Was the risk assessment adequate for the Dutch Boy site?
U.S. EPA used a streamlined risk evaluation to determine the on-site lead clean-up goal (CUG) under an occupational scenario. It is TOSCs opinion that the risk assessment used is seriously flawed because no site-specific data have been used. In its risk assessment, U.S. EPA has not taken into account that residents of the two communities are likely to have been exposed to lead and may be further exposed in the future. The risk evaluation and, therefore, the proposed CUG are unacceptable. Below, we provide justification for that conclusion. The Edward White Elementary School property is approximately 1000 feet from the boundary of the Dutch Boy site and within 500 ft. of the area of significant contamination (that is, a lead concentration greater than 500 mg/kg). Residential properties are also located in the vicinity of the site. By assessing the site exclusively for future industrial use, the model ignores the sites proximity to the community and thus seriously neglects the multiple e
