likely to be less than the 1976 value of 1.4) and soil
lead uptake distribution from overt lead toxicity (as opposed
to ALAD inhibition alone). In consideration of the fact that
the baseline blood lead already contains a contribution from
baseline soil exposure of approximately 1 to 1.5 ug/dl from
background soil lead of 180 ppm (calculated from Table 4-2,
U.S. EPA 1989), the 1,000 ppm soil lead residues at the
Taracorp/Granite City site will not represent a source of
adverse health effects for the worst case exposure population.
C. The Cincinnati Work Plan Cited By EPA As Support
For Its 500 ppm Level Also Has No Bearing On
Granite City Conditions.
EPA has also cited the'Cincinnati Soil Lead Abatement
Work Plan as support for Alternative H. The Work Plan was
- 32 -
-------
developed as part of the Cincinnati Soil Lead Abatement
Demonstration Project, one of three such projects authorized by
Section III(b) of SARA, which provides for: "a pilot program
for removal [and] decontamination ... with respect to
lead-contaminated soil in ... metropolitan areas." See
generally Clark, et al., "The Cincinnati Soil-Lead Abatement
Demonstration Project" (1989).
EPA's reliance on a lead-in-soil level used in a pilot
program as authority for the selection of a cleanup objective
for a National Priority List site is misplaced. The scientists
carrying out the pilot study design their experiment to suit
their hypotheses, and are free to do so with no regulatory,
statutory, or other legal constraints. They could choose to
examine the impact of absolutely any level of lead-in-soil. In
contrast, in selecting a remedy for the Taracorp/Granite City
site, the EPA must comply with the National Contingency Plan,
Section 121 of SARA and the Consent Order.
Moreover, the Cincinnati project is designed as a
research program to address several questions, first and
foremost: "Does soil lead and exterior dust abatement in
rehabilitated [lead paint-free] housing ... result in a
statistically significant reduction in blood lead of children
relative to children ... in a control area...?" Clark, at 292.
The researchers would be inclined to abate lead-in-soil to a
relatively low level, to insure that there will be a real
«
statistically significant difference between -the experimental
- 33 -
-------
and control groups. It does not follow at all that the pilot
program cleanup level should be applied to Superfund cites. To
the contrary, funding of the pilot program may indicate
Congressional awareness of the need for research in this field,
and the lack of scientifically established remedial references.
Even if the Cincinnati work plan cleanup were carried
out in Granite City, it does not go as far as Alternative H.
The excerpts from the Cincinnati Work Plan state that the study
areas selected had "the presence of a minimum [undefined]
number of children under four years of age and the presence of
lead contaminated soil" (p. 4-27). Thus, unlike Alternative H,
which proposes a universal cleanup without reference to a
protected population, the Cincinnati pilot program targets
children under four years old. No such differentiation among
affected residents has been proposed in Alternative H,
indicating a substantial degree of overprotection at an
extremely high cost.
D. EPA's Reliance On Other Records Of Decision To
Select A Cleanup Level For The Taracorp Site
Contravenes The Interim Guidance And Is
Scientifically Inappropriate.
The purpose of the Interim Guidance is to require a
site-specific analysis for selection of a clean-up level.
EPA's asserted reliance on other Superfund Records of Decision
(RODs) to select a clean-up level for Granite City not only
contravenes this policy, but leads to an absurd result. This
is obvious when the United Scrap Lead ROD* is carefully analyzed.
- 34 -
-------
The United Scrap Lead site only required removal of
1600 cubic yards of soil to achieve a 500 ppm level. In
contrast, Alternative H would require removal of approximately
160,000 cubic yards of soil, resulting in adverse impacts to
the community which were never considered at the United Scrap
Lead Site. Moreover, since the United Scrap Lead site is
located in a rural area, any adverse impacts from excavation
and disposal of soils on the population would be minor, as
opposed to Granite City, where the area to be remediated is
densely populated. The United Scrap Lead site had additional
pathways of potential exposure as well, via surface water and
groundwater, which are not present in Granite City. Clearly,
EPA's reliance on this ROD to support its 500 ppm clean-up
level falls short of any reasonable scientific justification.
V. ALTERNATIVE H IS NEITHER COST EFFECTIVE
NOR TECHNICALLY FEASIBLE.
EPA's premature release of Alternative H prevented
O'Brien & Gere, the engineers approved under the Consent Order,
and the persons with the most knowledge and expertise about
site from finalizing the feasibility study. Therefore, cost
and technical data supporting EPA's proposed Alternative H were
not analyzed by O'Brien 6 Gere before they were released to the
public. As a result, the cost of Alternative H and tine period
for implementation have been significantly underestimated by EPA
and technical roadblocks to implementing this Alternative were
completely overlooked.
- 35 -
-------
EPA's fact sheet on clean-up alternatives estimates
that the total cost for implementing Alternative H is $25
million. The implementation time is proposed to be 1.5 to 2.5
years. The actual cost of Alternative H vill be close to $30
million with an implementation time of 7 years. In contrast,
Alternative D is estimated to cost $6.8 million with an
implementation time of 1 to 2 years.
The assumptions and methods used by NL to calculate
the actual cost and implementation time for Alternative H are
explained below.
A. Cost Estimate.
To determine the impact of adding the additional
residential properties to the remediation area proposed in
Alternative H, each block identified by the USEPA was evaluated
by O'Brien 6 Gere. Aerial photographs taken during 1988 were
generated at approximately 100 scale and the area occupied by
each block (curb to curb) was calculated. In addition,
*
estimates were made on the amount of unpaved surface on
residential lots or alleys adjoining those lots. Exhibit C
presents a Figure with the numbered blocks as well as a Table
which includes the estimated unpaved residential surface area
targeted for remediation.
The estimated cost of $30 million assumes a pavement
to sod ratio of 1:2 to reflect the residential driveways and
the unpaved alleys through the middle of many blocks. The unit
- 36 -
-------
costs for excavation vere based on excavation of 50% of the
material by small equipment (Bobcat or equivalent) and 50%
manually. A drive-by survey of the targeted areas suggests that
the teaming of laborers with a light piece of equipment is the
method the contractor would use. The combined excavation cost
derived from Means .1989 Site Work Construction Cost guide
(Means) averaged 131/CY. For the purposes of the Feasibility
Study a combined cost of 145/CY was presented. The incremental
cost was added to reflect reduced production resulting from
tight working conditions associated with minimizing damage to
property and shrubs, as well as anticipated supplemental safety
requirements. Restoration costs were based on site specific
information and unit costs included in Means (see Exhibit D).
Exhibit D presents the detaile'd cost estimate for
Alternative H using the same presentation format that was used
in the Preliminary Draft Feasibility Study. The total
estimated cost of $30 million prepared using these methods is
approximately 20% higher than the EPA's published value. The
difference in costs is due to the methods utilized to estimate
areas for remediation. O'Brien and Gere conducted a block by
block tabulation of the area from aerial photographs while EPA
simply scaled up the costs developed by O'Brien 6 Gere for
Alternative D. In addition, EPA's estimate does not appear to
include costs for remediating unpaved alleys and sidewalks in
residential areas. Although a 20% deviation in costs during
the Feasibility Study is within the range expected at this
•»•
- 37 -
-------
stage in the project, the actual difference of $5 million is
substantial. For budget purposes a $30 million value is
considered more appropriate than the $25 million value proposed.
by the U.S. EPA.15
B. Implementation Time.
The USEPA's fact sheet estimated that the
implementation of Alternative H would require 1.5-2.5 years.
Prior to the Public Hearing, calculations were conducted to
provide an indication of project duration. Those calculations
resulted in approximately seven years from authorization to
begin design to contract closeout. The project duration can be
separated into three phases: design, excavation/transport, and
installation of the Taracorp Pile cover.
1. Design.
Final design will require supplemental sampling of
each of the residential properties according to EPA comments at
the February 9. 1990 public hearing. The areas to be evaluated
include somewhat in excess of 1600 residences based on the
aerial survey. Obtaining access for sampling, sampling,
analyses, data validation and reporting is expected to take at
least six months. Preparation of design documents, bid
15 The $30 million figure does not include any additional
monies necessary to purchase additional property for the
expansion of the Taracorp pile proposed in Alternative H.
See Section V, D.
- 38 -
-------
preparation, contractor selection and award is expected to take
an additional six months. This results in a one year design
process.
2. Excavation/Transport.
The excavation and transport of approximately 160,000
cubic yards of soil to the Taracorp Pile is the major component
of this project. Movement of SLLR piles and the removal of
contained lead bearing wastes to recycling facilities are
expected to require a short period of time and be able to be
conducted simultaneously with other activities. Therefore,
these activities were not factored into the estimated time
frame.
A preliminary time estimate was prepared prior to the
February 8 public meeting, by evaluating the production of a
work crew consisting of four laborers, and an equipment
operator using production rates quoted in Means. The results
suggested that each residential property might require 5 days
to complete the excavation of 6 inches of soil, replacement of
6 inches of soil, sodding/paving, and the replacement of shrubs
as well as other incidentals. NL Industries' experience with
similar cleanups suggests that the actual time might be closer
to six days/residence. For preliminary estimating purposes a
value of 5.5 was used. Remediation of 1690 estimated
properties results in 9300 work days for a single crew. This
is equivalent to 53 years when -corrected for a five day work
- 39 -
-------
week, 50 week work years, and 70% of the work days suitable for
construction (reasonable weather conditions).
While sequence of construction will be determined by
the contractor, for an initial estimate it was assumed that a
particular work crew would have responsibility for both
excavation and restoration of a given property. Each crew
could send an estimated three truckloads of soil to the
Taracorp pile/day during the 3.5 days estimated for excavation
at each property. Using a round trip time of l hour between
arrival at the residence for soil pickup and return to a
residence for soil pickup results in eight 10 CY loads per day.
Therefore, a truck could service three crews during excavation.
The number of crews which could work simultaneously
may be limited by Granite City and would also be limited by
truck access to the Taracorp Pile. Concerns raised at the
public hearing suggest that vehicles leaving the Taracorp site
will likely have to go through sufficient decontamination to
prevent tires from tracking dust throughout the city. It was
assumed that the time required to enter, dump, decontaminate,
and leave the Taracorp site was 20 minutes. Using the
staging/decontamination locations limits truck traffic to 48
loads per day. This traffic loading would allow a maximum of
16 crews to be excavating at any given time. Because the
loading and unloading is unlikely to be perfectly scheduled, it
was assumed that the contractor would elect to use twelve crews
and thus minimize truck waiting time at4 the pile.
- 40 -
-------
Applying twelve five man crews to the project
supported by four full time trucks, resulted in an estimated
residential excavation time of 53/12 or 4.4 years. Additional
time will be required to excavate material from the alleys in
Venice Township and Eagle Park Acres. Based on these
calculations/ an excavation/restoration period of 5 years was
estimated.16
3. Installation of the Cap.
The time required to cap and close the pile after the
soil transport is completed is estimated at one year. This
time frame would include finish grading of the pile,
installation of the two foot clay barrier, the synthetic
membrane, drainage layer, filter fabric, root zone, and seeded
topsoil. This assumes that during the soil transfer operations
compaction and grading were ongoing with only marginal
modifications expected during cover installation.
The time required to complete Alternative H within the
budget estimate of $30 million is thus estimated at
16 The time frame is substantially more than 1.5-2.5 years
estimated by the USEPA. The USEPA did not provide any
calculations to support the proposed implementation
schedule, therefore, critical review is impossible.
However, given the geometry of the existing Taracorp
Pile, its relationship to 16th and State Street, and the
need to minimize dust tracking through the city, it is
unlikely that truck throughput could be increased
substantially beyond that assumed. Using this method of
estimating and crew size, the time frame to do a city
block would range from 2-3 weeks• depending on the block
size.
- 41 -
-------
approximately seven years, compared to one to two years for
Alternative D. This increase is not unexpected when one
considers that the estimate for Alternate D of 1-2 years
includes only 220 residential properties to a depth of 3" while
Alternative H includes 1690 properties to a depth of 6".
C. EPA Failed To Consider The Technical
Infeasibilitv Of Implementing Alternative H.
Even more eggregious than the errors in EPA's cost and
implementation time estimate is EPA's failure to address the
technical obstacles to implementation of Alternative H.
Alternative H proposed to dig up soils from Areas 3 through 8
with lead levels greater than 500 ppm in residential areas and
place the soils on the existing Taracorp pile. The pile will
then be capped. EPA has erroneously assumed, however, that
excavated material can be disposed on the Taracorp pile. The
placement of an additional 160,000 cubic yards of soil on an
85,000 cubic yard pile will violate USEPA guidance for side
slopes on waste piles17 and impair the physical integrity of
the site. Therefore. EPA's option is to purchase the adjacent
lot occupied by TriCity Trucking for disposal (which is in a
100 year flood plain) or dispose of the additional soil
off-site. Off-site disposal will increase the cost of
Alternative H by an additional $5 million. Expansion of the
.Taracorp pile into a flood plain is truly nonsensical, if the
17 EPA 625/6 - 85/006 at p. 3-20.
- 42 -
-------
purpose of this project is to prevent releases of lead into the
environment.
Moreover, EPA's proposed Alternative H results in a
five-fold increase in the areas to be remediated when compared
to Alternative D. This enormous area of off-site remediation
was never contemplated by O'Brien & Gere, and was only proposed
by EPA after O'Brien & Gere's RI/FS work had been completed.
Consequently, the remedial investigation does not include
enough data points to identify and define the appropriate
extent of Areas 4-8 to be remediated.
EPA's remedial Alternative H partially relies upon
"Soil A" sample data selected from the "Study of Lead Pollution
in Granite City, Madison and Venice, Illinois" (1983),
p. 28-30. The IEPA report presented four distinct soil sample
classifications or groups. "Soil B" samples, "which were
intended to indicate levels to which children would most likely
be exposed, were taken from open dirt areas in yards,
playgrounds, etc." The soil B samples split between IEPA,
IDPH, and USEPA were not considered during the development of
Alternative H, however.
Moreover, the biased limited sampling data offered by
USEPA to support such remediation was not reviewed in the RI.
Amazingly. EPA has relied on only five residential soil samples
to require the remediation of almost 600 residences in Area 4,
and seven soil samples for the remediation of Area 8, which
«
includes over 600 residences. It is clear that such limited
- 43 -
-------
sampling provides an insufficient basis for the massive scale
soil removal program proposed by EPA in Alternative H.
VI. ALTERNATIVE H'S INCREASED RISK TO RESIDENTS AND
ADVERSE IMPACTS ON THE COMMUNITY AND THE ENVIRONMENT
ARE NOT JUSTIFIED BY THE MINIMAL PROTECTION IT
PROVIDES.
Implementation of Alternative H will result in the
excavation and disposal of 160,000 cubic yards of soil compared
to 23,000 cubic yards for NL's proposed Alternative D. EPA
admits that the "amount of digging required could expose the
community to contaminated dust." (EPA Clean-up Alternatives.)
What it has not analyzed or made clear to the public is that
Alternative H will have significantly more adverse community
and environmental impacts than Alternative D.
First, Alternative H will require almost 40,000 Dump
Truck Traffic loads traveling on Granite City streets, compared
to 6900 loads for Alternative D. This results in a 600%
increased risk of traffic fatality or injury — which is a far
more adverse impact than any increased lead exposure from a
1,000 ppm rather than 500 pptn clean-up level. Moreover, the
adverse impact from air pollution due to vehicle emissions and
unavoidable lead emissions from soil in dumptrucks as they
travel through Granite City roads has not been considered.
Furthermore, excavation of this enormous volume of
soil will have substantial construction impacts on the
community with little benefit in return. Residents will be
subject to noise, debris, traffic, parking restrictions, dust
- 44 -
-------
and the general - inconvenience of construction for several years
as the project proceeds. It is difficult to even imagine the
scale of a soil removal program encompassing 97 city blocks,
let alone the consequences for the residents living through
it. 18
Section 121(b)(l)(b) of CERCLA, 42 U.S.C.
S 6921(b)(l)(b), requires that when assessing remedial actions
EPA shall, at a minimum, take into account the potential threat
to human health and the environment associated with excavation,
transportation, and redisposal, or containment. The National
Contingency Plan similarly requires that the method and cost of
mitigating adverse impacts be taken into account and that
alternatives that have significant adverse effects with very
limited environmental benefits should be excluded from further
consideration. 40 C.F.R. $ 300.68(g)(3), and (h)(vi). EPA has
not provided any information in this record explaining how it
proposes to mitigate the adverse impacts from this massive
construction and excavation project, which will unavoidably
increase lead emissions in the Granite City community. Nor has
it provided valid scientific support for the implementation of
a 500 ppm clean-up level. The failure to analyze the
18 In addition, EPA has not analyzed the impact on surface
water and groundwater from its proposed use of wetting
agents and surfactants to control dust during excavation.
The cost of purchasing these materials as well as
... treating their discharge has not been addressed or
included in EPA's cost estimate. *
- 45 -
-------
consequences of Alternative H on the Granite City community or
justify the use of a 500 ppm clean-up level not only violates
CERCLA, but the public's trust in EPA.
VII. CONCLUSION
NL has demonstrated in these comments that EPA's
selection of Proposed Alternative H has no valid technical or
scientific justification and falls far short of CERCLA's
requirement of a cost effective remedy which will protect
public health and the environment. In contrast, Alternative D
will not only protect the residents of the Granite City
community and the surrounding environment, it is- cost effective
and technically feasible in terms of project duration and
ability to remedy and prevent future releases of lead into the
environment.
NL performed a three-pronged site-specific risk
assessment with detailed scientific references and provided the
Agencies with numerous recent studies and information on lead
exposure in support of the implementation of Alternative D. To
support Alternative H, EPA relied on extremely limited data,
which consisted of generic vegetable uptake studies irrelevant
to the site, an outdated lead exposure review, a Superfund
Record of Decision and a pilot program for lead remediation
which has not even been completed. These comments demonstrate
that each of these studies was irrelevant to Granite City
conditions and/or based on outdated information on lead
- 46 -
-------
exposure prior to the phasedown of leaded fuels. Morover, EPA
has completely failed to address the substantial adverse
impacts on the community from the enormous excavation and
construction required in Alternative H or the methods to
mitigate such impacts.
When the record is reviewed as a whole, it is clear
that EPA has no support for the selection of Alternative H as a
remedy at the Taracorp site. Selection of such remedy and
rejection of Alternative D is arbitrary and capricious,
violating the requirements of CERCLA and the Administrative
Procedure Act governing federal agency action.
- 47 -
-------
REFERENCES CITED
ATSDR. 1988. Toxicological Profile for Lead (draft). Agency
for Toxic Substances and Disease Registry. U.S. Public Health
Service. Atlanta, GA.
Bassuk, N.L. 1986. Reducing Lead Uptake in Lettuce.
HortScience. 21:993-995.
Binder, £., D. Sokal, and D. Maughan. 1986. Estimating Soil
Ingest ion: The Use of Tracer Elements in Estimating the Amount
of Soil Ingested by Young Children. Arch. Erviron. Health.
41: 341-345.
Budavari, S. 1989. The Merck Index, llth ed. pages
852-853. Merck & Co., Inc. Rahway, NJ.
Cincinnati Soil Lead Demonstration Project, EPA No. VOO 5035-01
Clark, et al., The Cincinatti Soil-Lead Abatement
Demonstration Project. Proceedings of Lead in Soil: Issues
and Guidelines, Supp. to Vol. 9 (1989). Environmental
Geochemistry and Health.
Clausing, P., B. Brunefcreef, J.H. Van Wijnen. 1987. A Method
for Estimating Soil Ingestion by Children. Int. Arch, of
Occup. Environ. Health. 59:73-82.
Duggan M. 1980. Lead in Urban Dust: An Assessment. Water,
Air, and Soil Pollution. 14: 309-321.
EFH. 1989. Exposure Factors Handbook. U.S. EPA Office of
Health and Environmental Assessment, Washington, DC 20460.
EPA/600/B-89/043. July 1989.
HHEM. 1989. Risk Assessment Guidance for Superfund. Volume
I. Human Health Evaluation Manual (Part A). Interim Final.
page 6-31. U.S. EPA Office of Emergency and Remedial Response,
Washington, DC 20460.
IEPA. 1983. Study of Lead Pollution in Granite City, Madison
and Venice, Illinois. Illinois Environmental Protection
Agency, Springfield, IL 62706. April, 1983.
Johnson, T. and L. Wijnberg. 1988. Statistical analysis of
lead exposure data collected in East Helena, Montana: Draft
report. PEI Associates, Inc. Durham, N.C., January, 1988. (as
cited in U.S. EPA 1989).
-------
Logan,.T.J. and R.L. Chaney. 1983. Proceedings of the 1983
Workshop on Utilization of Municipal Wastevater and Sludge on
Land. Eds. A.L. Page et al. pages 256-257. University of
California. Riverside, CA.
Madhavan, S., K.D. Rosenman, and T. Shehata. 1989. Lead in
Soil: Recommended Maximum Permissible Levels. Environ.
Research. 49:136-142.
0'Flaherty, E.J. 1981. Toxicants and Drugs: Kinetics and
Dynamics, page 287. John Wiley & Sons, New York, NY.
Rabinovitz, M.B.and D.C. Bellinger. 1988. Soil Blood-Lead
Relationship Among Boston Children. Bull. Environ. Contarn.
Toxicol. 41:791-797.
Spittler, T.M. and W.A. Feder. 1979. A Study of Soil
Contamination and Plant Lead Uptake in Boston Urban Gardens.
Commun. Soil Sci. Plant Anal. 10:1195-1210.
Stark, A.D., R.F. Quah, J.W. Meigs, E.R. DeLouise. 1982. The
Relationship of Environmental Lead to Blood-Lead Levels in
Children. Env. Res. 27:373-383.
U.S. EPA. 1986. Air Quality Criteria for Lead. U.S.
Environmental Protection Agency, ECAO/ORD. Research Triangle
Park, NC 27711. EPA-600/8-83/028dF. June 1986.
U.S. EPA. 1989. Review of the National Ambient Air Quality
Standards for Lead: Exposure Analysis Methodology and
Validation. (OAQPS Staff Report). U.S. Environmental
Protection Agency. Office of Air Quality. Research Triangle
Park, NC 27711. EPA-450/2-89-011. June 1989.
Weast, R.C. 1973. Handbook of Chemistry and Physics. 54th
ed. page B-101. CRC Press. Cleveland, OH.
-------
in
x
z
-------
AMCO Coal Company
295 S»*9M*i
tOXi
213
Pn.D
Environmental
October 26, 1989
Mr. Jonathan Z. Cannon
Acting Assistant Administrator
Office of Solid Waste and Emergency Response
US. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C 20460
Dear Mr. Cannon:
ARCO Coal Company, a division of Atlantic Richfield Company, submits the
attached comments on EPA's "Interim Guidance on Establishing Sofl Lead
Cleanup Levels at Superfund Sites" (OSWER Directive *9355.4-02), dated
September 7, 1989. lite Directive sets a cleanup level of 500-1,000 ppm for
total lead which the EPA considers protective for direct contact in residential
settings.
EPA states that it is adopting a recommendation ( "~Jead in sofl and dust
appears to be responsible for blood levels in children increasing above
background levels when the concentration in the soil and dust exceeds 500 to
1000 ppm" ) contained in the 1985 Centers for Disease Control (CDC)
document "Preventing Lead Poisoning in Young Children." Review of this
document mnft personal cffnniuntffition with CDC staff indicate that CDC
never intended the 500 to 1000 ppm statement to be considered a
"recommendation* and adopted as a sofl cleanup level There is no scientific
documentation in the CDC document or the EPA Directive to support the
interim cleanup level
Scientific justification must be provided by EPA in order to assure that any
sofl lead cleanup level is adequate to protect health. The Directive improperly
rejects use of the EPA Integrated Uptake Biokinetic Model which has been
demonstrated to be a reliable analytical method to determine the relationship
between environmental lead concentrations and blood lead concentrations in
EPA lead rulemakmg. In addition,' the Directive has not considered
background blood lead levels, target blood lead teve> after cleanup, population
of primary concern, fraction of the population to be protected, nature and
severity of health effects and factors which influence the bioavailabiliry of lead.
-------
Mr. Jonathan Z. Cannon
October 26, 1989
Page 2
If EPA uses the guidance document as it appears it was intended, the above
inadequacies could be at least partially remedied by site-specific studies, as in
an RI/FS leading to a remedial action. However, Region VTTI intends to use
the guidance as if it were a regulation, applying lead cleanup levels without
site-specific study.
ARCO understands EPA's need to set cleanup standards and to move forward
with Superfund cleanups as expeditiousry as possible. Yet, the basis of a soil
cleanup level for lead must be scientifically valid. Absent such validation, we
urge EPA to hold off on actions proposed to be conducted without regard to
establishing a scientific basis. Shortly, we will be sending you a proposed
methodology for deriving site specific soil lead cleanup levels. Our
methodology will include such factors as identification of the exposed
population, determining background blood lead concentrations, blood lead
levels contributed from soil health criteria, fraction of the population to be
protected and bioavailabiliry. We would appreciate the opportunity to meet
with you to discuss our methodology when it is completed.
We look forward to hearing from you at your earliest convenience regarding
the attachment and anticipate further discussion on sofl lead cleanup
methodology.
Sincerely,
Richard Krablin, PhD.
Manager
Environmental Projects
Attachment
DC J. L. Scberer/U3. EPA
W. K. Reflly/U.S. EPA
R L. Longest UAJ3. EPA
B. Diamond/US. EPA
-------
bpc: D. E. Pizzini/Montana Depanment of Health & Environmental Sciences
K. AJkema/Utah Department of Health
T. Vernon/Coiorado Department of Health
J. F. WardeU/EPA
R. L Duprey/EPA
-------
bpc P. D. Bergstroo
R L. Bflhara
R. L. Dem
J. R Deuuteb
L. D. Mflner
ECTkJball
W. R. Williams
B. L. Murphy/Gradient
G. N. Bigham/PTI
-------
ATTACHMENT TO LETTER TO JONATHAN Z. CANNON
DATED OCTOBER 26,1989
op Iptyrirn Owtfftnr? on HsfoMfehinp Soil Lc^d Q*^*y>up Levels
at Sunerfund Sites" fUS. EPA. Setrtember 7. 1989^
On September 7, 1989, the Offices of Emergency and Remedial Response and of Waste
Programs Enforcement of the U.S. Environmental Protection Agency (EPA) issued a
directive setting interim soil cleanup levels for lead at Superfund sites (Longest and
'Diamond, 1989). The stated range of soil lead concentrations (500 to 1,000 ppm) is
considered by these Offices to be "protective for direct contact at residential settings." The
directive further states that additional soil cleanup guidance wfll be developed after the
development of standard tootitity factors for lead (It* a Cancer Potency Factor and/or a
Reference Dose for non-cancer health effects.)
The Agency's establishment of this cleanup range, as presented in the September 7
directive, suffers from numerous methodological and technical deficknciei From a
methodological perspective, the Agency provides little basis for selection of this range.
-------
Instead, EPA states that h is adopting a "recommendation" of the Centers for Disease
Control (CDC). The EPA directive provides no discussion of the target blood lead levels
which would be expected following exposures to the soil cleanup levels, of the population
of primary concern, or of the fraction of the population that would be protected by use
of these guidelines.
EPA's inadequate technical basis is likely to reflect the limited technical justification
provided by CDC in its derivation of this range (U.S. DHHS, 1985). As presented in both
the EPA directive and the original CDC document to which the directive refers, the
500-1,000 ppm range is one which "appears to be responsible for blood lead levels in
children increasing above background levels." Neither CDC nor EPA discuss critical factors
for application of this soil lead range to site cleanup. Factors which should be considered
include the magnitude of expected increase above background blood lead, the background
blood lead level assumed, the nature and severity of health effects (if any) associated with
such increases, or the individual and population significance of these health effects.
Factors which influence the bioavaflabflfty of lead at specific sites, such as impacts of sofl
or other matrix composition (e^ mining wastes), on lead uptake must also be considered.
These concerns are presented in more detail in Comments 2 and 3 below.
In addition to providing insufficient «*?hnifal justification for the values it has selected, the
Agency's approach to setting these interim guidance levels ignores or inappropriately
-------
substantial available information on lead toncity, exposure, and risk. In
particular, EPA fails to acknowledge significant differences in exposure mechanisms
between fetuses (the primary population of concern for tow-level lead exposures - whose
exposure is determined by maternal exposures) and young children (who have the most
significant exposures to soil/dust lead due to enhanced soil/dust ingestion rates). The
Agency also improperly rejects the use of the Integrated Uptake/Biolrinetic (IU/BK) model,
which provides important insights into the relationships between environmental
concentrations of lead and blood lead levels. While EPA acknowledges the importance
of consideration of relative bioavailabflity of different forms and particle sizes of lead,
these data are not incorporated into the current cleanup guidance.
These comments as well as the appropriate incorporation of the IU/BK model and other
•generic and site-specific data into development of cleanup levels for lead are discussed in
more detail below.
Numerous methodotofjaj mtf ffiffriftyl defidenciq ftfft m EPA'« documentation
*J l»m ' I *n jrifl -* --- « -- «- ti\x * --- • l~ mnH
ajE a^^ft MyMM^Fi^^*a^^B fla^HM a^aa^^^K^ffn^3 I^Evr^CKK vaja^ ^a^^HD w^^ ^^ajla&
One of the most significant problems with EPA's proposed interim sofl lead cleanup
guidelines is its failure to provide either the rationale or bases for selection of the 500-
1*000 pom range as the range of concern. The Agency does not identify the population
-------
to be protected by these cleanup levels, e.g^ young children with elevated soil ingestion
rates or fetuses who may be more susceptible to the neurological effects associated with
lead exposures. EPA also does not relate the soil cleanup levels to blood lead levels or
advene health impacts of concern, it, the adverse heahh impacts which would be avoided
or mitigated by adhering to these cleanup levels are not specified. Information on the
level of protection, e.g., the fraction of the exposed population which would not experience
a particular adverse health impact or which would not exceed a certain blood lead level
of concern, also is not provided in the directive.
The failure to present such information raises questions regarding the scientific validity o'
the selected soO concentration range. In addition, vagueness regarding the derivation
procedures for the cleanup values presents difficulties for selecting specific site cleanup
levels either within or outside the range. For example, the Agency acknowledges that
"[sjite-sperific conditions may warrant the use of sofl cleanup levels" which are not within
the stated range. However, without any guidance as to the factors incorporated into the
initial selection of the stated range, it is unclear how selection of a value within the range
or modification of these cleanup levels could be undertaken. As discussed in Comment 3
below, she-specific considerations are likely to be significant enough to negate the
usefulness of generic cleanup leveb in favor of site-specific measures for all sites.
-------
Hie absence of supporting information in EPA's guidance reflects the limited basis for
derivation by CDC of the soO levels cited by EPA. As described in more detail in
Comment 2 below, EPA's use of CDCs values is technically inappropriate as the soil levels
were not necessarily associated with any adverse health impacts, but were merely described
as being levels which appeared to elevate children's blood lead levels "above background."
Other technical factors limiting the applicability of CDCs values for CERCLA use are
decreases in children's blood lead levels since the time of CDCs assessment, and
differences in the types of sites reviewed by CDC (largely urban conditions including lead
paint exposures) compared with those for which the cleanup levels are intended (CERCLA
hazardous waste sites, including mining sites). It should also be noted that there is no
indication CDC ever intended these sofl vmlues to serve as cleanup guides (CDC 1985).
*EPA attempts to provide some justification for its wholesale adoption of CDCs values by
stating that the use of this range is only an interim measure. Additional guidance.ir to be
provided by the Agency after it has finalized its reviews of development of a Cancer
Potency Factor (CPF) or a Reference Dose (RID) for lead. Whfle recently evolving data
on the health impacts of lead certainly merit systematic review by EPA (*+, toricity factor
development processes), the Mure to have completed these reviews does not justify
proposal of sofl cleanup levels which neither have a wen-documented technical support nor
acknowledge the substantial technically-based guidance alternatives which are currently
available. These include use of the IU/BK model together with exposure and rite-specific
-------
considerations in identifying populations of primary concern and levels of exposure and
risk. Such information has already undergone extensive review and compilation by several
EPA offices as weD as other Federal agencies (US. EPA, 1989a, 1989b, 1986; U.S. DHHS,
1988, 1985).
These factors, and their appropriate application in developing soil cleanup levels, are
discussed in Comment 3 below. It should also be noted that, as acknowledged by EPA's
Clean. Air Scientific Advisory Committee (CASAC) Joint Lead Group meeting of
April 27-28,1989, the data base for neurologicaJ effects on children is vastly more extensive
than that for lead carcinogenicity. Thus, even if quantification of carcinogenic potency for
lead indicates comparable exposure levels of concern, neurological endpoints are likely to
remain the primary focus of concern at sites where children may be exposed to lead
'contaminated soils.
2 EPA's annlicarion nf CDC*s «rril lead values for use as cleanirD levels is both
intended bv CDC.
As noted above, EPA does not provide documentation of the scientific rationale for the
soil cleanup levels announced in its September 7, 1989 directive, but instead claims that
the guidance adopts a "recommendation" generated by the CDC The section quoted by
-------
EPA as a "recommendation," however, appear* in the 1985 CDC document Preventing
Poiaonin* in Young Children, under the heading "Sources of Irftfl Exposure."
of the information provided in this document as weD as contacts with CDC
staff provides no indication that CDC either intended these levels to be interpreted as
levels of concern for adverse health effects or as levels to be used in establishing site
cleanup standards. In other words, CDC did not make a "recommendation" at all.
As quoted in EPA's directive, the CDC document specifically states that "_Jead in soil and
dust appears to be responsible for blood levels in children increasing above background
levels when the concentration in the soil or dust exceeds 500 to 1,000 ppm." No indication
is provided of the background level used or of any potential occurrence of adverse effects
following exposure to soil or dust lead levels in this range. With no index to either the
"magnitude of increase in blood lead from exposure or to anticipated health effects of such
exposures, the CDC statement is merely an observation of a statistical measure. It
provides no indication that exposure to the stated range of soil and dust lead levels will
result in Wood lead levels of health
In addition, CDC provides no documentation of the derivation of their statement that
Mood lead levels increase with sofl lead levels greater than 500-1,000 ppm. In personal
CDC staff indicated that the statement was intentionally not referenced.
Instead, the committee preparing the CDC document provided this ••••••rr" merely as
-------
a reflection of professional judgment regarding the impacts of soil and dust lead on blood
lead. The committee never intended for the information provided to be used as a
regulation.
It should also be noted that background blood lead levels in the US. have decreased since
the time at which the CDC report was issued. As outlined in Appendix C of the OAQPS
Staff Report on lead (US. EPA 1989a), sources of lead that contribute to background
levels of blood lead in the population have been decreasing since at least 1978. The
changes that have been observed are partly due to the phase-down in use of leaded
gasoline. This phase-down has been paralleled by a decline in blood lead levels, which is
anticipated to continue into the 1990s. Similarly, dietary intake of lead has been
decreasing since the late 1970s, and should continue to decrease as atmospheric deposition
«
of lead onto foods, use of lead-soldered cans, and drinking water levels of lead all continue
•
to decline. With the impact of these changes, EPA estimates that the 1990 baseline
average blood lead levels for two year old children wffl be 28 to 35 percent of the baseline
in 1978.
These changes in background levels would alter the significance of CDCs statement in
terms of the blood lead levels which would result from exposures to soil and dust with lead
concentrations of 500-1,000 ppm as well as in terms of the health impacts which might
be expected. Since, as discussed above, no documentation is provided by CDC for blood
-------
lead levels or anticipated health effects, the impacts of changes in background blood lead
levels on their view of these soil/dust concentrations is difficult to assess.
Another difference between the CDC derivation of the soil lead concentration of concern
and EPA'i intended use of this range is the types of sites, and thus the types of lead,
involved. CDC* review focused mainly on smelter sites and sites with typical urban lead
exposures, including lead-based paints. The she cleanup levels wfll be applied to CERCLA
she*, including mining sites. As discussed in Comment 3 below, evidence exists indicating
differentia] absorption of lead derived from different sources. Variations in outdoor/indoor
transfer of lead for different site types may also influence application of the CDC range
to CERCLA sites as the CDC evaluation looked at sofl and dust exposures together,
without segregating their individual effects. . These nictor may further increase the
*inappropriateness of EPA's adoption of the CDC values.
The EPA directive, in adopting the CDC sofl range for cleanups at hazardous waste sites,
clearly has extended the oae of these values well beyond their original intended purpose.
Difference* between the types of she* reviewed by CDC and those for which cleanup
levels would be applied, at weO as changes in background blood lead levels since the time
of derivation of CDC* value*, were not acknowledged by the Agency. Most importantly,
EPA failed to provide a scientific basis for application of these values or to link exposures
in excess of the suggested levels with advene beahh effect*.
-------
EPA'i tofl cleanup leveb fail to incorporate available modeling
nnj
ddtflfflsv)
b fnr
tMi
3.1
Considerations in Set^pg S/flfl Qeanx^y
As noted above. EPA's guidance fails to identify the population to be protected by the
stated cleanup leveb. For residential settings, the stated setting of concern in the
September 7 guidance, young children have been the primary population at risk due to
exposure to lead-contaminated soils. This is due to their increased susceptibility to the
neurological effects of lead (as compared to adults) as well as the likelihood of their
greater exposure to lead, especially via soil ingestion.
Recently, increasing concern has been expressed over neurological impacts observed
following prenatal exposures to lead at blood lead levels (10-15 jig/dl) which are lower than
those previously thought to be acceptable for postnatal exposuies for young children
(25 Mg/dl). While such impacts may exist, it must be recognized that the exposure pathway
for fetuses from lead-contaminated sous is substantially different from that for young
children. Specifically, while young children may directly ingest lead-contaminated sods,
fetuses are only exposed to lead-contaminated sofls via maternal ingestion and contact
Because young children are known to have enhanced sofl ingestion rates as well as higher
-------
lead absorption and retention rates compared to older children and aduhs, fetal exposures
(via maternal exposures) to lead-contaminated soils will be much less than young child
nires. It is likely that the difference in magnitude of exposures may more than
account for any difference in susceptibility to lead exposures (as indicated by blood lead
levels) that may exist between fetuses and young children. By ignoring these factor*, EPA
has fafled to develop sofl cleanup criteria for lead-contaminated sites based on a consistent
description of exposed populations of concern, exposure pathways, and acceptable exposure
criteria.
In setting the current soil cleanup levels, EPA has dismissed the use of bioldnetic uptake
•
models, stating that such models may only be used where extensive environmental and
biological data are available. This approach disregards the important contributions that
such models can make towanJi n ilimaatting the interrelationships between environmental
exposures, human body burden, and acahb Trr**** It is also inconsistent with efforts
being made in other puts of the Agency as well as by other groups. For example, in
proposing a Maximum Contammaot Level (MCL) for lead in drinking water, EPA's Office
of Drinking Water applied an uptake factor relating lead intake via water to blood lead
levels (US. EPA, 1988). Similarly, the Task Force of the Society of Environmental
-------
Geochemistry and Health is developing a methodology for establishing soil cleanup levels
which incorporates information on the relationship between sofl lead and blood lead
(Wboon, 1989).
One of the most intensively evaluated models of this type is the Integrated
Uptake/Biokinetic Model (IU/BK), which quantifies the relationship between environmental
(i.e., air, dust/soil) and dietary lead levels and the associated blood lead levels. This model
was selected by the US. EPA Office of Air Quality Planning and Standards (OAQPS) as
a regulatory tool in setting a National Ambient Air Quality Standard (NAAQS) for lead.
For this standard setting process, OAQPS is using the model to predict blood lead
concentrations in children under different exposure conditions (US. EPA, 1989a).
The uptake portion of the model, developed by Kneip et aL (1983), accepts site-specific
•
data or default values for lead levels in each medium and combines this information with
assumptions regarding behavioral and physiological parameters (Le, time spent indoors and
outdoors, time spent sleeping, diet, dust/wfl ingestion rates, daily breathing volumes,
deposition efficiency in the respiratory tract, and absorption efficiency in the respiratory
tract and gastrointestinal tracts (US EPA, 1989b)). The biokinetic portion of the model
(Harley and Kneip, 1985) accepts uptake predictions and computes age-specific blood lead
levels based on a roc-compartment biokinetic model of tissue distribution and excretion of
lead (US. EPA, 19S9b). Overall, the IU/BK model is very versatile in that the default
-------
assumptions and values on which uptake rate and blood lead calculations are based can
be replaced with available site-specific data or revised defaults. Thus, the mode) can be
updated as new information on exposure levels, intake and uptake parameters become
available.
To apply the model, a baseline blood lead level representing routine exposures to lead in
food, air, and water is compiled. Then, the contributions to blood lead from exposure to
housedust and soil are added to the baseline. The IU/BK model is then used to calculate
mean blood levels by multiplying estimated lead input rates (in Mg/day) by age-speciSc
biokinetic slope factors (BSF, in jig/dL per Mg/day). The mean blood lead levels can then
be used to estimate the frequency distribution, a useful parameter for risk assessment
purposes, for lead levels in populations of children (US. EPA, 1989b).
•
•
The results of several validation exercises conducted by the US. EPA for the IU/BK model
^
(Figures 1 and 2) indicate that the model accurately predicts mean blood lead levels and
population distributions •w>natffd with multimedia exposures in children (US. EPA,
1989a). These analyses assume a sofl ingestion rate of 80-135 mf/day and 25%
gastrointestinal absorption of lead from soil Figure 1 shows that when site-specific data
for air, dust, and sofl lead were used in the model, predicted and observed mean blood
lead levels and distributions were essentially identical Figure 2 shows that when default
-------
estimates of dust and soil lead were used in the model, predicted mean blood lead levels
were within 2% of observed.
The Lead Exposure Subcommittee of the Oean Air Scientific Advisory Committee
(CASAC) has "unanimously" agreed that the OAQPS document, "Review of the National
Ambient Air Quality Standards for Lead: Exposure Analysis Methodology and Validation"
(US. EPA, 1989a, which describes the IU/BK model) is scientifically adequate for use in
the standard setting process for lead as an ambient air pollutant. The CASAC endorsed
the opinion of its subcommittee in a recent letter addressed to U.S. EPA Administrator
Wflliam ReOly (US. EPA, I989a).
In addition, the recent Technical Support Document on Lead" (US. EPA, 1989b),
prepared by the U.S. EPA Office of Health and Environmental Assessment, stated that the
IU/BK model "provides a useful and versatile method for exploring the potential impact
of future regulatory decisions regarding lead levels in air, diet, and soil" The authors
observe that the use of the IU/BK model has revealed that dust and tofl ingestion are the
largest sources of lead exposure in 2-year-old children in areas near a lead point source
in which air lead levels are typical for urban areas in the United States.
»
In hs September 7 directive, EPA implies that models such as the IU/BK may only be used
where extensive, long-term environmental and biological data are available for a she. The
-------
Agency also sutes that blood lead testing should not be the "sole criterion for evaluating
the need for long-term remedial action at sites that do not already have an extensive, long-
term blood-lead data base." While long-term data are clearly desirable, their absence or
incompleteness should not totally preclude use of models such as the IU/BK. Indeed, it
seems that if the Agency is concerned about remedial action decision-making in the face
of limited data, it should encourage the use of models such as the IU/BK. In particular,
to the extent that any blood lead data are available, they could be used to validate the
assumptions used in the IU/BK model The empirical data and modeling results together
would provide insights into the site-specific relationships between soil concentrations and
blood lead levels, yielding a stronger base for assessing appropriate soil cleanup levels.
In summary, the advantages to using the IU/BK model for establishing sofl guidelines are
* that the model: incorporates flexibility in approaches to regulating exposures to lead, allows
•
for the use of the most current site-specific data, results in the prediction of population
distributions of blood Jead concentrations, can provide a stronger basis for evaluating site-
specific relationships between environmental concentrations and blood lead levels, and is
consistent with derivation of the NAAQS and MCL for lead, as well as approaches to
assessing lead toricity undertaken by other groups.
-------
In the case of lead, most information on the relationship between blood lead and lead in
soils is derived from studies conducted in urban communities or communities with
operating smelters. As discussed above, based largely on these types of studies, the US.
Centers for Disease Control (CDC) has suggested that when sofl lead concentrations
exceed 500-1,000 ppm, children's blood lead levels may increase above background levels
(US. DHHS, 1985). The current literature suggests, however, that children living in
mining towns without a recent history of smelting activities do not suffer from elevated
blood lead concentrations. Panicle size, lead species, and soil characteristics appear to be
the primary factors behind this noted difference in impacts of sofl lead from mining versus
'smelter sites on blood lead levels in children (Chancy, 1988). These factors appear to
influence lead bioavaflabfliry and patterns of lead transport and exposure.
Studies have shown that dissolution of lead in the gut is a function of the surface-to-mass
ratio associated with particle size (Steete et aL, 1989; HeaJy et aL, 1982; Barltrop and
Meek, 1979). The larger the panicle size, the smaller the relative surface area, and the
lower the bioavaflabfliry. The influence of particle size on intestinal absorption was found
to be especially important with panicles < 100 urn in diameter (Barltrop and Meek, 1979).
The particle sizes of a variety of taflings materials from different ores have been measured
-------
in the range of 10 to 1,000 jtm with none smaller than 1 MO (Andrews, 1975). In contrast,
primary panicles emitted from smelters fan in the 1 to 3 pm size range, with a significant
oumber of panicles smaller than 1 urn (Ferert and Ahmed, 1979).
Lead species is another critical factor in determining bioavailabiliry. For example, animal
toxicology studies show that some lead species are absorbed to a lesser extent than others.
Lead sulfide is significantly less absorbed than lead acetate and lead oxides (Barltrop and
Meek, 1975). Sampling data have demonstrated that mine waste lead is mostly in the form
of lead sulfide, a species of lower availability. By contrast, most lead in street dust is in
the sulfate, halide, or oxide forms (Duggan and Williams, 1977).
Another factor which appears to reduce the bioavailabOity of lead in mine waste is the
•binding effect of the surrounding sofls and rock matrix. The natural binding effect of lead
in sofls is enhanced in the case of mine waste or gaJena tailings, by the rock matrix
surrounding the residua] lead In galena, the lead sulfide is embedded in a rock matrix,
typically quartz. This rock matrix appears to reduce significantly the lead that is available
for dissolution in the stomach (Borrochein, 1988). For example, recent reviews of the
impact of sofls on the bioavaflabflity of lead (Steete et aL, 1989; Chancy et ai, 1988) have
shown that while powdered lead sulfide is essentially as available as more soluble forms
of lead, lead sulfide is Ucely to be much less bioavaflable when found in mining wastes.
-------
The transfer of lead in soils to housedust has also been observed to vary according to the
source of the lead, yielding different exposure patterns. For example, in urban settings or
areas with operating smelters, indoor dust concentrations were similar to sofl concentrations
(U.S. EPA, 1986). In mining studies, however, indoor dust concentrations were less than
sofl concentrations, varying from about 15 to 45% of the soil concentration when soil
concentrations were greater than about 500-1000 ppm (Barltrop, 1975; Barltrop, 1988;
Davies et aU 1985). At lower soil concentrations, housedust concentrations were often
simflar to or greater than soil concentrations, probably reflecting the predominance of
indoor sources of housedust lead (e.g., paint) at lower soil concentrations.
Possible reasons for lower housedust lead concentrations in mining communities include
the fact that in urban communities and/or communities with operating smelters, lead from
'deposition of airborne lead is more pervasive on sofl surfaces, and thus is more available
•
to be tracked into homes. In addition, airborne lead can penetrate buildings and
contribute to housedust lead concentrations in this manner. Such differences are due in
pan to panicle size. In particular, the panicle size of mine wastes is sufficiently large that
airborne particles from a mine waste source tend to settle out quickly and do not deposit
in as broad an area as the smaller aerosols from stack air emissions, which stay airborne
longer and travel farther (Davies and Wbson, 1985; Lagerweff and Brewer, 1975). Larger
particles are also less Kkeh/ to enter homes and thus to contribute to house dust
concentrations of lead.
-------
In summary, in establishing soil guidelines for a contaminant, site-specific and contaminant-
specific characteristics must be considered. The source and type of lead present at a
specific site can influence both its bioavailability and its distribution in the environment,
and resulting human exposures. Such factors would strongly influence development of
appropriate cleanup levels.
3.4 Consideration of Site-Specific Iffyct
As acknowledged by EPA, site-specific considerations may require derivation of different
soil cleanup levels than those proposed by the Agency. If the approaches suggested above
were adopted, it is not clear that any generic cleanup levels would be either necessary or
'appropriate. Site-specific factors to be considered would include the form of lead present
•
at a site (e.£, lead from mining activities versus kad from smelting activities with impacts
as described above) and characteristics of the surroundmf population (64, its proximity
and demographics).
Although the current interim guidance is described as being appropriate for "residential
settings", other types of sites (e^, industrial, commercial, or agricultural) may also require
establishment of soil cleanup levels. Other site uses (either current or future) would
necessitate different considerations in setting cleanup levels, such as different -population
-------
subgroups of primary concern, different exposure pathways of concern, or different
durations of exposure to site contamination. For example, children are unlikely to have
much if any exposure to lead-contaminated soils at industrial sites. Thus, • different
population subgroup, such as workers, is fikely to be of primary concern for these sites.
Childhood exposure to commercial sites would be determined in pan by their proximity
to residential areas, and would occur to a lesser extent than residential exposures. For
non-agricultural rural lands (for example, parks, open space), risk would need to be
determined in much the same way as for commercial property. Food chain exposures are
likely to be of primary concern for agricultural lands. Adoption of procedures which allow
for easier incorporation of these considerations into soil cleanup level derivation would
result in cleanup standards which better reflect actual risks.
Conclusions
In summary, EPA's interim guidance provides inadequate documentation of the rationale
and bases for the soil lead guidance levels proposed by the Agency. Their guidance
neither uses the CDC sou* values as intended by CDC nor acknowledges the substantial
technical database available for setting sofl lead cleanup levels. This lack of basis for their
guidance levels casts doubt on the validity of the values proposed by EPA and provides
-------
no clear method for incorporating site-specific considerations into the setting of soil
cleanup levels for specific lead-contaminated sites.
Hie generic values proposed by EPA should be replaced by a systematic process which
incorporates the substantial amount of information which is available on lead toxicity,
uptake, and body burden. This process would include use of the IU/BK model (or similar
models incorporating information on the relationships between environmental and body
burden concentrations of lead, such as that under development by SEGH) as well as
consideration of such critical factors as the bioavailabflity of different forms of lead. The
population of concern, target blood lead levels, and the fraction of the population to be
protected by the soil cleanup levels should also be specified in a consistent way. Such an
approach would both provide a scientifically valid basis for deriving sofl cleanup levels and
'would allow for incorporation of site-specific and other considerations. The type of results
generated by this approach would also assist in understanding more clearly the impacts of
proposed remedies oo reducing risks from lead exposure.
-------
References
Andrews, HD. 1975. " Tailings: Environmental Consequences and Review of Control
Strategies." Paper presented at the International Conference on Heavy Metals in the
Environment, Toronto, Ontario, Canada.
Barltrop, D, and F. Meek. 1979. "Effect of Particle Size on Lead Absorption from the
Gut." Arch. Environ. Healthy. 24:280»28S.
Bornschein, R.U, CS. Clark, J. Grote, S. Rod*, B. Peace, and P. Succop. 1988. "Soil/Lead-
Blood/Lead Relationships in an Urban Community and in a Mining Community." Paper
presented at a Conference on Lead in Sofl: Issues and Guidelines, March 7-9, 1988, at
Chapel HiU, North Carolina.
Chancy, RI_ H.W. Mielke, and S.B. SterretL 1988. "Speciation, Mobility, and
Bioavailabflity of Soil Lead." Environ. Geochem. and HeaHh. In Press.
Davies, B.E, and B.C. Wkton. 1985. "Trace Elements in Surface Soils from the
Mineralized Area of Madison County, Missouri, USA." J. SoD Science. &55 1-570.
Duggan, M J, and S. Williams. 1977. "Lead-in-Dust in City Streets." Sci. Total Environ..
2:91-97.
* Harley, N.R, and T.H. Kneip. January 30, 1965. An Integrated Metabolic Model for Lead
in Humans of All Ayei. Final Repon to the U.S. EPA, Contract No. B44899 with the New
York University School of Medicine, Dept. of Environmental Medicine.
Healy, M, P. Harrison, M. Asian, S Davies, and C WDson. 1982. lead Sulfide and
Traditional Preparations: Routes for I'yrton ir^ Solubility and Reactions in Gastric
Fluid."
Kneip, TJn RJ». Maflon. and N X. Harley. 1983. "Biokinetk modelling for mammalian lead
metabolism.' Neurotflncqt- 1:189.192.
Lagerweff, J.Vn and Di. Braver. 1975. "Source Determination of Heavy Metal
Contaminants in the Sofl of a Mine and Smelter Area," ;
tklj& 9/.207-215.
Longest, RL, and B. Diamond (US EPA, Directors, Office of Emergency and Remedial
Response and Office of Waste Program Enforcement). September 7, 1969. Memorandum
-------
to Directors, Regional Waste Management Divisions Re: Interim Guidance on Establishing
Soil Lead Cleanup Levels at Superfund Sites. OSWER Directive 093S5.4-02.
Perera, F.P., and A.K. Ahmed. 1979. Respirable Panicles. Cambridge, MA: BaOinger
Publishing Company.
Sleek, MJn BJ>. Beck, and B.L Murphy. 1989. "Assessing the contribution from lead in
mining waste to blood lead." Accepted for publication in Regulatory Toneolopr and
US. Department of Health and Human Services (Agency for Toxic Substances and
United States: A Report to Congress. Atlanta, GA: US. DHHS, ATSDR.
US. Department of Health and Human Service* (Centers for Disease Control). January
1985. Preventing Lead Poisoning m Young Children.
VS. Environmental Protection Agency (Office of Air Quality Planning and Standards).
1989s. Review of the National Ambient Air Q*tahTY Standard! for L-fffl'f' BfPfffure
Analysis Methodology and Validation. EPA-450/2-89-011.
US. Environmental Protection Agency (Office of Health and Environmental Assessment).
1989b. Technical Support Document on Lead. (Pint Draft.) ECAO-CIN-G7.
•US. Environmental Protection Agency (Office of Drinking Water). 1988. Drinking Water
Regulations; Maximum Contaminant Level Goals and National Primary Drinking Water
Regulations for Lead and Copper; Proposed Rule. Federal Register. 53n6fr>:31516-31578.
40 CFR Pans 141 and 142.
US. Environmental Protection Agency (Environmental Criteria and Assessment Office).
March 1966. Afr Ovjlftr Often* far Lead. EPA-60CV8-«3A)28C
Woson, R, 1989. Presentation on Methodology for Establishing Sofl Cleanup Standards
Developed by the Lead Task of the Society of Environmental Geochemistry and Health
at their May 29-June 1,1989 meeting in Cincinnati, OR
-------
ILKiA
Finn i
M tf llstrlbvtloa tf HtastrH lltt« Itt* Itvtls 1t
1-1 TMTS tf Aft. LUlBf WUU I.2S MlUf tf « LMl SMli«r Mitt ItvtU
PrHlclH fro« ttt OpUkt/llrttnttlc Httf«1. ftoisarH Ntt «rt 1*11
tvtli Utrt lielMM !• tlM Input PariMitrs U ttt Ht^tl.
Sovct: f.f. EPA, lint
-------
rime 2
Cwp«r1sta tf Hstrltatlm tf Ktaswttf Hootf UU Itvtls U Chlldrtn.
.*' %• L1vlA« *'1U111 2-» """ »f • LtM S»1i«r mu Ltvtls
I1*** "*• Optakt/BttkiMtU Httftl. tast «M toll IM* Itvtls Utrt
OflAf Otfatlt
Sovret: «.S. EM. If Hi
-------
EXHIBIT B
-------
3376J
EXHIBIT B
City
Granite City
Granite CUy
Granite City
Granite CUy
Granite CUy
Granite City
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite City
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite CUy
Granite City
Granite CUy
Granite CUy
Granite City
Granite CUy
Granite CUy
Granite City
Granite CUy
Granite CUy
Granite City
Granite City
Granite CUy
Granite City
Granite CUy
Granite City
Granite City
Granite CUy
Granite City
Granite City
Strttt
2026 Cleveland
2026 Cleveland
900 Alton
900 Alton
1401 Io«4
1401 Iowa
1401 Iowa
1710 Cleveland
1710 Cleveland
1770 Cleveland
302S Buxton
3025 Buxton
3156 3111
3156 J111
2406 A State (Apt?)
2406 A State (Apt?)
1737 Olive
1737 Olive
2341 Benton
2341 Benton
2502 State
2502 State
2919 Denver
2919 Denver
2132A Adams (Apt?)
2132A Adams (Apt?)
2132A Adams (Apt?)
2132A Adams (Apt?)
2443 State
2443 Sttte
2436 Adams
2436 Adams
2641 Benton
2691 Benton
1742 Popular
1742 Popular
1739 Edison
1739 Edison
1739 Edison
2618 Denver
26)8 Denver
1634 Cleveland
1634 Cleveland
2145 Cleveland
2145 Cleveland
2152 State
2152 State
2158 State
2158 State
Sex
Age
M
F
F
P
P
M
F
M
M
F
F
F
M
P
M
M
M
F
M
P
H
P
H
M
H
F
F
M
F
F
H
F
H
P
P
M
P
P
F
F
P
F
F
"M
F .
"M
F
M
F
5
29
2
22
5
40
33
2
4
27
1
30
1
20
6
32
5
31
5
30
5
26
39
2
4
1
Adult
30
30
1
4
27
3
34
2
5
4
3
20
5
25
5
23
3
23
•4
24
4
29
FEP
9
13
21
13
13
12
20
16
15
43
1
2
13
21
24
21
14
17
24
21
IB
28
17
49
9
10
10
9
30
21
8
22
18
19
31
13
13
45
13
12
19
9
10
19
18
11
11
10
21
BL
10
5
2
8
9
6
23
21
28
6
10
5
10
8
7
14-
9
20
12
8
8
21
5
3
5
5
10
5
5
6
8
6
6
11
11
10
15
2
14
8
14
11
19
32
11
4
10
-------
City
StrMt
Stx
FEP
BL
Granite City
Granite City
Granite City
Granite City
Cranlte City
Granite City
Granite City
Granite City
Granite City
Granite City
Granite City
Granite City
Granite City
Granite City
Granite City
Granite City
Granite City
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Mad 1 son
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison
Madison ...
Madison
Madison
Madison
2904 Harding M 43
2904 Harding F 2
2021 Dewy M 2
2021 Dtwey F 22
2322 Delmar F 3
2322 Delmar F 4
2322 Delmar F 32
1619 Edison F 6
1619 Edison F 30
2159 Benton M 4
2159 Benton F
1442 Grand F 4
1442 Grand P 30
1443 Grand F 38
1443 Grand H 4
1103 Madison M 1
1103 Madison F 27
1021 Grand (Apt) F 3
1021 Grand (Apt) H 4
1021 Grand (Apt) P 13
1021 Grand (Apt) P 25
1207 Market H 1
1207 Market F 3
1207 Market P 27
1109 Blssell F(?) 1
1109 Blssell F 35
1109 Blssell M 38
202 Logan M 60
202 Logan M 5
1034 Logan F 5
1034 Logan M 24
1034 Logan M 54
1217 Market (rear) P 24
1217 Market (rear) F 5
713 Jackson M 3
713 Jackson F 29
213 Blssell M 1
213 Blssell F 18
403 M 3rd F(?) 1
403 M 3rd F 26
615 MtredocU M 56
615 MeredocU M 6
201 Heaver (Apt) F 2
201 Weaver (Apt) F 32
914 Grand F 3
914 Grand F 35
925 low* F 26
925 Iowa M 23
B57 Alton -F 25
B57 Alton M 1
405 M 3rd F 21
405 N 3rd F 3
18
18
16
12
18
19
18
20
6
13
13
15
10
20
8
10
76
30
11
12
59
16
24
18
53
32
11
18
16
18
19
25
23
14
15
6
11
5
6
1
1
63
1
11
9
7
3
21
4
3
26
22
5
14
13
15
24
15
10
11
30
7
9
37
11
3
28
27
8-
12
5
9
5
6
5
11
8
9
14
16
22
2
8
13
3
10
16
18
8
4
10
22
8
12
7
6
1
10
11
-------
Results - Granite City 1982 IDPH
Blood Lead Survey
Areas1
Number2
2
3
4
5
6
7
8N
6
2
6
1
3
2
13
Totil
Granite City 13
FIP3
16.8 (9-45)
16.1 (13-20)
19.5 (8-76)
1
17.8 (13-31)
28.8 (17-49)
13.8 (6-24)
14.1 (1-49)
P6B«
17.1 (10-24)
33.5 (30-37)
15.8 (8-41)
10
11.9 (11-14)
8.4 (5-14)
8.0 (3-32)
10.4 (3-41)
Potential*
Health Risk
0
0
2 6
0
0
0
0
1
2
3
4
5
6
Areas correspond to areas proposed by EPA for reevdlatlon In Figures 4-5.
Ntmber of children age 1 to 6 years.
FEP - Geoevtrlc Mean (range). Free Evythrocyte (ag/dl).
P6B - Geooetrlc Mean (range). Blood Lead (eq/dl).
CDC action level of both FEP>35 ag/dl and P6B>15.
Area 4 levels are believed to be fro* a source other than soil lead.
-------
IMOUSTi :?!ES
. GRANITE CITY SITE
GRANITE CITY, ILLINOIS
Areas
-------
*«'i {' '• ' '*** ' '• '*"
GRANITE CITY SITE
GRANITE CITY, ILLINOIS
-------
EXHIBIT C
-------
MS M»
t
9 n
LI It
1.1 *.*
u MM.I
«.* IMM
II tMt.1
II
t.l
III
II
Nil
a.t M
n.i «.i
I MM*.*
I 11.1
* MH.1
III
11
m.i
MM
MM
W.I
M.)
MM
MI.I
M
M
•.IW1MM IM.I
n.* IIIM.I HU.I
•.IIBNM M>.«
M.I HM.I MM.I
•.I BNM W.t
IVHM.I Ml.)
• M.I
W I1IKI
• MNI.I
WLI
iw.t
III. I
itj.i
IM.«
I
I
n
MM.? IM.I IMM I Mil.I
lUl.r I ItMN.I Mil.I
» WM
111
»
*
.I
M
M
I.I
M
l.»
II
II
M
M
•ID
M
M
1.1
M
I.I
1.1
IL!
1.1
M
M M
I.I M
•.I MN.I MM
u.« nw.i M.S
N.I M M
B.I IM.I MJ
M.I M M
0.1 MM.I MM
•.IMM.I MM
-------
IVI
SCALE
-------
EXHIBIT D
-------
Attachment 3
.. Page I of i
Memorandum
To: Files IMIC: 17 July I «>«')
f. «{)«.
Fiom J-M. O'LooeMin «\ * ' III,. MU
NL Grin'ne City Materials Cost Estimates Ca«i.. 'r V
****»**•'• «% -% r* .
!).(». Colem:iii
K. Lamb
Topsoil
n. Litton Hicavnting (314) 781-6000 J«»5 im/7 O
b. Kurtz Nursery & lopsoil (314)946-9(91 $79UU/7CY
c. Dixon lopsoil Co. (314) 143-0134 $70 .00/7 CV
Average: SIO.OO/CY clelivcied 10 St. Louis niclrn men. Souice* cnnlncinl li:ul
adequate quantities available
Sand/Gravel
a Riverview Quarry (314) 817-3511 $3..15/lon $-1 4(/on
b. St. Cliailes Quarry (314) 9-16-0004 S-t.<15/lon SS.OO/ton
Average: S3.90/lon sand. $4.70/ton gravel, nut tlclivm-d.
Assume S3.30/loaded mile. IS mile haul. 16 CY truck.
Sand 1 .5 'ton/yd. Gravel 1.0 ion/yd.
Sand delivered: S9.00/CY Uinvel drlivnnl *R 0()/O
3. Clay
a. St Charles Quarry
7921 Alabama Road
Si. Louis, MO 63111
POO Darrel Emfie (314) S44.4.H'! (mnin nlliir)
(314)946-0004 (quaii y)
several thousand tons currently available for cost or load and haul.
estimate S7/CY load and haul to Granite City
NOTE: Clay pits, perse, do not exist in St. I.ouis area (Kevin Lamb. Dnurl r.mgr). Cl:i>
generally available as a result of construction excavation, quarry excavation.
Summary:
Topsoil: SIO.OO/CY delivered
Sand: S 9.00/CY delivered
Gravel; S I.OO/CY delivered
Clay. S 7.00/CY delivered
•
Time cost estimnles nre based on Mi
-------
TABLE 17
NL GRANITE CITY
PRELIMINARY COST ESTIMATE
ALTERNATIVE 1!
Attachment 4
Page I of 5
TARACORP PILE MULTIMEDIA CAP
Grading/contour ing/consolidation
Buy/haul/place 24" clay
Buy/place 60-«ll synthetic eevar
Buy/haul/plaea 6* gravel
Buy /haul/place Ceotextlle filter fabric
Buy/haul/place €* •abanfcment
Buy/haul/plac« 6* topsoil
Seed, fertilizer, aiulch
Fencing
SUBTOTAL
CONTAINED DROSSES
Loading (Crane 6 Crev)
Transport to secondary swelter (600
•iles 9 $3. SO/loaded mile
Saialting (adjusted for recovery)
SUBTOTAL
SLLR PILES
Excavation
Transport to Taracorp Pile
SUBTOTAL
VENICE ALLEYS EXCAVATE AND RESTORE
Clear/replace incidental*
Excavate to depth of 3m
Load and transport to Taracorp Pile
Grade and apply base eeurae
Buy /haul /pi ace asphalt
Buy /haul/pi ace 3* topsoil
Buy/haul/place aod
SUBTOTAL
EAGLE PARK EXCAVATE AND RESTORE
Clear
Manual excevation
Light equipment excavation
Heavy equipment excavation
Load and transport to Taracorp Pile
Buy/ltaul/plaee backfill
Buy/haul/place 3" topaoil
Buy/haul/place aod
SUBTOTAL
QUANTITY
66.440
29,630
400.000
7.400
400.000
7.400
7,400
44,440
3.000
IS
I
12
3,920
3,920
1.6
670
670
5.300
5.300
225
2.700
.5
100
500
2.100
2,700
2.500
200
2.200
"
UNITS
SY
CY
SF
CY
SF
CY
CY
SY
FT
LS
Load
Ton
CY
CY
Acres
CY
CY
SY
SY
CY
SY
Acres
CY
CY
CY
CY
CY
CY
SY
*
UNIT
COST
$3
$20
$1
$15
$0.2
$10
$20
$1
• 10
$800
$2,100
300
$25
$3
$5,000
$30
$6
$3
$6
$25
$<•
$3.000
$60
$30
$20
$6
$10
$20
$4
EXTENDED
COST
$133,320
$592.600
$600.000
$111.000
$80.000
$74.000
$148,000
$44.440
$30.000
$1,613,360
$800
$2,100
$3,600
$6,500
$98.000
$11.760
$109.760
$8.000
$20.100
$4,020
$1 5 . 900
$42.400
A & 0 4k f
$5.625
$10.800
$106.845
$1.500
$6.000
$15.000
$42.000
$16.200
$25.000
$4.000
$1.180
flll.580
TOTAL
COST
$1.613,360
,
A 0 f a * * t
$6,501)
$109,760
$106.865
A « « fl CfasssaW
$118,5J^^
-------
TABLE 17
NL GRANITE CITY
PRELIMINARY COST ESTIHATE
ALTERNATIVE II
Attachment 4
Pile 2 of 5
AREA 1 EXCAVATE AND RESTORE
Clear/Replace Incidentals
Manual Excavation
Light Equipment Excavation
Heavy Equipment Excavation
Load and Transport to Taracorp Pile
Grade and apply pavement base course
Buy/haul/place asphalt
Buy/haul/place topsoll
Buy /haul/pi ace sod
Buy/haul/place shrubs
Buy/haul/place trees
SUBTOTAL
«A 2 EXCAVATE AND RESTORE
ar/Replace Incidentals
ual Excavation
Light Equipment Excavation
Heavy Equipment Excavation
Load and Transport to Taracorp Pile
Grade and apply pavement base course
Buy /haul/place asphalt
Buy/haul/place topsoil
Buy /haul/pi ace sod
Buy/haul/place shrubs
Buy/haul/place trees
SUBTOTAL
AREA 3 EXCAVATE AND RESTORE
Clear/Replace Incidentals
Manual Excavation
Light Equipment Excavation
Heavy Equipment Excavation
Load and Transport to Taracorp Pile
Grade and apply pavement base course
Buy/haul/place asphalt
Buy /haul/pi ace topsoil
Buy/haul/place aod
Buy/haul/place shrubs
Buy /hau I/place trees
SUBTOTAL
QUANTITY
13.5
465
7,890
7,890
16,265
27,200
27.200
9,450
37.780
10
5
11.6
6,667
4,667
0
9.336
23.770
23.770
5,372
32.230
150
70
10.8
4,344
4,344
0
8,688
3,280
3.280
8.140
48.840
70
30
UNITS
ACRES
CY
CY
CY
CY
SY
SY
CY
SY
EA
EA
ACRES
CY
CY
CY
CY
SY
SY
CY
SY
EA
EA
ACRES
CY
CY
CY
CY
SY
SY
CY
SY
EA
EA
UNIT
COST
$5,000
$60
$30
$20
$6
$3
$8
$20
•54
$50
$200
$5,000
$60
$30
$20
$6
$3
$8
$35
$6
$50
$200
$5,000
$60
$30
$20
$6
$3
$8
$35
$4
$50
$200
EXTENDED TOTAL
COST COST
$67.500
$27.900
$236,700
$157.800
$97,470
$81,600
$717.600
$189.000
$151.120
$500
$1,000
$1,228,190 $1.228.190
$58,000
$280.070
$140,010
$0
$56.004
$71.310
$190,160
$188,020
$128.920
$7.500
A • * tffe4%*t
$14.000
$1,133,944 $1,133.944
$54,000
$260,640
$130,320
$0
A A A A A A
$52,128
$9,840
A ^ ^ A f 4^
$26.240
$284.900
$195.360
$3.500
$6.000
$1.022.928 $1,022,928
-------
Attachment 4
Pate 3 or 5
TABLE 1?
NL GRANITE CITY
PRELIMINARY COST ESTIMATE
ALTERNATIVE II
AREA 4 EXCAVATE AND RESTORE
Clear/Replace Incidentals
Manual Excavation
: Light Equipment Excavation
Heavy Equipment Excavation
Load and Transport to Taracorp Pile
Grade and apply pavement base course
Buy/haul/place aaphalt
. Buy/haul/place topsoll
Buy/haul/place sod
. Buy/haul/place shrubs
Buy/haul/place trees
SUBTOTAL
AREA 5 EXCAVATE AND RESTORE
Clear/Replace Incidentals
Manual Excavation
Light Equipment Excavation
Heavy Equipment Excavation
Load and Transport to Taracorp Pile
Grade and apply pavement baa* course
Buy/haul/place asphalt
Buy /haul/pi ace topsoil
Buy /haul/pi ace sod
Buy /haul /pi ace shrubs
Buy/haul/place trees
SUBTOTAL
, AREA 6 EXCAVATE AND RESTORE
i Clear/Replace Incidental*
• Manual Excavation
. Light Equipment Excavation
{ Heavy Equipment Excavation
j Load and Transport to Taraeorp Pile
• Grade and apply pavement base couria
.' Buy /haul/place asphalt
i Buy/haul/place topsoil
' Buy/haul/place sod
> Buy/liaul/place shrubs
• Buy/liaul/place trees
! SUBTOTAL
QUANTITY
(0.7
24.500
2*4.500
0
49.000
98.000
98.000
32.667
196.000
395
170
2.5
1.000
1.000
0
2.000
4.000
4,000
1.333
8.000
16
7
19.8
8.000
8.000
0
16.000
32,000
32.000
10.667
64.000
129
55
UNITS
ACRES
CY
CY
CY
CY
SY
SY
CY
SY
EA
EA
ACRES
CY
CY
CY
CY
SY
SY
CY
SY
EA
EA
ACRES
CY
CY
CY
CY
SY
SY
CY
SY
EA
EA
UNIT
COST
$5,000
$60
$30
$20
$6
$3
$8
$35
$4
$50
$200
$5,000
$60
$30
$20
$6
$3
$8
$35
$4
$50
$200
$5.000
$60
$30
$20
$6
$3
$8
$35
$<•
$50
$200
EXTENDED TOTAL
COST COST
$303,500
$1,470.000
$735.000
$0
$294,000
$294,000
$784,000
$1,143.345
$784,000
$19,750
$34,000
$5.861.595 $5.861.595
$12.500
$60.000
$30,000
$0
$12.000
$12.000
$32,000
$46,655
$32,000
$800
$1,400
$239,355 $239,355
$99.000
$480,000
$240.000
$0
$96.000
$96,000
$256.000
$373.345
$256.000
^k ^ f A m^
$6.450
$11.000
$1.913.795 $1,913,795
-------
Attachment 4
Page 4 of 5
TABLE 17
NL GRANITE CITY
PRELIMINARY COST ESTIMATE
ALTERNATIVE 1!
AREA 7 EXCAVATE AND RESTORE
Clear/Replace Incidentals
Manual Excavation
Light Equipment Excavation
Heavy Equipment Excavation
Load and Transport to Taracerp Pile
Grade and apply pavestent base course
Buy /haul/place asphal t
Buy/haul/place topsoil
Buy/haul/place sod
Buy/haul/place shrubs
Buy /haul/place trees
SUBTOTAL
AREA 85 EXCAVATE AND RESTORE
JBfckr/Replace Incidentals
^l|al Excavation
Light Equipment Excavation
Heavy Equipment Excavation
Load and Transport to Taracorp Pile
Grade and apply pavement baae course
Buy /haul/place asphalt
Buy/haul/place topsoil
Buy/haul/place sod
Buy/haul/place shrubs
Buy/haul/place trees
SUBTOTAL
AREA 8N EXCAVATE AND RESTORE
Clear/Replace Incidentals
Manual Excavation
Light Equipment Excavation
Heavy Equipment Excavation
Load and Transport to Taracorp PI la
Grade and. apply pavestent base course
Buy/haul/place asphalt
Buy/haul/place topsoil
Buy/haul/place sod
Buy /haul/pi ace shrubs
Buy /haul /pi ace trees
SUBTOTAL
quAjrriTY
3.9
1,556
1.556
0
3.112
6.222
6.222
2.074
12.444
25
11
7.8
3,127
3,127
0
6.254
12.507
12.507
4.169
25,015
51
22
57. B
23.322
23,322
0
46.644
93.289
93.289
31.096
186.578
376
162
UNITS
ACRES
CY
CY
CY
CY
SY
SY
CY
SY
EA
EA
ACRES
CY
CY
CY
CY
SY
SY
CY
SY
EA
EA
ACRES
CY
cy
CY
CY
SY
SY
CY
SY
EA
EA
UNIT
COST
$5.000
$60
$30
$20
$6
$3
$8
$35
$4
$50
$200
$5.000
$60
$30
$20
$6
$3
$8
$35
$<•
$50
$200
$5.000
$60
$30
$20
$6
$3
$8
$35
$4
$50
$200
EXTENDED
COST
$19,500
$93.360
$'•6.680
$0
$18.672
$18.666
$49.776
$72.590
$49.776
$1.250
$2.200
$372.470
$39.000
$187, 6?0
$93,810
$0
$37,524
$37.521
$100.056
$145.915
$100.060
$2.550
$4,400
$748.456
$289,000
$1.399.320
$699,660
A «*
$0
$279.864
$279.867
$746,312
$1,088,360
$746,312
A. A A A***%
$18.800
$32.400
$3.579.895
TOTAL
COST
$372.470
•
•
$748,456
$5.579.895
-------
Attachment 4
Page 5 of 5
TABLE 17
NL CRANfTE CITY
PRELIMINARY COST ESTIMATE
ALTERNATIVE H
OTHER COSTS
Monitoring Well
Deed Restrictions
Safety Program
Mobilization
Dust Control
Equipment Decontaalnation
Off-Site Drainage Control
SUBTOTAL
ESTIMATED DIRECT CAPITAL COST
INDIRECT CAPITAL COSTS
Contingency Allowance (2SZ)
Engineering Fees (1SZ)
Legal Fees (5Z)
ESTIMATED INDIRECT CAPITAL COST
TOTAL ESTIMATED CAPITAL COST
QUANTITY
90
LS
LS
LS
LS
LS
LS
UNITS
LF
LS
1.S
LS
LS
LS
LS
UNIT
COST
$60
$15.000
$'•0.000
$65.000
$60.000
$60.000
$25,000
•
EXTENDED
COST
$5.600
$15.000
$/iO.O(IO
$65.000
$60.000
$60,000
$25.000
$230.600
TOTAL
COST
$230.
$20.286.
$5.071.
$3.0'.2.
$1.016.
$9.12B.
$29.616.
600
073
518
^k
9
733
806
ANNUAL OPERATING AND MAINTENANCE COSTS
Air Monitoring
Sample analysis
Groundwater sample collection
Sample analysis
Site Moving
Site inspection
Miscellaneous site work
Sice work materials
ESTIMATED ANNUAL 0 6 M
PRESENT WORTH OF ANNUAL 0 X M
FOR 30 YEARS (1-5Z)
ALTERNATIVE H ESTIMATED COST
2 Mandays
8 Samples
8 Mandays
22 Samples
26 Mandays
8 Mandays
36 Mandays
LS LS
$250
$1,000
$250
$150
$250
$250
$250
$6.000
$500
$8.000
$2,000
$3.300
$6,500
$2.000
$9.000
$6.000
$35,300
$562,630 $562,630
$29.957,636
-------
ADDENDUM
The following additions and corrections should be made to Appendix B:
Selection of a Lead Soil Clean-up Level for the NL/Taracorp Superfund Site.
1) Sixth page, last line. SOO aicrograas per deciliter should read 900
ppa.
2) Eighth page, line 11. Reference 198?c should be 1989a.
3) Ninth page, line 9. Text should read: It is notable that at a lead
in soil level of SOO ppa, the aodel shows that for «ost ages the
soil/dust lead intake is approximately IS aicrograas per day. At a
lead soil level of 1000 ppa, the soil/dust lead intake is greater than
29 aicrograas per day, accounting for approximately 63 percent of the
total daily intake. At both soil lead levels, the intakes fro* air
and*water are nonsignificant.
-------
APPENDIX B
SELECTION OF A LEAD SOIL CLEAN-UP LEVEL FOR THE Nt/TARACOftP SUPERFUND SITE
Prepared by U.S. EPA, Region V
Several sets of coaments to the Proposed Plan at the NL/Taracorp
rite have questioned U.S. EPA's decision regarding tfle selection of the lead
in.soil clean-up standards to be used at the site. This document is intended
to respond to these comments by setting forth U.S. EPA rationale supporting
this decision.
*•
Lead poisoning in young children is one of the most prevalent and
preventable childhood public health problems in the U.S. today (USDHHS, 1985).
The Environmental Protection Agency's concern with the health hazards of lead
.is longstanding - The Clean Air Act of 1970 authorized the EPA to set
National Ambient Air Quality Standards (NAAQS) for the regulation of air
emissions of pollutants considered harmful to public health or welfare; lead
was one of the six pollutants to be regulated. In 1974 under the regulatory
requirements of the Safe Drinking Water Act, EPA Office of Drinking Water
issued its National Interim Primary Drinking Water Regulations; again lead
was one of the 26 contaminants addressed. Since 1975, EPA has increasingly
restricted automobile emissions; *IT new cars since 1975 have been equipped
\
wfth catalytic converters. Because lead destroys the effectiveness of these
converters, the use of unleaded gasoline has increased dramatically, with
corresponding decreases in lead emissions from exhaust. EPA has moved to
accelerate this progress by phasing out lead in gasoline during the 1980s.
-------
Further reductions in the National Ambient Air Quality Standard for lead and
the Maximun Concentration Level for lead in drinking water are expected in
1990. The overall effect of these control programs has been a major reduction
In the amount of lead being released to the environment.
Lead released into the environment in the past from stationary
sources such as factories, power plants and smelters and from mobile sources
such as automobiles, buses and other forms of transportation remains a
persistent problem. Deposition and precipitation have resulted in the
accumulation of high concentrations of lead in the soil in areas where
significant releases to the air have occurred. Thus, lead-contaminated soil*:
and housedust have emerged as important contributors to blood lead
concentrations in the general population.
The present action has provided a mechanism for the clean-up of the
lead in the soil at the NL/Taracorp Superfund site in Granite City. A risk
assessment has been prepared by O'Brien & Gere as part of the Remedial
Investigation for the NL/Taracorp Superfund site (Remedial Investigation
Report 1988). This health risk assessment has correctly identified children
as the most sensitive tubpopulation, noting that they are at particular risk
to lead poisoning due to their greater lead absorption efficiency than adults
and to their greater probability of exposure to environmental lead in soil
through outdoor play activities, mouthing habits and through intentional
ingestion of soil (pica). It further identifies two pathways for lead
exposure to the resident population stemming from the Superfund tlte as being
complete: • 1) the airborne route, with lead-beanng soil particulates and
•*-
dusts transported from friable soils on the Taracorp site to offsite locat'ions
-------
for subsequent inhalation, and 2) the direct contact route, with exposed soils
previously contaminated with lead from participate fallout from smelting
emissions in previous years providing a source for ingest ion of lead
residues". Pathways have been identified as complete based on contaminant
existence, magnitude, environmental fate, toxicological impact* of components
released from the «.1te and transport to receptors. The assessment also
acknowledges that "lead in its various environmental forms is able to combine
with a variety of physiologically significant proteins in the body, with
resultant effect', on rtri;rtyre anc< function".
Because children are developing, they absorb and retain more lead
than adults. Thus, even at very low levels cf lead exposure, children can
experience reduced I.Q. levels, impaired learning and language skills, loss of
hearing, and reduced attention spans and poor classroom performance. At
higher levels, lead can damage their brains and central nervous systems,
interfering with both learning and physical growth. Needleman (1988) has
provided a review of 110 publications documenting the health effects of lead
in children. He summarized that at low blood lead levels, neurocognitive
effects of lead expressed as diminished psychometric intelligence, attention
deficits, conduct problems, alterations in the electroencephalogram, school
failure and increased referral rates for special needs predominant. He
emphasizes that careful epidemiologic studies, which have controlled for the
important confounders, have set the level for these effects at 10-15
nicrograms per deciliter lead in blood. Exposure to lead in men can cause
Increases in blood pressure. These health effects and their associated blood
lead levels have been summarized by EPA and the Agency for Toxic Sub.stances
and Disease Registry (ATSOR), and are summarized in Table 1. Particularly
-------
notable are the risk* of lead to women of child-bearing age. They Include
fertility problem*: and ni'carriage'.. In pregnant women, lead can cause
inpaired development of the fetus, premature births and reduced birth weight;.
The data in Table 2 shows that miscarriage*: and reproductive effect*, such as
premature birth and low birth weight, may occur at blood lead levels as low as
10 micrograms per deciliters and possibly lower. It is this growing
preponderance of literature that has prompted the National Centers for Disease
Control (CDC) to consider the lowering of the blood lead level from 25 to 15
micrograms per deciliter to protect for the health effects seen at lower
levels. It is also this same growing accumulation of evidence that has led
EPA to reject the suggestion put forth by the contractors for NL Industrie*: in
their risk assessment that the proposed 15 micrograms per deciliter blood lead
level can be considered as a threshold level for the adverse health effects of
lead in children. This lack of ability to identify a thresold level for lead
coupled with the understanding that Reference Dose (RfD) methodologies are
basically route-specific and do not Incorporate site-specific Information has
led EPA to withdraw the RfD for lead. The EPA Environmental Criteria and
Assessment Office (ECAO) has suggested instead the use of an uptake/biokinetic
modeling approach to develop health critera for lead (U.S.EPA 1989b).
Many considerations have gone into the documentation of a lead soil
clean-up level for the NL/Taracorp Superfund site. The first was the
Inability to find a suitable basis on which to perform a risk assessment based
on dose-response relationships given the withdrawal of the RfD for lead. The
second was the EPA Interim Guidance on Establishing Soil Lead Cleanup Levels
at Superfund Sites (OSWER Directive f 9355.4-02, 1989). This directive sets
-*•
forth an interim soil clean-up guideline for total lead in soil at 500 to
-------
1.000 ppm. However, It also allow? that "site-specific condition*: may warrant
the ur.e of toil clean-up level*; below 500 ppm or somewhat above the 1000 ppm
level". This latter guidance was used to evaluate the condition*; at the
RL/Taracorp Superfund site.
A number of factor*; have Influenced the netting of a lead soil
clean-up level for the NL/Taracorp site.
1) The soil at the NL/Taracorp (Granite City) rite has been documented as
containing elevate- level0, of lead (Remedial Investigation Report 1988).
2) Snelter operations are known to result in the emission of small
aerosol particles which stay airborne and travel over an extensive area
(Steele 1989). Because the lead deposits at the NL site originated from air
emissions from smeltring operations, the resulting discharge was as fine
particles having a wide area of distribution and deposition. (This area has
not been fully delineated and further soil testing will be needed to determine
the extent of the area contaminated by lead emissions from the NL Industries
operations.)
3) The '.mall particles deposited in the soil can cling to skin, clothing
and children's toys and can be transferred into the indoor environment as
windborne dust or carried in on the shoes or clothing of residents or the fur
of household pets.
4) The small lead particles have high bioavailability, due to their easy
dissolution in the stomach and the chemical form of the lead salts.
5) Even low exposures to lead have been shown to have significant health
effects on developing children, especially those under the age of six years.
6) Children who show tendencies toward frequent mouthing activities can
Ingest large amounts of soil and indoor dust and rfence, large amoun'ts of lead
-------
(Calabrese 1989, Binder 1986). Those who are nutritionally compromised and/or
exhibit pica might be at risk for severe health effects.
7) The area of Granite City most affected by the smelter emissions is
highly residential and contains a significant number of young children - the
subpopulation known to be the most sensitive to the toxic effects of lead.
8) GraTnte City and the surrounding area is highly industrialized and
residents are likely to be exposed to a complex mixture of toxic substances in
the air and in the soil, which may act to increase the toxic effects of lead
in a synergistic manner. The assessment of health risks from chemical
mixtures is of growing concern to EPA (FR 50 1985).
These factors indicate that there is a high possibility of adverse
health effects in young children living in the Granite City areas impacted by
the NL/Taracorp Superfund site. Accordingly, a soil lead clean-up level of
500 ppm was deemed necessary if this subpopulation is to be fully protected.
This lead soil clean-up level is consistent with the approach being
taken for similiar contaminated sites in other countries, other Regions in the
U.S. and is advocated by researchers examining lead toxicity in pediatric
populations. In a report to the Ontario Minister of the Environment by their
Lead in Soil Committee, the committee responded to the request that they
review the available literature on lead in soil and recommend "scientifically
defensible" soil removal guidelines for lead-contaminated soil (OLSC Report
1987). The committee recommended that a 1000 ppm guideline level is
appropriate for areas to which children do not have routine access, while a
guideline level between 500 and 1000 ppm is appropriate for areas to which .
«
children do have routine access. The comments of the Royal Society of Canada
were also included in the report. They recommended that for clean-up around
-------
lead-processing or lead-unrig plants, toil lead levels of up to 500 micrograms
per deciliter are acceptable for residential area*: and for garden and
allotment*, while levels of up to 1000 ppm should be acceptable for parkland'.
and other areas to which children have only intermittent access. Similiar
conclusions have been reached in the U.S. regarding the soil clean-up at lead
smelter sites; lead soil clean-up levels in such impacted residential areas
in Regions I, II and VIII have recently been set at 200 t 500 ppm. These are
also the conclusions being echoed by researchers in the field. Milar and
•
Mushak (1982) warned that a definite health hazard exists to children when
household dust levels exceed either 1000 ppm or 50 micrograms per square
meter. Mielke et al. (1989) summarized the work of a number of researcher*:
addressing the question of the safe lead concentration in soil to protect
children from undue exposure with the conclusion that a rapid rise in
population blood lead levels taker. place when the lead content of soil
increases from less than 100 ppm to 500-600 ppm. Dr. Mielke has stated in a
personal communication that he believes the safe lead soil level in areas
contaminated with fine lead particles to be between 200 qnd 250 ppm. A
study by Shellshear et al. (1975) in New Zealand concluded that children
exposed to more than JOO ppm lead in toil and who also exhibit pica are at
major risk to lead exposure.
The site-specific conditions presented earlier led Region v to
consider the use of a modeling approach to further evaluate the lead soil
clean-up level proposed for this site. This approach is consistent with the
recent comments received from NL Industries that the incorporation of the
Biokinetic Model and other generic and site-speciflc data Into the development
-/•
of clean-up levels for lead are appropriate (NL Industries comment to the
-------
public response. Exhibit A). The letter from Dr. Krablin, Manager for
Environmental Projects. ARCO, included in Exhibit A defends the EPA Integrated
Upteke/Biokinetic Model as having been "demonstrated to be a reliable
Analytical method to determine the relationship between environmental lead
concentrations and blood lead concentrations for EPA lead rulemaking". The
EPA Office of Research and Development has examined several other modeling
approaches, including a lead soil matrix model proposed by the Society for
Environmental Geochemistry and Health (SE6H) Task Force on Lead in Soil, and
has indicated that the favored approach is the Biokinetic Model. Two recent
technical support documents have been issued which present the rationale for
this modeling approach for developing health criteria for lead (USEPA 1989b,
USEPA 1989c). The Biokinetic Model provides a means for incorporating either
site-specific or internationally consistent default assumption values
regarding exposure scenarios and absorption efficiencies for lead uptake from
various media into the exposure analysis to yield estimates of the relative
contributions of air, dietary and soil lead to the total estimated lead
uptake.
When site-specific data collected in Granite City and soil lead/dust
lead levels of 500 ppm and 1,000 ppm were input into the Lead Uptake/
Biokinetic Model, the graphs presented in Figures 1 and 2 were obtained.
Figure 1 uses the 500 ppm soil lead/dust lead level, soil ingestion rates of
0.100 grams per day as suggested by O'Brien & Gere rather than the default
Calabrese data, air lead levels taken from the Remedial Investigation Report,
and default values as listed from the Users Guide for Lead: A PC Software
Application of the Uptake/Biokinetic Model. No pica was considered; lead in
•f
paint was considered not to be available for ingestion (painted surfaces in
-------
jd condition). An U.S. average water lead level was included to account for
the contribution from lead in plumbing. The model predicted the mean blood
lead level for children under the age of six to be 8.37 micrograms per
deciliter, with approximately 8.5 percent of the children predicted to attain
blood lead level? greater than 15 micrograms per deciliter. When a soil
lead/dust lead level of 1,000 ppm was substituted into the model.
approximately 34 percent of the children were predicted to have blood lead
levels greater than 15 micrograms per deciliter. This would put 34X of the
Granite Cit> cfcHdren above a level which may represent a risk of adverse
health effects. It is notable that the model shows that for most ages, the
soil/dust lead intake is greater than 29 micrograms per day while the lead
intakes from air and water are nonsignificant. The model also shows that the
500 ppm fci'7 clean-u; fevel appears to be appropriate because further
reductions in food lead levels are anticipated due to the removal of
lead-containing soils, to education of residents on ways to reduce lead intake
in children provided by the U.S. EPA and IEPA, and to the possible impact of
reductions in allowable releases of lead to the air and in the water expected
from changes to the National Ambient Air Quality standard and the National
Primary Drinking Water Regulations later this year.
In conclusion, EPA Region V has set a 500 ppm lead soil clean-up
level at the NL/Taracorp Superfund site. It ii the best professional
judgement of the *taff that this level represents the miniroun soil clean-up
level which can be expected to protect the most sensitive granite City
residents, children under the age of six years.
-------
REFERENCES
ATSDR, The Nature and Extent of Lead Poisoning in Children In the United
States:""? Report to Congress. U.S. Department of Health and Human Service*:,
Agency for Toxic Substance*, and Disease Registry, Atlanta, 6A, 1988.
Binder, S.To. Sokal and D. Maugham, Estimating toil ingestion: the use of
tracer element* in estimating the amount of soi1 ingestion by young children,
Arch. Environ. Health. 4J: 341-345 (1986).
Calabrese, E.J., H. Pastides, R. Barnes, et al., How much soil do young
childrer. ingest; an ep'demiological study, Reg. lexical. Pharmacol.. (1989)
FR 50, Proposed Guidelines for the Health Risk Assessment of Chemical
Mixtures, Federal Register 50; 1170-1178, Wednesday, January 9, 1985.
Mielke, H.W., J.L. Adams, P.L. Reagan, and P.W. Mielke, Jr., Soil-dust lead
and childhood lead exposure as a function of city *ize and community traffic
flow: the case for lead abatement in Minnesota, In B.E. Oavies and B>G>
Wixson, eds., Lead in Soil: Issues and Guidelines, Supplement to
Environmental Geochemistry and Health, Supplement to Volume 9, 253-268 (1989).
Milar, C. and P. Mushak, "Lead contaminated housedust; hazard, measurement and
decontamination", in J. Chisolm and 0. O'Hara, eds.. Lead Absorption in
Children. Urban and Schwarzenberg, Baltimore, MD, 1982. PP 143-152.
Needleman, H.L., The persistent threat of lead: medical and sociological
issues, Curr. Probl. Pediatr. 18; 697-744 (1988).
OLSC (Ontario Lead in Soil Committee), Review and Recommendations on a Lead in
Soil Guide1 me. Report to the Ontario Minister of the Environment, ISBN 0-
7729-2715-4, Hazardous Contaminants Branch, May 1987.
Remedial Investigation Report, Granite City Site. Granite City. Illinois.
prepared by O'Brien & Gere Engineers, Inc., Syracuse, NY, September 1988.
Shell shear, I., L. Jordan, 0. Hogan and F. Shannon, Environ-mental lead
exposure in Christchurch children: *oil lead as a potential hazard, New
Zealand Med. J.. 81: 382-386 (1975).
Steele, M.J., B.O. Beck and B.L. Murphy. Assessing the contribution from lead
1n mining wastes to blood lead. Gradient Corporation, Cambridge, MA,
prepublication copy, 1989.
USEPA 1986a, Air Quality Criteria for Lead. EPA-600/8-83/028aF-dF,
Environmental Criteria and Assessment Office, U.i. Environmental Protection
Agency, Research Triangle Park, NC, 1986.
USEPA 1989a, Review of the National Ambient Air Quality standards for Lead:
Exposure Analysis Methodology and Validation, Final Draft.Office of Air
-------
Quality Planning and Standard', Air Quality Management Division, U.S.
Environmental Protection Agency, Research Triangle Park, me, 1989.
USEPA 1989b, Technical Support Document on Lead. ECAO-CIN-G7, Environmental
Criteria and Assessment Office, U.S. Environmental Protection Agency,
Cincinnati, OH, 1989.
USDHHS, Preventing Lead Pol toning In Young Children. U.S. Department of Health
and Human service* (Center? for Disease Control), January 1985.
-------
TABLE 1
Summary of Lowest Obse-/ed Effect Levels For Uad-tnduced
HeiJth Effects in Children and Adults
HEMf SYNTHESIS
..*i
IX
80
«o
JO
10
C«»M« ALA
T
t
i
CMK
1
IQ)
A|t
J. •
-------
TABLE 2
31'MMAftY Of *£CEXT ITtSlLS )N TlfE »55OCUTTON OP
PRENATAL LEAD tXPOSLTH WTTH WLZJrED FtT-U. OCTCOMUm
Rtfcrtace
E.*aAart ct aj.
(193fa.l986)
Sc.:..'.jer e*. *.
./s^'-
Vee^f asa s: al.
;i?3-;
S.'?r.':.ir± s: -.
:iw
3ie:n:3 it aJ.
U9SS;
Wo^ •: ai
(19ST)
VcNfickiel et at.
(1916)
Moore ct al.
{i9ej
» *
RottebergeriL
(1589)
Crasuao ct al.
/1910k
i « 'O / f
wirdtiai
(19T)
n^ • • ^ <9CVa<40>Ai fliro
N ir-ifcs AVT-:.- Ass 'Actpr
«: 41
135 •n.-.rertii ;t • $ -1 )
16: --?: 5.: ', 0
113 <:*c *./ 4. .-1
J?S e.-rr -f.5 : ;
--- -.;,:;-.., ;;« 10 j .»
15* r.;:t—ii ;-r g.;
13: rr:i' ,-v:- Jfi.? .• •
na:a.
'^9 r-..i;rn-, '.• H.1! •* ^
:crfi JC.-1 •• «.
a« T..::-.ai if N.OJ.T. .• C
i-Jfd U.8 f.r. .' C
51 aatsrta! 'p« liO
matersal -'c*i 1&4 0 ••
card IJ4
90? aatcraAi I7.tja. 0
/ M *A« flkA ^* \
• J7"OIC*CI. '
639 maceraa; 15.9 g. 71 0*
fretrotp '
100 pi««mal Pb 2J5p{, g - •*
Symbeic fl. « ividcat rcUiiooikir. ». por.tr.-e
•filfflnit « p «6jOJ; fA, gtomeif K «ean
r«BftnlfT
vtifht showed ao reUciouhio. b« Uw trend >. -er?:t ^- af *«*»-f«r-«ettaufi.iai.jge
Marly KMutioUy ligufieau ai p
-------
Figure 1
Integrated Uptake/BioMnetlc Model
U. JU
O.25
0.20
\4
H
M
u
M 0.15
ffl
2
0
«
61 0.1O
O.O5 .
0 •
, , , j . ... ... _,
*
;'
-. .'
/* *»
.
• .
i »,
i
i
/\
i
/ \
•
- i
i
/
•
/
i i
/
i • '
jX* L J L i
.... .
L i
0
(500 ppm soil /dust Ph + NI./Tnrnrorp si»p-spncf fie data)
i • i -- i
(n'«,r»if: ?-...o
x ttftioi*: 4^i. :vr
i j :
•j
10
BI.OOD LFAD CONCIHTRnTlON
O to Y;> Hi.Hil.h-,
. r i- •
f. i
-------
Sir Concentration: O.260 uQ/m3
Diet: DEFAULT
D«-in»mg Water; 8.68 ug/L
Soil * House Dust: Values
DEFAULT
ent«»»-ed by use*
Age
0-1
1-2
2-3
3-4
4-5
5-6
6-7
Soil (u<;
500.0
500.0
500.0
500.0
500.0
5OO.O
500. C
House Dust (ug Pb/g)
500.0
500.0
500.0
500.0
500.0
500. C
500. O
Additional DJS*. rr_--ces: None DEFAULT
Paint Intake: 0. OO ug/day DEP"AULT
0.5-1:
1-2:
2-3:
3-4:
4-5:
5-6:
6-7:
Blood Level
(ug/dD
5.13
7.50
8.78
9.22
9.66
9.83
10.01
(ug/day)
15.73
30.42
32.04
32.24
32.54
33.57
35.08
Soil-Dust Uptake
(ug/day)
3.75
14.99
14.99
14.98
14.97
14.96
14.95
YEAR
0.5-1:
1-2:
2-3:
3-4:
4-5:
5-6:
6-7:
Diet Uptaki
(ug/day)
«• ^ ^ ^ •• ^ ^^ |>»^W>
10.93
12.96
14.33
14.49
14.71
15.45
16.94
Water Uptake
(ug/day)
0.89
2.22
2.31
2.35
2.44
2.58
2.62
Paint Uptake
(ug/day)
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Air Uptake
(ug/day)
0.16
0.25
0.41
0.41
0.41
0.57
0.57
-------
Integrated Uptake/Biokir^tlc Model
O.JO i 1 1 1 f — ~r— f-~
(1000 ppm soil/dust Ph * NI./T.ir.irorp siip-sporific data)
n.25
0.20
>«
H
M
u
M 0.15
A
/*
«
0
K
* 0.10
•i
0.05
-
C
.-
r
1 *(
— f ' ',
/*
'.
,' '»
» •
1 1
/
,'
I
/
r
* * 1
•
,'
- i
/
i
i
i
i
1
i
\
I
/
/
i
•'
1 •" 1 L _i L
1 T» 10 I?
^.i«r. i r ;!>.« uti/dl,
"! 0..' o'" •; %M . ^V
/. !to?i»w i»!r7t
• MI-^II . I 1 . \\(\
V
•
•
\
'•
i
i
i
•,
*(
'.
'•.
•-. ..
L... ...!....,... 1 _ . i 1 i J" •'•• 4 .„ .. L 1
3 20 ;^ 'Ml ; » f.'i 1'
m.ooD LT:M> CONCENTRATION
-------
0.26O
uQ/m3
Diet:
DEFAULT
Drinking Water: 8. 68 ug/L DEFAULT
Soil & House Dust: Values »nt*r»d by user
_ooo.o
10OO.O
LOOO.O
,000.0
1000.0
1000.0
1OOO.O
1OOO.O
1000,0
1000.O
100O.O
1000.0
(ug Pb/g)
Additional Dust Sources: None DEFAULT
Paint Intake: 0.00 ug/day DEFAULT
0.5-1 :
3-4:
4-5:
5-6:
6-7:
Blood Level
(ug/dL)
"6721
10.66
12.89
13.47
14:27
Total Uptake
(ug/day)
19.48
45.33
46.88
46.98
47. 16
48.04
4
-------
"IOAU function.
t. VALUES Of DEFAULT PARAMETERS
The values of the default parameters which can be changed by the user
are as follows:
*A1r Data: Air Concentration: 0.20 »g Pb/»»
Lung Absorption: 31.S%
Vary A1r Cone by Year: MO
Ventilation Rate
Age 0-1: 2.0 «»/day
1-2: 3.0 «»/day
2-3: 5.0 »Vday
3-4: S.O nVday
4-5: 5.0 tiVday
5-6: 7.0 n»/day
6-7: 7.0 nVday
Water Concentration: 8.88 Mo/i
Use Alternate Values: NO
Water Consumption
0-1: 0.20
L2: 0.50 I/day
2-3: 0.52 t/day
3-4: 0.53 I/day
4-5: 0.55 I/day
5-6: 0.56 I/day
6-7: 0.59 t/day
Use Alternate Values: NO
Diet Intake
0>1: 21.86 vg Pb/day
1-2: 25.94 wg Pb/day
2-3: 26.71 vg Pb/day
3-4: 29.05 ^g Pb/day
4-<- »q.53 -
31.10 Vfl Pb/day
34.26
Use Alternate Oust Values: NO
ngested Dall
g/day *a-7 ~.e.eiv.e./*«•*'
g/day * c
__. g/day *
0.050 g/day
0.050 g/day
O.OSO g/day
': 0.0 »g Pb/day (all
------- |