IN THE MATTER OF
:
)
)
PROPOSED AMENDMENTS TO
)
TIERED APPROACH TO CORRECTIVE
)
ACTION OBJECTIVES
)
(35 Ill. Adm. Code 742)
)
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite 11-500
Chicago, Illinois 60601
Matt Dunn
Environmental Bureau Chief
Office of the Attorney General
James R. Thompson Center
100 W. Randolph, 12th Floor
Chicago, Illinois 60601
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the
Illinois Pollution Control Board the written testimony of Gary P. King, Gregory W. Dunn,
Lawrence W. Eastep, and Thomas C. Hornshaw as well asERRATA SHEET NUMBER 1, a
copy of each of which is herewith served upon you
.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
B
Kimberly A. Geving
Assistant Counsel
Division of Legal Counsel
DATE: January 9, 2006
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217)782-5544
THIS FILING SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARI
TREGEIVED
CLERK'S OFFICE
JAN 10 2006
NOTICE
R06-10
(Rulemaking-Land) STATE
OF
ILLINOIS
Pollution Control Board
General Counsel
Illinois Dept. of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
Richard R. McGill, Jr
.
Ill. Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite 11-500
Chicago, Illinois 60601
RE
CKEOVED
JAN 1 0 2006
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
STATE OF ILLINOIS
)
pollution cbhT1*PAF
kTER OF :
R06-10
PROPOSED AMENDMENTS TO
)
(Rulemaking-Land)
TIERED APPROACH TO CORRECTIVE
)
ACTION OBJECTIVES
)
(35 Ill. Adm. Code 742)
)
MOTION FOR ACCEPTANCE
NOW COMES the Illinois Environmental Protection Agency ("Illinois EPA")
and, pursuant to 35111 Adm. Code 101 .Subpart C and 35 111 . Adm. Code 102 .424, moves
the Illinois Pollution Control Board ("Board") to accept the attached written testimony of
Gary P. King, Gregory W. Dunn, Lawrence \V'. Eastep, and Thomas C. Homshaw as well
as ERRATA SHEET NUMBER 1 for the above-captioned matter
.
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
B
imberly
Geving
Assistant
ounsel
Division of Legal Counsel
DATE: January 9, 2006
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217)782-5544
THIS FILING SUBMITTED ON RECYCLED PAPER
STATE OF ILLINOIS
)
COUNTY OF SANGAMON
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the attached written testimony
of Gary P. King, Gregory W. Dunn, Lawrence W. Eastep, and Thomas C. Homshaw as
well as ERRATA SHEET NUMBER 1 upon the persons to whom they are directed, by
placing a copy of each in an envelope addressed to :
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite 11-500
Chicago, Illinois 60601
Matt Dunn
Environmental Bureau Chief
Office of the Attorney General
James R. Thompson Center
100 W. Randolph, 12` h Floor
Chicago, Illinois 60601
(Service List)
and mailing them (Firs Class Mail) from Springfield, Illinois on January 9, 2006, with
sufficient postage affixed as indicated above
.
SUBSCRIBED AND SWORN TO BEFORE ME
This
9th_ day of
January, 2006
.
Notary Public
General Counsel
Illinois Dept. of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
Richard McGill
Illinois Pollution Control Board
100 W. Randolph St
.
Suite 11-500
Chicago, Illinois 60601
.oaar~a.a.oaar»ksooa
• •:
a$
OFFICIAL SEAL
BRENDA BOEHNER
y NOTARY
PUBLIC, STATE OF ILL N01$ $
° MY COMMISSION EXPIRES I 1 .32000
THIS FILING SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOAC E I V E D
LERK'8 OFFICE
IN THE MATTER OF :
)
PROPOSED AMENDMENTS TO )
TIERED APPROACH TO CORRECTIVE )
ACTION OBJECTIVES )
(35 Ill. Adm. Code 742)
)
ERRATA SHEET NUMBER 1
NOW COMES the Illinois Environmental Protection Agency ("Agency") through one of
its attorneys, Kimberly Geving, and submits this ERRATA SHEET NUMBER 1 to the Illinois
Pollution Control Board ("Board") and the participants listed on the Service List. Thomas C .
Homshaw has provided testimony in support of these changes in his pre-filed written testimony,
also served upon the Board and the Service List
.
Section
App. A, Table G
For some of the constituents, periods were used in the value rather than
commas. Thus, for Aluminum, the value should be 9,500 9.500 for
_Counties Within the Metropolitan Statistical Areas ("MSA") and 9,200
9.200 for Counties Outside the MSA. For Calcium, 9,300 9.300 and 5,525
5.525, respectively. For Iron, 15,900 15.900 and 15.000 15 .000,
respectively. For Magnesium, 4 820 4.820 and 2,700 2.700, respectively
.
For Potassium, 1,268 1 .268 and 1,100 1 .100, respectively
.
App. A, Table H
The first chemical, 2-Methylnaphthalene, does not have any value
reflected in the Chicago column . Although there is no value for that cell,
please add:_ .
App. A, Table 114
Please change the value for the 1 in 1,000,000 Cancer Risk Concentration
column for the chemical 1,2 Dibromoethane as follows : 0.00002
0.0000019. Additionally, there was a typographical error in the chemical
name, and it should be capitalized as follows : 1,2 Dibromoethane 1,2
dlbremeethane .
1
JAN 1 0 2006
STATE OF ILLINOIS
R06- 10
Pollution Control Board
(Rulemaking-Land)
App. B, Table A For the chemical 1,2 Dibromoethane (Ethylene dibromide), CAS No . 106-
93-4, please delete the new reference to footnote x. The new value should
only have footnote e next to it .
App. B, Table A
Beginning with the Inorganics and continuing through the rest of the table,
all new (underlined) references to
--- in the Class I and Class II columns,
with the exception of the new_-` for Calcium, Magnesium, Phosphorus,
Potassium, and Sodium, should be deleted. Only the existing values
should be reflected in those columns. Where there are existing --- entries
without underlining (for the two Chromium entries), those values are
correct and should remain
.
App. B, Table A
For the chemical Nitrate, CAS No . 14797-55-8, a second footnote in the
Class I column should be added as follows : 10.09
'x .
App. B, Table A
For the chemical Silver, CAS No . 7440-22-4, there is a typographical error
in the Class II column . The new footnote added should be a footnote c,
not footnote m. Please delete the m footnote and insert c in its place
.
App. B, Table B
For the chemical Acetone, CAS No . 67-64-1, the new value of 1,000,000
that was added into the Ingestion columns for both the
Industrial/Commercial and Construction Worker Exposure Routes is
incorrect . Please delete the references to 1,000,000b and insert ---9 into
both those columns instead. No change to the stricken material is
necessary
.
App. B, Table B
For the chemical 1,2-Dibromoethane (Ethylene dibromide), CAS No . 106-
93-4, an incorrect value was added for the Construction Worker Inhalation
Exposure Route. Please delete the new reference to 0.036 and replace it
with 0.16` . No change to the stricken material is necessary
.
App. B, Table B
For each of the Ionizable Organics, a formatting error was noticed for the
footnote I in the Class I column. Every one of those footnotes should be a
lower case i rather than a capital I . Please make the following change for
every Ionizable Organic in that column : iI. Additionally, the actual
footnote at the end of the table should also be corrected the same way
.
App. B, Table B
As with App . B, Table A, beginning with the Inorganics and continuing
through the rest of the table, all new (underlined) references to --- in the
Class I and Class II columns, with the exception of the new_` for
Calcium Magnesium, Phosphorus, Potassium, and Sodium, should be
deleted. Additionally, the existing values that were mistakenly stricken
should be restored without strikethroughs . Where there are existing ---
2
App. B, Table B
App. B, Table B
App. B, Table B
App. B, Table B
entries without underlining (for the two Chromium entries), those values
are correct and should remain
.
For the chemical Boron, CAS No . 7440-42-8, please make the following
change in the Inhalation column of the Industrial/Commercial Exposure
Route : ---` 1,000,000.
For the chemical Lead, CAS No . 7439-92-1, please make the following
change in the Ingestion column of the Industrial/Commercial Exposure
Route : 80014W .
For the chemical Nitrate, CAS No. 14797-55-8, please make the following
addition in the Class I column: 10 .09'`"
In the footnote section, please strike the entire footnote k as follows : ~-A
preliminary rcmcdiation goal of 400 mg/kg has been set for I ad based on
. Additionally,
please strike the entire footnote v as follows : '-calcu lated values
correspond to soil concentrations that should not result in air
concentrations that exceed criteria for workplace air
. The Agency has not
re-lettered any of the existing footnotes to reflect these changes. If the
Board would instead like to replace the deleted footnotes with one of the
new footnotes (w, x, or y), that would be acceptable to the Agency .
App. B, Table F
For the chemical Acetone, CAS No . 67-64-1, please change both the Class
I and Class II values as follows: 6.3 470" and 6.3 40.
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
3
Kimberl A. Geving
Assistan Counsel
Division of Legal Counsel
Date: January 9, 2006
1021 North Grand Ave. East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217)782-5544
THIS FILING IS SUBMITTED ON RECYCLED PAPER
4
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
TESTIMONY OF GARY P. KING
My name is Gary King. I am the manager of the Division of Remediation Management
within the Bureau of Land of the Illinois Environmental Protection Agency (Agency)
. I have
been in my current title since May 1990. Within this Division are located three Sections : the
Leaking Underground Storage Tank (LUST) Section, the Remedial Project Management (RPM)
Section, and the Federal Sites Remediation (FSR) Section . The LUST section is responsible for
administration of the corrective action portions of the LUST program . The RPM Section is
responsible for administration of IEPA cleanup programs relative to voluntary cleanups, State-
enforced cleanups, and State-funded cleanups. The FSR Section is responsible for federal
Department of Defense cleanups, and National Priority List (NPL) cleanups
.
Prior to assuming my current position I was the senior counsel for the Bureau of Land
within the Agency's Division of Legal Counsel. I have been employed at the Agency since 1977 .
I received a B.S. in Civil Engineering in 1974 from Valparaiso University and a J .D. in 1977
from the same university .
I have testified before the Board in numerous rulemaking proceedings, including all of the
Board's rulemakings under Title XVII of the Environmental Protection Act, which led to the
IN THE MATTER OF
:
)
R
cERC
jr
'E'
VED
JAN 10 2006
PROPOSED AMENDMENTS TO
)
STATEOF ILLINOIS
Pollution
TIERED APPROACH TO CORRECTIVE
)
R06-10
Control Board
(Rulemaking-Land)
ACTION OBJECTIVES
)
(35 Ill. Adm. Code 742)
)
adoption of 35 Ill. Adm. Code 740, Site Remediation Program, and 35 Ill . Adm. Code, Tiered
Approach to Corrective Action Objectives. The Agency's proposal in this proceeding proposes
amendments to Part 742
.
A . REGULATORY DEVELOPMENT
The Agency has been implementing Part 742 since its adoption in 1997 . It has proven to
be a very effective methodology for developing remediation objectives . Other States have used
TACO as a baseline for developing their own State programs . I have personally spoken with
State environmental representatives from Indiana, Missouri, Wisconsin, New York, and
Mississippi as they have developed their own State programs and have looked to the Illinois
TACO rules to help guide their decision making
.
As we have progressed with the implementation of TACO, we have found the need for
updating and refinements, based on new information (such as studies on background levels of
PNAs or changes to the federal Soil Screening Levels) or operational experience (such as model
institutional control documents). This regulatory proceeding is the second time the Agency has
proposed such amendments to Part 742 to the Board for adoption
.
B. DISCUSSION OF PROPOSED REGULATIONS
In this testimony I will be discussing changes to Part 742 in the following areas
:
Section 742.105 Applicability
The changes to Subsections (a) and (h) are proposed for purposes of making explicit
considerations that were already implicit from the structure of TACO . These changes represent
longstanding Agency practices in interpreting TACO . For instance, in the original TACO
2
rulemaking in 1997 I testified that landfills were not an appropriate fit for use of TACO because
of technical and regulatory issues
.
Section 742.200 Definitions
The Agency has added a number of new definitions because of other changes being
proposed in this proceeding
.
Section 742 .1000 Institutional Controls
Language has been added to subsection (c)(5) to clarify the use of highway authority
agreements. In the Leaking Underground Storage Tank Program, the tank owner/operator is the
responsible party and the person that receives the No Further Remediation Letter, but is not
necessarily the property owner .
Language has been added to subsection
(c)(6) to include a new instrument as an
institutional control to address situations where the highway authority and the responsible party
(the property owner or the leaking underground storage tank owner or operator) are the same
entity. In that case, the institutional control would be an agreement between the highway
authority and the Agency (Highway Authority Agreement Memorandum of Agreement) with
respect to any contamination that remains under the highway
.
Section 742.1010 Environmental Land Use Controls
The Agency is proposing changes to Section 742 .1010 that clarify how ELUCs work and
to make more transparent the procedures for how they can be changed in the future
.
Section 742 1015 Ordinances
The Agency is proposing amendments to Section 742 .1015 that are needed to support the
short- and long-term effectiveness of ordinances used as environmental institutional controls by
3
clarifying specific details of how ordinances are to be used and applied. Ordinances, like all
other institutional controls, must remain in effect in perpetuity unless a responsible party
demonstrates to the Agency that the ordinance (or other institutional control) is no longer
necessary, and the Agency agrees with that demonstration
.
Agency administration of ordinances as institutional controls includes : 1) The review of
ordinances for suitability as institutional controls pursuant to Section 742 .1015; 2) The
application of approved ordinances to specific sites in accordance with all technical and legal
requirements under TACO and the applicable programs ; and 3) The long-term tracking of the
ordinances themselves and of the compliance by sites that have used them to obtain closure . The
Agency understands there is some uncertainty inherent in using ordinances as institutional
controls. Ordinances, by their nature, may be amended . Section 742.1015(d) is designed to alert
the Agency of such amendments (although the Agency has never been informed of any such
amendment but knows of at least two cases where approved ordinances were used to close sites
and subsequently amended or repealed with no notification to the Agency) . However,
minimizing the uncertainties to the extent practical is in the best interests of effective
administration of these institutional controls
.
Section 742.1020 Highway Authority Agreements
Highway Authority Agreements ("HAAS") are one of the instruments that may be used as
an institutional control under the Tiered Approach to Corrective Action Objectives ("TACO")
regulations, 35 Ill . Adm. Code 742. An HAA is an agreement between the owner of the property
from which a release occurred and the highway authority having jurisdiction over an adjacent
right of way below which contamination has migrated
.
4
In general, the HAA provisions of Section 742.1020 have worked effectively. The
Agency, however, has noted legal difficulties in instances where the highway authority is also the
property owner of the site. We concluded that a bilateral agreement with only one entity involved
could not be binding. This problem was not foreseen or contemplated when the TACO
regulations were adopted .
This oversight in the regulations can lead to unintended results . For example,
contamination at a site located at an intersection may have migrated under two rights of way
; one
under the jurisdiction of the Illinois Department of Transportation ("IDOT") and one under the
jurisdiction of the local government. If the local government owns the site, it can enter into an
HAA with IDOT to address the contamination below IDOT's right of way . However, it cannot
enter an HAA with itself to address the contamination under its own right of way
.
As a result, in instances where the highway authority and the property owner are the same
entity we have required the highway authority to enter an MOA with the Agency with terms
similar to the HAA. The HAA MOA is substantially the same as any other HAA, except for the
parties to the agreement. The HAA MOA allows a highway authority that is also a site owner to
enter an agreement with the Agency (in lieu of itself) where it promises to restrict groundwater
use and soil access to the extent required by the TACO regulations .
Section 742.1020 (b)(2) contains new language to clarify that a Highway Authority
Agreement must limit access to soil contamination under the highway right of way above the
residential Tier 1 remediation objective or the construction worker remediation objective, which
ever is less. This is to address the situations where the construction worker objective is less that
the Tier 1 objective
.
5
Section 742 .1020 (g) and (h) contains new language to address the situation where the
highway authority and the responsible party (the property owner or leaking underground storage
tank owner/operator) are one and the same . In this case, the highway authority would enter into a
Highway Authority Agreement Memorandum of Agreement (HAA MOA) between the highway
authority and the Agency. The HAA MOA provides that the responsible party shall agree to
prohibit use of groundwater and limit access to soil under the highway right of way to protect
human health and the environment The HAA MOA must match the form and contain the same
substance as the model in new Appendix E
.
The addition of subsections (g) through (i) and Appendix E will codify Agency practices
concerning HAA MOAs
.
Addendices D through I . Cross references to Section 742 .1010(d), 742.1012(a), 742.1015(a) and
(i), 742.1020(a)
.
Over the last seven years the Agency has developed model documents implementing the
various institutional control options in Subpart J . We did this to make document preparation and
Agency review more effective. We are now at a point where we think it is appropriate to codify
these model documents in the Board regulations and require their use . The model documents are
provided in Appendices D through I with appropriate cross references within Subpart J to those
instruments .
Other changes found in these section are non-substantive typographical changes
.
THIS FILING IS SUBMITTED ON RECYCLED PAPER .
6
RECEIVED
CLERKS OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
JAN 1 0 2006
IN THE MATTER OF
:
)
STATE OF
ILLINOIS
Pollution Control Board
PROPOSED AMENDMENTS TO
)
TIERED APPROACH TO CORRECTIVE
)
R06-10
ACTION OBJECTIVES
)
(Rulemaking - Land)
(35 Ill. Adm. Code 742)
)
PRE-FILED TESTIMONY OF GREGORYW.DUNN
My name is Gregory W . Dunn. I am currently manager of one of the Voluntary
Site Remediation Units, in the Bureau of Land of the Illinois Environmental Protection
Agency (Agency) that administers the Site Remediation Program (SRP). The SRP, as
established under 35 Ill. Adm. Code 740, provides Remediation Applicants (property
owners, developers, bankers, real estate agents, businesses, etc .) the opportunity to
receive review and evaluation services, technical assistance, and no further remediation
determinations from the Agency .
I graduated from Eastern Illinois University in 1986 with a B .S. in Geology and a
B.S. in Earth Science. I have been employed with the Agency since September 1986 . I
was a project manager in the Site Assessment Unit from September 1986 until October
1992. From October 1992 until July 1997, I was a project manager in the Pre-Notice
Program, which became the Site Remediation Program in June 1997. From July 1997
until December 1998, I was a project manager in the State Sites Unit, which uses State
funds to remediate sites. Since December 1998, I have been manager of one of the
1
Voluntary Site Remediation Units . I am registered as a Licensed Professional Geologist
in the State of Illinois and have almost 19 years of environmental experience .
Today I will testify in support of proposed rule changes in 35 Ill. Adm. Code 742
concerning the Incorporations by Reference (Section 742 .210), Determination of Soil
Attenuation Capacity (Section 742.215), Contaminant Source and Free Product
Determination (742 .305(e)), Groundwater Ingestion Exposure Route (742 .320(d)), Tier 2
Groundwater Remediation Objectives (742.805(c)(1)), Ordinances (742 .1015(b)(2)),
Appendix C, Table D, and Appendix C, Table F
.
Incorporations byReference :
(Section 742.210)
Section 742.210 incorporates by reference several documents that are required for
use elsewhere in Part 742 . In order to keep current with the changes by the American
Society for Testing and Materials (ASTM), the Agency proposes the following changes to
Section 742.210(a): change the address and phone number of ASTM from 1916 Race
Street, Philadelphia, PA 19103 (215) 299-5400 to the current address of 100 Ban - Harbor
Drive, West Conshohocken, PA 19428-2959 (610) 832-9585 . Change "Standard Test
Methods for Moisture, Ash and Organic Matter of Peat and Other Organic Soils" from
ASTM D 2974-87 to ASTM D 2974-00, change the date approved from May 29, 1987 to
August 10, 2000, and delete the reapproved 1995 . Change "Standard Practice for
Description and Identification of Soils (Visual-Manual Procedure)" from ASTM D 2488-
93 to ASTM D 2488-00 and change the date approved from September 15, 1993 to
Februaryl0, 2000. Change "Standard Test Method for Density and Unit Weight of Soil
2
in Place by the Sand-Cone Method" from ASTM D 1556-90 to ASTM D 1556-00 and
change the date approved from June 29, 1990 to March 10, 2000 . Change "Standard Test
Methods for Density of Soil and Soil-Aggregate in Place by Nuclear Methods (Shallow
Depth)" from ASTM D 2922-91 to ASTM D 2922-01 and change the date approved from
December 23, 1991 to June 10, 2001 . Change "Standard Test Method for Density of Soil
in Place by the Drive-Cylinder Method" from ASTM D 2937-94 to ASTM D 2937-00el
and change the date approved from June 15, 1994 to June 10, 2000 . Change "Standard
Test Method for Specific Gravity of Soils" to "Standard Test Methods for Specific
Gravity of Soil Solids by Water Pycnometer" to reflect the correct name of the reference,
change the ASTM D 854-92 to ASTM D 854-02 and change the date approved from
November 15, 1992 to July 10, 2002 . Change "Standard Method for Laboratory
Determination of Water (Moisture) Content of Soil and Rock" to "Standard Test Method
for Laboratory Determination of Water (Moisture) Content of Soil and Rock by Mass" to
reflect the correct name of the reference, change ASTM D 2216-92 to ASTM D 2216-98
and change the date approved from June 15, 1992 to February 10, 1998 . Change
"Standard Test Method for Determination of Water (Moisture) Content of Soil by Direct
Heating Method" to "Standard Test Method for Determination of Water (Moisture)
Content of Soil by Direct Heating" to reflect the correct name of the reference, change
ASTM D 4959-89 to ASTM D 4959-00, change the date approved from June 30, 1989 to
March 10, 2000 and delete reapproved 1994 . Change "Standard Test Method for
Determination of Water (Moisture) Content of Soil by the Microwave Oven Method"
3
from ASTM D 4643-93 to ASTM D 4643-00, and change the date approved from July
15, 1993 to February 10, 2000 . Change "Standard Test Method for Measurement of
Hydraulic Conductivity of Saturated Porous Materials Using a Flexible Wall
Permeameter" to "Standard Test Methods for Measurement of Hydraulic Conductivity of
Saturated Porous Materials Using a Flexible Wall Permeameter" to reflect the correct
name of the reference, change ASTM D 5084-90 to ASTM D 5084-03, and change the
date approved from June 29, 1990 to November 1, 2003 . Change "Standard Test Method
for Particle-Size Analysis of Soils" from ASTM D 422-63 to ASTM D 422-63 (2002),
change the date approved from November 21, 1963 to November 10, 2002, and delete the
reapproved 1990. Change "Standard Test Method for Amount of Material in Soils Finer
than the No. 200 (75 inn) Sieve" to "Standard Test Methods for Amount of Material in
Soils Finer than the No . 200 (75 um) Sieve" to reflect the correct name of the reference,
change ASTM D 1140-92 to ASTM D 1140-00, and change the date approved from
November 15, 1992 to June 10, 2000 . Change "Standard Test Method for Water Content
of Soil and Rock in Place by Nuclear Methods (Shallow Depth)" from ASTM D 3017-88
to ASTM D 3017-01 and change the date approved from May 27, 1988 to June 10, 2001
.
Change "Standard Test Method for Permeability of Rocks by Flowing Air" from ASTM
D 4525-90 to ASTM D 4525-90 (2001) . Change "Standard Test Method for
Classification of Soils for Engineering Purposes" to "Standard Classification of Soils for
Engineering Purposes (Unified Soil Classification System)" to reflect the correct name of
the reference, change ASTM D 2487-93 to ASTM D 2487-00, and change the date
4
approved from September 15, 1993 to March 10, 2000. Change "Standard Practice for
Environmental Site Assessments : Phase I Environmental Site Assessment Process" from
ASTM E 1527-93 to ASTM E 1527-00 and change the date approved from March 15,
1993 to May 10, 2000. Change "Standard Guide for Risk-Based Corrective Action
Applied at Petroleum Release Sites" from ASTM E 1739-95 to ASTM E 1739-95 (2002)
.
The Agency proposes to insert an addition into Section 742.210(a) to keep current
with all available reference materials . "Methods for the Determination of Organic
Compounds in Drinking Water Supplement I", EPA Publication No . EPA/600/4-90/020
(July 1990) will be added as additional reference material in support of EPA Publication
No. EPA/600/4-88/039 dated December 1988 and revised July 1991 titled
" Methods for
the Determination of Organic Compounds in Drinking Water"
.
Determination ofSoil Attenuation Capacity :
(Section 742.215)
Section 742 .215(b) states the soil attenuation is not exceeded if the sum of the
organic contaminant concentrations at a discrete sampling point is less than the natural
organic carbon fraction of the soil. The natural organic carbon fraction (ff) of soil shall
be either a default value as identified in Section 742 .215(b)(1)(A) or measured by one of
the methods identified in Section 742.215(b)(1)(B). The methods identified in Section
742.215(b)(1)(B) are ASTM Method D2974-87 (to be updated to D2974-00), SW 846
Method 9060 and Nelson and Sommers (1982)
.
TACO identifies two methods for determining the organic carbon content of soil,
ASTM Method D-2974-87 (to be updated to D-2974-00) and SW-846 Method 9060 (now
5
updated to 9060A), and one reference document, Nelson and Sommers (1982) . The
ASTM method measures the concentration of Total Organic Matter in a soil sample, and
according to Nelson and Sommers, a conversion factor must estimate the organic carbon
fraction in soil . SW-846 Method 9060A is used to determine the concentration of organic
carbon of a liquid such as ground water, surface and saline waters, and domestic and
industrial wastes. SW-846 Method 9060A is not for soil. Although this method can be
modified for soil samples by individual laboratories, the Agency is not aware of any
nationally recognized protocol to modify this method . Additionally, USEPA states on
their web page that there is no SW-846 method for total organic carbon in soils since the
USEPA Office of Solid Waste does not have a regulatory driver for total organic carbon
.
The ASTM method measures the concentration of total organic matter; therefore,
a conversion factor must be applied to this concentration to give an estimate of the
organic carbon concentration. Nelson and Sommers states the total organic matter
concentration should be multiplied by a conversion factor, typically between 0.50 and
0.58. Multiplying the total organic matter value derived from the ASTM test method by
the conversion factor will result in an estimate of the organic carbon concentration that
may be used to determine soil attenuation capacity. Therefore, the Agency proposes to
make the following change to Section 742.215(b)(1)(B) : A site-specific value as
measured by the analytical method referenced in Appendix C, Table F, appropriately
adjusted to estimate the fraction of organic carbon, as stated in ASTM D2971 87, Nelson
and Sommers (1982) ; or by SW 816 Method 9060: Total Or anic Carbon, as
6
incorporated be reference in Section 742 .210 ;
Contaminant Sourceand Free Product Determination :
(Section 742.305(e))
Section 742.305 identifies the requirements that must be met prior to excluding an
exposure route. Pursuant to 742 .305(e), an exposure route may not be excluded if any
soil exhibits the characteristics of toxicity for hazardous waste as determined by 35
Illinois Administrative Code Section 721 .124 or an alternative method approved by the
Agency. However, Section 721 .124 identifies the Toxicity Characteristic Leaching
Procedure as the only test method used in determining the characteristics of toxicity
.
Since no alternative method exists to determine the characteristics of toxicity, the Agency
proposes to strike the language stating "or an alternative method approved by the
Agency" .
Groundwater Ingestion Exposure Route
:
(Section 742 .320(d))
Section 742.320(d) identifies one of the requirements for excluding the
groundwater ingestion exposure route. Current language indicates that an ordinance,
effectively prohibiting the installation and use of potable water supply wells, is required
for any area within 2,500 feet from the source of the release . The 2,500 feet was
originally proposed by the Site Remediation Advisory Committee to correspond with the
maximum setback zone for a community water supply well under Section 14 .3 of the
Environmental Protection Act. However, this requirement that an ordinance be adopted
for any area within 2,500 feet excludes certain sites from using this Section of TACO . If
7
a site lies within 2,500 feet of a municipal boundary and no ordinance exists beyond the
municipal boundary, Section 742.320 cannot be used to exclude the pathway. This would
include sites that may only have measured and modeled concentrations extending only a
short distance off-site, but well within 2,500 feet of the boundary of the municipality with
the groundwater ordinance. To resolve this issue, the Agency proposes the following
language to 742.320(d): "As demonstrated in accordance with Section 742 .1015, for any
area within the measured and modeled extent of groundwater contamination above what
would otherwise be the applicable Tier 1 groundwater remediation objectives, an
ordinance adopted by a unit of local government is in place that effectively prohibits the
installation of potable water supply wells (and the use of such wells)." The language
change will allow a person to exclude the groundwater ingestion exposure route if the
contamination is measured and modeled to be within the agency approved ordinance area
of a municipality.
Tier 2 Groundwater Remediation Obiectives :
(Section 742.805(c)(1))
Section 742 .805(c)(1) identifies an equation to be used to satisfy the mixtures of
similar acting chemicals at the point of human exposure . In this equation, the parameter
x, through x2 is defined as the "Concentration of each individual contaminant at the
location of concern. Note that depending on the target organ/mode of action, the actual
number of contaminants will range from 2 to 14 ." Reviewing Appendix A, Table E and
Appendix E, Table F, the range of contaminants should be from 2 to 33. Therefore, the
Agency proposes the following language to 742 .805(c)(1): "Concentration of each
8
individual contaminant at the location of concern . Note that, depending on the target
organ/mode of action, the actual number of contaminants will range from 2 to 33 ."
Ordinances :
(Section 742.1015(b)(2))
During the last rulemaking (R00-19), the Agency proposed language for Section
742.1015(b)(2). However, the word "modeled" was left off the proposed change in the
final version of the docket . Therefore, the Agency proposes to add the following change
to Section 742 .1015(b)(2): "A scaled map(s) delineating the area and extent of
groundwater contamination modeled above the applicable remediation objectives
including any measured data showing concentrations of contaminants of concern in which
the applicable remediation objectives are exceeded" . The underlined "modeled" would
be added to the proposed language
.
AppendixC, Table D
Appendix C, Table D identifies the symbols, parameters, units, source, and
parameter values to be used in the Risk Based Corrective Action (RBCA) equations . The
Agency found an error in the tables for the soil bulk density symbol . The symbol for the
soil bulk density is currently P s, when the symbol should be Pb. The Agency proposes to
change the symbol for the soil bulk density to Pb to reflect the correct symbol and to be
consistent with the symbol for soil bulk density identified in Appendix C Table B and
Appendix C Table F
.
9
AppendixC, Table F
Pursuant to the discussion regarding the change to Section 742 .215, the Agency
proposes to modify Appendix C, Table F to reflect the Agency's proposed language in
Section 742.215(b)(1)(B) by removing Nelson and Sommers (1982) and USEPA SW-846
Method 9060A Total Organic Content from the Method column, updating ASTM-D2974-
87 to ASTM-D2974-00 Moisture, Ash and Organic Matter', adding "appropriately
adjusted to estimate the fraction of organic carbon as stated in Nelson and Sommers
(1982)" in the method column of the ASTM method, and add fraction in front of organic
carbon in the parameter column for fa .
This concludes my testimony .
THIS FILING IS SUBMITTED ON RECYCLED PAPER
.
10
RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERKS OFFICE
INTHE MATTER OF
:
JAN 10 2006
)
STATE OF
ILLINOIS
TIERED APPROACH TO CORRECTIVE
)
R06-10
Pollution Control Board
ACTION OBJECTIVES: AMENDMENTS)
(Rulemaking-Land)
TO 35 Ill. Adm. Code 742
)
PRE-FILED TESTIMONY OF LAWRENCEW.EASTEP, P.E .
My name is Lawrence W. Eastep. Until December 31, 2005, I was the manager of the
Remedial Project Management Section of the Bureau of Land of the Illinois Environmental
Protection Agency ("Agency") . The Remedial Project Management Section ("RPMS") is
generally responsible for Bureau of Land remedial actions at sites that may pose environmental
threats and that are not otherwise regulated by CERCLA, RCRA or LUST programs . The RPMS
also is responsible for the voluntary Site Remediation Program ("SRP"), which encourages and
administers many private party clean-ups .
I graduated from the University of Missouri at Rolla in 1969 with a B .S. in Civil
Engineering. I received my M.S. in Civil Engineering (Sanitary/Environmental) in 1976 from
the same institution. Except for a brief period from 1978 to early 1979 and my retirement on
December 31, 2005,1 was employed by the Agency since 1971 in a variety of positions including
manager of the Bureau of Land Permit Section from 1983 through 1993. I assumed my most
current responsibilities in January 1994 . I am registered as a Professional Engineer in Illinois . I
have thirty-three years experience in the environmental engineering field
.
I will be testifying in support of the proposed amendments to 35 111. Adm. Code 742
:
Tiered Approach to Corrective Action Objectives . Specifically, my testimony will address the
background table for polynuclear aromatic hydrocarbons, changes to Appendix B, Table A, and
the inclusion of construction worker remediation objectives in Appendix B, Table A for
residential scenarios .
1 .
Background Table For Polynuclear Aromatic Hydrocarbons And
Changes To Appendix B, Table A
Introduction
Over the last several years, The Illinois Environmental Protection Agency ("IEPA") has
become aware of significant "background" levels of polynuclear aromatic hydrocarbons, or
PNAs, in Illinois soils . PNAs can occur as a result of the incomplete combustion of organic
material and as a result of either natural or anthropogenic activities . Natural sources of PNAs are
suspected to be forest fires or volcanic activity. Anthropogenic sources include operation of
motor vehicles, coal burning power plants, burning refuse, outdoor grilling, and various
industrial operations such as activities at manufactured gas plants . An obvious source in Illinois
would be the great Chicago fire.
As a result of IEPA experience in reviewing contaminant investigations submitted
pursuant to the SRP, it became evident that PNAs were somewhat ubiquitous. However, the
IEPA did not have enough information to quantify the levels of PNAs, and it was determined that
additional study was needed . In order to meet existing remedial objectives for certain PNAs,
remedial applicants must remediate to below naturally occurring levels . This could mean
removal of soils to excessive depths and then trying to find clean fill that might meet all the Tier
I objectives. In many cases this was either technically infeasible or economically unreasonable .
In July 2000, a Brownfield Redevelopment Grant was approved for the City of Chicago to
allow for the investigation of PNA levels in ambient soils in the City of Chicago . In 2001 and
2002, a study was subsequently conducted by the City in conjunction with the U .S. Geological
Survey ("USGS") . The USGS assessed ambient soils, or "
.
. .those soils whose chemical
composition is affected by ubiquitous natural and anthropogenic processes rather than site-
specific disposal of waste materials ." Results of the investigation and a statistical analysis are
presented in Polynuclear Aromatic Hydrocarbon Background Study, City of Chicago, IL
(Chicago Study) prepared by Tetra Tech Inc . for the City of Chicago .
In the same time period, the Electric Power Research Institute ("EPRI") conducted an
investigation of PNAs in soils in the State outside of Chicago . The State of Illinois did not fund
this study, nor was it an active partner, but the IEPA and EPRI were in consultation, and the
IEPA did concur with the site selection and sampling protocols prior to commencement of the
study. Results of the investigation and a statistical analysis are presented in Polycyclic Aromatic
Hydrocarbons (PAHs) in Surface Soil in Illinois
: Background PAHs ("EPRI Study"),
incorporated by reference in Section 742 .2 10 .
Results of Background Studies
In the Chicago Study, results from fifty-seven randomly selected sampling locations
across the City were used. Sixteen separate PNAs were analyzed for each sample . These
locations represented properties owned by the City (such as police stations, fire stations, and
libraries) and Commonwealth Edison. Sites were rejected from sampling if there was evidence
of prior releases ; the sites were close to industries that might have an impact on the sample ; they
were completely paved, etc . The resultant data were statistically evaluated and found to be
lognormally distributed. The parametric 95 th percentile was selected for use as the appropriate
background value. It represents a number that 95% of any samples would be less than . The 95th
percentile and median concentrations for the data are listed in Table 1 . Where available, Tier 1
TACO limits are included for reference
.
In the EPRI study, the State was divided into sixteen areas from which samples were
selected. Areas selected were considered "populated areas" (with 1000 people/ sq . mile or 1 .56
persons per acre), with a minimum population of 10,000 people. These were not necessarily
within any municipal boundaries . Many of the sample locations were located in apparent
unincorporated areas of their counties outside of municipal limits . In some cases, sample
locations were 1-2 miles out from municipal limits, and in one case, Macomb, almost 3 miles
out. Sample sites selected included parks, roadway medians, utility rights-of-way, commercial
property, residential property, parking lot buffers and vacant lots . Most of the general areas
around the actual sites sampled were residential, commercial, or rural . Contaminated sites were
not sampled. For the actual sites sampled, only 1 % of the sites were deemed to be "industrial"
.
Results showing the 95' h percentile are shown in Table 1
.
In general, both studies showed that several PNA compounds were found to be present in
almost every sample collected throughout the State . Not all of the specific PNA compound
background levels exceeded TACO Tier I objectives, and the relationships of which PNAs
exceeded particular Tier 1 objectives varied from Chicago, the metropolitan, and non-
metropolitan areas. For the purposes of this testimony, when background is referenced, it means
the 95th percentile value derived as a result of the studies . For example, the Benzo(a)Anthracene
background levels found in Chicago (1.099mg/kg) and the downstate metropolitan areas (1.84
mg/kg) exceeded the TACO Tier 1 residential ingestion level of 0 .9mg/kg, but not the
industrial/commercial, migration to groundwater, or construction worker levels . However,
benzo(a)pyrene in Chicago (1 .302mg/kg), in the downstate metropolitan areas (2 .14 mg/kg), and
in the non-metropolitan areas (0 .98mg/kg), all exceeded the TACO Tier 1 residential ingestion
level of 0.09 mg/kg and the industrial commercial level of 0.8 mg/kg
.
Development of Background Values
The IEPA proposes to allow PNA background levels to be used in the City of Chicago
and in other populated areas . This change is similar to the amendments IEPA made for the
background for arsenic . A new table has been added, the term "populated area" has been
defined, and the Tier 1 tables have been changed. A new Table H (in Appendix A) is proposed
that would show the background levels for the various PNAs in Chicago and in populated areas
outside of Chicago, identified as either metropolitan or non-metropolitan . Additionally, the term
"populated area" is newly defined and means any municipality with a population greater than
10,000 and the area within three miles of the municipal boundary . Finally, the Tier 1 tables have
been modified. For the PNAs that have background levels exceeding a tier objective of any kind,
the appropriate background level is incorporated into the Tier 1 table by virtue of a footnote . The
footnote directs the reader to Appendix A, Table H
.
New Table H has three columns . These columns have values for Chicago, Metropolitan
Areas and Non-Metropolitan areas. The three separate areas were used because levels were
statistically different in those areas . For benzo(a)anthracene, background levels exceeded Tierl
ingestion levels only in Chicago and the downstate metropolitan areas, but not non-metropolitan
areas. Thus, the non-metropolitan areas would not use Table H since background in these areas
was below Tier 1 levels. For benzo(a)pyrene (`BaP"), both the residential and
industrial/commercial ingestion columns have a footnote telling the reader that any "populated"
area in the state could use the background numbers in Table H
.
,
The use of the term "metropolitan area" refers to counties in "standard metropolitan
statistical areas" ("SMSA")
. The term "non-metropolitan areas" refer to counties not in SMSAs .
These counties are identified in Appendix A, Table G . The term "populated area" refers to any
municipality with a population greater than 10,000 and the area within three miles of the
municipal boundary boundary. There are many communities in the State that are somewhat
urbanized far beyond their corporate limits and the EPRI study basically took this into account
.
This definition differs from the strict definition EPRI used
(i .e., an "area" with 10,000 people and
a density of 1000/sq .mile) because the IEPA felt that defining populated area without utilizing
municipal boundaries would be much too cumbersome for all affected parties . The density factor
(1,000 persons/square mile or 1 .56 persons/acre) did not appear to make much of a difference,
and areas meeting the populated area definition will likely have the appropriate density
.
Obviously, a city of 10,000 would clearly be identified as fitting within the definition. Without
the reference of a boundary there would be a problem finding 10,000 people if they are not in an
incorporated area. In making such a determination, the IEPA would have to consider such things
as the proximity of the site to larger communities, and the nature of the surrounding area
(e.g.,
whether it is a high traffic area, it is agricultural, it is an unincorporated "doughnut" located
between larger communities, it is rural with only a history of residential use, etc) . The IEPA
feels that most sites will be easily categorized, one way or another, in a clear objective manner
.
Conclusion
There were five PNAs that had background levels that exceeded at least one of the
objectives listed in TACO . Of these, it is felt that the greatest impact will be for cleanups where
Benzo(a)Pyrene is present. From personal experience, it appears that many Chicago area and
downstate cleanups encounter Benzo(a)Pyrene at some level, generally above the Tier 1
residential level and near the background level. Allowing remedial applicants to utilize
background will help hold costs down and allow them to focus on contaminants of concern,
while still protecting human health and the environment
.
Chicago study
TABLE 1
EPRI study
TACO limits for reference
Chemical Name
Chicago
95th
percentile
(mg/kg)
Chicago
Median
(mg/kg)
Metro
mg/kg
Non-
metro
mg/kg
Resident
Industrial Migration Construction
Ingestion Commercial to ground-
Worker -
ingestion or
inhalation
(mg/kg)
(mg/kg)
Ingestion
(mg/kg)
water
(mg/kg)
2-methylnaphthalene
0.135
0.289
Acenapthene
0.085
Acenaphthylene
0.03
0.016
0.0685
0.044
Anthracene
0.248
0.017
0.402
0.143
23000
610000
12000
610000
Benzo (a) Anthracene
1 .099
0.855
1.84
0.719
0.9
8
2
170
Benzo (a) pyrene
1 .302
0.975
2.14
0.98
0.09
0.8
8
17
Benzo (b) fluoranthene
1 .484
1 .05
2 .05
0.704
0.9
8
5
170
Benzo (g,h,I) perylene
0.684
0.46
1 .67
0.843
Benzo (k) fluoranthene
0.992
0.77
1 .68
0.634
9
78
49
1700
Chrysene
1.158
0 .88
2 .72
1 .07
88
780
160
17000
Dibenzo (a,h,)
0.205
0.14
0.422
0.154
0.09
0 .8
2
17
anthracene
Fluoranthene
2.72
2.05
4.08
1 .83
3100
82000
4300
82000
Fluorene
0.102
0.084
0.179
0.041
3100
82000
560
82000
Ideno (1,2,3-cd) pyrene
0.858
0.595
1.552
0.513
0 .9
8
14
Naphthalene
0.038
0.02
0.201
0.168
1600
41000
12
1 .8
Phenanthrene
1.333
1 .1
2 .46
0.991
Pyrene
1 .9
1 .65
3 .03
1 .23
2300
61000
4200
61000
Examples of some Benzo (a) Pyrene values from the EPRI study showing the range of values
detected
.
*areas outside of city limits
Sample
No .
BE-06
City
Bellville
Site use
Utility
Area use
Heavy Residential
B(a)P -value ug/kg
3830
BE-06
Bellville
Right of Way
Light Industrial
1020
*
BE-10
Bellville
Right of Way
Light Industrial
8 .2
CA-08
Carbondale
Right of Way
Commercial
2850
CA-05
Carbondale
Municipal
Light Industrial
5.03
DA-10
Danville
Right of Way
Heavy Residential
3260
DA-04
Danville
Recreational
Heavy Residential
42 .9
DE-02
Decatur
Right of Way
Heavy Residential
1420
EF-08
*
Effingham
Right of Way
Heavy Residential
1110
GL-01
Glenview
Municipal
Heavy Residential
5960
GL-02
Glenview
Municipal
Commercial
394
GL-07
Glenview
Municipal
Commercial
3360
LA-10
Lansing
Right of Way
Commercial
1150
QY-08
Quincy
Utility
Commercial
124
QY-09
Quincy
Utility
Heavy Industrial
1970
RF-06
Rockford
Right of Way
Light Industrial
1760
RF-07
Rockford
Right of Way
Heavy Residential
21
II .
Inclusion of Construction Worker Objectives for Certain Chemicals in
Appendix B, Table A for Residential Scenarios
Introduction
There are a number of chemicals (28) that have industrial commercial construction
worker remedial inhalation objectives that are more stringent than the residential inhalation
objectives. However, the manner in which TACO is used allows for construction activities on
residential properties. For example, a site cleaned up to residential objectives might be expected
to have construction of residential properties, repairs to those properties, etc . Additionally, many
sites clean up to TACO residential objectives, even though the intended use of the property is
industrial. Therefore, in order to protect the construction worker, the IEPA felt that it was still
necessary to apply the industrial commercial construction worker remedial inhalation objectives
to residential scenarios
.
Revisions to TACO
In order to apply the industrial commercial construction worker remedial inhalation
objectives that are more stringent than residential objectives, the chemicals in question have been
footnoted. The footnotes require the applicant to consider the construction worker objectives
when evaluating Tier 1 residential uses for inhalation. An option would have been to add
another column to the residential tables, but since only 28 chemicals are involved, a footnote
seemed sufficient. Another option would have been to simply replace the residential inhalation
objective with the construction worker objective, but the basis for the residential objectives is a
residential setting, not construction work. For example, if an applicant in the Site Remediation
Program is evaluating naphthalene in a residential setting, the residential inhalation Tier 1
objective is 170mg/kg. The Tier I table (Appendix B, Table A) now has a footnote "x" for
naphthalene that tells the applicant to go to Appendix B, Table B, where the naphthalene
construction worker objective is 1 .8mg/kg. Thus, the applicant in this case would also have to
comply with the industrial commercial construction worker remedial inhalation objective
.
The IEPA also considered adjusting the exposure period for construction workers in a
residential setting, since construction worker exposures in a residential setting would normally be
shorter than in an industrial/commercial setting. However, since many applicants remediate to
residential levels in order to reduce encumbrances on their property, and actually intend on using
the property for industrial uses, no changes were deemed necessary.
Conclusion
Since construction workers could be subjected to similar, if not identical, exposures in a
residential setting as they would in an industrial setting, this change is necessary to be protective
of human health .
RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERICS OFFICE
JAN 1 0 2006
STATE OF
ILLINOIS
Pollution Control Board
IN THE MATTER OF
:
)
PROPOSED AMENDMENTS TO
)
TIERED APPROACH TO CORRECTIVE
)
ACTION OBJECTIVES
)
(35 Ill. Adm. Code 742)
)
R06-10
(Rulemaking - Land)
PRE-FILED TESTIMONY OF THOMAS C. HORNSHAW, Ph.D.
Qualifications
My name is Thomas C. Homshaw. I am a Senior Public Service Administrator and the
Manager of the Toxicity Assessment Unit of the Illinois Environmental Protection Agency
(Agency). I have been employed at the Agency since August of 1985, providing expertise to the
Agency in the area of environmental toxicology. Major duties of my position include development
and use of procedures for toxicity and risk assessments, review of toxicology and hazard
information in support of Agency programs and actions, and critical review of risk assessments
submitted to the Agency for various cleanup and permitting activities
.
1 was a member of the Agency's Cleanup Objectives Team until February of 1993, when that
Team's responsibilities were assumed mainly by the Toxicity Assessment Unit . I was also a
member of the Groundwater Standards Technical Team during the development of the
Groundwater Quality Standards. These two teams have looked in depth at the problems involved
with determining acceptable residual concentrations of chemicals in soil and/or groundwater . I
have also participated in the development of the original 35 Ill . Adm. Code Part 742 rule, Tiered
Approach to Corrective Action Objectives (TACO ; R97-14) and the first amendment to this rule
(ROO- 19) .
1
I received Bachelor of Science (with honors) and Master of Science degrees in Fisheries Biology
from Michigan'State University, East Lansing, Michigan . I also received a dual Doctor of
Philosophy degree from Michigan State University, in Animal Science and Environmental
Toxicology. I am a member of the Society of Environmental Toxicology and Chemistry and
Sigma Xi, the Scientific Research Society. I have authored or co-authored six papers published in
peer-reviewed scientific journals, one report issued through the U.S. Environmental Protection
Agency, and have written or co-written six articles which have appeared in trade journals
. I have
also presented fourteen posters and/or talks describing facets of my graduate work and my work at
the Agency at various regional and national meetings . A more descriptive account of my work and
educational background and a list of publications, posters, and talks is included in
a
Curriculum
Vitae presented as Exhibit A to this testimony
.
Testimonial Statement
My testimony today concerns several changes and updates needed to the text and tables
of Part 742. I will describe changes necessary to remediation objectives for certain chemicals in
Appendix B, Tables A, B, E, and F due to changes in the toxicity information for these
chemicals. I will testify about the development of new remediation objectives for Lead for the
Industrial/Commercial and Construction Worker Ingestion Route that are added to Appendix B,
Table B, and pH-specific objectives for the Soil Component of the Groundwater Ingestion Route
that are added to Appendix B, Tables C and D. I will also testify about the development of soil
ingestion remediation objectives for the major nutrients Calcium, Magnesium, Phosphorus,
Potassium, and Sodium. Finally, I will describe several minor changes or corrections that need
2
to be made to the text and tables of TACO that have come to the attention of the Toxicity
Assessment Unit .
TOXICITY INFORMATION CHANGES
As was the case in the first amendment of TACO, updating of the toxicity information for
certain chemicals by USEPA necessitates the revision of remediation objectives for these
chemicals in the associated Tier 1 remediation objective tables in Appendix B . Toxicity criteria
have been updated since the R00-19 rulemaking for Acetone, Boron, 1,2-Dibromoethane, 1,1-
Dichloroethylene, Phenol, and Xylene . The specific changes for these chemicals include : a new
Reference Dose (RID) for Acetone ; a revised RID and withdrawal of the Reference
Concentration (RfC) for Boron ; a new RfD and revised RfC, oral cancer Slope Factor (SFo), and
inhalation cancer Unit Risk Factor (URF) for 1,2-Dibromoethane; a revised RfD and a new RfC
for 1,1-Dichloroethylene; a revised RfD for Phenol ; and a revised RID and a new RfC for
Xylene. These updated toxicity values were used in the appropriate SSL Equations in Appendix
C, Table A to calculate updated soil objectives for these chemicals, and the updated objectives
have been entered into Appendix B, Tables A and B . The procedures of 35 Ill. Adm. Code
620.Subpart F were also used to update the groundwater objectives to 6.3 mg/L in Appendix B,
Tables E and F for Acetone . Note that since the Tier 1 Groundwater Remediation Objective for
all chemicals except Acetone is also the Groundwater Standard under 35 Ill . Amd. Code 620 for
these chemicals, only Acetone's objective is being changed in Appendix B, Tables E and F at
this time. These updated objectives are proposed to be included in Appendix B, Tables A, B, E,
and F (the change in Table F was inadvertently omitted from the original filing of this proposal
and is now included in Errata Sheet Number 1) .
3
In addition, the Toxicity Assessment Unit has become aware of a clarification from
USEPA on the need for an adjustment to the RfD for Manganese for soil ingestion exposures to
account for dietary intake of this element. Specifically, USEPA has determined that the RID of
0.14 mg/kg/d, which corresponds to a daily intake of 10 mg/d (0.14 mg/kg/d times the assumed
body weight of 70 kg) must be adjusted to account for the assumed 5 mg/d intake from the diet
.
Using the Modifying Factor of 3 contained in the USEPA's Integrated Risk Information System
(IRIS) file for Manganese, the adjusted RfD is 0 .02 mg/kg/d for non-dietary ingestion (5 mg/d
divided by the Modifying Factor of 3 divided by 70 kg body weight) . This adjusted RID was
used as above in the appropriate SSL equations to calculate replacement values for the Ingestion
Route, which are being proposed for this chemical's Tier 1 remediation objectives .
NEW LEAD OBJECTIVES
In response to inquiries regarding the appropriateness of the existing 400 mg/kg soil
objective (based on a child's exposure assumptions) for the worker exposures assumed for the
Industrial/Conunercial and Construction Worker Ingestion Route, the Toxicity Assessment Unit
researched this issue in discussions with USEPA staff. After reviewing the USEPA Adult Blood
Lead Model, it was decided that the default inputs for this model could be used to calculate new
soil objectives of 800 and 700 mg/kg for the Industrial/Commercial and Construction Worker
Ingestion Routes, respectively. These values are proposed to be added to Appendix B, Table B
.
The details of these calculations are contained in Memoranda from Les Morrow and Connie
Sullinger to me, which are attached as Exhibits B and C to this testimony. Note that the 800
mg/kg value for the Industrial/Commercial worker was inadvertently left out of the original
filing of this proposal and is now included in the Errata Sheet
.
4
The Toxicity Assessment Unit also became aware of a USEPA publication
(Understanding Variation in Partition Coefficient, Kd, Values . Volume II: Review of
Geochemistry and Available Kd Values for Cadmium, Cesium, Chromium, Lead, Plutonium,
Radon, Strontium, Thorium, Tritium, and Uranium . USEPA Office of Air and Radiation
.
EPA402-R-99-004B, August 1999) that could provide an approach to developing pH-specific
objectives for the Soil Component of the Groundwater Ingestion Route for Lead . The section on
Lead contains a review of the variations in the soil-water partition coefficient (Kd) under
different soil pH conditions, and contains a table listing the minimum and maximum Kd for three
different pH ranges and four different equilibrium Lead concentration ranges . From this table,
the Toxicity Assessment Unit selected the most restrictive Kd values, corresponding to the
minimum Kds for the three pH ranges at an equilibrium Lead concentration range of 100-200
ug/1 (Kds of 150 L/kg for pH 4.0-6.3, 710 L/kg for pH 6 .4-8.7, and 1,880 L/kg for pH 8.8-11 .0),
as the basis for calculating the soil objectives for the Soil Component of the Groundwater
Ingestion Route. These Kds were used in SSL Equation S 17 from Appendix C, Table A to
calculate soil objectives for the three pH ranges . It is proposed to add objectives for lead of 23
mg/kg for pH 4.5 through 6.24, 107 mg/kg for pH 6.25 through 8.74, and 282 mg/kg for pH
8.75-9.0 in Appendix B, Table C, and values of 300, 1,420, and 3,760 mg/kg for these ranges,
respectively, in Appendix B, Table D. A copy of the Lead section of the USEPA document is
attached as Exhibit D to this testimony. Note that these Kd values are also added to the pH-
specific table of Kds in Appendix C, Table J
.
MAJOR NUTRIENTS
In response to several requests for and submissions of remediation objectives for essential
nutrient minerals, I reviewed recent literature
(A
Risk Assessment Model for Establishing Upper
5
Intake Levels for Nutrients
.
Food and Nutrition Board, Institute of Medicine, National Academy
of Sciences. June 1998 ; and
Recommended Dietary Allowances, 10` 1' Edition .
Subcommittee on
the Tenth Edition of the RDAs, Food and Nutrition Board, Commission on Life Sciences,
National Research Council. 1989) pertaining to the normal, recommended, and tolerable upper
intakes for Calcium (Ca), Magnesium (Mg), Phosphorus (P), Sodium (Na), and Potassium (K)
.
Even when taking into account upper percentiles of the normal daily dietary intake of Ca, P, Na,
and K, and assuming that the "soil" ingested by the receptors listed in TACO is 100% nutrient,
there are no concerns for any soil concentration of these minerals for the Ingestion Route by any
of the receptors. For Mg, there is no concern for ingestion by industrial/commercial receptors at
any soil concentration, while the Residential receptor will be protected at concentrations up to
325,000 mg/kg and the Construction Worker receptor will be protected at concentrations up to
730,000 mg/kg. Therefore, the Agency proposes to add these nutrients to Appendix B, Tables A
and B with the above listed values for Mn for the Residential and Construction Worker receptors,
and footnote "g" (indicating no concern at any concentration) for all receptors for the other
nutrients for the Ingestion Route. There are no appropriate criteria for evaluating the Inhalation
Route, and these nutrients are not able to be analyzed by the leachate tests used for the Soil
Component of the Groundwater Ingestion Route, so no soil objectives are proposed for these
routes. Since these nutrients are all included in the analytical procedure for Total Dissolved
Solids (TDS), it is proposed that they be added to the Appendix B, Table E groundwater
objectives, with a new footnote citing the 35 Ill . Adm. Code 620 Groundwater Quality Standards
for TDS of 1,200 mg/I for both classes of groundwater as the remediation objective . It should be
noted that there may be ecological receptors, especially plant species, that could be impacted by
high levels of essential nutrients in soil ; therefore, it is also proposed to include footnote "n"
6
(indicating that the Agency reserves the right to evaluate potential threats to crops, livestock, or
wildlife) to the entries for these nutrients in Appendix B, Tables A and B
.
MINOR CHANGES AND CORRECTIONS
As a result of its own review or because of questions from outside the Agency, the
Toxicity Assessment Unit has become aware of several minor changes and corrections needed in
TACO. Therefore, the following modifications are proposed :
Section 742 .200 - The definition of "Volatile Organic Compounds (VOCs)" contains a
list of USEPA SW-846 Methods that identify VOCs. The most recent update to the SW-846
Methods contains the following changes to this list : Method 8010 has been deleted ; Method 8015
has been changed to Method 8015B; Method 8020 has been deleted ; Method 8021 has been
changed to Method 8021B; Method 8030 has been deleted ; Method 8240 has been deleted ;
Method 8260 has been changed to Method 8260B; and Method 8315 has been changed to
Method 8315A. These changes are proposed for this definition .
Section 742.210(a) - As described above, the USEPA SW-846 methods have been
updated since the last TACO amendment, necessitating a revision of this document's
Incorporation by Reference citation under the Government Printing Office documents
.
However, a problem has arisen regarding this citation. In the past, the Agency has routinely
been provided hard copies of SW-846 updates as they became available in draft, proposed, and
final versions. Recently, however, USEPA has begun making these documents available to the
public on line, and paper and CD copies must now be purchased. Due to budgetary constraints,
the Agency does not intend to purchase either a paper or CD copy of the SW-846 methods since
it is free on line. Therefore, the Agency is proposing a website citation for SW-846 instead of a
date-certain document .
7
The Agency is aware that the Illinois Administrative Procedures Act (IAPA) requires that
a date-certain document be used when incorporating documents by reference . However, at the
time the IAPA was written, we were not in the on line information age that we are today
.
Additionally, with the advent of paperless office legislation, many businesses and governmental
bodies do not keep paper copies of documents, especially those that are regularly updated such as
SW-846. It is vitally important that current analytical procedures be used in conjunction with
TACO-based cleanup projects, and the on line version of SW-846 will always contain these
current procedures. Therefore, we request that the Board make special exception to the general
rule regarding date-certain incorporations by reference and accept this citation via an on line web
address. In support of this request, we contend that the latest updates are readily available to the
public via the world wide web, and if a person does not have access to the web the Board could
download the most current update for inspection. Thus, we propose that the current citation for
SW-846 be replaced by: "Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods", USEPA Publication number SW-846 (Third Edition, Final Update IIIA), as amended
by Final Updates 1, II,.IIA, JIB, III, and IIIA (Document No. 955-001-00000-1). Available at
www.epa.gov/epaoswer/hazwaste/test/main.htm
.
There are also some outdated references in the National Technical Information Services
documents in this section that need to be replaced . The Agency proposes to delete the 1992
"Dermal Exposure Assessment: Principles and Applications" citation and replace it with "Risk
Assessment Guidance for Superfund, Vol . 1 : Human Health Evaluation Manual (Part E,
Supplemental Guidance for Dermal Risk Assessment) Interim", EPA Publication No
.
EPA/540/R/99/005 (September 2001). Also, it is proposed to delete the 1989 "Exposure Factors
Handbook" and replace it with the three-volume update, which will add : "Exposure Factors
8
Handbook, Vol . I: General Factors", EPA Publication No . EPA/600/P-95/002Fa (August 1997) ;
"Exposure Factors Handbook, Vol . II: Food Ingestion Factors", EPA Publication No
.
EPA/600/P-95/002Fb (August 1997) ; and "Exposure Factors Handbook, Vol. III: Activity
Factors", EPA Publication No . EPA/600/P-95/002Fc (August 1997). Note that only Volume I
has been used in the development of TACO, but the other two Volumes are being cited because
they could be used in Tier 3 assessments
.
Finally, it is proposed to add to this section USEPA's update to the original Soil
Screening Guidance, "Supplemental Guidance for Developing Soil Screening Levels for
Superfund Sites", OS WER Directive 9355 .4-24 (December 2002). It is not proposed to delete
the original Soil Screening Guidance references, as these documents contain information still
used in TACO .
Section 742 .220(b) - After discussion with USEPA, the Agency determined that it was
intended that the requirement not to exceed the soil saturation limit only applies to liquid
chemicals for the Soil Component of the Groundwater Ingestion Route, as is already the case for
the Inhalation Route in Section 742.220(a). Therefore, the Agency proposes to add "that has a
melting point below 30°C" after "For any organic contaminant" in the first line
.
Section 742 .225 - In order to clarify the acceptable procedures for compositing and
averaging samples to demonstrate compliance with remediation objectives, the Agency proposes
several changes for this Section: change Subsection (c)(1) to specify that if samples are
composited for the Soil Component of the Groundwater Ingestion Exposure Route, the samples
must be collected beginning at six inches below the ground surface for surface contamination
and at the upper limit of contamination for subsurface contamination ; add a new Subsection
(c)(4) prohibiting the averaging of composite samples for this exposure route, since composite
9
samples are already averages of soil concentrations, and allowing arithmetic averaging of
samples collected at every two feet of depth as specified in Subsection
(c)(1)
; add a new
Subsection (d)(4) also prohibiting the averaging of composite samples for the Ingestion and
Inhalation Exposure Routes, and specifying the use of USEPA's "Calculating Upper Confidence
Limits for Exposure Point Concentrations at Hazardous Waste Sites", USEPA Office of
Emergency and Remedial Response, OSWER 9285 .6-10 (December 2002), or an alternative
procedure approved by the Agency, as the method to be used to demonstrate compliance with
remediation objectives for these routes of exposure (this document is proposed for addition to the
incorporations by reference) ; and change Subsection (e) to reduce the limit on the number of
non-detect samples allowed to be averaged from 50% to 15%, based on USEPA's "Guidance for
Data Quality Assessment, Practical Methods for Data Analysis, EPA QA/G-9, QAOO Update",
EPA/600/R-96/084 (July 2000), and specifying this guidance or an alternative procedure
approved by the Agency as the method to be used to address non-detect values at greater than
15% when determining averages . This document is also proposed for addition to the
incorporations by reference .
Section 742 .5 10(a)(5) - When the Agency expanded the upper limit of pH values
included in Appendix B, Tables C and D from 8 .0 to 9.0 in the R00-19 amendment to TACO, we
inadvertently neglected to change the text of this Section to reflect the change in the tables, and it
is proposed to do so now .
Appendix A, Table G - Due to a typographical error, the values for Aluminum, Calcium,
Iron, Magnesium, and Potassium include decimal points instead of commas (changes listed
in
Errata Sheet Number 1) .
10
Appendix A, Table H - No data are available for Chicago for 2-Methylnaphthalene
;
therefore, the Agency proposes to add dashes instead of leaving this space blank (change listed in
Errata Sheet Number 1)
.
Section 742 .Appendix A, Table I -Since Beryllium is no longer thought to be
carcinogenic by the oral route, it must be deleted from this table (this should have been done in
the R00-19 amendment when the Ingestion Route soil objectives were updated) . Also, the
updated toxicity data for 1,2-Dibromoethane requires that the 1 in 1,000,000 Cancer Risk
Concentration be changed from 0.0000010 to 0.00002
mg/L,
and this chemical needs to be
capitalized in the Chemical column (1,2-Dibromoethane changes listed in Errata Sheet Number
1)
.
Section 742.Appendix B, Tables A and B - In addition to the changes needed because of new
toxicity data, several changes/corrections are necessary to these tables (Note : Changes marked
by * are listed in Errata Sheet Number 1)
:
•
Due to a typographical error, the value for the Soil Component of the Groundwater
Ingestion Route for 1,2-Dibromo-3-chloropropane for Class II Groundwater should be
changed from 0.002 mg/kg to 0.02 mg/kg in both tables .
•
Due to an error in using the Toxicity Assessment Unit's computer program that calculates
TACO remediation objectives, an incorrect value has been listed for 1,2-Dibromoethane
for the Inhalation Exposure Route for the Construction Worker in Table B, requiring a
change from 0.03 to 0.16 mg/kg; since the correct value is now greater than the value
(0.06 mg/kg) for the Inhalation Route for Residential Exposures, Footnote x is no longer
necessary for this chemical in Table A.*
11
•
Due to an unknown problem, there are two entries listed for remediation objectives for
the Soil Component of the Groundwater Ingestion Exposure Route for most of the
Inorganics in both tables, --- and a numerical value. Where this occurs, the --- must be
deleted, leaving only the numerical value. In addition, in Table B the numerical value
has also been lined through ; the lining through must be removed, leaving only the
numerical value.*
•
In both tables, the Footnote m has been inadvertently deleted from the values for Nitrate
for the Soil Component of the Groundwater Ingestion Route, and must be added .*
•
In Table A, the Footnote m has been inadvertently added to the --- listing for Silver for
the Soil Component of the Groundwater Ingestion Route for Class II Groundwater, and
must be deleted.*
•
In Table B, the values for the Ingestion Exposure Route for Acetone for the
Industrial/Commercial and Construction Workers were originally listed as 1,000,000
mg/kg, but the more correct Footnote g should have been entered .*
•
Due to a typographical error, the value for the Ingestion Route for Chlordane for the
Industrial/Commercial receptor should be changed from 1 .6 mg/kg to 16 mg/kg
.
•
Due to a formatting error, the footnote i has been capitalized for all Ionizable Organics
except 2,4,5-TP in Table B for the Soil Component of the Groundwater Ingestion
Exposure Route for Class I Groundwater, and in the list of Footnotes to the table . This
must be changed to lower case .*
•
As noted above, the Reference Concentration for Boron has been withdrawn, but the
previous value in Table B for the Inhalation Exposure Route for the
12
Industrial/Commercial Worker (1,000,000 mg/kg) has been inadvertently left in the table_
This value should be replaced by --- (as was done for the Construction Worker) .*
•
The Toxicity Assessment Unit has discovered that the computer program used to
calculate TACO remediation objectives has incorrectly used equations for particulates
instead of for vapors in calculating the Inhalation Exposure Route objectives for Mercury
for the Industrial/Commercial and Construction Workers. These objectives were re-
calculated using the appropriate equations, and the new values are proposed as
replacement values. Since the objectives are to be used for the Inhalation Route,
Footnote s in both tables has been changed to specify that the Inhalation objectives apply
only at sites where elemental mercury is a contaminant of concern
.
•
As discussed above, new Ingestion Exposure Route objectives have been developed for
Lead for the Industrial/Commercial and Construction Workers, and a new Reference
Concentration for 1, 1 -Dichloroethylene has allowed calculation of new Inhalation
Exposure Route objectives for these workers. These changes have rendered Footnotes k
and v unnecessary, and they should be deleted and the footnotes re-numbered
.
Section 742.Appendix B, Tables E and F - Since there is no reason to list Ionizable Or2anics
separately for groundwater objectives, it is proposed to merge these chemicals alphabetically
with the non-ionizable organics in these tables . The Toxicity Assessment Unit has also
determined that there are three chemicals, 2-Chlorophenol, 2,4,5-Trichlorophenol, and 2,4,6-
Trichlorophenol, whose organic carbon partition coefficient (Koc) values fall below the
threshold Koc at which routine water treatment procedures (in this case, granular activated
carbon) may not sufficiently remove a chemical from the water . Note that: Koc values for
ionizable organics change with pH due to the relative proportions of ionized versus un-ionized
13
species present at a particular pH; the Agency has testified in the original TACO rulemaking that
we have used the Koc of Ethylbenzene as the threshold for determining whether a chemical may
not be sufficiently removed by granular activated carbon ; and we also testified that if a chemical
is able to be removed by routine water treatment procedures, then the Class II groundwater
objective will be five times the Class I objective . The Kocs for these three chemicals fall below
the threshold Koc of 363 L/kg at pHs of 7 .4, 7.9, and 6.9, respectively, which requires that we
not use the five-fold increase above these pH values . Therefore, the Agency proposes that at and
above these pH values the chemicals' Class II objectives be equal to the Class I objectives
instead of five times the objectives as in the current version of TACO . Finally, due to a
typographical error, the values for Class II Groundwater for 1,2-Dibromo-3-chloropropane
should be changed from 0.0002 mg/I to 0.002 mg/I in these tables .
Appendix C, Table E - Due to a typographical error, an incorrect CAS No . has been listed
for Chlorobenzene. The CAS No. should be corrected to 108-90-7
.
Appendix C, Table I - When the above-mentioned expansion of the upper limit of pH values
to pH 9.0 occurred in R00-19, the Agency also neglected to expand the pH range in this table to
9 .0. The expanded table will be included in a second Errata Sheet
.
Concluding Statement
I feel it is important to mention at this time that there are changes included in USEPA's
2002 update to the Soil Screening Guidance that will likely result in major changes to the
calculation of some of the TACO Tier I remediation objectives, and, thus, changes to the values
of these objectives. There is also new USEPA guidance about preferred sources for the toxicity
data to be used in deriving risk-based concentrations, and newly-updated physical/chemical
constants, all of which will result in additional changes to the Tier I values. There are other
14
issues that the Toxicity Assessment Unit has brought up internally for discussion within the
Agency regarding certain aspects of TACO that could also impact the development of
remediation objectives . In light of these changes and issues, it is the Agency's intent to begin a
dialog with the Site Remediation Advisory Committee to assess these items, and to eventually
come before the Board with a separate docket that may contain major revisions to TACO
.
This concludes my portion of the Agency's testimony for the proposed amendments to
TACO .
15
CURRICULUM VITAE
THOMAS C. HORNSHAW
EDUCATION: Ph.D., Animal Science and Environmental Toxicology, 1985
.M.S ., 1981, and B.S.,
1976,
Fisheries Biology, Michigan State University
.
EXPERIENCE: Senior Public Service Administrator, Illinois Environmental Protection Agency, 1985
-
Present.
Graduate Research Assistant, Department of Animal Science, Michigan State University, 1981
- 1984 .
Graduate Research Assistant, Department
of
Fisheries and Wildlife, Michigan State University, 1978 -
1981 .
Student Aide, Water Quality Division, Biology Section, Michigan Department
of
Natural Resources,
1976-1977 .
FIELDS OF EXPERIENCE: At the Illinois Environmental Protection Agency, Dr . Hornshaw's major
duties include the management
of
the Toxicity Assessment Unit; development and use
of
procedures
for human and environmental exposure assessments and risk assessments ; review of toxicological data
and hazard information in support
of
Agency programs and actions; and critical review
of
remedial
investigation and risk assessment documents submitted to the Agency during hazardous waste
site
investigations and cleanups. Dr. Hornshaw was a member of the Agency's Cleanup Objectives Team
until 1993, when that Team's functions were assumed by the Toxicity Assessment Unit . As a member
of the Air Toxics Action Committee, he participated in the development of Illinois= Air Toxics rules
.
He is one of the Agency's representatives to the Great Lakes Toxic Substances Control Agreement
(member of the Fish Advisory Task Force) and is the Chair of the multi-agency
Illinois Fish
Contaminant Monitoring Program
.
Dr. Hornshaw is also a member of the National Advisory
Committee for Acute Exposure Guidance Levels, moderated, by
USEPA, whose task is the
development of action levels for use in unplanned air releases
of
hazardous chemicals. In an earlier
assignment at the Agency, Dr. Hornshaw assisted in the development of bioassay protocols and quality
assurance procedures for the Biomonitoring Unit
.
As part of his duties during his Ph.D. research at Michigan State University, Dr. Hornshaw conducted
experiments to develop protocols for mammalian wildlife dietary LC 50
and reproduction tests, using
mink and European ferrets as representative mammalian carnivores . He has published four papers in
scientific journals as a result of this research, and the protocols developed from these studies have been
published by USEPA
.
As part of his duties during his M .S. research at Michigan State, Dr . Hornshaw conducted experiments
to assess the suitability of several species of Great Lakes fish for animal feed,
testing the fish in
reproduction trials with mink . He quantitated levels of polychlorinated biphenyls in fish, mink fat,
and mink milk as a portion of this research, and published the results of these studies in a scientific
journal. These results were also published in several trade journals serving the fur industry
. He has
authored or co-authored articles detailing the results of several other studies sponsored by the fur
industry in these trade journals .
After receiving his Bachelor's degree from Michigan State, Dr . Hornshaw worked as a student aide
in
the Biology Section of the Water Quality Division of Michigan's Department of Natural Resources
.
His duties included assisting staff aquatic biologists in the collection of fish, water,
sediment, and
benthos samples, in laboratory work, in data handling, and in reporting requirements
.
His field
experience included sample collection and identification from inland lakes, Great Lakes,
and rivers
and streams
.
HONORS: Bachelor of Science, with honors ; Member, Sigma Xi, the Scientific Research Society
.
AFFILIATIONS: Member, Society of Environmental Toxicology and Chemistry
.
THESES
:
Hornshaw, T. C. 1984. Development of Dietary LC
50
and Reproduction Test Protocols Using Mink
and Ferrets as Representative Mammalian Carnivores. Ph.D. Thesis, Michigan State University, East
Lansing, MI. 212pp
.
Hornshaw, T. C. 1981. Renewed Use of Underutilized Species of Great Lakes Fish for Animal Feed
.
M .S. Thesis, Michigan State University, East Lansing, MI
. 45pp .
PUBLICATIONS (Peer Reviewed) :
Ringer, R. K., Hornshaw, T. C., and Aulerich, R. J. Mammalian Wildlife (Mink and Ferret) Toxicity
Test Protocols (LC
50,
Reproduction, and Secondary Toxicity) . U.S. Environmental Protection Agency
Report No. EPA/600/3.91/043. July 1991. NTIS Document # PB91-216507
.
Hornshaw, T. C., Aulerich, R . J., and Ringer, R. K. 1987 .
Toxicity
of thiram (tetramethylthiuram
disulfide) to mink and European ferrets . Bull. Environ. Contam. Toxicol
. 38: 618 - 626 .
.
Hornshaw, T. C., Ringer, R. K., Aulerich, R. J., and Casper, H. H .
1986 .
Toxicity
of sodium
monofluoroacetate (Compound 1080) to mink and European ferrets
.
Environ. Toxicol. Chem. 5
:
213 -223 .
Hornshaw, T. C ., Aulerich, R . J., and Ringer, R. K. 1986 .
Toxicity
of o-cresol to mink and European
ferrets. Environ. Toxicol. Chem. 5: 713 - 720 .
Hornshaw, T. C., Safronoff, J., Ringer, R. K., and Aulerich, R. J. 1986. LC50 test results in
polychlorinated biphenyl-fed mink : age, season, and diet comparisons. Arch. Environ. Contam
.
Toxicol. 15: 717-723 .
Bleavins, M . R., Aulerich, R . J., Hochstein, J. R., Hornshaw, T. C., and Napolitano, A. C. 1983
.
Effects of excessive dietary zinc on the intra- uterine and postnatal development of mink . J. Nutr .
113: 2360 .2367
.
Hornshaw, T. C., Aulerich, R . J., and Johnson, H. E. 1983. Feeding Great Lakes fish to mink: effects
on mink and accumulation and elimination of PCBs by mink . J. Toxicol. Environ. Health 11 : 933,
946 .
PUBLICATIONS (Trade Journals):
Hornshaw, T. 1992. Illinois' Air Toxics selection process described
. National Air Toxics Information
Clearinghouse (NATICH) Newsletter
.
USEPA Office of Air Quality Planning and Standards,
Research Triangle Park, NC . January, 1992
.
Aulerich, R . J., Napolitano, A. C., and Hornshaw, T. C. 1986. How supplemental copper affects
mink kit hemoglobin concentration
.
In The
Fur Rancher Blue Book of Fur Farming
.
Communications Marketing, Inc., Eden Prairie, MN. pp. 42 .46 .
Hornshaw, T. C., Aulerich, R . J., and Ringer, R. K. 1985. Mineral concentrations in the hair of
natural dark and pastel mink . Scientifur 9(3) : 216 .219 .
Aulerich, R . J., Napolitano, A. C., and Hornshaw, T. C .
.1985. Effect of supplemental copper on
mink kit hemoglobin concentration . Fur Farmer's Gazette of the United Kingdom 35(4): 8 . 11
.
Hornshaw, T. C., Aulerich, R . J., Johnson, H . E., and Ringer, R. K. 1982. How suitable are today's
Great Lakes fish for use in feeding mink? Fur Rancher 62(9) : 21 - 23
.
Hornshaw, T. C., and Aulerich, R . J. 1980. Can Great Lakes fish again be fed safely to mink? In The
Fur Rancher Blue Book of Fur Farming
. Communications Marketing, Inc., Eden Prairie, MN. pp. 48
-49 .
PRESENTATIONS :
Hornshaw, T.C. "Background Metals and PAHs - Panel Discussion." Session Chair and Panel
Member at the Midwestern States Risk Assessment Symposium, August 25-27, 2004, Indianapolis, IN
.
Hornshaw, T.C.
"Vapor Intrusion Action Levels
- Panel Discussion." Panel Member at the
Midwestern States Risk Assessment Symposium, July 24.26, 2002, Indianapolis, IN
.
Hornshaw, T. C. AThe Illinois Strategy for Endocrine Disruptors.@ Talk presented at The Endocrine
Disruptor Debate: Environmental Chemicals and Reproductive and Developmental Health, October
17, 1997, St. Paul, MN
.
Hornshaw, T. C. ARisk Pathways and Exposure Potential as Critical Factors in the Determination of
Remedial Objectives .@ Talk presented at the Science for Environmental Professionals and Attorneys
Conference, January 8, 1997, Chicago, IL .
Hornshaw, T . C
.
APotential Health
Effects of Triazine Herbicides and Their Metabolites in
Community Water Supplies .@ Talk presented at the 1996 Illinois Agricultural Pesticides Conference,
January 34, 1996, Champaign, IL.
Hornshaw, T. C. "The Illinois Fish Contaminant Monitoring Program ."
Talk presented at the
Biannual Meeting of the Federal-State Toxicology and Risk Assessment Committee (FSTRAC),
November 68, 1991, Chicago, IL
.
Hornshaw, T. C .
"Assessing Exposure to Toxic Air Releases from a Chemical Facility :
Illinois
Acrylonitrile Exposure Assessment ."
Talk presented at the National Governors' Association
Conference on Assessing Exposure to Toxic Contaminants :
Issues and Problems Facing State
Government, March 29, 1989, Salt Lake City, UT
.
Hornshaw, T. C. "Risk Assessment from State Point of View ."
Talk presented at the 1st Annual
Hazardous Materials Management Conference/Central, March 16, 1988, Chicago, IL
.
Perino, J. V., Whitaker, J . B., and Hornshaw, T. C .
Technical aspects of an aquatic toxicological
testing program at a state regulatory agency . Poster presented at the 1st Annual Meeting of the Ozark-
Prairie Chapter of the Society of Environmental Toxicology and Chemistry, April 24-26, 1986,
Columbia, MO
.
Hornshaw, T. C. "Illinois EPA's Aquatic Toxicity Testing Program ."
Talk presented to the Illinois
Environmental Consensus Forum . December 12, 1985 . Springfield, IL .
Aulerich, R . J., Bursian, S. J., Nachreiner, R. F., Olson, B . A., Hochstein, J. R., Hornshaw, T. C ., and
Koudele, K. A. Toxicological manifestations of dietary exposure to 3,4,5,3', 4', 5'- hexachlorobiphenyl
in mink. Poster presented at the 24th Annual Meeting of the Society of Toxicology, March
18-22,
1985, San Diego, CA .
Hornshaw, T. C. "Effects of Feeding Great Lakes Fish to Mink ." Talk presented at the Great Lakes
Commercial Fisheries Workshop, March 12, 1985, Mackinaw City, MI
.
Hornshaw, T. C., Safronoff, J ., Aulerich, R . J., and Ringer, R. K .
Development and validation of
dietary LC50 test protocols for wildlife mammalian carnivores using mink and
ferrets. Poster
presented at the 5th Annual Meeting of the Society of Environmental Toxicology and Chemistry,
November 4-7, 1984, Arlington, VA
.
Hornshaw, T. C., Ringer, R. K., and Aulerich, R . J. Toxicity of thiram to mink and European ferrets
.
Poster presented at the 23rd Annual Meeting of the Society of Toxicology,
March 12-16, 1984,
Atlanta, GA.
Hornshaw, T. C., Ringer, R. K., and Aulerich, R. J .
Toxicity of sodium monofluoroacetate
(Compound 1080) to mink
.
Poster presented at the 22nd Annual Meeting of the Society of
Toxicology, March 611, 1983, Las Vegas, NV .
Hornshaw, T. C., Aulerich, R . J., Johnson, H . E., and Ringer, R. K. Suitability of today's Great Lakes
fish for animal feed. Poster presented at the International Symposium on PCBs in the Great Lakes,
March 15-17, 1982, East Lansing, MI
.
Notes
I
Site-specific information on race/ethnicity for the industrial/commercial worker population maybe used to alter the GSD
; .
Only those values based upon "Al I Regions" and stratified by race/ethnicity from the following reference may be used in
place of the default value: USEPA. March 2002 . Blood Lead Concentrations of 11 .S. Adult Females : Summary Statistic
from Phases I and2of the National Health and Nutrition Evaluation Survey (NHANES 111) . EPA 9285.7-52 .
2
Site-specific information on race/ethniciry, for the industrial/commercial worker population may be used to alter the PbB 9 .
Only those values based upon "All Regions" and stratified by race/ethnicity from the following reference may be used in
place of the default value: USEPA. March 2002 . Blood Lead Concentrations of U .S. Adult Females: Summary Statistics
from Phases I and2of the National Health and Nutrition Evaluation Survey (NHANES III)
. EPA 9285.7-52 .
R
OCKFORD-4302
North Main Street, Rockford, IL
61103 - (815) 987-7760
•
Des
PLAINES - 9511
W. Harrison St., Des Plaines, IL
60016 - (847) 294-4000
ELGIN-595
South State, Elgin, IL
60123-(847) 608-3131
•
PEORIA- 5415
N. University St., Peoria, IL
61614-(309) 693-5463
BUREAU OF LAND
- PEORIA- 7620
N. University St., Peoria, IL
61614-(309) 693-5462
•
CHAMPAIGN- 2125
South First Street, Champaign, IL
61820- (217) 278-5800
SPRINGFIELD-4500
S. Sixth Street Rd., Springfield, IL
62706-(217) 786-6892
•
COtLINSVIttE-2009
Mall Street, Collinsville, IL
62234 - (618) 346-5120
MARION-2309
W. Main St., Suite
116,
Marion, IL
62959-(618) 993-7200
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 NORTH GRAND AVENUE EAST, P.O . Box 19276,
SPRINGFIELD, ILLINOIS 62794-9276, 217-782-3
JAMES R. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601, 312-814-6026
ROD R . BLAGOJEVICH, GOVERNOR
RENEE CIPRIANO, DIRECTOR
MEMORANDUM
DATE :
February 25, 2005
TO :
Tom Homshaw
FROM :
Les Morrow
SUBJECT: Default Assumptions for Adult Lead Model
Industrial/Commercial Worker Scenario
The following are the default assumptions recommended by the Toxicity Assessment
Unit for developing a Tier 3 soil remediation objective for lead for the
industrial/commercial worker scenario . The assumptions are to be used in the USEPA
Adult Lead Model and result in a default soil remediation goal of 800 mg/kg for the
industrial/commercial worker receptor. A copy of the output page of the spreadsheet
model including the final PRIG of 794 mg/kg (rounded to 800 mg/kg to be consistent with
the USEPA recommendation) is attached
.
PRLNTrn
ON
Rrrvrlrn PAPER
EXHIBIT
1
6
Exposure
Parameter
Description of Exposure Variable
Units
Default Values for
Industrial/Commercial
Worker Scenario
PbBretaLO .95
95
6 percentile blood lead in fetus
gg/dl
10
Rree,vmarernal
Fetal/maternal blood lead ratio
0.9
BKSF
Biokinetic Slope Factor
pg/dl per
µg/day
0.4
1R
Soil ingestion rate
g/dav
0.05
AFs
_
Absorption fraction for soil
--
0.12
.GSD i
Geometric standard deviation blood lead
2 .29
PbB0
Baseline blood lead
2
µg/dl
1 .70
EF,
Exposure Frequency
days/yr
219
AT,
Averaging Time
days/yr
365
Calculations of Preliminary Remediation Goals (PRGs)
Source: U.S. EPA (1996) . Recommendations of the Technical Review Workgroup for Lead
for an Interim Approach to Assessing Risks Associated with Adult Exposures to Lead in Soil
Values for Non-Residential . Ex . osure Scenano
Exposure-
Variable
sin-
Equation I _
k '
'1
sin
Equation --
nits`,
GSDi:-?Hom
GSDi=Hek_ C, Di.=:Hooi
'':GSDi =_
PbBIetai,
0 95
ug/dL
10
10
10
10-
Rfetavi
t a
,
0.9
0.9
_ 9
0
BKSF
ug/dL per
ug/day
0.4
0 .4
0
.
GSD
i
∎
2.29
PbB
o
ug/dL
T
1.70
IR
s
g/day
0
0.050
flTfl
.
IRS+D
g/day
i
--
0.050
AL
0.050
Ws
£
--
1 .0
1 .0
KSD
.A∎
--
0
=a
A-FS, o
- - 0.12
11
0.12 W®
0
•W
EFs.
D
days/yr .
219 ,
219 - 219
IM-'U
ATS
p
days/yr
'
365
1
365
/
365
365 ,
PRG
I
ppm
794
DATE
:
May 29, 2003
TO
:
Tom Hornshaw
FROM
:
Connie Sullinger
SUBJECT :
Default Assumptions for Adult Lead Model
Construction Worker Scenario
The following are the default assumptions recommended by the Toxicity Assessment
Unit for developing Tier 3 soil remediation objectives for lead for the construction
worker scenario. The assumptions are to be used in the USEPA Adult Lead Model and
result in a default soil remediation goal of 700 mg/kg for the construction worker .
Notes
I
Site-specific information on race/ethnicity for the construction worker population may be used to alter the GSD
;. Only
those values based upon "Alt Regions" and stratified by race/ethnicity from the following reference may be used in place
of the default value: USEPA. March 2002 . Blood Lead Concentrations of U .S. Adult Females: Summary Statistics from
Phases 1 and 2 of the National Health and Nutrition Evaluation Survey (NHANES III). EPA 9285 .7-52 .
2
Site-specific information on race/ethnicity for the construction worker population may be used to alter the PbB0. Only
those values based upon "All Regions" and stratified by race/ethnicity from the following reference may be used in place
of the default value: USEPA. March 2002
. Blood Lead Concentrations of U.S. Adult Females: Summary Statistics from
Phases I and 2 of the National Health and Nutrition Evaluation Survey (NHANES 111)
. EPA 9285.7-52 .
ROCKFORD-4302 North Main Street, Rockford, IL 61103 -(815) 987-7760
•
DES PLAINES-9511 W . Harrison St., Des Plaines, IL 60016-(847) 294-4000
ELGIN-595 South State, Elgin, IL 60123-(847) 608-3131
•
PEORIA-5415 N . University St., Peoria, IL 61614-(309) 693-5463
BUREAU OF LANG- PEORIA-7620 N . University St., Peoria, IL 61614 - (309) 693-5462
•
CHAMPAIGN - 2125 South First Street, Champaign, IL 61820-(217) 278-5800
SPRINGFIELD-4500 S. Sixth Street Rd., Springfield, IL 62706-(217) 786-6892
•
COLLINSVILLE -2009 Mall Street, Collinsville, IL 62234- (618) 346-5120
MARION -2309 W. Main St., Suite 116, Marion, IL 62959 - (618) 993-7200
PRINTED ON RECYCLED PAPER
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021
NORTH GRAND AVENUE EAST,
P.O. Box 19276,
SPRINGFIELD, ILLINOIS
62794-9276, 217-782-33
JAMES
R .
THOMPSON CENTER,
100
WEST RANDOLPH,
SUITE 11-300,
CHICAGO,
IL 60601, 312-814-6026
ROD
R .
BLAGOJEVICH, GOVERNOR
RENEE CIPRIANO, DIRECTOR
MEMORANDUM
EXHIBIT
Exposure
Parameter
Description of Exposure Variable
Units
Default Values
for
Construction
Worker
Scenario
PbBretal.o.95
95'
percentile blood lead in fetus
.tg/dl
10
....I
Fetal/matemal blood lead ratio
0 .9
BKSF
Biokinetic Slope Factor
µg/dl per
,LLg/day
0.4
ER,
Soil
ingestion rate
g/day
0.1
AF
5
Absorption fraction for soil
0.12
GSD ;
Geometric standard deviation blood lead
2.3
PbBo
Baseline blood lead 2
pg/dl
1 .7
EF,
Exposure Frequency
days/yr
30
AT,
Averaging Time
days/yr
90
United States
Ofscaof
EPA402-R-99-004B
Environmental Protection
Air and Radiation
Auoust 1999
A9ancy
6502J
Understanding Variation
In Partition Coefficient,
K
d
, Values
Volume II: Review Of
Geochemistry And Available
1<d Values For Cadmi
Cesium, Chromiu
Plutonium, Radon, Strontium,
Thorium, Tritium
(
3
H),
And Uranium
COSe t Kd - I mUg
Continuous Source of Contamination
Y
r
Y Y
r
C/Cb =O-8'
C/Cp =0.3-4
^y
-C/Ca =0 .1
ii
Steady State
Flaw
Case II :
Kd =l0 mUg
Continuous Source of Contamination
Steady State
Y Y Y Y
Flow
EXHIBIT
15 Lead Geoehanisrry and K, Values
5.5.1 Overview: Important Aqueous-and Solid-Phase Parameters
Controlling Retardation
Lead has 3 known oxidation states, 0, +2, and +4, and the most common redox state encountered
in the environment is the divalent fvwL Total dissolved lead concentrations in natural
waters are
very low (-10' INI). Dissolved lead in natural systems may exist in free ionic form and also as
hydrolytic and complex species.
Spcciation calculations show that at pH values exceeding 7,
aqueous lead exists mainly as carbonate complexes [PbCOs(eq), and Pb(CO,J
] . Important
factors that control aqueous speciation of lead include p$ the types and concentrations of
completing ligands and major cationic constimeats, and the magnitude of stability constants for
lead-ligand aqueous complexes.
A number of studies and calculations show that undernxf Thing conditions depending on pH and
ligaad concentrations, pure-phase lead solids, such as PbCO„ Pb,(OB),(CO3)~, PbSO„
Pbs(PO,)s(Cl), and Pb,SO,(CO,)i(OH),, may control aqueous lead concentrations. Under
reducing conditions, galena (PbS) may regulate the cancent ations of dissolved lead .
It is also
possible that lead concentrations in some natural systems are being controlled by solid solution
phases such as barite (Ban,rPb,SOa, apatite [Ca
n,,pbi
(PO,)3OI1L calcite (CaoJb,COS), and
iron sulfides (Fa( ,Jb,S).
Lead is known to adsorb onto soil constituent surfaces such as clay, oxides, hydroxides,
oxyhydroxides, and organic matter. In the absence of a distinct lead solid phase, natural lead
concentrations would be controlled by adsorptan/desorydon reactions . Adsorption data show -
that lead has very strong adsorption affinity for soils as compared to a number of first transition
metals. Lead adsorption studies on bulk soils indicate that the adsorption is strongly correlated
with pH and the CEC values of soils . Properties that affect CEC of soils, such as organic matter
content, clay amtent, and surface area, have greater affect on lead adsorption than
soil p1i
AS.2 GmcralGeochernishy
Lead is an ubiquitous heavy metal and its concentration in uncontaminated soil ranges from 2 to
200 mg/kg and averages 16 mg(kg (Bowen, 1979). Annual anthropogenic lead input into soils
hzabe-.n--t,-:
. t24 to be from 0.04
m n
pwkg (TtfHasr el at., !967). In contaminated soils,
.
lead concentrations maybe as high as I8 per=t by weight (Mattigod and Page, 1983; Ruby el
ai,1994). Lead in nature occurs in 4 stable isotopic forms Mb, 70'Pb,'°'Pb, and a"Pb). The
isotopes, }O'Pb, r07Pb, and °'Pb are the stable end products of the a'U, 'U, and2Ih thorium
decay series, respectively (Bobbins, 1980). Additionally, heavier isotopes of lead (DOPh, "Pb,
27'Pb, and 'r'Pb) are known to occur in nature as intermediate products of uranium and thorium
decay (Robbins, 1978) . The
5.25
most common valence state of lead encountered in the environment is the divalent form (Baes and
Mesmer, 1976). Extensive studies of lead biogeochemistry have been
conducted
due to its
known adverse effects on organisms (Hammond, 1977) . Comprehensive descriptions of
environmental chemistry of lead have been published by Boggess and Whsson (1977) and Nriagu
(1978).
S. 53 Aqueous Specimion
Lead exhibits typical ampboteric' metal ion behavior by forming hydrolytic species (Bats and
Mesmer, 1976). Formation of monomeric hydrolytic species, such as PbOH', Pb(OH)3(aq) and
Pb(OH); , is well established Although several polymeric hydrolytic species such as Pb,OH",
Pb,(OH)r, Pb,(OH);, and Pbb(OH)tme known to font at high lead concentrations, calculations
show that these types of species are unlikely to form at concentrations of
dissolved
lead (-10''M)
typically encountered even in contaminated environments (Rickard and Nriagu, 1978). These
investigators also showed that computation models of speciatlon of dissolved lead in fresh- or
seawater predicted that at pH values exceeding about 6 .5, the dominant species are lead-
carbonate completes. Lead is known to form aqueous complexes with inorganic Uganda such as
carbonate, chloride, fluoride, nitrate, and sulfate
.
To examine the distribution of dissolved lead species in natural waters, MIIITEQA2 model
calculations were completed using the water composition described in Table 5 .1. The total lead
concentration was assumed to be I pg/I based on the data for natural waters tabulated by Duram
et at. (1971) and Hem (1985). A total of 21 aqueous species (uncomplexed Pb", and 20 complex
species, listed in Table 5.8) were used in the computation. Results of the computation are plotted
as a species distribution diagram (Figure 5.2) . The data show that, under low pH (<6) conditions,
free ionic P9' appears to be the dominant species, and the neutral species; PbSO,(aq), accounts
for about 5 percent of the total dissolved lead. Within the pH range of 6.5 to 7.5, the main
species of lead appear to be free ionic species, PV', and the neutral complex species, PbCO3(aq)
with minor percentage of the species consisting of PbHCO3 (about 15 percent), PbSO,(aq) (<5
percent), and PbOH' (<5 percent). Between the pH range 7 to 9 . the neutral complex species
PbCO3(aq) dominates dissolved lead speciation . At pH values exceeding 9, in addition to
PbC03(aq),a significant fraction of soluble lead is present as the anionic carbonate complex,
Pb(CO3)y.
These calculations also confirm Rickard and Nriagu's (1978) observation that
polymeric species are not significant in the chemistry of lead in natural waters
.
The species
distribution illustrated in Figure 52 does not change if the concentration of total dissolved lead is
increased from 1. to 1.000
This speciation calculation demonstrates that the important factors that control aqueous
speciation of lead include pH and the types of tvmplexing ligands. Aqueous spcciation of lead
has a direct bearing on dissolution/precipimtion of lead-solid phases and the adsorptioddesorption
t Amphoteric behavior is the ability of an aqueous complex or solid material to have a negative,
neutral, or positive charge.
5 .26
reactions. Complastion enhances the solubility of lead-bearing solid phases . This enhancement
in solubility is dependent on the strength of complexation (indicated by the magnitude of stability
constant] and the total concentrations of complexing ligands . Also, as will be disc ssed shortly,
adsorption of lead is affected by the type, charge, and the concentration of lead complexes present
in solution. Cationic lead species, especially Ph' and its hydrolysis species, adsorb more
commonly than anionic lead complexes
.
£5.4 Disso tdon'Predphaton/Coprrcipitation
Lead solids in the environment may occur in a number of mineral forms (P ickard and Nriagu
1978; Mattigod et aL, 1986; Zimdabl and Hassett, 1977). However, these authors have identified
a limited number of secondary lead minerals that may control the concentrations of dissolved lead
in sailfwater environments. If the coriccentratirm of dissolved lead in a pore water or groundwater
exceeds the solubility of any of these phases, the lead-containing solid
phase
will precipitate and
thus control the maximum concentration of lead that could occur in the aqueous phase.
According to Rickard and Nriagu (1978), under oxidizing conditions, depending on pH and ilgand
coacentratiocs, cerussite (PbCOJ, hydracenssite [Pb3(OH),(COJJ, anglesite (PbSOJ, or .
,
chloropyromorphite [Pb,(POJ,CI] may control aqueous lead conatarations . A review paper by
McLean and Bledsoe (1992) included data which showed that lead concentrations in a calcareous
soil was controlled by lead-)hosphate compounds at lower pH and by mixed mineral phases at pH
values exceeding 7.5. A study conducted by Mattigod et aL (1986) indicated that the mineral
leadhillite [Pb,SO,(CO,),(OH)j may be the solubility controlling solid for lead in a mine-waste
contaminated soil .
5.27
Table 5.8 .
Lead aqueous species included in the
speciation calculations .
Aqueous Species
Pbr
PbOH', Pb(OH)j(aq), Pb(OH);, Pb(OH);
Pb,(OH);, Pb,(OHt
PbCO,(aq), Pb(CO,)t, PbHCO;
TSO,(aq), Pb(SO,),'
PbNo
PmCC, PbCls(aq), PbCI; PbCI3
PbF, PbF=(aq), PbF;, PbF;
5.28
Iso
a
2
7
4
a
6
Figure 5.2 .
Calculated distribution of lead aqueous species as a function of pH for the
water composition in Table 5.1. [The species distribution is based on a
concentration of I pg/l total dissolved lead]
Lead may also e,dst in soils as solid-solution phases . Solid solutions are defined as solid phases in
which a minor element will substitute for a major dement in the mineral stnxaue. Depending on
the degree of substitution and the overall solubility of the solid-solution phase, the equilibrium
solubility of the minor element in the solid solution phase will be leis than the solubility of the
.^.c9d phase xestainiag only
the
rlinor element (pure phase). For imtance,lead may occvrfs,
..~:_.
minor replacement in barite [Ba
2Jb,SOJ, spatite [Cat„JPb,(PO,),OH1 calcite [Car ,.,Pb,COs),
and imn sulfides, [Fei1atPb,S] (Driesens, 1984 Goldschmidt, 1954; Nriagu and Moose, 1984;
Pickard and Nriagu, 1978)_ Consequently, the equilibrium solubility of lead controlled by these
phases will be Less than the concentrations controlled by corresponding pure phases, namely
PbSO,, Pb,(PO,),OH, PbCO„ and PbS, respectively.
5.29
rH
7
a
a
Is
Under reducing conditions, galena (PbS) may control the lead coow
'ons in the environment
Rickard andNriagu (1978) calculated that, within the pH range of 6-9, the equilibrium solubility
of galena would control total lead concentrations at Levels less than approximately 10"
70
M
(<I no. Therefore, if galena is present in a soil underiwhrdeg conditions, the aqueous
concentrations of lead will be controlled at extremely low concentrations
.
5.5.5 SorptiowDesotpdcx
Lead is known to adsorb onto soil constituent surfaces such as clays, oxides, hydroxides,
oxyhydroxides, and organic matter. Ion exchange reactions of lead on a number of clay minerals
such as montmon'DorMe, knolinite, Mite, and vermiculite have been studied by a number of
investigators. These studies showed,that lead was preferentially adsorbed by exchange on clays,
readily replacing calcium and potassium (Bittel and lvfiller; 1974; Oversteet and Krishnamurthy,
1950)
. Studies conducted by Lagerwer f and Brower (1973) on montmorillonitic, illitia, and
kaolinitic soils confirmed that lead would preferentially exchange for calcium. Another clay
mineral, vermiculite, is also known to exhibit very high ion exchange selectivity for lead (Rickard
and Nriagu, 1978). Based on a number of studies Rickard and Nriagu (1978) also concluded that
beyond neutral pH, precipitation reactions may control lead concentrations in solution rather than
ion exchange and adsorption reactions involving clay mineral surfaces
.
Experimental data show that only hydrogen ions and unhydrolyzed aluminum ions
am
capable of
displacing lead from exchange sites on clay mineral (Lagerwerff and Brower, 1974 ; Zimdahl and
Hwactt, 1977). Clay minerals also differ in their exchange preference for lead . Bittel and Miller
(1974) showed that the exchange preference for lead varies in the sequence,
kaolinite > Mite > monunocillonite .
f
These studies also showed that, in neutral to high pH conditions, lead can preferentially exchange
or calcium,pohsssimn, and cadmium. Under low pH conditions, hydrogen ions and aluminum
ions would displace lead from mineral exchange sites
.
Studies of-lead adsorption on oxide, hydroxide, and oxyhydroxide minerals show that the
substrate properties, such as the specific surface and degree of crystallinity, control the degree of
adsorption (Rickard and Nriagu.1979), Experimental data by Forbes et aL (1976) showed that
goethite (FeOOH) has higher adsorption affinity for lead than zinc, cobalt, and cadmium . Dam
show thatm
eat oxide minerals also a4sot i'!
'! 'r(Pickarda-INrisg',1978). These
investigators concluded that the high specificity of lead adsorption on oxide and hydroxide
surfaces and the relative lack of desorbability (<10 percent) of adsorbed lead indicated that lead
upon adsorption forms solid solutions with oxide or hydroxide surfaces. Therefore, this lack of
reversibility indicated that the reaction is not a m e adsorption phenomenon-
A number of studies have confirmed that marry natural and synthetic organic materials adsorb
lead. Data showing significant correlations between concentrations of organic matter and
lead
i n
5.30
soils indicate that soil organic matter has a higher affinity for lead adsorption as compared soil
minerals.
A munber of lead adsorption studies on bulk soils indicate that the adsorption is strongly
correlated with pH and the CEC values of soils (Zhndahl and Hassett, 1977). A multiple
regression analysis by Hassett (1974) of lead adsorption data indicated that properties that affect
CEC of soils, such as organicmaarr content, clay content, and surface area, have a greater effect
on lead adsorption than soil pf The results of a number of studies of lead adsorption on a
variety of soil and mineral surfaces weresummarized by McLean and Bledsoe (1992). These data
show that lead has very strong adsorption affinity as compared to a number of first row transition
metals (cobalt, nickel, copper, and Tint). According to a recent study (Peters and Shem, 1992),
the presence of very strong chelating organic ligands dissolved in solution will reduce adsorption
of lead onto soils. These data show that the adsorption of lead in the environment is influenced by
a number of factors such as the type and properties of adsorbing substrate, p$ the concentrations
of lead, and the type and concentrations of othe competing rations and complex forming
inorganic and organic ligands.
5.5.6 Partition Coefcient, K1, Vabra
S.S.6.1 Genera Availability ofKiDafa
The review of lead Y, data reported in the literature for a number of soils (Appendix F) led to
the following important conchtsicas regarding the factors which inference lead adsorption on
minerals and soils.' These principles were used to evaluate available quantitative data and
generate a look-up table. These conclusions are:
Lead may precipitate in soils if soluble canoenhations exceed about 4 mgll at pH 4 and
about 02 mgA at pH 8. In the presence of phosphate and chloride, these solubility limits
may be as low as 0.3 mgl at pH 4 and 0.001 mgA at pH 8. Therefore, in experiments
m
which concentrations of lead exceed these values, the calculated K s values may reflect
precipitation reactions rather than adsorption reactions
.
Anionic constituents such as phosphate, chloride, and carbonate are known to influence
lead reactions in soils either by precipitation of minerals of limited solubility or by reducing
adsorption through complex formation .
A number of adsorption studies indicate that within the pH range of soils (4 to 11), lead
adsorption increases (as does precipitation) with increasing pH
.
r
Since the completion of our review and analysis of K, data for the selected contaminants and
radionuclides, the studies by Azizian and Nelson (1998) and Yong and MacDonald (1998) were
identified and may be of interest to the reader .
5.31
•
Adsorption of lead increases with increasing organic matter content of soils.
•
increasing equilibrium solution concentrations correlates with decreasing lead adsorption
(decease inK,).
The factors which influence lead adsorption were identified from the following sources of data, A
description and assessment of these data are provided in Appendix F . Lead adsorption behavior
on soils and soil constituents (clays, oxides, hydroxides, oxyhydroxides, and organic matter) has
been studied extensively. However, calculations by Ricluad and Nriagu (1978) show that the
solution lead concentrations used in a number of adsorption studies may be high enough to induce
precipitation. For instance, their calculations show that lead may precipitate in soils if soluble
concentrations exceed about 4 mgll at pH 4 and about 02 mg/l at pH 8 . In the presence of
phosphate and chloride, these solubility limits may be as low as 03 mgJl at pH 4 and 0.001 mg/l at
pH 8. Therefore, in experiments in which concentrations of Iced exceed these values, the
calculated 1(4 values may reflect precipitation reactions rather than adsorption
reactions.
Lead adsorption studies on manganese and iron oxides and oxyhydwxida indicate irreversible
adsorption which was attributed to the formation of solid solution phases (La ., coprecipitation)
(Forbes
et at., 1976;
Grasselly and Hetenyi, 1971; Rickard and Nriagu,1978). No correlation
however have been established between the type and coetmt of oxides in soil and the lead
adsorption characteristics of soil .
Anionic constituents such as phosphate, chloride, and carbonate are known to influence lead
reactions in soils either by precipitation of minerals
of
limited solubility orby reducing adsorption
through complex formation (Rickard and Nriagu, 1978) . Presence of synthetic chelating ligands,
such as EDTA, has been shown to reduce lead adsorption on soils (Peters and Sheen, 1992)
.
These investigators showed that the presence of strongly relating EDTA in concentrations as
low as 0.01 M reduced K a for lead by about 3 orders of magnitude. By comparison quantitative
data is lading on the effects of more common inorganic ligands (phosphate, chloride, and
carbonate) on lead adsorption on soils .
A number of adsorption studies indicate that within the pH range of soils (4 to 11), lead
adsorption increases with increasing pH (Braids
er aL,
1972; Bittel and Miller, 1974; Griffin and
Skimp, 1976; Hsji-Ajafari
etaL,
1981; Hldebrand and Bhun, 1974; Overstreet andKrishamu thy,
1950; Scrudato and
Estes,
1975; Zimdahl and Hassett, 1977). Griffin and Skimp (1976) also
noted that clay minerals adsorbing increasing amounts of lead with increasing pH may also be
- :
attributed to the formation of lead carbonate precipitates which was observed When the solicit n
pH values exceeded 5 or 6.
Solid organic matter such as humic material in soils is known to adsorb lead (Rickard and Nriagu,
1978;Zimgahl and Hassett, 1977). Additionally, soluble organic matter such as fulvates and
amino acids are known to chelate soluble lead and affect its adsorption on soils (Rickard and
Nriagu, 1978). Correlative relationships between the organic matter content of soils and its
5.32
effect on lead adsorption have been established by Gerritse
etaL
(1982) and Soldatini
et aL
(1976) .
Lead adsorption by a subsurface soil sample from Hanford Washington was investigated by
Rhoads et aL
(1992). Adsorption data from these experiments showed that K, values increased
with decreasing lead concentrations in solution (from 0 .2 mg/I to 0.0062
mg/1).
5..5.6.2 K,Look-Up Tables
Among all available data, Gerritse et al (1982) obtained adsorption data at lead concentrations
(0.0001 - 0.01 mgA) which apparently precluded precipitation reactions . Also, these
concentrations arc within the range of lead concentrations most frequently encountered in ground
waters (Chow, 1978). Additionally, data obtained by Rhoads
et
aL
(1992) indicated that K,
values vary log-linearly as a fltaction of equillbrium lead concentrations within the range of
0.00001 to 0.2 mg/l. The data generated by Gertitse
et at
(1982) and Rhoads
et al
(1992) were
used to develop a look-up table (Table 5 .9) of K, as a function of soil pH and equilibrium lead
concentrations.
.
5.5.62.1 Limits of K, Values with Respect to pH
The pH ranges in the look-up table (Table 59),were selected from the rate of change that we
noted in the K, data as a function of pH. The K, values within this pH range increase with
increasing pH, and are greatest at the madmun pH limit (pH 11) of soils-
Table 5.9. Estimated range of K, values for lead as a function of soil pH, and
equilibrium lead concentrations
.
5 .33
Equilibrium Lead
Son pH
Concentration (pg)!)
*C(mUg)
4.0-6.3
6.4-8.7
8.8-11.0
0_1-0.9
A Inimvm
940
4,360
11,520
Madmum
8,650
23,270
44,580
1.0-9.9
Minimum
420
1,950
5,160
i faRmran
- 4,C
10,760
20,620
10-99.9
Minhmrm
190
900
2,380
Madmum
1,850
4,970
9,530
100-200
I fnimum
150
710
1,880
.
um
860
2,300
4.410
5 .5.6? 2 Limits of 1 d Values with Respect to Equilibrium Lead Concentrations
The limits of equilibrium lead concentrations (0.0001 mg/l to about 0.2 mg/[) were selected based
on the experimental data generated by Gerritse
et al.
(1982) and Rhoads
et a7
(1992). These
investigators showed that within the range of initial lead concentrations used in their experiments
the principal lead removal reaction from solution was adsorption and not precipitation. Four
concentration ranges were selected to develop the K, values
.
16 Plutonium
Geochemishy
and
%, Vataa
5.61
Overview: Importanl
Aqueous-
andSo
rul-
Phase
Parameters
Controlling Retardation
In the ranges of pH and conditions typically encountered in the environment, plutonium can cost
in all 4 oxidation states, namely +3, 4, +5, and +6 . Under oxidizing conditions. Pu(V), Pu(V),
and Pu(VI)
are
common, whereas, under reducing conditions, Pu(M) and Pu(IV) would exist
.
Dissolved plutonium forms very strung hydroxy-carbonate mixed ligand complexes, therefprr,
its
adsorption and mobility is strongly affected by these complex species. Under conditions of low
pH and high concentrations of dissolved organic carbon,
it appears that plutonium-organic
complexes may be control adsorption and mobility of plutonium in the environment
If plutonium is present as a distinct solid phase (amorphous or partly crystalline PuO2 xH,O) or as
a solid solution, the upper limits of aqueous plutonium concentrations would be in the 10u to
10' M range. Dissolved plutonhrm in the environment is typically present at
s 10" M levels
indicating that adsorption may be the principal phenomenon that regulates the mobility of this
actinide.
Plutonium can adsorb on geologic material from low to extremely high affinities with K, values
ranging from 11 to 300,000 ml/S. Plutonium in the higher oxidation state adsorbed on iron oxide
surfaces may be reduced to the tetravalent state by Fe(U) present in the iron oxides
.
Two factors that influence the mobilization of adsorbed plutonium under environmental pH
conditions (>7) are the concentrations of dissolved carbonate and hydroxyl ions . Both these
ligands form very stmng'mixed ligand complexes with plutonium, resulting in desorption and
increased mobility in the environment
5.62 Ge heai Geochemistry
Plutonium is produced by fissioning uranium fuel and is used in the construction of nuclear
weapons. Plutonium has entered the environment either through accidental releases or through
disposal of wastes generated during fuel processing and the production and detonation of nuclear
weapons. Plutonium has 15 isotopes, but only 4 of these isotopes namely, r"Pu [tp (half life) =
5.34
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Role
City & State
Phone/Fax
217/782-
IEPA
1021 North Grand Avenue East Springfield
5544
Petitioner
P.O. Box 19276
IL 62794-9276 217/782-
9807
Kimberly A. Geving, Assistant Counsel
Annet Godiksen, Legal Counsel
217/523-
Hodge Dwyer Zeman
3150 Roland Avenue
Springfield
4900
Interested Party
Post Office Box 5776
IL 62705-5776 217/523-
4948
Christine G. Zeman
Karen L. Bernotelt
Katherine D. Hodge
Thomas G. Safley
312/853-
Sidley Austin LLP
Chicago
7000
Interested Party
One South Dearborn
IL 60603
312/853-
7036
William G. Dickett
EPI
Interested Party
16650 South Canal
South Holland
IL 60473
Bob Mankowski
217/523-
Illinois Environmental Requlatory
Springfield
4942
Group
3150 Roland Avenue
IL 62703
217/523-
Interested Party
4948
Katherine D. Hodge, Executive Director
Thomas G. Safley
DesPlaines
Chemical Industry Council of Illinois
2250 E. Devon Avenue
Interested Party
Suite 239
IL 60018-4509
Lisa Frede
312/853-
Bellande & Sargis Law Group, LLP
19 South LaSalle Street
Chicago
8188
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Suite 1203
IL 60603
312/782-
0040
Mark Robert Sargis
314/231-
The. Stolar Partnership
The Lammert Building,
, 7th
St. Louis
2800
Floor
MO 63101-
Interested Party
911 Washington Avenue
1290
314/436-
8400
Musette H . Vogel
217/788-
Hanson Engineers,
Inc.
Springfield
2450
Interested Party
1525 South Sixth Street
IL 62703-2886 217/788-
2503
Tracy Lundein
773/380-
Conestoga-Rovers & Associates
Interested Party
West Bryn Mawr Avenue
Chicago
Chicago
606
IL 60631
IL
9933
773/380-
6421
Douglas G. Soutter
312/814-
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Environmental Bureau
Chicago
312/814-
188 West Randolph, 20th Floor IL 60601
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2347
Matthew J . Dunn, Division Chief
847/688-
Naval Training Center
Great Lakes
4422
Interested Party
2601A Paul Jones Street
IL 60088-2845 847/688-
6917
Georgia Vlahos
312/814-
Illinois Pollution Control Board_
100 W. Randolph St .
Chicago
3620
Interested Party
Suite 11-500
IL 60601
312/814-
3669
Dorothy M. Gunn, Clerk of the Board
Richard McGill, Hearing Officer
Commonwealth Edison
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10 South Dearborn Street
35FNW
Chicago
IL 60603
Diane H. Richardson
Clayton_ Group Services
Interested Party
3140 Finley Road
Downers Grove
IL 60515
Monte Nienkerk
We ver Boos & Gordon
2021 Timberbrook Lane
Springfield
IL 62702
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Elizabeth Steinhour
Andrews Environmental Engineering
Interested Party
3535 Mayflower Boulevard
Springfield
IL 62711
Mark Marszalek
Graef Anhalt Schloemer & Associates,
Inc .
8501 West Higgins Road
Suite 280
Chicago
IL 60631-2801
Interested Party
Dr. Douglas C. Hambley, P.E., P.G
.
Midwest_ Engineering
Services
Interested Party
4243 West 166th Street
Oak Forest
IL 60452
Erin Curley, Environmental Dept. Manager
Rockford
IL 61110-0827
Missman Stanley & Associates
Interested Party
333 East State Street
John W. Hochwarter
Jeffrey Larson
Trivedi Associates~Inc .
2055 Steeplebrook Court
Naperville
IL 60565
Interested Party
Chetan Trivedi
217/782-
Department of Natural Resources
Springfield
1809
Interested Party
One Natural Resources Way
IL 62702-1271 217/524-
9640
Stan Yonkauski
William Richardson, General Counsel
Suburban
Laboratories,
Inc .
Hillside
708-544-
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4140 Litt Drive
IL 60162
3260
.
Jarrett Thomas, V.P .
Illinois_D_epajt2Lent_of r s ortatikon
Interested Party
2300 S. Dirksen Parkway
Room 330
Springfield
IL 62764
Charles A . King, Assistant Corporation Counsel
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Steven Gobelman
Thomas Benson
McGuire Woods LLP
77 W. Wacker
Chicago
312/849-
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Suite 4100
IL 60601
8100
David Rieser
Reott Law Offices, LLC
35 East Wacker Drive
Chicago
Interested Party
Suite 650
IL 60601
Raymond T. Reott
Jorge T. Mihalopoulos
Chicago Department of-Law
Interested Party
30 N . LaSalle Street
Suite 900
Chicago
IL 60602
